EPA-HQ-OAR-2008-0708-DRAFT-0309[1] From: Antonio Santos [asantos@meca.org] Sent: Thursday, January 21, 2010 1:26 PM To: Tanya Parise Subject: RE: FW: EPA Proposed Existing RICE NESHAP - Cost of Aftertreatment Hi, Tanya. Sorry for the delay. I passed along your question to MECA member companies two weeks ago and just received responses this week. Below are the two responses I received. Hope this helps.

A ntonio

--- Response #1: Generally, you will not find any information for DPFs and DOCs for engines over 2000 ekW. The systems themselves become quite costly and cumbersome when applied to very large engines. I ran some numbers just to get some idea as to the cost for a 2500 ekW engine and found that, for the DPF alone (our system incorporates both the DPF and DOC in the same housing ), the price would be in excess of $125,000. We find that, when a site requires power in excess of 2000 ekW, they will install multiple gen sets to accomplish their needs. The main issue with these devices is the back pressure they impart on the engine. Once the exhaust flow exceeds a certain rate, the number of filters and catalyst elements required for safe engine operation increases dramatically along with the size of the housings. The result is units that become extremely large in size and weight, making both shipping and installation both costly and challenging. Response #2: In our experience, there is no off-the shelf solution for engines applications of this size due to the site specific details for every project. These engines normally have site specific emission permits, which will vary greatly according to operating specification and emission standards for the j urisdiction. The design and configuration of the existing exhaust system (ducting, bellows, silencers, stacks, etc.) in some cases allow for easy retrofit of emission controls and, in other cases, pose significant challenges in cost and complexity. That said, the emission control technology for these engines are generally scaled-up versions of existing DOC and DPF technology. The cost of this technology per unit horsepower tends to remain the same or decrease as the engine size increases. Our experience is that this rule continues to apply on lean-burn engines above 3000 hp. Therefore, following this rule, the estimated cost for a DOC on a 3000 hp engine is approximately 3x$8500 = $25,500. The installation cost can vary significantly -- approximately $1000 to $10,000 depending on the complexity of the exhaust system retrofit.

-----Original Message----- From: Tanya Parise [mailto:parise.tanya@ecrweb.com] Sent: Tuesday, December 22, 2009 7:39 AM Page 1EPA-HQ-OAR-2008-0708-DRAFT-0309[1] To: Antonio Santos Subject: RE: FW: EPA Proposed Existing RICE NESHAP - Cost of Aftertreatment

A ntonio, I wanted to follow-up on the question I asked below. I apologize if you've already sent a response, but I haven't received anything. Does MECA have a response? Tanya -----Original Message----- From: Tanya Parise [mailto:parise.tanya@ecrweb.com] Sent: Wednesday, October 14, 2009 11:18 AM To: 'Antonio Santos' Subject: RE: FW: EPA Proposed Existing RICE NESHAP - Cost of Aftertreatment

A ntonio, Thanks. I really appreciate the information. It's very helpful for our rulemaking. One follow-up question. In the comments, MECA cited California's information on costs for applying DOC and DPFs to diesel engines. As far as I know, those costs were mostly applicable to engines less than about 3,000 HP. Is that right? Does MECA have any information on the costs of applying DOC and DPF to larger stationary diesel engines, say about 3,000 HP? We've heard that catalysts and associated equipment would be more expensive for larger engines than what EPA estimated for proposal and want to get an estimate of what such costs would be. Tanya -----Original Message----- From: Antonio Santos [mailto:asantos@meca.org] Sent: Friday, October 02, 2009 5:06 PM To: parise.tanya@ecrweb.com Subject: RE: FW: EPA Proposed Existing RICE NESHAP - Cost of Aftertreatment Hi, Tanya. Per your request, MECA staff surveyed its member companies to assess the the validity of the emission control costs for stationary IC engines shown in your e-mail. (Note: I also provided the member companies with a copy of your February 25, 2009 cost memo that was posted in the EPA docket.) We received two responses from our member companies. I've summarized the responses below. Hope this helps. Please feel free to contact me (asantos@meca.org) if you have any questions. If I receive any additional input from our members, I will forward the responses along to you.

A ntonio

--- Page 2EPA-HQ-OAR-2008-0708-DRAFT-0309[1] Response #1: I have reviewed the comments in Tanya's email and feel that the NSCR capital cost are overestimated. We would expect the total capital cost to be in the range of $5,000.00 to about $15,000.00. These numbers assume converter costs and installation. It does not take into consideration silencing. Properly sized catalyst should not require any maintenance for at least 3 years. The only cost that should be needed during that time would be the annual certification. We would estimate this to be about $2,000.00 per engine per year. Catalyst cleaning would be the only other cost involved; we would estimate that to be about $500.00 per catalyst element. For 4SLB engines, we would expect the total cost to be in the range of $3,000.00 to $12,000.00 without considering any silencing. As for annual operating costs, they also seem to be high. As above, properly sized catalyst should not require any maintenance for at least 3 years. The only cost that should be needed during that time frame would be the annual certification. We would estimate this to be about $2,000.00 per engine per year. Catalyst cleaning would be the only other cost involved; we would estimate that to be about $500.00 per catalyst element. 2SLB engine are a little more difficult to estimate. Major contributing factors are the percent reduction needed, exhaust temperatures, and the maximum allowable back pressure on the engine. Typically, the requirement calls for CO reduction. At times, we have seen that to meet the back pressure requirement it requires additional catalyst to be installed. Also, these engines typically have a rated horsepower greater than 500. With all that said, our estimate for engines of 500 hp or less: the capital cost would be about $20,000.00 to $45,000.00 per engine and once again no silencing. The annual operating cost should be the same as the only yearly cost will be for the annual certification (about $2,000.00 per engine). Catalyst cleaning, when needed, will be about the same at $500.00 per catalyst element. For example, if there are eight elements in the converter, we would assume $4,000.00 per engine. Response #2: To assess the validity of the cost estimates in the report, I provide a few pricing examples below. The prices for the catalysts are directly based on our current price list. We are not suppliers of A/F controllers and do not conduct installation, but I have provided estimates for those items as well. A ll prices take into account the mark-ups for our dealers and re-sellers. Based on these examples, I would say the capital cost component given in the report (Section 3.1 in the cost memo) is quite realistic, and perhaps even overly conservative. 500 hp, rich burn: Catalytic converter - $5,500 A

/F Controller - $4,000 Installation - ~$1,500 Page 3EPA-HQ-OAR-2008-0708-DRAFT-0309[1] 1,000 hp, rich burn: Catalytic converter - $11,000 A

/F Controller - $4,000 Installation - ~$2,000 1,000 hp, lean burn: Catalytic converter - $8,500 A

/F Controller - N/ A Installation - ~$1,000 We are only manufacturers and don't get involved in the service side of the business. However, the operating costs presented in the report look realistic in my view.

-----Original Message----- From: Tanya Parise [mailto:parise.tanya@ecrweb.com] Sent: Thursday, September 03, 2009 2:27 PM To: Joe Kubsh Subject: Re: FW: EPA Proposed Existing RICE NESHAP - Cost of Aftertreatment Josh, I appreciate it. Please note my new email address (I've left the company I was previously with when I emailed you originally, but I am still working with EPA on this project): parise.tanya@ecrweb.com. Please use this address when you send MECA's response.

Thanks so much. Tanya > > > > -----Original Message----- > From: Joe Kubsh [mailto:jkubsh@meca.org] > Sent: Tue 9/1/2009 10:45 AM > To: Tanya Parise > Subject: RE: EPA Proposed Existing RICE NESHAP - Cost of > Aftertreatment > > Tanya, MECA is reaching out to our members to get some input to your > cost questions. We will be back to you soon with our input. > > Joe Kubsh > MECA > > ________________________________ > > From: Tanya Parise [mailto:tparise@alpha-gamma.com] > Sent: Fri 8/28/2009 10:35 AM > To: Joe Kubsh > Subject: EPA Proposed Existing RICE NESHAP - Cost of Aftertreatment > > Page 4EPA-HQ-OAR-2008-0708-DRAFT-0309[1] > > Joseph, > > I am a contractor working with Ms. Melanie King of the US EPA on the > existing RICE NESHAP. We are hoping MECA can assist EPA in providing > additional cost information on adding aftertreatment to existing > stationary engines and verifying some available aftertreatment costs. > > In MECA's comments on the proposal, MECA cited some information on the > cost of retrofitting DOC and DPF to existing stationary diesel engines > from the CA ARB. In terms of retrofitting gas engines with oxidation > catalyst for lean burn engines and NSCR for rich burn engines, does > MECA have any information on the total costs of these controls that > you could share with EPA? > > Comments received on the proposal suggested that EPA's costs were > underestimated and some commenters indicated that total capital costs > were on the order of $8,000-$25,000 for adding NSCR to engines below > 500 HP with annual operating costs of $3,000-$11,000. For 4SLB > engines, industry indicated that capital costs would be in ballpark of > $10,000-$25,000 with annual costs of $5,000-$7,000 with an oxidation > catalyst. For 2SLB engines, industry indicated that costs would be > higher at $64,000 in capital costs and $20,000 in annual costs to add > oxidation catalyst. Does MECA feel that these estimates are > reasonable and representative of the actual costs to retrofit engines? > Any information you can send us to either support or refute these numbers would be greatly appreciated. > > I appreciate any guidance and information MECA can provide on this > matter and look forward to your response. > > Thanks, > Tanya > > Tanya Parise > Senior Chemical Engineer > Alpha-Gamma Technologies, Inc. > 3301 Benson Drive, Suite 535 > Raleigh, NC 27609 > Phone : (919) 954-0033 ext: 109 > Fax : (919) 954-0379 > Email : tparise@alpha-gamma.com > URL : http://www.alpha-gamma.com > > > > >

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