From:•Antonio Santos [asantos@meca.org]

Sent:•Tuesday, April 20, 2010 6:05 PM

To:•Tanya Parise

Subject:•RE: Question Related to EPA's NESHAP for Existing Stationary SI 

Engines

Hi, Tanya. Just received another reply today (see below).

Antonio

---

Engines less than 500 hp - My best estimate would be 20-30 % (not too sure of

total engine counts in operation); however, I am seeing that many of the

packagers of the small engine compressors are now including catalysts. There

are still a large number of engines in the field that do not have engine

aftertreatment.

Engines larger than 500 hp - I would estimate 80-90% have aftertreatment;

however, I would like to mention that most engines I come across are 750 hp

and larger. I do not see many 500 to 750 hp engines in use.

And, finally, I don't think there will be any difference from major source or

area source. What I have found is that on larger engines many operators (such

as DCP Midstream) have taken a pro-active approach and have had catalysts on

the engines for years throughout their fleet. And the small engine packagers

are now including this as part of the packages in preparation for the NESHAP

for SI engines.

-----Original Message-----

From: Tanya Parise [mailto:parise.tanya@ecrweb.com]

Sent: Tuesday, April 20, 2010 9:02 AM

To: Antonio Santos

Subject: RE: Question Related to EPA's NESHAP for Existing Stationary SI

Engines

Antonio,

I appreciate this information. It helps. Do you anticipate responses from

any other MECA member companies?

Tanya

-----Original Message-----

From: Antonio Santos [mailto:asantos@meca.org]

Sent: Friday, April 09, 2010 5:12 PM

To: Tanya Parise

Subject: RE: Question Related to EPA's NESHAP for Existing Stationary SI

Engines

Tanya - Here's a response to your questions from one of the MECA member

companies (see below).

I sent them the questions exactly as you sent them to me.

1. Does MECA have an estimate of the percentage of rich burn engines currently

operating with NSCR/three-way catalyst?

2. What would the percentage be for engines below 500 HP?

3. Would the percentage be different if you look at engines at a major source

vs. an area source?"

Hope this helps.

Antonio

---

1. For major sources, 100% of rich burn engines would be operating with threeway catalysts. For area sources, the estimate is 60-70% of rich burn engines

would be operating with three-way catalysts. These values are across all

horsepower ranges and the estimates are based on observations of in-use SI

engines.

2. We think the percentage of engines <500 hp equipped with three-way

catalysts is about the same as the numbers in 1. above.

3. Yes, see response to 1. above.

For some of these engines, the catalyst was retrofitted and, for others, the

catalyst came with the original equipment. We don't have a percentage

breakdown for OE vs. retrofit catalysts. That said, these engines have very

long life-cycles and so the catalyst can be replaced a number of times. As

such, we believe a great number of the in-use catalysts are retrofits or
replacements for the original catalyst.

-----Original Message-----

From: Tanya Parise [mailto:parise.tanya@ecrweb.com]

Sent: Monday, April 05, 2010 1:43 PM

To: Antonio Santos

Subject: RE: Question Related to EPA's NESHAP for Existing Stationary SI

Engines

Thanks so much. I appreciate you clearing this up.

-----Original Message-----

From: Antonio Santos [mailto:asantos@meca.org]

Sent: Monday, April 05, 2010 11:37 AM

To: Tanya Parise

Subject: RE: Question Related to EPA's NESHAP for Existing Stationary SI

Engines

That is our old location. MECA's new address is: 2020 North 14th Street,

Suite 220, Arlington, VA 22201. Our phone number remains the same: (202)

296-4797. We no longer share a suite with ICAC (they also moved to a new

office; their new address is: 1220 N. Fillmore Street, #410, Arlington, VA

22201). ICAC's new phone number is: (703) 812-4811.

Antonio

-----Original Message-----

From: Tanya Parise [mailto:parise.tanya@ecrweb.com]

Sent: Monday, April 05, 2010 11:28 AM

To: Antonio Santos

Subject: RE: Question Related to EPA's NESHAP for Existing Stationary SI

Engines

No problem. Sounds good.

So is your new location the 1730 M Street, NW, Suite 206 address? Or is that

your old location?

Are you sharing suites with ICAC? I was putting together a contact list of

stakeholders and was inputting addresses and phone numbers, etc.

Thanks so much.

Tanya

-----Original Message-----

From: Antonio Santos [mailto:asantos@meca.org]

Sent: Monday, April 05, 2010 11:19 AM

To: Tanya Parise

Subject: RE: Question Related to EPA's NESHAP for Existing Stationary SI

Engines

Hi, Tanya. My apologies for not getting back to you sooner. Your e-mail fell

through the cracks during our office move last month (we changed e-mail

providers as part of the move and messages were lost). Thanks for the

reminder. I just sent out an inquiry to the MECA members. As before, I'll

send to you whatever I hear back (hopefully I'll have some responses before

the end of this week).

Antonio

-----Original Message-----

From: Tanya Parise [mailto:parise.tanya@ecrweb.com]

Sent: Monday, April 05, 2010 9:05 AM

To: Antonio Santos

Subject: RE: Question Related to EPA's NESHAP for Existing Stationary SI

Engines

Antonio,

Just a friendly follow-up to make sure you received my below information and

to find out of MECA has an estimate of the number of engines with three-way

catalyst/NSCR? We're on a tight schedule to get the rule finalized, so any

feedback you have is appreciated.

Tanya

-----Original Message-----

From: Tanya Parise [mailto:parise.tanya@ecrweb.com]

Sent: Sunday, March 14, 2010 12:16 PM

To: 'Antonio Santos'
Subject: Question Related to EPA's NESHAP for Existing Stationary SI Engines

Antonio,

I appreciate all the information MECA has provided so far. I have another

question that I'm hoping MECA can help with.

Does MECA have an estimate of the percentage of rich burn engines currently

operating with NSCR/three-way catalyst? What would the percentage be for

engines below 500 HP? Would the percentage be different if you look at

engines at a major source vs. an area source?

Thanks again for your help.

Thanks,

Tanya

Tanya Parise

EC/R Incorporated

501 Eastowne Drive, Suite 250

Chapel Hill, NC 27514

(919) 484-0417