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

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

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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 Metals’s 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

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