From:•Antonio Santos [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.

Antonio

--- 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. All 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 1,000 hp, rich burn: Catalytic converter - $11,000 A/F Controller - $4,000 Installation - ~$2,0001,000 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 > > > > 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 > > > > >