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OAR Box 1778 

Prepped by Ollie Stewart 

Document Number: 

34) ll-B-9 

Docket Number: 

A-90-06 

Printed 10/28/2008 9:50:52 AM Sheet 34 of 276 
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ENVIRONMENTAL PROTECTION AGENCY 

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MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

EPA AIR POCKET 

City Utilities, Springfield, Missouri: Reconstruction 

Director 

Division of Stationary Source Enforcement 

Sari J. Stephenson, Director 

Enforcement Division - P.egion vll 

**? 

^. x. 

This is in response to a request submitted to your office 

by City Utilities, Springfield, Missouri pursuant to 40 CFR 

§50.5 concerning the Janes River Power Plant Unit Ho. 4 boiler. 

Cur determination in this case relies heavily upon tha information submitted to this office by City Utilities, dated 

December 16, 1977. 

We have evaluated the information and it is our conclusion 

that this facility is not a reconstructed facility pursuant 

to 40 CFR 560.15 and is therefore not subject to the new 

source performance standards (NSPS) for fossil fuel-fired 

stea.a generators. This determination is based solely on the 

fixed capital cost criteria established in 40 CFR §60.15 

(b)(1). Our analysis shows that, under the iiiost conservative 

conditions, the capital expenditure estimated for the rehabilitation will only approach 43 percent of the cost for a 

comparable entirely new facility. Since this regulatory 

criteria has not been satisfied, we have not investigated 

the economic or technological feasibility of meeting the 

USPS. 

As mentioned earlier, this determination is based 

almost entirely on the information submitted to this office 

by City Utilities. For this reason, I would urge you in 

your reply to City Utilities to- require them to submit the 

actual cost data for the rehabilitation of this facility, 

upon its completion. . This will serve as a final evaluation 

of the data, since some of the data is based on very rough 

estimates. 

In regard to the City Utilities resolution to cease 

operation of Unit Mo. 3 at the end of 20 additional years of 

operation , >* fc IS nnrKsnogfi^r-y t*n pnr^l.^o r t-hi e rafT'lvfri^ l 

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since our evaluation and determination is not based on the 

exclusion of any costs estimated by City Utilities. 

If you h3ve any additional questions or comments concerning this determination, please contact Rich Biondi (755-2564) 

of my staff. 

Edward E. Reich 

cci Jack Farmer - SDB 
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•'!EW SOURC E PERFORMANC E STA.NDARC S i ;-D C E ::;"; 0 . I 5 ) 

r h e purpos e o f th e reconstructio n regulation s is 

to recogniz e tha t replacemen t o f man y o f th e compone n ts o f 

a facilit y ca n b e substantiall y equivalen t t o totall y 

replacin g th e facilit y a t th e en d o f it s usefu l lif e wit h a 

newl y constructe d facility . Fo r thi s reason , th e reconstructio n 

rcnula t ioi.s *r e intende d co appl y whe n a n existin g facility' s 

component s are replace d t o suc h an exten t tha t it is techno -

locicall y an d economicall y feasibl e fo r th e facilit y t o compl y 

with NSPS and therefore become a affected 

facility. 

Section 60.15(d) of the regulations requires an owner 

or operator of an existing facility, which could be subject : o 

NSPS, who proposes to replace componen ts and the fixed ca.ital 

cost of the new components exceeds 50% of the fixed capital 

cost to construct a new facility comparable to the reconstructed 

affected facility, to notify the Administrator of the 

proposed replacement. THis notification must be postmarked 

60 days (or as soon as practicable) before construction is 

commenced. 

The Administrator is then required to make a 

determination within 30 days of reciept of sufficient information 
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V i > Tho rixodcopiia l cost of the- replacements in 

comparison to the fixed capital cost that would be required 

to construct a new facility comparable to the reconstructed 

affected facility; 

(2) The estimated life of the facility after the 

reo 1 acements• compared to the life of a new facility comparable 

to the reconstructed affected facility; 

(3) The extent to which the componen ts being 

replaced cause or contribute to the emissions from the 

facility; and 

(h) Any economic or technical limitations on 

compliance with applicable standards of performance which 

are inherent in the proposed replacements. 

By examining the criteria above, it can be seen 

that determinations will need to be made on a strict case by 

case examination of the facts surrounding each request. Very 

detailed specific guidance can not be formulated to handle 

the varied cases that will arise. 

L 
".•'.-.•:• :•-.-1 , <*••:,.' i i •• iri'.i- tha t ..-!.' fee l nee d t o b e 

i.: s. r !.• s -, e i' • I ) .-.:•. -i t ^ : • : M t i • i t e - i reconstructe d affecte d 

: - * c i 1 i t v . .1 r. ii {21 :-Or.,i i i - included in fixed capital cost? 

It is in tru-se t.vo areas that in most cases the determination 

•.-. il! be made. A source will either be applicable or not based 

on the costs associated with these two areas and whether or not 

these costs represent a 5 0? replacement value. 

What is a reconstructed affected facility? 

Reconstructed affected facility is defined by 

specific sections of the regulations in each subpart of the 

appropriate NSPS category. The section numbers are indicated 

on the attached list. For example, a fossil fuel fired 

steam generator is defined as a furnace or boiler. Therefore, 

in making a determination in this category, costs would only 

be associated with that unit and not the turbine, stack, 

coal handling equipment, building, and other materials and 

equipment not directly connected to or considered a part of 

the boiler or furnace. 

Appropriate definitions for unresolved categories 

are being developed. If needed, separate reconstructed 

affected facility definitions may be made for certain 

categories of affected facilities as specific cases come 

i n to view. 

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- •' • ' s [ •' c i ud eJ in f i x e 'i capital c o ^ l ? 

, "rixt'c: Ciiiiit.il cijst" is defined in Section' 60.15(c ) 

a -; the c ,Tp i r a I needed r o provide all the depreciabl e con -

ponents." It is recommende d that the following formula be 

used as a guide for determinin n these costs . 

R + L > C/2 

where : R = the total cost of replacemen t parts , equipment , 

and material s required to reconstruc t the 

reconstructe d affecte d facility . 

L = the total cost of all labor required to remove 

the old parts and facility , to prepar e the 

old site for the reconstruction , to refurbis h 

the old parts , and to replac e the new parts of 

t he reconstructe d affecte d facility . 

C = the total costs of the parts and labor required 

to install a new facilit y whic h is comparabl e 

to the reconstructe d affecte d facility . 

i 

Care shoul d be exercise d to include only those costs 

associate d wit h the reconstructe d affecte d facility . For 

example , parts whic h are not covered by this definitio n are 

not included in determinin g reconstructi o ncosts . 

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that co^t s associate d wit h the purchas e and installatio n of 

a i r pollutio n contro l equipmen t ^ r e not considere d in estimatin g 

t he cost of a comparabl e ne w facilit y unles s that contro l 

equipmen t is require d as part of the proces s (that is, produc t 

recovery ) . 

In th e fina l analysis , th e 50'4 replacemen t criteri a 

i s no t th e onl y basi s fo r determination , sinc e th e Administrato r 

wil l conside r al l technica l an d economi c limitation s tha t 

t h e facilit y ma y hav e in complyin g wit h th e applicabl e standard s 

o f performanc e afte r th e propose d replacements . 

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unresolved 

unresolved 

60.91(a) 

60.100 

60.111(a) 

60.120 

60.131(b,c,d) 

60.141(a) 

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60.150 

60.161(b,c,f,g) 

60.171(b,c) 

60.181(b,d,e,f,g,h) 

60.191(b,d) 

unresolved' 

unresolved 

unresolved 

unresolved 

60.241(a) 

60.251(e,f,g,h,i) 

60.261(afk) 

60.271(a,b)