Title: NSPS APPLICABILITY TO PRIMELINE

Recipient: SWEITZER, TERRY A., IL EPA

Author: CZERNIAK, GEORGE T., AIR COMPLIANCE BRANCH REGION V

Date: 10/09/90

Subparts: TT

References: 60.15, 60.460

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Does the replacement of the water quench system and the prime oven constitute reconstruction?

Region V determined that the cost of replacing the water quench system and the prime oven does not exceed 50% of the fixed capital cost the would be required to construct a comparable entirely new prime line. Therefore, replacing the above mentioned equipment does not represent reconstruction. Costs would be aggregated which result from a single planning decision.

October 09, 1990

Terry A. Sweitzer, Manager

Permit Section

Division of Air Pollution Control

Illinois Environmental Protection Agency

P.O. Box 19276

Springfield, Illinois 62794­9276

Dear Mr. Sweitzer:

This letter follows up our previous correspondence dated July 11, 1990 as to whether Pre Finish Metalss number 3 prime line has reconstructed as defined at 40 C.F.R. §60.15, thereby subjecting it to the New Source Performance Standard (NSPS) requirements of 40 C.F.R. Part 60, Subpart TT. (Standards of Performance for Metal Coil Surface Coating).

After considering the cost estimate of constructing an entirely new prime line, U.S. EPA, Region V determined that the cost of replacing the water quench system and the prime oven does not exceed 50 percent of the fixed capital cost that would be required to construct a comparable entirely new prime line. Therefore, replacing the above mentioned equipment does not represent reconstruction. Therefore, number 3 prime line is not subject to Subpart TT.

Also, I would like to reiterate that U.S. EPAs policy is to aggregate the costs of periodic physical changes stemming from what may be viewed objectively as a single planning decision, for the purpose of determining whether the replacement constitutes "reconstruction". This policy may impact any future changes on the line in question.

If you have any questions or comments, please call Spiros Bourgikos, of my staff at (312) 886­6862.

Sincerely yours,

(signed)

George T. Czerniak, Chief

Compliance Section I