×
INTELLIGENT WORK FORUMS
FOR ENGINEERING PROFESSIONALS

Log In

Come Join Us!

Are you an
Engineering professional?
Join Eng-Tips Forums!
  • Talk With Other Members
  • Be Notified Of Responses
    To Your Posts
  • Keyword Search
  • One-Click Access To Your
    Favorite Forums
  • Automated Signatures
    On Your Posts
  • Best Of All, It's Free!
  • Students Click Here

*Eng-Tips's functionality depends on members receiving e-mail. By joining you are opting in to receive e-mail.

Posting Guidelines

Promoting, selling, recruiting, coursework and thesis posting is forbidden.

Students Click Here

Jobs

"Reconstructed" applies to engine overhaul?

"Reconstructed" applies to engine overhaul?

"Reconstructed" applies to engine overhaul?

(OP)
Alright, maybe this isn't the best forum for the question... but I'm not sure where else it would fit either.  If one looks at the EPA spark-ignition NSPS regulation that covers natural gas engines in the USA, one might wonder what was meant by "reconstructed or modified."  In particular, one might wonder whether overhauling an engine used for gas compression triggers the "reconstructed" requirements if the rest of the compression skid is not concurrently reworked:   

http://www.epa.gov/EPA-TOX/2008/January/Day-18/t25394.htm
The final standards apply to stationary SI engines subject to the SI NSPS that are modified or reconstructed after June 12, 2006. The definitions for modification and reconstruction are given in 40 CFR 60.14 and 40 CFR 60.15, respectively. A stationary engine that is overhauled as part of a maintenance program is not considered a modification if there is no increase in emissions.

modified http://edocket.access.gpo.gov/cfr_2005/julqtr/40cfr60.14.htm
reconstructed http://edocket.access.gpo.gov/cfr_2005/julqtr/40cfr60.15.htm

Sec. 60.15  Reconstruction.        
(a) An existing facility, upon reconstruction, becomes an affected facility, irrespective of any change in emission rate.      

(b) ``Reconstruction' means the replacement of components of an   existing facility to such an extent that:      
....(1) The fixed capital cost of the new components exceeds 50 percent   of the fixed capital cost that would be required to construct a   comparable entirely new facility
, and      
....(2) It is technologically and economically feasible to meet the   applicable standards set forth in this part.      

(c) ``Fixed capital cost' means the capital needed to provide all   the depreciable components.      

(d) If an owner or operator of an existing facility proposes to   replace components, and the fixed capital cost of the new components   exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, he shall notify the   Administrator of the proposed replacements. The notice must be postmarked 60 days (or as soon as practicable) before construction of the replacements is commenced and must include the following information:      
....(1) Name and address of the owner or operator.      
....(2) The location of the existing facility.      
....(3) A brief description of the existing facility and the components   which are to be replaced.      
....(4) A description of the existing air pollution control equipment   and the proposed air pollution control equipment.      
....(5) An estimate of the fixed capital cost of the replacements and of   constructing a comparable entirely new facility.      
....(6) The estimated life of the existing facility after the   replacements.      
....(7) A discussion of any economic or technical limitations the   facility may have in complying with the applicable standards of   performance after the proposed replacements.      

(e) The Administrator will determine, within 30 days of the receipt   of the notice required by paragraph

(d) of this section and any   additional information he may reasonably require, whether the proposed   replacement constitutes reconstruction.      

(f) The Administrator's determination under paragraph

(e) shall be   based on:      
....(1) The fixed capital cost of the replacements in comparison to the   fixed capital cost that would be required to construct a comparable   entirely new facility;      
....(2) The estimated life of the facility after the replacements   compared to the life of a comparable entirely new facility;      
....(3) The extent to which the components being replaced cause or   contribute to the emissions from the facility; and      
....(4) Any economic or technical limitations on compliance with   applicable standards of performance which are inherent in the proposed   replacements.      

(g) Individual subparts of this part may include specific provisions   which refine and delimit the concept of reconstruction set forth in this   section.


 

RE: "Reconstructed" applies to engine overhaul?

No, I've been through this with them and the important issue is that you spend more than 50% of the cost of a replacement skid.  I've never had either an overhaul or an engine swap that met that criteria (since the cost of the skid includes a LOT of fabricator overhead and profit).

David

RE: "Reconstructed" applies to engine overhaul?

(OP)
it looks to me as though an engine itself can be reconstructed (versus simply being part of a facility that is reconstructed)

it looks like the question of whether or not an overhaul triggers the "reconstructed" requirements depends on whether you count the new pistons, rings, turbos, etc., as fixed capital or circulating capital.  Based on the definitions of each, I'm inclined to say that the engine parts replaced during an overhaul are circulating capital.  Using that interpretation, it would seem that one would never trigger the "reconstructed" requirement because of an engine overhaul alone.

If that's the case, then what's the point of having the "reconstructed" requirement in the regulation at all?  

If that's not the case, then are we really supposed to send a letter to the EPA giving them 60 days notice for each-and-every engine overhaul?  Who is going to read all those letters?


 

RE: "Reconstructed" applies to engine overhaul?

(OP)
sorry, I was typing the second bit while you were responding to the first.
 

RE: "Reconstructed" applies to engine overhaul?

We had a situation a couple of years ago where a client was replacing a skid vessel, the cooler, much of the piping, and all the heads on a compressor while doing an engine overhaul (yes it would have been cheaper to buy a new skid if they could have waited 56 weeks for a new frame).  All the modifications together kicked in the "greater than 50% of replacement" requirements and the client initiated the paperwork.  I was only involved in the planning part so I never knew how the process worked out.  I can't imagine a scenario where the engine overhaul by itself would ever get you to the trigger point.

David

RE: "Reconstructed" applies to engine overhaul?

(OP)
was this something that people were doing (deciding whether reconstructed applies, and sending in the paperwork) prior to the final rule coming out in January of this year?
 

RE: "Reconstructed" applies to engine overhaul?

The reconstruction language hasn't changed much in the last few years.  I'm not sure exactly what changed in this version (I only get it out and read it when I'm moving or installing compression).

David

RE: "Reconstructed" applies to engine overhaul?

(OP)
David, thanks for the input.  It's at least a bit of a comfort to know that I'm not alone in thinking that triggering "reconstructed" would be a rare occurence.

Is there anyone else in here who has had similar experiences, or who has a different interpretation?



 

RE: "Reconstructed" applies to engine overhaul?

(OP)
Just a follow-up:  I'm attending an API workshop on the NSPS rule, and they explicitly stated that the pertinent costs are related to the engine alone, not to a separable compressor or the rest of the skid.  Apparently there are some EPA example calculations that show this - I don't have a URL handy at the moment. This makes it a bit more likely (especially on a small or old engine) that one would trigger "reconstructed" by doing an overhaul.

 

Red Flag This Post

Please let us know here why this post is inappropriate. Reasons such as off-topic, duplicates, flames, illegal, vulgar, or students posting their homework.

Red Flag Submitted

Thank you for helping keep Eng-Tips Forums free from inappropriate posts.
The Eng-Tips staff will check this out and take appropriate action.

Reply To This Thread

Posting in the Eng-Tips forums is a member-only feature.

Click Here to join Eng-Tips and talk with other members!


Resources