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EPA Refines “Replacement Unit” Concepts

Mar 11, 2019

In two recent actions, Hilcorp Monopod and Newport News Shipbuilding, EPA Region X and OAQPS provided additional guidance on when a unit qualifies as a replacement unit under 40 CFR 52.21(b)(33). EPA gave general guidance that horsepower generally is the most appropriate design parameter for reciprocating internal combustion engines and that a significant increase in horsepower is not “identical to or functionally equivalent to” an earlier, lower horsepower unit and that fuel changes are not necessarily determinative, but are a factor to be considered when applying the replacement unit test.
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