"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.go v/EPA-TOX/ 2008/Janua ry/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://edo cket.acces s.gpo.gov/ cfr_2005/j ulqtr/40cf r60.14.htm
reconstructed http://edo cket.acces s.gpo.gov/ cfr_2005/j ulqtr/40cf r60.15.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.
http://
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://edo
reconstructed http://edo
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?
David
RE: "Reconstructed" applies to engine overhaul?
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?
RE: "Reconstructed" applies to engine overhaul?
David
RE: "Reconstructed" applies to engine overhaul?
RE: "Reconstructed" applies to engine overhaul?
David
RE: "Reconstructed" applies to engine overhaul?
Is there anyone else in here who has had similar experiences, or who has a different interpretation?
RE: "Reconstructed" applies to engine overhaul?