1 

i n n o v a t i v e e n v i r o n m e n t a l s o l u t i o n s , i n c . 

MEMORANDUM 

Date: April 19, 2010 

To: Brad Nelson, EC/R 

From: Tom McGrath/IES Inc. 

c: Melanie King/EPA, Lisa Beal/INGAA, Matt Todd/API, James Harrison/Exterran, Jeff 

Adams/BP, Jim McCarthy/IES, Jeff Panek/IES Inc. 

Re: Request for Additional Cost Detail for Gas-Fired Engines Emission Controls 

To support comments on the proposed revisions to the National Emission Standard for 

Hazardous Air Pollutants (NESHAP) for reciprocating internal combustion engines (RICE), the 

Interstate Natural Gas Association of America (INGAA) and the American Petroleum Institute 

(API) collectively submitted cost-effectiveness data for post-combustion controls for gas-fired 

engines. These cost-effectiveness data were submitted November 2, 2009 in a Technical Report 

titled “Reciprocating Internal Combustion Engine National Emission Standard for Hazardous Air 

Pollutants (RICE NESHAP) Proposed Revisions – Emission Control Cost Analysis Background 

for “Above the Floor” Emission Controls for Natural Gas-Fired RICE.” 

Subsequently, EC/R has requested additional cost detail associated with Attachment L in the 

Technical Report: “Baseline” Cost Effectiveness Calculations for Gas-Fired Engines PostCombustion Controls: Industry Cost Effectiveness Values – based on capital and operating cost 

data provided by industry and vendors and using best estimate values for useful equipment life 

(10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP control efficiency (90%).” 

This memorandum presents a discussion of capital and annual operating cost estimates 

associated with oxidation catalyst installations on four-stroke lean burn (4SLB) engines between 

300 and 500 hp: a Waukesha F18GL engine, a Waukesha F18GLD engine, and a Caterpillar 

G3408CLE engine. The data were compiled using historical costs for installation and current 

equipment and service cost estimates, typically quoted by a supplier. 

Table S-1 presents capital cost data; the detailed costs used to calculate Purchased Equipment 

Costs (PEC) and Total Capital Costs (TCC) provided in Attachment L. Costs are presented for 

each of the three engines along with the averages. The Notes column provides background 

information used to calculate the cost estimates. 

Table S-2 presents annual operating and maintenance cost data: the detailed costs used to 

calculate Operating and Maintenance Material Costs (O&MM), O&M Labor Cost (O&ML), 

Annual Performance Testing or Downtime or other allowance for Catalyst washing (ATC), and 

Total Direct Annual Costs (TDAC) provided in Attachment L. Costs are presented for each of 

the three engines along with the averages. The Notes column provides background information 

used to calculate the cost estimates. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

2 

During the detailed cost data compilation it was determined that some of the capital cost quotes 

from one of the catalyst vendors had been misinterpreted and catalyst element capital costs for 

Waukesha engines in the 300 – 500 hp 4SLB category were revised. These revised costs are 

included in Tables S-1 and S-2 and in revised Technical Report summary tables and attachments 

provided below. 

 

It should be noted that because the capital costs are annualized through the capital recovery 

factor, the capital cost revisions result in an insignificant change (i.e. about 5%) to the costeffectiveness estimates presented in the original Technical Report; thus, the cost revisions do not 

change or alter the conclusions contained in the November 2, 2009 report that demonstrated that 

above the floor controls for affected gas-fired engines are not warranted.. In addition, capital 

costs were also misinterpreted for a fraction of the 4SRB engines and a few transcription errors 

were noted and corrected. These changes impacted 4SRB engines in the size ranges 100 – 175 

hp, 175 – 300 hp, and 300 - 500 hp. Because only a fraction of the engines in each subcategory 

had cost revisions, the change to the average capital costs were small, and because the capital 

costs are annualized through the capital recovery factor, the impact of these capital cost revisions 

on the cost-effectiveness was minimal (i.e. less than 1%). Based on the updated capital costs, 

revisions to the following summary tables and attachments from the Technical Report are also 

provided below: 

Table 4. Cost Effectiveness Estimates for 4-Stroke Lean Burn Engines (2007 $) 

Table 5. Cost Effectiveness Estimates for 4-Stroke Rich Burn Engines (2007 $) 

Attachment D: “Baseline” Cost Effectiveness Calculations for Gas-Fired 4SRB Engines 

NSCR/Post-Combustion Controls: Industry Cost Effectiveness Values - based on capital and 

operating cost data provided by industry and vendors, and using best estimate values for 

useful equipment life (10 years), AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and 

HAP control efficiency (90%) 

Attachment I: “Baseline” Cost Effectiveness Calculations for Gas-Fired 4SRB Engines 

NSCR/Post-Combustion Controls: Industry Cost Effectiveness Values - based on capital and 

operating cost data provided by industry and vendors, 6,500 annual operating hours, and 

using best estimate values for useful equipment life (10 years), AP-42 HAP emission factor 

(2.43E-04 lb HAP/hp-hr), and HAP control efficiency (90%) 

Attachment L: “Baseline” Cost Effectiveness Calculations for Gas-Fired 4SLB Engines 

Post-Combustion Controls: Industry Cost Effectiveness Values - based on capital and 

operating cost data provided by industry and vendors and using best estimate values for 

useful equipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP 

control efficiency (90%) 

In summary, it should be emphasized that the cost revisions discussed above result in an 

insignificant change (i.e. less than 5%) to the cost-effectiveness estimates presented in the 

original Technical Report; thus the cost revisions do not change or alter the conclusions 

contained in the November 2, 2009 report that demonstrated that above the floor controls are not 

warranted for affected gas-fired engines because the cost-effectiveness estimates are four to ten 

or more times higher than the EPA proposed rule cost. In addition, the review determined other 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

3 

areas where capital and annual costs could be refined (i.e. some costs would increase slightly and 

some costs would decrease slightly); however, a cursory review of these refinements determined 

they would typically result in a small increase in the cost-effectiveness ($/ton HAP) estimates 

(i.e. total changes would increase $/ton HAP values by no more than 10%) and thus would not 

impact the report analyses and conclusions that post combustion controls are not cost-effective 

HAP controls for affected gas-fired engines. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

4 

Table S-1. Detailed Capital Costs for 4SLB Engines 300 to 500 hp. 

Cost Parameter Costs for Individual Engines Average Costs N

Engine Make Waukesha Waukesha Caterpillar Engine Model F18GL F18GLD G3408CLEEngine Category 4SLB 4SLB 4SLB OEM-HP 400 400 425 Engine OEM-RPM 1800 1800 1800 Emissions Control Equipment and Auxiliary Equipment Capital Costs (ECC) Engine O2 Sensors 0 0 0 0 Silencer: Parts $3,808.00 $3,808.00 $4,250.00 $3,955.33

Silencers will be repreasons when the pacatalyst access will (i.e. catalyst will ne& integrated into thBackpressure and sconsiderations. Sup

any mounting hard

Number of Catalyst Elements 1 1 1 1 Supplier quotes for 

catalyst elements. 

Catalyst: Parts $1,606.50 $1,606.50 $2,150.50 $1,787.83 Supplier quotes for Crankcase Upgrade: Parts $507.00 $507.00 $0.00 $338.00

Waukesha GL engiloop crankcase ventthe installation of a 

prevent catalyst fou

AFR Controls: Parts $0.00 $0.00 $0.00 $0.00AFR Controls: Misc. Parts $0.00 $0.00 $0.00 $0.00 AFRC not required Catalyst Thermocouples: Parts $160.00 $160.00 $160.00 $160.00Thermocouples: Misc. parts and fittings (conduit, wiring, etc) $250.00 $250.00 $300.00 $266.67

TC installation and 

because equipment be installed at majo

ongoing internal mato measure catalyst 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

5 

24V Power: Battery $0.00 $0.00 $0.00 $0.0024V Power: Battery Box Parts $0.00 $0.00 $0.00 $0.0024V Power: Alternator $0.00 $0.00 $0.00 $0.0024V Power: Misc. Parts $0.00 $0.00 $0.00 $0.00

AFRC not required 

ECC Total $6,331.50 $6,331.50 $6,860.50 $6,507.83 Sum of equipment cFreight $243.65 $243.65 $288.02 $258.44

Estimated as 4.5% o

parts cost. Shippin

supplier

Purchased Equipment Costs (PEC) $6,575.15 $6,575.15 $7,148.52 $6,766.28 PEC = ECC + FreDirect Installation Costs (DIC) Silencer: Removal of Existing Silencer and Supports. $225.00 $225.00 $225.00 $225.00 Based on average la

rates. Includes time 

Silencer: Welding $350.00 $350.00 $550.00 $416.67 Based on average la

rates. Can include h

Silencer: Assoc. Lift Equipment Rental. $1,000.00 $1,000.00 $1,000.00 $1,000.00

Requirement for larCost for rental equifor minimum of one 

Silencer: Labor $375.00 $375.00 $375.00 $375.00 Based on average la

rates. 

Catalyst: Labor $75.00 $75.00 $75.00 $75.00 Based on average la

rates. 

Crankcase Upgrade: Labor $536.00 $536.00 $0.00 $357.33 Based on average la

rates. 

AFR Controls: Labor $0.00 $0.00 $0.00 $0.00O2 Sensors: Labor $0.00 $0.00 $0.00 $0.00 AFRC not required Catalyst Thermocouples: Labor $150.00 $150.00 $450.00 $250.00

Based on average larates. Drill and tap 

bungs. 

Other Upgrades: Welding $250.00 $250.00 $350.00 $283.33 Based on average h
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

6 

24V Power: Battery Box Labor $0.00 $0.00 $0.00 $0.00 AFRC not required Direct Installation Costs (DIC) $2,961.00 $2,961.00 $3,025.00 $2,982.33 Sum of direct costIndirect Installation Costs (IIC) Start-up Testing (maintenance test) $300.00 $300.00 $300.00 $300.00

Based on average larates. To ensure un

properly. 

Notification and Consult $700.00 $700.00 $700.00 $700.00

Cost for Exterran coinitial notification adocumentation (i.e. emissions data - entBased on fleet aver

Exterran Labor: Testing $402.00 $402.00 $402.00 $402.00 Based on average la

rates. 

Customer Labor: Start-up and Shut Down $402.00 $402.00 $402.00 $402.00 Based on average la

rates. 

Customer Labor: Testing (avg) $201.00 $201.00 $201.00 $201.00 Based on average la

rates. 

Indirect Installation Costs (IIC) $2,005.00 $2,005.00 $2,005.00 $2,005.00 Sum of indirect coTotal Capital Costs (TCC) $11,541.15 $11,541.15 $12,178.52 $11,753.61 TCC = PEC + DIC 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

7 

Table S-2. Detailed Operating and Maintenance Costs for 4SLB Engines 300 to 500 hp

Cost Parameter Costs for Individual Engines Average Costs N

Engine Make Waukesha Waukesha Caterpillar Average 

Engine Model F18GL F18GLD G3408CLE 300-500Hp Engine Category 4SLB 4SLB 4SLB 4SLB OEM-HP 400 400 425 Engine OEM-RPM 1,800 1,800 1,800 

Number of Carburetors 1 1 1 Number of Catalysts 1 1 1 

Operating and Maintenance (O&M) Material Costs (O&MM) Crankcase Filter: parts $383.60 $383.60 $0.00 $255.73 Replace crankcase fil

on Waukesha engines

Replace: Per Catalyst Part $481.95 $481.95 $645.15 $536.35

Annualized replacemreplacing catalyst eveannualized cost = repAssumed that catalysoperated (e.g. 2,800 hdeactivate at similar rcontinuously operated central gathering statifrequent start-ups and cycle the catalysts anunburned HC deposit

Replace: O2 sensors Parts $0.00 $0.00 $0.00 $0.00 AFRC not required foReplace: Thermocouples Parts $16.00 $16.00 $16.00 $16.00

Annualized replacemreplacing TC every 7cost = replacement coquote for TC and wir

Replace: Fuel Valve Parts $0.00 $0.00 $0.00 $0.00 AFRC not required foReplace: Batteries Parts $0.00 $0.00 $0.00 $0.00 AFRC not required fo
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

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Extra Catalyst for Washing Schedules $24.10 $24.10 $32.26 $26.82

Annualized replacemcatalyst in rotation (1 20 units) based on repthree years (i.e. annuareplacement cost *3/1rotational catalyst is requipment downtown (i.e. approach to miniapplying catalyst). Su

Maintenance Materials (MMC) $905.65 $905.65 $693.41 $834.90 Sum of maintenance Cleaning Catalyst $52.50 $52.50 $63.00 $56.00

Annualized cost to wwashing catalysts anncatalyst every three ycost = annual washincatalysts not washed years). Supplier quot

Catalyst Cleaning & Replacement: Crane $1,000.00 $1,000.00 $1,000.00 $1,000.00

Cost for crane to remreplacement or cleanilarger engines (> 300 equipment, most rentone day. 

Catalyst Cleaning & Replacement Costs (CCRC) $1,052.50 $1,052.50 $1,063.00 $1,056.00O&M Material Costs (O&MM) $1,958.15 $1,958.15 $1,756.41 $1,890.90 O&MM = MMC + CO&M Labor Cost (O&ML) Customer Labor: Testing (avg) $201.00 $201.00 $201.00 $201.00

Based on average labaverage rates. Some 

be on-site during test

Customer Labor: Testing (CL) $201.00 $201.00 $201.00 $201.00Crankcase Filter: Labor $268.00 $268.00 $0.00 $178.67

Replace crankcase filon Waukesha engineslabor hours per engin
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

9 

event (4 events/yr). Wthat have closed loop systems require the incrankcase filter to preContractor quote. 

Replace: Catalyst Labor $60.30 $60.30 $60.30 $60.30

Annualized replacemreplacing catalyst eveannualized labor cost cost *3/10). Based on and average rates per (4/11/10), the catalysfor cleaning; thus, lab

multiplied by 3/10 anunderestimated (i.e. lmultiplied by 10/3). 

Replace: O2 sensors Labor $0.00 $0.00 $0.00 $0.00 AFRC not required foReplace: O2 sensor test $0.00 $0.00 $0.00 $0.00 AFRC not required foReplace: Thermocouples Labor $13.40 $13.40 $13.40 $13.40

Annualized replacemreplacing TC every 7cost = replacement coquote. 

Replace: Fuel Valve Labor $0.00 $0.00 $0.00 $0.00 AFRC not required foReplace: Batteries Labor $0.00 $0.00 $0.00 $0.00 AFRC not required foEmissions Equipment Testing (Maintenance) $600.00 $600.00 $600.00 $600.00

Emissions check (porafter catalyst replacemensure proper functiocompliance. Based o(per engine and averaoccurs requires remob

personnel after maint

Maintenance labor (ML) $941.70 $941.70 $673.70 $852.37 Sum of maintenance O&M Labor Cost (O&ML) $1,142.70 $1,142.70 $874.70 $1,053.37 O&ML = CL + ML 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

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Annual Performance Testing or Downtime or other allowance for Catalyst washing (ATC) Compliance Testing $800.00 $800.00 $800.00 $800.00

Third party, portable required each time cacatalyst or rotation). contractor quote. 

Compliance Testing: Exterran Cost $402.00 $402.00 $402.00 $402.00

For Exterran personntesting. Based on aveengine and average ra

Annual Performance Testing or Downtime or other allowance for Catalyst washing (ATC) 

$1,202.00 $1,202.00 $1,202.00 $1,202.00 Sum of compliance t

Total Direct Annual Costs (TDAC) $4,302.85 $4,302.85 $3,833.11 $4,146.27 TDAC = O&MM + 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

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Table 4. Cost Effectiveness Estimates for 4-Stroke Lean Burn Engines (2007 $) – Revised 4

<50 hp 50-100 hp 100-175 hp 175-300 hp 300-500 hp 500-1000 

DocketA 19,887 7,798 5,039 3,658 2,887 2,316

BaselineB 11,961 8,069 6,122 5,034 

Industry DataC Baseline 25,090

2004 RICE NESHAPD Baseline 2

Argonne/ NMDEQE Baseline 36,148 2

Proposed RuleF Baseline 5,152 3,476 2,637 2,169 

Industry DataC Baseline 10,808

DocketG 15,748

BaselineH 1

Argonne/ NMDEQE Baseline 15,572 

Engine Size Range /Post-Combustion Emssion Control Cost-Effectiveness ($/t

2,800 Operating Hours per Year

2004 RICE NESHAP

Proposed Rule

Cost Basis

6,500 Operating Hours per Year

Cost Method

A. Cost Effectiveness data from docket document EPA-HQ-OAR-2008-0708-0017 Table 2. For 500 – 1,000 hp size categ

600-750 hp and > 750 hp cost per ton ($/ton) HAP reduction values. Refer to Attachment J for additional detail. 

B. Cost Effectiveness calculated using data from docket document EPA-HQ-OAR-2008-0708-0017 with adjustments usin

useful equipment life (10 years) and HAP emission factor (0.000478 lb HAP/hp-hr). Control efficiency = 90%. Refer additional detail. 

C. Industry cost effectiveness values based on capital and operating cost data provided by industry and vendors and using 

useful equipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP control efficiency (90%). 

for additional detail. 

D. 2001 cost effectiveness data from original RICE NESHAP (docket document number OAR-2002-0059-0225) with adju

(to 2007 dollars based on 3% annual cost escalation/inflation), annual operating hours (2,800) and using best estimate v

emission factor (0.000478 lb HAP/hp-hr) and control efficiency (90%). Refer to Attachment E for additional detail. 

E. Estimated costs from cost data presented in “Engine Classification Matrix Control Options and Costs” prepared by Arg

Laboratory and the State of New Mexico Department of Environmental Quality [Argonne 2007] using best estimate va

equipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP control efficiency (90%). Refer to 

additional detail. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

12 

F. Cost Effectiveness calculated using Proposed Rule data from docket document EPA-HQ-OAR-2008-0708-0017 with a

operating hours (6,500), and using best estimate values for useful equipment life (10 years), HAP emission factor (0.00and control efficiency (90%). Refer to Attachment M for additional detail. 

G. 2001 cost effectiveness data from original RICE NESHAP (docket document number OAR-2002-0059-0225) with adju

2007 dollars based on 3% annual cost escalation/inflation). Refer to Attachment E for additional detail. 

H. 2001 cost effectiveness data from original RICE NESHAP (docket document number OAR-2002-0059-0225) with adju

(to 2007 dollars based on 3% annual cost escalation/inflation) and using best estimates for HAP emission factor (0.000control efficiency (90%). Refer to Attachment E for additional detail. 

Table 5. Cost Effectiveness Estimates for 4-Stroke Rich Burn Engines (2007 $) – Revised 4/9/1

<50 hp 50-100 hp 100-175 hp 175-300 hp 300-500 hp 500-1000 

DocketA 33,373 13,162 8,549 6,241 4,952 3,998

BaselineB 44,168 29,372 21,971 17,835 14

Revised EPA ModelC Baseline 269,008 267,273 178,868 129,486

Industry DataD Baseline 176,718 220,388 147,111 101,7032004 RICE NESHAPE Baseline 57Argonne/ NMDEQF Baseline 107,820 65Proposed RuleG Baseline 19,206 12,653 9,464 7,683 6

Revised EPA ModelH Baseline 138,223 133,132 92,850 70,349

Industry DataI Baseline 112,906 119,258 81,526 58,452

DocketJ 86,935

BaselineK 24

Argonne/ NMDEQF Baseline 46,446 28

2004 RICE NESHAP

Cost Basis

Engine Size Range /Post-Combustion Emssion Control Cost-Effectiveness ($/t

HAP)

2,800 Operating Hours per Year6,500 Operating Hours per YearProposed Rule

A. Cost Effectiveness data from docket document EPA-HQ-OAR-2008-0708-0017 Table 2. For 500 – 1,000 hp size categ

600-750 hp and > 750 hp cost per ton ($/ton) HAP reduction values. Refer to Attachment A for additional detail. 

B. Cost Effectiveness calculated using data from docket document EPA-HQ-OAR-2008-0708-0017 with adjustments to b

equipment life (10 years) and AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr). Control efficiency = 90%. Refer 

additional detail. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

13 

C. Revised EPA Model data. Cost Effectiveness approach from docket document EPA-HQ-OAR-2008-0708-0017 was re

were made to best estimates for useful equipment life (10 years) and AP-42 HAP emission factor (2.43E-04 lb HAP/hp

(inflation adjust docket cost data and include costs for AFRC and power source), and O&M costs (EPA assumption tha

is equivalent to diesel particulate filter cleaning is incorrect and severely underestimates cost) and a fuel penalty associ

operation at a less efficient AFR for NSCR is considered. Control efficiency = 90%. Refer to Attachment C for additio

D. Industry cost effectiveness values based on capital and operating cost data provided by industry and vendors and using 

useful equipment life (10 years), AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and HAP control efficiency (9Attachment D for additional detail. 

E. 2001 cost effectiveness data from original RICE NESHAP (docket document number OAR-2002-0059-0225) with adju

(to 2007 dollars based on 3% annual cost escalation/inflation), annual operating hours (2,800), and using best estimate emission factor (2.43E-04 lb HAP/hp-hr) and control efficiency (90%). Refer to Attachment E for additional detail. 

F. Estimated costs from cost data presented in “Engine Classification Matrix Control Options and Costs” prepared by Arg

Laboratory and the New Mexico Department of Environmental Quality [Argonne 2007] using best estimate values for 

(10 years), AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and HAP control efficiency (90%). Refer to Att. F 

G. Proposed Rule Values (Docket Document EPA-HQ-OAR-2008-0708-0017 Table 2) with adjustments ] using best estim

equipment life (10 years) and AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and annual operating hours (6,500

G for additional detail. 

H. Revised EPA Model data. Cost Effectiveness approach from docket document EPA-HQ-OAR-2008-0708-0017 was re

to 6,500 annual operating hours and as described in footnote C. Refer to Attachment H for additional detail. 

I. Industry cost effectiveness values based on capital and operating cost data provided by industry and vendors and using 

useful equipment life (10 years), AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and HAP control efficiency (9Attachment I for additional detail. 

J. 2001 cost effectiveness data from original RICE NESHAP (docket document number OAR-2002-0059-0225) with adju

2007 dollars based on 3% annual cost escalation/inflation). Refer to Attachment E for additional detail. 

K. 2001 cost effectiveness data from original RICE NESHAP (docket document no. OAR-2002-0059-0225) with adjustm

2007 dollars based on 3% annual cost escalation/inflation), and using best estimate values for AP-42 HAP emission facHAP/hp-hr) and control efficiency (90%). Refer to Attachment E for additional detail. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

14 

Attachment D – “Baseline” Cost Effectiveness Calculations for Gas-Fired 4SRB Engines NSCR/Post-Co

Industry Cost Effectiveness Values - based on capital and operating cost data provided by industry and 

best estimate values for useful equipment life (10 years), AP-42 HAP emission factor (2.43E-04 lb HAP

control efficiency (90%) – Revised 4/19/10. 

1 Parameter Value Units Notes/Com2 Engine Type 4SRB 4SRB 4SRB 4SRB 3 Fuel Used Natural Gas 4 Post Combustion Control NSCR NSCR NSCR NSCR 5 Control Purpose CH2O, CO, & NOx 6 Target Reduction - Catalyst Control Efficiency (CCE) 90% 90% 90% 90% % Assumed control efficiency for 

2008-0708-0017, OAR-2008-0

7 Project Duration (n) 10 10 10 10 years 

 Industry budgets for AFRC and replacement/system overhaul evnotes that for budgetary reasons a catalyst element after 24,000 operation. Average = 28,000 = 0030-0087). These hours not bguarantees, industry experience 

performance is more frequent c

OAR-2005-0029-0038 lists cata

- 5 years. 

8 Project Discount Interest Rate (i) 7.0% 7.0% 7.0% 7.0% % (OAR-2005-0030-0005) 9 Engine Size Range (ESR) 50 - 100 100 - 175 175 - 300 300 - 500 hp OAR-2008-0708-0017 Table 2

10 Site-Rated Power (SR) 75 137.5 237.5 400 hp Midpoint of Engine Size Range 11 Average Operating Load (OL) 100% 100% 100% 100% % Assume 100% load for cost ana12 Annual Operating Hours (AOH) 2,800 2,800 2,800 2,800 hrs Annual operating hours that are 

control cost analysis (OAR-200

13 HAP Emission Factor (HAPEF) 2.43E-4 2.43E-4 2.43E-4 2.43E-4 lb HAP/ hp-hr AP-42 EF for total HAP for 4S14 HAP Emission Reductions (∆HAP) 45.9 84.2 145.4 244.9 lb HAP/ yr ∆HAP = SR * OL * AOH * HA15 Capital Costs 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

15 

16 Purchased Equipment Cost (PEC) $9,195 - - - Refer to Footnote A. 17 Purchased Equipment Cost (PEC) - $11,389 - - Refer to Footnote B. 18 Purchased Equipment Cost (PEC) - - $12,413 - Refer to Footnote C. 19 Purchased Equipment Cost (PEC) - - - $14,086 Refer to Footnote D. 20 Total Capital Cost (TCC) $12,222 - - - $ Refer to Footnotes A, E 21 Total Capital Cost (TCC) - $13,974 - - $ Refer to Footnotes B, E 22 Total Capital Cost (TCC) - - $15,653 - $ Refer to Footnotes C, E 23 Total Capital Cost (TCC) - - - $17,333 $ Refer to Footnotes D, E 24 Direct Annual Costs 25 Operating and Maintenance Material Costs (O&MM) $664 $1,071 $1,706 $2,384 $ 

Annualized equipment Cost to ryears), O2 Sensors (8 months, ~ 

Thermocouples (7.5 years), Cramonths), Fuel Valve (4 - 8 yearCost for annual catalyst cleaninengines), and rotational catalyst

26 O&M Labor Cost (O&ML) $1,275 $1,320 $1,360 $1,380 $ 

Annualized labor Cost to replaccleaning) Catalyst, O2 Sensor, Valve, Crankcase Filter, BatteryEquipment Testing (e.g. O2 Senoptimization after O2 sensor rep

27 

Annual Performance Testing or Downtime or other allowance for Catalyst washing (ATC) 

$0 $3,978 $3,978 $3,978 $ 

Estimated cost for annual FTIR 

associated cost; required when rotated for outside cleaning. 

28 Total Direct Annual Costs (TDAC) $1,939 $6,369 $7,044 $7,742 $ = O&MM + O&ML + ATC 29 Indirect Annual Costs 

Administrative Charges (ADMC) $0 $225 $225 $225 

30 Fuel Penalty (FPC) $379 $695 $1,200 $2,021 $ 

FPC = [7,420 - 7,188] (Btu/hp-LHV)) * 1/1000 (scf/Mcf) * SR AOH (hrs) * $7/Mcf. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

16 

• 7,420 Btu/hp-hr is brake speci(BSFC) for Waukesha VGF GSat AFR = 0.995 (AFR for optim• 7,188 Btu/hp-hr is brake speciWaukesha VGF GSI 4SRB eng=1.06 (AFR for optimum engin• Waukesha VGF GSI BSFC daKosinski, Waukesha engineer. • $7/Mcf - estimated average na[DOE/EIA website] 

31 Capital Recovery Factor (CRF) 0.142378 0.142378 0.142378 0.142378 CRF = i * (1+i)^n / [(1+i)^n - 1

decimal - e.g., 10% = 0.1) 

32 Capital Recovery (CRC) $1,740 $1,990 $2,229 $2,468 $ CRC = CRF * TCC 33 Total Indirect Annual Costs (TIAC) $2,119 $2,909 $3,654 $4,714 $ TIAC = ADMC + FPC + CRC 34 Cost Summary - Total Annual Costs (TAC) 35 Total Direct Annual Costs (TDAC) $1,939 $6,369 $7,044 $7,742 $ 36 Total Indirect Annual Costs (TIAC) $2,119 $2,909 $3,654 $4,714 $ 37 Total Annual Costs (TAC) $4,058 $9,278 $10,698 $12,456 $ TAC = TDAC + TIAC 38 Cost-Effectiveness 39 Cost-Effectiveness (CE) $176,718 $220,388 $147,111 $101,703 $/ton HAP CE = TAC / ∆HAP / 2000 40 

A. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 50 to 100 hp. Exterran provid

recent installations with average PEC = $9,195 (range of $8,935 - $10,099) and average installed TCC = $12,665 (range of $11,

Engines include Arrow VRG 220 and VRG 330; Waukesha VRG 265, 195 GK, VRG 310, 135 GZ, VRG 330, 140 GZ, and F55

G3304NA (range of 53 - 95 hp) and the costs do not include an initial performance test. Devon estimated installed NSCR cost/T

engines 50 - 500 hp "based on some recent catalyst installations performed in two different operational areas." MCBU provided 

and AFR procurement and installation costs for 50-250 HP range from $10,000 - $15,000." MCBU has five engines of 50 - 100 

NSCR. For this smallest engine range (50 - 100 hp), the low end of these costs were used. TCC used for cost-effectiveness calc

average of Exterran average and the Devon and MCBU values. The average ratio of Total Capital Cost to Purchased Equipmen

where PEC was provided) was 1.38. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

17 

41 

B. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 100 to 175 hp. Exterran prov

recent installations with average PEC = $11,389 (range of $10,827 - $12,284) and average installed TCC = $16,172 (range of $1Engines include Waukesha F11G, F817G, WAK-B, 145 GZ; and Caterpillar G3306NA and G333NA (range of 116 - 172 hp) an

include an initial performance test. Devon estimated installed NSCR cost/TCC = $14,000 for engines 50 - 500 hp "based on som

installations performed in two different operational areas." MCBU provided that "Rich burn NSCR and AFR procurement and i250 HP range from $10,000 - $15,000." MCBU has 51 engines of 100 - 250 hp equipped with NSCR. For this engine range (10

extrapolated estimate based on 137.5 hp was used. TCC used for cost-effectiveness calculations based on average of Exterran a

and MCBU values. The average ratio of Total Capital Cost to Purchased Equipment Cost (for engines where PEC was provide

42 

C. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 175 to 300 hp. Exterran prov

recent installations with average PEC = $12,413 (range of $10,667 - $16,119) and average installed TCC = $17,958 (range of $1Engines include Waukesha F1197G, F1905G, F18G, and F11GSI; and Caterpillar G3306TA, G3406NA, G3306TAA, G342NAG3408NA, G342TA, and G342TAA... (range of 203 - 265 hp) and the costs do not include an initial performance test. Devon ecost/TCC = $14,000 for engines 50 - 500 hp "based on some recent catalyst installations performed in two different operational 

that "Rich burn NSCR and AFR procurement and installation costs for 50-250 HP range from $10,000 - $15,000." MCBU has 5hp equipped with NSCR. For this engine range (175 - 300 hp), the maximum of $15,000 was used. TCC used for cost-effectiv

on average of Exterran average and the Devon and MCBU values. The average ratio of Total Capital Cost to Purchased Equipm

where PEC was provided) was 1.40. 

43 

D. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 300 to 500 hp. Exterran prov

recent installations with average PEC = $14,086 (range of $11,777 - $16,689) and average installed TCC = $20,666 (range of $1Engines include Waukesha H2475G, LRO, F18GSI, F18GSID, F2895G, LRZ, L3711G; and Caterpillar G3508NA, G306TA, GG3408TAW, G379TA, G379TAA, AND G398NA. (range of 310 - 500 hp) and the costs do not include an initial performance t

installed NSCR cost/TCC = $14,000 for engines 50 - 500 hp "based on some recent catalyst installations performed in two diffeTCC used for cost-effectiveness calculations based on average of Exterran average and the Devon value. The average ratio of TPurchased Equipment Cost (for engines where PEC was provided) was 1.42. 

44 E. Total Capital Costs do not include initial performance test which would be required with or without post-combustion control
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

18 

 Attachment I – “Baseline” Cost Effectiveness Calculations for Gas-Fired 4SRB Engines NSCR/Post-Com

Industry Cost Effectiveness Values - based on capital and operating cost data provided by industry and ve

operating hours, and using best estimate values for useful equipment life (10 years), AP-42 HAP emission 

HAP/hp-hr), and HAP control efficiency (90%) – Revised 4/19/10. 

1 Parameter Value Units Notes/Comm2 Engine Type 4SRB 4SRB 4SRB 4SRB 3 Fuel Used Natural Gas 4 Post Combustion Control NSCR NSCR NSCR NSCR 5 Control Purpose CH2O, CO, & NOx 6 

Target Reduction - Catalyst Control Efficiency (CCE) 

90% 90% 90% 90% % Assumed control efficiency for NSCR 

0017, OAR-2008-0708-0001) 

7 Project Duration (n) 10 10 10 10 years 

 Industry budgets for AFRC and alternoverhaul every 10 years. Miratech not

reasons should expect to replace a cata

32,000 hours of operation. Average = 

2005-0030-0087). These hours not baguarantees, industry experience for gumore frequent catalyst replacement. Ocatalyst replacement every 3 - 5 years. 

8 Project Discount Interest Rate (i) 7.0% 7.0% 7.0% 7.0% % (OAR-2005-0030-0005) 9 Engine Size Range (ESR) 50 - 100 100 - 175 175 - 300 300 - 500 hp OAR-2008-0708-0017 Table 2. 

10 Site-Rated Power (SR) 75 137.5 237.5 400 hp Midpoint of Engine Size Range 11 Average Operating Load (OL) 100% 100% 100% 100% % Assume 100% load for cost analysis 12 Annual Operating Hours (AOH) 6,500 6,500 6,500 6,500 hrs Annual operating hours that are the ba

analysis (OAR-2005-0030-0005). 

13 HAP Emission Factor (HAPEF) 2.43E-4 2.43E-4 2.43E-4 2.43E-4 lb HAP/ hp-hr AP-42 EF for total HAP for 4SRB NG14 HAP Emission Reductions (∆HAP) 106.6 195.5 337.6 568.6 lb HAP/ yr ∆HAP = SR * OL * AOH * HAPEF * 15 Capital Costs 16 Purchased Equipment Cost (PEC) $9,195 - - - Refer to Footnote A. 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

19 

17 Purchased Equipment Cost (PEC) - $11,389 - - Refer to Footnote B. 18 Purchased Equipment Cost (PEC) - - $12,413 - Refer to Footnote C. 19 Purchased Equipment Cost (PEC) - - - $14,086 Refer to Footnote D. 20 Total Capital Cost (TCC) $12,222 - - - $ Refer to Footnotes A, E 21 Total Capital Cost (TCC) - $13,974 - - $ Refer to Footnotes B, E 22 Total Capital Cost (TCC) - - $15,653 - $ Refer to Footnotes C, E 23 Total Capital Cost (TCC) - - - $17,333 $ Refer to Footnotes D, E 24 Direct Annual Costs 25 

Operating and Maintenance Material Costs (O&MM) 

$839 $1,246 $1,881 $2,589 $ 

Annualized equipment Cost to replace 

O2 Sensors (8 months, ~ 2,000 operati(7.5 years), Crankcase Filters (3 monthand Battery (2 years). Cost for annual larger engines), and rotational catalyst

26 O&M Labor Cost (O&ML) $2,560 $2,604 $2,664 $2,667 $ 

Annualized labor Cost to replace and Catalyst, O2 Sensor, Thermocouples, F

Filter, Battery, and Perform EquipmenTest, AFRC optimization after O2 sen

27 

Annual Performance Testing or Downtime or other allowance for Catalyst washing (ATC) 

$0 $3,978 $3,978 $3,978 $ 

Estimated cost for annual FTIR perfor

cost; required when catalysts are replacleaning. 

28 Total Direct Annual Costs (TDAC) $3,399 $7,828 $8,523 $9,234 $ = O&MM + O&ML + ATC 29 Indirect Annual Costs 

Administrative Charges (ADMC) $0 $225 $225 $225 

FPC = [7,420 - 7,188] (Btu/hp-hr) * 1/1/1000 (scf/Mcf) * SR (hp) * OL (hp/h

30 Fuel Penalty (FPC) $880 $1,613 $2,786 $4,692 $ 

• 7,420 Btu/hp-hr is brake specific fue

Waukesha VGF GSI 4SRB engines op(AFR for optimum NSCR performanc
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

20 

• 7,188 Btu/hp-hr is brake specific fueVGF GSI 4SRB engines operated at Aoptimum engine efficiency) • Waukesha VGF GSI BSFC data provWaukesha engineer. • $7/Mcf - estimated average natural gwebsite] 

31 Capital Recovery Factor (CRF) 0.142378 0.142378 0.142378 0.142378 CRF = i * (1+i)^n / [(1+i)^n - 1] (i exp

10% = 0.1) 

32 Capital Recovery (CRC) $1,740 $1,990 $2,229 $2,468 $ CRC = CRF * TCC 33 Total Indirect Annual Costs (TIAC) $2,620 $3,827 $5,239 $7,384 $ TIAC = ADMC + FPC + CRC 34 Cost Summary - Total Annual Costs (TAC) 35 Total Direct Annual Costs (TDAC) $3,399 $7,828 $8,523 $9,234 $ 36 Total Indirect Annual Costs (TIAC) $2,620 $3,827 $5,239 $7,384 $ 37 Total Annual Costs (TAC) $6,019 $11,655 $13,762 $16,618 $ TAC = TDAC + TIAC 38 Cost-Effectiveness 39 Cost-Effectiveness (CE) $112,906 $119,258 $81,526 $58,452 $/ton HAP CE = TAC / ∆HAP / 2000 40 

A. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 50 to 100 hp. Exterran provid

installations with average PEC = $9,195 (range of $8,935 - $10,099) and average installed TCC = $12,665 (range of $11,945 to $Arrow VRG 220 and VRG 330; Waukesha VRG 265, 195 GK, VRG 310, 135 GZ, VRG 330, 140 GZ, and F554G; and Caterpill

95 hp) and the costs do not include an initial performance test. Devon estimated installed NSCR cost/TCC = $14,000 for enginesome recent catalyst installations performed in two different operational areas." MCBU provided that "Rich burn NSCR and AFinstallation costs for 50-250 HP range from $10,000 - $15,000." MCBU has five engines of 50 - 100 hp equipped with NSCR. Frange (50 - 100 hp), the low end of these costs were used. TCC used for cost-effectiveness calculations based on average of Ext

Devon and MCBU values. The average ratio of Total Capital Cost to Purchased Equipment Cost (for engines where PEC was p
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

21 

41 

B. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 100 to 175 hp. Exterran provi

installations with average PEC = $11,389 (range of $10,827 - $12,284) and average installed TCC = $16,172 (range of $15,139 tinclude Waukesha F11G, F817G, WAK-B, 145 GZ; and Caterpillar G3306NA and G333NA (range of 116 - 172 hp) and the cos

performance test. Devon estimated installed NSCR cost/TCC = $14,000 for engines 50 - 500 hp "based on some recent catalyst 

two different operational areas." MCBU provided that "Rich burn NSCR and AFR procurement and installation costs for 50-250 $15,000." MCBU has 51 engines of 100 - 250 hp equipped with NSCR. For this engine range (100 - 175 hp), a linearly extrapo137.5 hp was used. TCC used for cost-effectiveness calculations based on average of Exterran average and the Devon and MCB

ratio of Total Capital Cost to Purchased Equipment Cost (for engines where PEC was provided) was 1.40.

42 

C. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 175 to 300 hp. Exterran provi

installations with average PEC = $12,413 (range of $10,667 - $16,119) and average installed TCC = $17,958 (range of $16,165 tinclude Waukesha F1197G, F1905G, F18G, and F11GSI; and Caterpillar G3306TA, G3406NA, G3306TAA, G342NA, G343NAG342TA, and G342TAA... (range of 203 - 265 hp) and the costs do not include an initial performance test. Devon estimated inst

$14,000 for engines 50 - 500 hp "based on some recent catalyst installations performed in two different operational areas." MCB

NSCR and AFR procurement and installation costs for 50-250 HP range from $10,000 - $15,000." MCBU has 51 engines of 100 

NSCR. For this engine range (175 - 300 hp), the maximum of $15,000 was used. TCC used for cost-effectiveness calculations 

Exterran average and the Devon and MCBU values. The average ratio of Total Capital Cost to Purchased Equipment Cost (for 

provided) was 1.40. 

43 

D. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 300 to 500 hp. Exterran provi

installations with average PEC = $14,086 (range of $11,777 - $16,689) and average installed TCC = $20,666 (range of $17,240 tinclude Waukesha H2475G, LRO, F18GSI, F18GSID, F2895G, LRZ, L3711G; and Caterpillar G3508NA, G306TA, G379NA, G

G379TA, G379TAA, AND G398NA. (range of 310 - 500 hp) and the costs do not include an initial performance test. Devon estcost/TCC = $14,000 for engines 50 - 500 hp "based on some recent catalyst installations performed in two different operational a

effectiveness calculations based on average of Exterran average and the Devon value. The average ratio of Total Capital Cost to 

(for engines where PEC was provided) was 1.42. 

44 E. Total Capital Costs do not include initial performance test which would be required with or without post-combustion controls 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

22 

 Attachment L – “Baseline” Cost Effectiveness Calculations for Gas-Fired 4SLB Engines Post-Combustion 

Cost Effectiveness Values - based on capital and operating cost data provided by industry and vendors an

values for useful equipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP control efficie

4/19/10.

1 Parameter Value Units Notes/Comments 2 Engine Type 4SLB 3 Fuel Used Natural Gas 4 Post Combustion Control Ox Cat Ox Cat 5 Control Purpose 6 Target Reduction - Catalyst Control Efficiency (CCE) 90% 90% % Assumed control efficiency for Oxidation catalysts (OAR

OAR-2008-0708-0001) 

7 Project Duration (n) 10 10 years 

Miratech notes that for budgetary reasons should expect element after 24,000 to 32,000 hours of operation. Averayears (OAR-2005-0030-0087). These hours not based on guarantees, industry experience for guaranteed performancatalyst replacement. OAR-2005-0029-0038 lists catalys

3 - 5 years. 

8 Project Discount Interest Rate (i) 7.0% 7.0% % (OAR-2005-0030-0005) 9 Engine Size Range (ESR) 300 - 500 300 - 500 hp OAR-2008-0708-0017 Table 2. 

10 Site-Rated Power (SR) 400 400 hp Midpoint of Engine Size Range 11 Average Operating Load (OL) 100% 100% % Assume 100% load for cost analysis 12 Annual Operating Hours (AOH) 2,800 6,500 hrs Annual operating hours that are the basis for the EPA con

(OAR-2005-0030-0005). 

13 HAP Emission Factor (HAPEF) 0.000478 0.000478 lb HAP/ hp-hr EF for total HAP for NG-fired engines < 500 hp; the siz

basis for the above the floor analysis (OAR-2005-0030-0

14 HAP Emission Reductions (∆HAP) 481.8 1118.5 lb HAP/ yr ∆HAP = SR * OL * AOH * HAPEF * CCE 15 Capital Costs 16 Purchased Equipment Cost (PEC) $6,766 $6,766 Refer to Footnote A. 17 Total Capital Cost (TCC) $11,754 $11,754 $ Refer to Footnotes B. 18 Direct Annual Costs 
Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis” 

Supplemental Information – April, 2010 

23 

19 Operating and Maintenance Material Costs (O&MM) $1,891 $1,891 $ 

Annualized equipment Cost to replace Catalyst (every 3 Thermocouples (7.5 years), and Crankcase Filters (3 mon

catalyst rotation for cleaning. Cost for rotational catalyst

and crane. 

20 O&M Labor Cost (O&ML) $1,053 $1,053 $ Annualized labor Cost to replace and rotate (for cleaning

Thermocouples, and Crankcase Filter. 

21 

Annual Performance Testing or Downtime or other allowance for Catalyst washing (ATC) 

$1,202 $1,202 $ Estimated cost for annual performance test and associate

catalysts are replaced or for annual rotation for outside cl

22 Total Direct Annual Costs (TDAC) $4,146 $4,146 $ = O&MM + O&ML + ATC 23 Indirect Annual Costs 24 Administrative Charges (ADMC) $225 $225 25 Capital Recovery Factor (CRF) 0.142378 0.142378 CRF = i * (1+i)^n / [(1+i)^n - 1] (i expressed as a decima26 Capital Recovery (CRC) $1,674 $1,674 $ CRC = CRF * TCC 27 Total Indirect Annual Costs (TIAC) $1,899 $1,899 $ TIAC = ADMC + CRC 28 Cost Summary - Total Annual Costs (TAC) 29 Total Direct Annual Costs (TDAC) $4,146 $4,146 $ 30 Total Indirect Annual Costs (TIAC) $1,899 $1,899 $ 31 Total Annual Costs (TAC) $6,045 $6,045 $ TAC = TDAC + TIAC 32 Cost-Effectiveness 33 Cost-Effectiveness (CE) $25,090 $10,808 $/ton HAP CE = TAC / ∆HAP / 2000 34 

A. Based on capital cost data provided by Exterran for engines ranging from 300 to 500 hp. Exterran provided cost data for thre

average PEC = $6,766 (range of $6,575 - $7,149) and average installed TCC = $11,754 (range of $11,541 to $12,179). The data 

using historical costs for installation and current equipment cost estimates, typically quoted by a supplier. Engines include WaukF18GLD, Caterpillar G3408CLE and the costs do not include an initial performance test. The average ratio of Total Capital Co

Equipment Cost was 1.73. 

35 B. Total Capital Costs do not include initial performance test which would be required with or without post-combustion controls