# 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-Fire d Engines Emission Controls

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

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

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

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

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

titled “Reciprocating Internal Combustion Engine Na tional Emission Standard for Hazardous Air

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

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

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

Technical Report: “Baseline” Cost Effectiveness Cal culations for Gas-Fired Engines PostCombustion Controls: Industry Cost Effectiveness Va lues – based on capital and operating cost

data provided by industry and vendors and using bes t 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 an d 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 hist orical costs for installation and current

equipment and service cost estimates, typically quo ted 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 all owance for Catalyst washing (ATC), and

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

the three engines along with the averages. The Not es column provides background information

used to calculate the cost estimates.

# Technical Report: RICE NESHAP Control Costs Backgr ound for “Above the Floor Analysis”

Supplemental Information – April, 2010



# 2 During the detailed cost data compilation it was de termined that some of the capital cost quotes

from one of the catalyst vendors had been misinterp reted 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 Techn ical Report summary tables and attachments

provided below.

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

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

change or alter the conclusions contained in the No vember 2, 2009 report that demonstrated that

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

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

were noted and corrected. These changes impacted 4 SRB 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 capit al costs were small, and because the capital

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

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

revisions to the following summary tables and attac hments 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 Calcul ations for Gas-Fired 4SRB Engines

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

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

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

HAP control efficiency (90%)

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

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

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

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

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

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

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

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

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

control efficiency (90%)

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

insignificant change (i.e. less than 5%) to the cos t-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 demon strated that above the floor controls are not

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

or more times higher than the EPA proposed rule cos t. In addition, the review determined other

# Technical Report: RICE NESHAP Control Costs Backgr ound for “Above the Floor Analysis”

Supplemental Information – April, 2010



# 3 areas where capital and annual costs could be refin ed (i.e. some costs would increase slightly and

some costs would decrease slightly); however, a cur sory 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 pos t 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, 20104Table S-1. Detailed Capital Costs for 4SLB Engines300 to 500 hp.Cost Parameter Costs for Individual EnginesAverageCostsNotesEngine Make Waukesha Waukesha CaterpillarEngine Model F18GL F18GLD G3408CLEEngine Category 4SLB 4SLB 4SLBOEM-HP 400 400 425Engine OEM-RPM 1800 1800 1800Emissions Control Equipment and Auxiliary EquipmentCapital Costs (ECC)Engine O2 Sensors 0 0 00Silencer: Parts $3,808.00$3,808.00$4,250.00$3,955.33Silencers will be replaced for multiplereasons when the packages are retrofitted:catalyst access will be taken into account(i.e. catalyst will need to be atop the cooler& integrated into the silencer).Backpressure and size constraints are alsoconsiderations. Supplier quotesincludeany mounting hardwareNumber of Catalyst Elements 1 1 11Supplier quotes for number of requiredcatalyst elements.Catalyst: Parts $1,606.50$1,606.50$2,150.50$1,787.83Supplier quotes for catalyst element only.Crankcase Upgrade: Parts $507.00$507.00$0.00$338.00Waukesha GL engines that have closedloop crankcase ventilation systems requirethe installation of a crankcase filter toprevent catalyst fouling.AFR Controls: Parts $0.00$0.00$0.00$0.00AFR Controls: Misc. Parts $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Catalyst Thermocouples: Parts $160.00$160.00$160.00$160.00Thermocouples: Misc. parts and fittings(conduit, wiring, etc)$250.00$250.00$300.00$266.67TC installation and operation requiredbecause equipment are portable and couldbe installed at major source. TCs also forongoing internal maintenance requirementto measure catalyst T rise.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 2010524V 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$0.00AFRC not required for oxidation catalysts.ECC Total $6,331.50$6,331.50$6,860.50$6,507.83Sum of equipment costsFreight $243.65$243.65$288.02$258.44Estimated as 4.5% of silencer and catalystparts cost.Shipping formula fromsupplierPurchased Equipment Costs (PEC)$6,575.15$6,575.15$7,148.52$6,766.28PEC = ECC + FreightDirect Installation Costs (DIC)Silencer: Removal of Existing Silencerand Supports.$225.00$225.00$225.00$225.00Based on average labor hours and averagerates. Includes time for system cool down.Silencer: Welding $350.00$350.00$550.00$416.67Based on average labor hours and averagerates. Can include hot work permit.Silencer: Assoc. Lift Equipment Rental. $1,000.00$1,000.00$1,000.00$1,000.00Requirement for larger engines (> 300 hp).Cost for rental equipment, most rentals arefor minimum of one day.Silencer: Labor $375.00$375.00$375.00$375.00Based on average labor hours and averagerates.Catalyst: Labor $75.00$75.00$75.00$75.00Based on average labor hours and averagerates.Crankcase Upgrade: Labor $536.00$536.00$0.00$357.33Based on average labor hours and averagerates.AFR Controls: Labor $0.00$0.00$0.00$0.00O2 Sensors: Labor $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Catalyst Thermocouples: Labor $150.00$150.00$450.00$250.00Based on average labor hours and averagerates. Drill and tap holes and installbungs.Other Upgrades: Welding $250.00$250.00$350.00$283.33Based on average hours and average rates.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 2010624V Power: Battery Box Labor $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Direct Installation Costs (DIC) $2,961.00$2,961.00$3,025.00$2,982.33Sum of direct costsIndirect Installation Costs (IIC)Start-up Testing (maintenance test) $300.00$300.00$300.00$300.00Based on average labor hours and averagerates. To ensure unit is operatingproperly.Notification and Consult $700.00$700.00$700.00$700.00Cost for Exterran consultantto accomplishinitial notification and compliancedocumentation (i.e. track catalystemissions data - enter into database).Based on fleet average costs.Exterran Labor: Testing $402.00$402.00$402.00$402.00Based on average labor hours and averagerates.Customer Labor: Start-up and Shut Down$402.00$402.00$402.00$402.00Based on average labor hours and averagerates.Customer Labor: Testing (avg) $201.00$201.00$201.00$201.00Based on average labor hours and averagerates.Indirect Installation Costs (IIC) $2,005.00$2,005.00$2,005.00$2,005.00Sum of indirect costsTotal Capital Costs (TCC)$11,541.15$11,541.15$12,178.52$11,753.61TCC = PEC + DIC + IICTechnical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20107Table S-2. Detailed Operating and Maintenance Costs for 4SLB Engines 300 to 500 hp.Cost Parameter Costs for Individual EnginesAverageCostsNotesEngine Make Waukesha Waukesha CaterpillarAverageEngine Model F18GL F18GLD G3408CLE300-500HpEngine Category 4SLB 4SLB 4SLB4SLBOEM-HP 400 400 425Engine OEM-RPM 1,800 1,800 1,800Number of Carburetors 1 1 1Number of Catalysts 1 1 1Operating and Maintenance (O&M) Material Costs (O&MM)Crankcase Filter: parts $383.60$383.60$0.00$255.73Replace crankcase filter every three monthson Waukesha engines. Contractor quote.Replace: Per Catalyst Part $481.95$481.95$645.15$536.35Annualized replacement cost based onreplacing catalyst every three years (i.e.annualized cost = replacement cost *3/10).Assumed that catalysts intermittentlyoperated (e.g. 2,800 hrs/yr at wellhead)deactivate at similar rate as catalysts morecontinuously operated (e.g. 6,500 hrs/yr atcentral gathering station) because morefrequent start-ups and shut-downs thermallycycle the catalysts and contribute to moreunburned HC deposits. Supplier quote.Replace: O2 sensors Parts $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Replace: Thermocouples Parts $16.00$16.00$16.00$16.00Annualized replacement cost based onreplacing TC every 7.5 years (i.e. annualizedcost = replacement cost *1/10). Supplierquote for TC and wiring.Replace: Fuel Valve Parts $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Replace: Batteries Parts $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20108Extra Catalyst for Washing Schedules$24.10$24.10$32.26$26.82Annualized replacement cost for extracatalyst in rotation (1 rotational catalyst for20 units) based on replacing catalyst everythree years (i.e. annualized cost =replacement cost *3/10). This additional,rotational catalyst is required to minimizeequipment downtown and production losses(i.e. approach to minimize total cost ofapplying catalyst). Supplier quote.Maintenance Materials (MMC) $905.65$905.65$693.41$834.90Sum of maintenance materials costs.Cleaning Catalyst $52.50$52.50$63.00$56.00Annualized cost to wash catalysts based onwashing catalysts annually and replacingcatalyst every three years (i.e. annualizedcost = annual washing cost *(10-3)/10;catalysts not washed during replacementyears). Supplier quote.Catalyst Cleaning & Replacement:Crane$1,000.00$1,000.00$1,000.00$1,000.00Cost for crane to remove catalyst forreplacement or cleaning; requirement forlarger engines (> 300 hp). Cost for rentalequipment, most rentals are for minimum ofone day.Catalyst Cleaning & ReplacementCosts (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$1,890.90O&MM = MMC + CCRCO&M Labor Cost (O&ML)Customer Labor: Testing (avg) $201.00$201.00$201.00$201.00Based on average labor hours per engine andaverage rates. Some clients require that theybe on-site during testing, some do not.Customer Labor: Testing (CL) $201.00$201.00$201.00$201.00Crankcase Filter: Labor $268.00$268.00$0.00$178.67Replace crankcase filter every three monthson Waukesha engines. Based on averagelabor hours per engine and average rates perTechnical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20109event (4 events/yr). Waukesha GL enginesthat have closed loop crankcase ventilationsystems require the installation of acrankcase filter to prevent catalyst fouling.Contractor quote.Replace: Catalyst Labor $60.30$60.30$60.30$60.30Annualized replacement cost based onreplacing catalyst every three years (i.e.annualized labor cost = replacement laborcost *3/10). Based on average labor hoursand average rates per event. Upon review(4/11/10), the catalysts are rotated annuallyfor cleaning; thus, labor cost shouldnotbemultiplied by 3/10 and these costs areunderestimated (i.e. listed values should bemultiplied by 10/3). Contractor quote.Replace: O2 sensors Labor $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Replace: O2 sensor test $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Replace: Thermocouples Labor $13.40$13.40$13.40$13.40Annualized replacement cost based onreplacing TC every 7.5 years (i.e. annualizedcost = replacement cost *1/10). Contractorquote.Replace: Fuel Valve Labor $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Replace: Batteries Labor $0.00$0.00$0.00$0.00AFRC not required for oxidation catalysts.Emissions Equipment Testing(Maintenance)$600.00$600.00$600.00$600.00Emissions check (portable analyzer test)after catalyst replacement or rotation toensure proper function and continuedcompliance. Based on average testing hours(per engine and average rates. This eventoccurs requires remobilization of specializedpersonnel after maintenance activities.Maintenance labor (ML) $941.70$941.70$673.70$852.37Sum of maintenance labor costs.O&M Labor Cost (O&ML)$1,142.70$1,142.70$874.70$1,053.37O&ML = CL + MLTechnical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201010Annual Performance Testing or Downtime or other allowance for Catalyst washing (ATC)Compliance Testing $800.00$800.00$800.00$800.00Third party, portable analyzer testingrequired each time catalyst is replaced (newcatalyst or rotation). Based on testingcontractor quote.Compliance Testing: Exterran Cost $402.00$402.00$402.00$402.00For Exterran personnel to be onsite duringtesting. Based on average labor hours perengine and average ratesAnnual Performance Testing orDowntime or other allowance forCatalyst washing (ATC)$1,202.00$1,202.00$1,202.00$1,202.00Sum of compliance testing costsTotal Direct Annual Costs (TDAC)$4,302.85$4,302.85$3,833.11$4,146.27TDAC = O&MM + O&ML + ATCTechnical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201011Table 4. Cost Effectiveness Estimates for 4-StrokeLean Burn Engines (2007 $) –Revised 4/19/10.<50 hp50-100 hp100-175 hp175-300 hp300-500 hp500-1000 hpDocketA19,887 7,798 5,039 3,658 2,887 2,316BaselineB11,961 8,069 6,122 5,034 4,288Industry DataCBaseline25,0902004 RICE NESHAPDBaseline24,415Argonne/ NMDEQEBaseline36,148 21,407Proposed RuleFBaseline 5,152 3,476 2,637 2,169 1,847Industry DataCBaseline10,808DocketG15,748BaselineH10,517Argonne/ NMDEQEBaseline15,572 9,221Engine Size Range /Post-Combustion Emssion ControlCost-Effectiveness ($/ton2,800 Operating Hours per Year2004 RICE NESHAPProposed RuleCost Basis6,500 Operating Hours per YearCost MethodA.Cost Effectiveness data from docket document EPA-HQ-OAR-2008-0708-0017 Table 2. For 500 – 1,000 hp size category, value is average of600-750 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 using best estimates foruseful equipment life (10 years) and HAP emission factor (0.000478 lb HAP/hp-hr). Control efficiency= 90%. Refer to Attachment K foradditional detail.C.Industry cost effectiveness values based on capitaland operating cost data provided by industry and vendors and using best estimate values foruseful equipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP control efficiency (90%). Refer to Attachment Lfor additional detail.D.2001 cost effectiveness data from original RICE NESHAP (docket document number OAR-2002-0059-0225) with adjustments for inflation(to 2007 dollars based on 3% annual cost escalation/inflation), annual operating hours (2,800) and using best estimate values for HAPemission factor (0.000478 lb HAP/hp-hr) and controlefficiency (90%). Refer to Attachment E for additional detail.E.Estimated costs from cost data presented in “EngineClassification Matrix Control Options and Costs” prepared by Argonne NationalLaboratory and the State of New Mexico Department of Environmental Quality [Argonne 2007] using best estimate values for usefulequipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP control efficiency (90%). Refer to Attachment F foradditional detail.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201012F.Cost Effectiveness calculated using Proposed Rule data from docket document EPA-HQ-OAR-2008-0708-0017with adjustments for annualoperating hours (6,500), and using best estimate values for useful equipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr),and control efficiency (90%). Refer to AttachmentM for additional detail.G.2001 cost effectiveness data from original RICE NESHAP (docket document number OAR-2002-0059-0225) with adjustment for inflation (to2007 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 adjustments for inflation(to 2007 dollars based on 3% annual cost escalation/inflation) and using best estimates for HAP emission factor (0.000478 lb HAP/hp-hr) andcontrol efficiency (90%). Refer to Attachment E for additional detail.Table 5. Cost Effectiveness Estimates for 4-StrokeRich Burn Engines (2007 $)–Revised 4/9/10.<50 hp50-100 hp100-175 hp175-300 hp300-500 hp500-1000 hpDocketA33,373 13,162 8,549 6,241 4,952 3,998BaselineB44,168 29,372 21,971 17,835 14,999Revised EPA ModelCBaseline 269,008 267,273 178,868 129,486Industry DataDBaseline 176,718 220,388 147,111 101,7032004 RICE NESHAPEBaseline57,444Argonne/ NMDEQFBaseline107,820 65,791Proposed RuleGBaseline 19,206 12,653 9,464 7,683 6,461Revised EPA ModelHBaseline 138,223 133,132 92,850 70,349Industry DataIBaseline 112,906 119,258 81,526 58,452DocketJ86,935BaselineK24,745Argonne/ NMDEQFBaseline46,446 28,3412004 RICE NESHAPCost BasisEngine Size Range /Post-Combustion Emssion ControlCost-Effectiveness ($/tonHAP)2,800 Operating Hours per Year6,500 Operating Hours per YearProposed RuleA. Cost Effectiveness data from docket document EPA-HQ-OAR-2008-0708-0017 Table 2. For 500 – 1,000 hpsize category, value is average of600-750 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 best estimates for usefulequipment life (10 years) and AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr). Control efficiency= 90%. Refer to Attachment B foradditional detail.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201013C. Revised EPA Model data. Cost Effectiveness approach from docket document EPA-HQ-OAR-2008-0708-0017 was revised. Adjustmentswere made to best estimates for useful equipment life (10 years) and AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), capital costs(inflation adjust docket cost data and include costs for AFRC and power source), and O&M costs (EPA assumption that NSCR annual O&Mis equivalent to diesel particulate filter cleaningis incorrect and severely underestimates cost) anda fuel penalty associated with engineoperation at a less efficient AFR for NSCR is considered. Control efficiency = 90%. Refer to Attachment C for additional detail.D. Industry cost effectiveness values based on capital and operating cost data provided by industry and vendors and using best estimate values foruseful equipment life (10 years), AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and HAP control efficiency (90%). Refer toAttachment Dfor additional detail.E. 2001 cost effectiveness data from original RICENESHAP (docket document number OAR-2002-0059-0225)with adjustments for inflation(to 2007 dollars based on 3% annual cost escalation/inflation), annual operating hours (2,800), and using best estimate values for AP-42 HAPemission factor (2.43E-04 lb HAP/hp-hr) and controlefficiency (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 Argonne NationalLaboratory and the New Mexico Department of Environmental Quality [Argonne 2007] using best estimate values for useful equipment life(10 years), AP-42 HAP emission factor (2.43E-04 lbHAP/hp-hr), and HAP control efficiency (90%). Refer to Att. F for detail.G. Proposed Rule Values (Docket Document EPA-HQ-OAR-2008-0708-0017 Table 2) with adjustments ] usingbest estimate values for usefulequipment life (10 years) and AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and annual operatinghours (6,500). Refer to AttachmentG for additional detail.H. Revised EPA Model data. Cost Effectiveness approach from docket document EPA-HQ-OAR-2008-0708-0017was revised with adjustmentsto 6,500 annual operating hours and as described infootnote C. Refer to Attachment Hfor additional detail.I. Industry cost effectiveness values based on capital and operating cost data provided by industry and vendors and using best estimate values foruseful equipment life (10 years), AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and HAP control efficiency (90%). Refer toAttachment Ifor additional detail.J. 2001 cost effectiveness data from original RICENESHAP (docket document number OAR-2002-0059-0225)with adjustment for inflation (to2007 dollars based on 3% annual cost escalation/inflation). Refer to Attachment E for additional detail.K. 2001 cost effectiveness data from original RICENESHAP (docket document no. OAR-2002-0059-0225) with adjustments for inflation (to2007 dollars based on 3% annual cost escalation/inflation), and using best estimate values for AP-42 HAP emission factor (2.43E-04 lbHAP/hp-hr) and control efficiency (90%). Refer toAttachment E for additional detail.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201014Attachment 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 andvendors, and usingbest estimate values for useful equipment life (10years), AP-42 HAP emission factor (2.43E-04 lb HAP/hp-hr), and HAPcontrol efficiency (90%) –Revised 4/19/10.1Parameter Value Units Notes/Comments2 Engine Type 4SRB 4SRB4SRB 4SRB3 Fuel UsedNatural Gas4 Post Combustion Control NSCR NSCRNSCR NSCR5 Control Purpose CH2O, CO, & NOx6Target Reduction - CatalystControl Efficiency (CCE)90% 90%90% 90% %Assumed control efficiency for NSCR catalysts (OAR-2008-0708-0017, OAR-2008-0708-0001)7 Project Duration (n) 10 1010 10 yearsIndustry budgets for AFRC and alternatorreplacement/system overhaul every 10 years. Miratechnotes that for budgetary reasons should expect to replacea catalyst element after 24,000 to 32,000 hours ofoperation. Average = 28,000 = 10 years (OAR-2005-0030-0087). These hours not based on any performanceguarantees, industry experience for guaranteedperformance is more frequent catalyst replacement.OAR-2005-0029-0038 lists catalyst replacement every3- 5 years.8Project Discount Interest Rate(i)7.0% 7.0%7.0% 7.0% % (OAR-2005-0030-0005)9 Engine Size Range (ESR) 50 - 100100 -175175 -300300 -500hp OAR-2008-0708-0017 Table 2.10 Site-Rated Power (SR) 75 137.5237.5 400 hp Midpoint of Engine Size Range11 Average Operating Load (OL) 100% 100%100% 100% % Assume 100% load for cost analysis12 Annual Operating Hours (AOH) 2,800 2,8002,800 2,800 hrsAnnual operating hours that are the basis for the EPAcontrol cost analysis (OAR-2005-0030-0005).13 HAP Emission Factor (HAPEF) 2.43E-4 2.43E-42.43E-4 2.43E-4lb HAP/hp-hrAP-42 EF for total HAP for 4SRB NG-fired engines.14HAP Emission Reductions(∆HAP)45.9 84.2145.4 244.9lb HAP/yr**∆**HAP = SR * OL * AOH * HAPEF * CCE15Capital CostsTechnical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20101516Purchased Equipment Cost(PEC)$9,195 -- - Refer to Footnote A.17Purchased Equipment Cost(PEC)- $11,389- - Refer to Footnote B.18Purchased Equipment Cost(PEC)- -$12,413 - Refer to Footnote C.19Purchased Equipment Cost(PEC)- -- $14,086 Refer to Footnote D.20 Total Capital Cost (TCC) $12,222 -- - $ Refer to Footnotes A, E21 Total Capital Cost (TCC) - $13,974- - $ Refer to Footnotes B, E22 Total Capital Cost (TCC) - -$15,653 - $ Refer to Footnotes C, E23 Total Capital Cost (TCC) - -- $17,333 $ Refer to Footnotes D, E24Direct Annual Costs25Operating and MaintenanceMaterial Costs (O&MM)**$664 $1,071** **$1,706 $2,384** $Annualized equipment Cost to replace Catalyst (every 3years), O2 Sensors (8 months,**~**2,000 operating hours),Thermocouples (7.5 years), Crankcase Filters (3months), Fuel Valve (4 - 8 years), and Battery (2 years).Cost for annual catalyst cleaning, crane (for largerengines), and rotational catalyst.26 O&M Labor Cost (O&ML)**$1,275 $1,320** $1,360**$1,380**$Annualized labor Cost to replace and rotate (forcleaning) Catalyst, O2 Sensor, Thermocouples, FuelValve, Crankcase Filter, Battery, and PerformEquipment Testing (e.g. O2 Sensor Test, AFRCoptimization after O2 sensor replacement)27Annual Performance Testing orDowntime or other allowancefor Catalyst washing (ATC)$0 $3,978$3,978 $3,978 $Estimated cost for annual FTIR performance test andassociated cost; required when catalysts are replaced orrotated for outside cleaning.28Total Direct Annual Costs(TDAC)$1,939 $6,369$7,044 $7,742 $ = O&MM + O&ML + ATC29Indirect Annual CostsAdministrative Charges(ADMC)$0 $225$225 $22530 Fuel Penalty (FPC) $379 $695$1,200 $2,021 $FPC = [7,420 - 7,188] (Btu/hp-hr) * 1/900 (scf/Btu(gasLHV)) * 1/1000 (scf/Mcf) * SR (hp) * OL (hp/hp) *AOH (hrs) * $7/Mcf.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201016• 7,420 Btu/hp-hr is brake specific fuel consumption(BSFC) for Waukesha VGF GSI 4SRB engines operatedat AFR = 0.995 (AFR for optimum NSCR performance)• 7,188 Btu/hp-hr is brake specific fuel consumption forWaukesha VGF GSI 4SRB engines operated at AFR=1.06 (AFR for optimum engine efficiency)• Waukesha VGF GSI BSFC data provided by NickKosinski, Waukesha engineer.• $7/Mcf - estimated average natural gas price in 2007[DOE/EIA website]31 Capital Recovery Factor (CRF) 0.142378 0.1423780.142378 0.142378CRF = i * (1+i)^n / [(1+i)^n - 1] (i expressed as adecimal - e.g., 10% = 0.1)32 Capital Recovery (CRC) $1,740 $1,990$2,229 $2,468 $ CRC = CRF * TCC33Total Indirect Annual Costs(TIAC)$2,119 $2,909$3,654 $4,714 $ TIAC = ADMC + FPC + CRC34Cost Summary - Total Annual Costs (TAC)35Total Direct Annual Costs(TDAC)$1,939 $6,369$7,044 $7,742 $36Total 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 + TIAC38Cost-Effectiveness39 Cost-Effectiveness (CE) $176,718 $220,388$147,111 $101,703$/tonHAPCE = TAC /**∆**HAP / 200040A. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 50 to 100 hp. Exterran provided cost data for tenrecent installations with average PEC = $9,195 (range of $8,935 - $10,099) and average installed TCC =$12,665 (range of $11,945 to $13,363).Engines include Arrow VRG 220 and VRG 330; WaukeshaVRG 265, 195 GK, VRG 310, 135 GZ, VRG 330, 140 GZ,and F554G; and CaterpillarG3304NA (range of 53 - 95 hp) and the costs do notinclude an initial performance test. Devon estimated installed NSCR cost/TCC = $14,000 forengines 50 - 500 hp "based on some recent catalystinstallations performed in two different operational areas." MCBU provided that "Rich burn NSCRand AFR procurement and installation costs for 50-250 HP range from $10,000 - $15,000." MCBU has fiveengines of 50 - 100 hp equipped withNSCR. For this smallest engine range (50 - 100 hp),the low end of these costs were used. TCC used for cost-effectiveness calculations based onaverage of Exterran average and the Devon and MCBUvalues. The average ratio of Total Capital Cost to Purchased Equipment Cost (for engineswhere PEC was provided) was 1.38.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20101741B. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 100 to 175 hp. Exterran provided cost data for sixrecent installations with average PEC = $11,389 (range of $10,827 - $12,284) and average installed TCC= $16,172 (range of $15,139 to $17,132).Engines include Waukesha F11G, F817G, WAK-B, 145 GZ; and Caterpillar G3306NA and G333NA (range of 116- 172 hp) and the costs do notinclude an initial performance test. Devon estimated installed NSCR cost/TCC = $14,000 for engines 50- 500 hp "based on some recent catalystinstallations performed in two different operational areas." MCBU provided that "Rich burn NSCR and AFR procurement and installation costs for 50-250 HP range from $10,000 - $15,000." MCBU has 51engines of 100 - 250 hp equipped with NSCR. For this engine range (100 - 175 hp), a linearlyextrapolated estimate based on 137.5 hp was used.TCC used for cost-effectiveness calculations basedon average of Exterran average and the Devonand MCBU values. The average ratio of Total Capital Cost to Purchased Equipment Cost (for engines where PEC was provided) was 1.40.42C. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 175 to 300 hp. Exterran provided cost data for 13recent installations with average PEC = $12,413 (range of $10,667 - $16,119) and average installed TCC= $17,958 (range of $16,165 to $22,117).Engines include Waukesha F1197G, F1905G, F18G, andF11GSI; and Caterpillar G3306TA, G3406NA, G3306TAA,G342NA, G343NA, G353NA,G3408NA, G342TA, and G342TAA... (range of 203 - 265hp) and the costs do not include an initial performance test. Devon estimated installed NSCRcost/TCC = $14,000 for engines 50 - 500 hp "based on some recent catalyst installations performed in two different operational areas." MCBU providedthat "Rich burn NSCR and AFR procurement and installation costs for 50-250 HP range from $10,000 - $15,000." MCBU has 51 engines of 100 - 250hp equipped with NSCR. For this engine range (175- 300 hp), the maximum of $15,000 was used. TCC used for cost-effectiveness calculations basedon average of Exterran average and the Devon and MCBU values. The average ratio of Total Capital Cost to Purchased Equipment Cost (for engineswhere PEC was provided) was 1.40.43D. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 300 to 500 hp. Exterran provided cost data for 15recent installations with average PEC = $14,086 (range of $11,777 - $16,689) and average installed TCC= $20,666 (range of $17,240 to $24,502).Engines include Waukesha H2475G, LRO, F18GSI, F18GSID, F2895G, LRZ, L3711G; and Caterpillar G3508NA, G306TA, G379NA, G3408TA,G3408TAW, G379TA, G379TAA, AND G398NA. (range of 310 - 500 hp) and the costs do not include an initialperformance test. Devon estimatedinstalled NSCR cost/TCC = $14,000 for engines 50 -500 hp "based on some recent catalyst installationsperformed in two different operational areas."TCC used for cost-effectiveness calculations basedon average of Exterran average and the Devon value.The average ratio of Total Capital Cost toPurchased Equipment Cost (for engines where PEC wasprovided) was 1.42.44 E. Total Capital Costs do not include initial performance test which would be required with or without post-combustion controls installation.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201018Attachment 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 andvendors, 6,500 annualoperating hours,and using best estimate values for useful equipmentlife (10 years), AP-42 HAP emission factor (2.43E-04 lbHAP/hp-hr), and HAP control efficiency (90%) –Revised 4/19/10.1Parameter Value Units Notes/Comments2 Engine Type 4SRB 4SRB 4SRB4SRB3 Fuel Used Natural Gas4 Post Combustion Control NSCR NSCR NSCRNSCR5 Control Purpose CH2O, CO, & NOx6Target Reduction -Catalyst ControlEfficiency (CCE)90% 90% 90%90% %Assumed control efficiency for NSCR catalysts (OAR-2008-0708-0017, OAR-2008-0708-0001)7 Project Duration (n) 10 10 1010 yearsIndustry budgets for AFRC and alternator replacement/systemoverhaul every 10 years. Miratech notes that for budgetaryreasons should expect to replace a catalyst elementafter 24,000 to32,000 hours of operation. Average = 28,000 = 10 years (OAR2005-0030-0087). These hours not based on any performanceguarantees, industry experience for guaranteed performance ismore frequent catalyst replacement. OAR-2005-0029-0038 listscatalyst replacement every 3 - 5 years.8Project Discount InterestRate (i)7.0% 7.0% 7.0%7.0% % (OAR-2005-0030-0005)9 Engine Size Range (ESR) 50 - 100100 -175175 -300300 -500hp OAR-2008-0708-0017 Table 2.10 Site-Rated Power (SR) 75 137.5 237.5400 hp Midpoint of Engine Size Range11Average Operating Load(OL)100% 100% 100%100% % Assume 100% load for cost analysis12Annual Operating Hours(AOH)6,500 6,500 6,5006,500 hrsAnnual operating hours that are the basis for the EPA control costanalysis (OAR-2005-0030-0005).13HAP Emission Factor(HAPEF)2.43E-4 2.43E-4 2.43E-42.43E-4lb HAP/hp-hrAP-42 EF for total HAP for 4SRB NG-fired engines.14HAP Emission Reductions(∆HAP)106.6 195.5 337.6568.6lb HAP/yr∆HAP = SR * OL * AOH * HAPEF * CCE15Capital Costs16Purchased Equipment Cost(PEC)$9,195 - -- Refer to Footnote A.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20101917Purchased Equipment Cost(PEC)- $11,389 -- Refer to Footnote B.18Purchased Equipment Cost(PEC)- - $12,413- Refer to Footnote C.19Purchased Equipment Cost(PEC)- - -$14,086 Refer to Footnote D.20 Total Capital Cost (TCC) $12,222 - -- $ Refer to Footnotes A, E21 Total Capital Cost (TCC) - $13,974 -- $ Refer to Footnotes B, E22 Total Capital Cost (TCC) - - $15,653- $ Refer to Footnotes C, E23 Total Capital Cost (TCC) - - -$17,333 $ Refer to Footnotes D, E24Direct Annual Costs25Operating andMaintenance MaterialCosts (O&MM)$839 $1,246 $1,881$2,589 $Annualized equipment Cost to replace Catalyst (every 3 years),O2 Sensors (8 months, ~ 2,000 operating hours), Thermocouples(7.5 years), Crankcase Filters (3 months), Fuel Valve (4 - 8 years),and Battery (2 years). Cost for annual catalyst cleaning, crane (forlarger engines), and rotational catalyst.26O&M Labor Cost(O&ML)$2,560 $2,604 $2,664$2,667 $Annualized labor Cost to replace and rotate (for cleaning)Catalyst, O2 Sensor, Thermocouples, Fuel Valve, CrankcaseFilter, Battery, and Perform Equipment Testing (e.g. O2 SensorTest, AFRC optimization after O2 sensor replacement)27Annual PerformanceTesting or Downtime orother allowance forCatalyst washing (ATC)$0 $3,978 $3,978$3,978 $Estimated cost for annual FTIR performance test andassociatedcost; required when catalysts are replaced or rotated for outsidecleaning.28Total Direct Annual Costs(TDAC)$3,399 $7,828 $8,523$9,234 $ = O&MM + O&ML + ATC29Indirect Annual CostsAdministrative Charges(ADMC)$0 $225 $225$225FPC = [7,420 - 7,188] (Btu/hp-hr) * 1/900 (scf/Btu(gas LHV)) *1/1000 (scf/Mcf) * SR (hp) * OL (hp/hp) * AOH (hrs)* $7/Mcf.30 Fuel Penalty (FPC) $880 $1,613 $2,786$4,692 $• 7,420 Btu/hp-hr is brake specific fuel consumption (BSFC) forWaukesha VGF GSI 4SRB engines operated at AFR = 0.995(AFR for optimum NSCR performance)Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201020• 7,188 Btu/hp-hr is brake specific fuel consumption for WaukeshaVGF GSI 4SRB engines operated at AFR =1.06 (AFR foroptimum engine efficiency)• Waukesha VGF GSI BSFC data provided by Nick Kosinski,Waukesha engineer.• $7/Mcf - estimated average natural gas price in 2007 [DOE/EIAwebsite]31Capital Recovery Factor(CRF)0.142378 0.142378 0.1423780.142378CRF = i * (1+i)^n / [(1+i)^n - 1] (i expressed as adecimal - e.g.,10% = 0.1)32 Capital Recovery (CRC) $1,740 $1,990 $2,229$2,468 $ CRC = CRF * TCC33Total Indirect AnnualCosts (TIAC)$2,620 $3,827 $5,239$7,384 $ TIAC = ADMC + FPC + CRC34Cost Summary - Total Annual Costs (TAC)35Total Direct Annual Costs(TDAC)$3,399 $7,828 $8,523$9,234 $36Total Indirect AnnualCosts (TIAC)$2,620 $3,827 $5,239$7,384 $37 Total Annual Costs (TAC) $6,019 $11,655 $13,762$16,618 $ TAC = TDAC + TIAC38Cost-Effectiveness39 Cost-Effectiveness (CE) $112,906 $119,258 $81,526$58,452$/tonHAPCE = TAC / ∆HAP / 200040A. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 50 to 100 hp. Exterran provided cost data for ten recentinstallations with average PEC = $9,195 (range of $8,935 - $10,099) and average installed TCC = $12,665 (range of $11,945 to $13,363). Engines includeArrow VRG 220 and VRG 330; Waukesha VRG 265, 195 GK, VRG 310, 135 GZ, VRG 330, 140 GZ, and F554G; andCaterpillar G3304NA (range of 53 -95 hp) and the costs do not include an initial performance test. Devon estimated installed NSCR cost/TCC = $14,000 for engines 50 - 500 hp "based onsome recent catalyst installations performed in twodifferent operational areas." MCBU provided that"Rich burn NSCR and AFR procurement andinstallation costs for 50-250 HP range from $10,000- $15,000." MCBU has five engines of 50 - 100 hpequipped with NSCR. For this smallest enginerange (50 - 100 hp), the low end of these costs were used. TCC used for cost-effectiveness calculations based on average of Exterran average and theDevon and MCBU values. The average ratio of TotalCapital Cost to Purchased Equipment Cost (for engines where PEC was provided) was 1.38.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20102141B. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 100 to 175 hp. Exterran provided cost data for six recentinstallations with average PEC = $11,389 (range of$10,827 - $12,284) and average installed TCC = $16,172 (range of $15,139 to $17,132). Enginesinclude Waukesha F11G, F817G, WAK-B, 145 GZ; and Caterpillar G3306NA and G333NA (range of 116 - 172 hp) and the costs do not include an initialperformance test. Devon estimated installed NSCR cost/TCC = $14,000 for engines 50 - 500 hp "based onsome recent catalyst installations performed intwo different operational areas." MCBU provided that "Rich burn NSCR and AFR procurement and installation costs for 50-250 HP range from $10,000 -$15,000." MCBU has 51 engines of 100 - 250 hp equipped with NSCR. For this engine range (100 - 175 hp), a linearly extrapolated estimate based on137.5 hp was used. TCC used for cost-effectiveness calculations based on average of Exterran averageand the Devon and MCBU values. The averageratio of Total Capital Cost to Purchased EquipmentCost (for engines where PEC was provided) was 1.40.42C. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 175 to 300 hp. Exterran provided cost data for 13 recentinstallations with average PEC = $12,413 (range of$10,667 - $16,119) and average installed TCC = $17,958 (range of $16,165 to $22,117). Enginesinclude Waukesha F1197G, F1905G, F18G, and F11GSI;and Caterpillar G3306TA, G3406NA, G3306TAA, G342NA,G343NA, G353NA, G3408NA,G342TA, and G342TAA... (range of 203 - 265 hp) andthe costs do not include an initial performance test. Devon estimated installed NSCR cost/TCC =$14,000 for engines 50 - 500 hp "based on some recent catalyst installations performed in two different operational areas." MCBU provided that "Rich burnNSCR and AFR procurement and installation costs for50-250 HP range from $10,000 - $15,000." MCBU has51 engines of 100 - 250 hp equipped withNSCR. For this engine range (175 - 300 hp), the maximum of $15,000 was used. TCC used for cost-effectiveness calculations based on average ofExterran average and the Devon and MCBU values. The average ratio of Total Capital Cost to PurchasedEquipment Cost (for engines where PEC wasprovided) was 1.40.43D. Based on capital cost data provided by Devon, Exterran, and MCBU for engines ranging from 300 to 500 hp. Exterran provided cost data for 15 recentinstallations with average PEC = $14,086 (range of$11,777 - $16,689) and average installed TCC = $20,666 (range of $17,240 to $24,502). Enginesinclude Waukesha H2475G, LRO, F18GSI, F18GSID, F2895G, LRZ, L3711G; and Caterpillar G3508NA, G306TA, G379NA, G3408TA, G3408TAW,G379TA, G379TAA, AND G398NA. (range of 310 - 500 hp) and the costs do not include an initial performance test. Devon estimated installed NSCRcost/TCC = $14,000 for engines 50 - 500 hp "based on some recent catalyst installations performed in two different operational areas." TCC used for cost-effectiveness calculations based on average of Exterran average and the Devon value. The average ratio of Total Capital Cost to Purchased 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 controls installation.Technical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 201022Attachment L – “Baseline” Cost Effectiveness Calculations for Gas-Fired 4SLB Engines Post-CombustionControls: IndustryCost Effectiveness Values - based on capital and operating cost data provided by industry and vendorsand using best estimatevalues for useful equipment life (10 years), HAP emission factor (0.000478 lb HAP/hp-hr), and HAP control efficiency (90%)–Revised4/19/10.1Parameter Value Units Notes/Comments2 Engine Type 4SLB3 Fuel Used Natural Gas4 Post Combustion Control Ox CatOx Cat5 Control Purpose6Target Reduction - CatalystControl Efficiency (CCE)90%90% %Assumed control efficiency for Oxidation catalysts(OAR-2008-0708-0017,OAR-2008-0708-0001)7 Project Duration (n) 1010 yearsMiratech notes that for budgetary reasons should expect to replace a catalystelement after 24,000 to 32,000 hours of operation.Average = 28,000 = 10years (OAR-2005-0030-0087). These hours not basedon any performanceguarantees, industry experience for guaranteed performance is more frequentcatalyst replacement. OAR-2005-0029-0038 lists catalyst replacement every3 - 5 years.8 Project Discount Interest Rate (i) 7.0%7.0% % (OAR-2005-0030-0005)9 Engine Size Range (ESR)300 -500300 -500hp OAR-2008-0708-0017 Table 2.10 Site-Rated Power (SR) 400400 hp Midpoint of Engine Size Range11 Average Operating Load (OL) 100%100% % Assume 100% load for cost analysis12 Annual Operating Hours (AOH) 2,8006,500 hrsAnnual operating hours that are the basis for the EPA control cost analysis(OAR-2005-0030-0005).13 HAP Emission Factor (HAPEF) 0.0004780.000478lb HAP/hp-hrEF for total HAP for NG-fired engines < 500 hp; the size range that is thebasis for the above the floor analysis (OAR-2005-0030-0009)14HAP Emission Reductions(∆HAP)481.81118.5lb HAP/yr∆HAP = SR * OL * AOH * HAPEF * CCE15Capital Costs16Purchased Equipment Cost(PEC)$6,766$6,766 Refer to Footnote A.17 Total Capital Cost (TCC) $11,754$11,754 $ Refer to Footnotes B.18Direct Annual CostsTechnical Report: RICE NESHAP Control Costs Background for “Above the Floor Analysis”Supplemental Information – April, 20102319Operating and MaintenanceMaterial Costs (O&MM)$1,891$1,891 $Annualized equipment Cost to replace Catalyst (every 3 years),Thermocouples (7.5 years), and Crankcase Filters (3months) and annualcatalyst rotation for cleaning. Cost for rotational catalyst, catalyst cleaning,and crane.20 O&M Labor Cost (O&ML) $1,053$1,053 $Annualized labor Cost to replace and rotate (for cleaning) Catalyst,Thermocouples, and Crankcase Filter.21Annual Performance Testing orDowntime or other allowance forCatalyst washing (ATC)$1,202$1,202 $Estimated cost for annual performance test and associated cost; required whencatalysts are replaced or for annual rotation for outside cleaning.22Total Direct Annual Costs(TDAC)$4,146$4,146 $ = O&MM + O&ML + ATC23Indirect Annual Costs24 Administrative Charges (ADMC) $225$22525 Capital Recovery Factor (CRF) 0.1423780.142378 CRF = i * (1+i)^n / [(1+i)^n - 1] (i expressed as a decimal - e.g., 10% = 0.1)26 Capital Recovery (CRC) $1,674$1,674 $ CRC = CRF * TCC27Total Indirect Annual Costs(TIAC)$1,899$1,899 $ TIAC = ADMC + CRC28Cost Summary - Total Annual Costs (TAC)29Total Direct Annual Costs(TDAC)$4,146$4,146 $30Total Indirect Annual Costs(TIAC)$1,899$1,899 $31 Total Annual Costs (TAC) $6,045$6,045 $ TAC = TDAC + TIAC32Cost-Effectiveness33 Cost-Effectiveness (CE) $25,090$10,808$/tonHAPCE = TAC / ∆HAP / 200034A. Based on capital cost data provided by Exterranfor engines ranging from 300 to 500 hp. Exterranprovided cost data for three engines withaverage PEC = $6,766 (range of $6,575 - $7,149) andaverage installed TCC = $11,754 (range of $11,541to $12,179). The data were compiledusing historical costs for installation and currentequipment cost estimates, typically quoted by a supplier. Engines include Waukesha F18GL andF18GLD, Caterpillar G3408CLE and the costs do not include an initial performance test. The averageratio of Total Capital Cost to PurchasedEquipment 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 installation.