Tanya –

Attached are the following documents which describe the use of the oxidation

converter with Ajax engines:

1.•A 2006 article from Compressor Tech Two magazine.

2.•A 2009 article from Compressor Tech Two magazine.

3.•A 2008 article in the GMC Today news magazine.

4.•A 2006 technical paper describing the development and early field testing 

with

the converter for 2SLB engines.

Based on the test results collected up until early 2009, we had been 

guaranteeing the

following emissions removal efficiencies for at least one year before 

cleaning of the

catalyst elements would be needed:

CO – 83% removal

NMNEHC – 70% removal

H2CO – 73% removal

These removal efficiencies are reflected in the stack emissions data which are

provided in Table 1 of the 2nd attachment. Now that we have gained more 

operating

experience with these converters, we have recently been guaranteeing a CO 

removal

of 90%.

Because these are guaranteed emissions removal efficiencies, we are cautious 

with

our claim about operating time allowed before catalyst cleaning. Several of 

the field

sites have operated for a few years with no catalyst cleaning needed, and the 

original

site has accumulated more than five years of operation with no catalyst 

cleaning

needed.

All of the attached documents contain field test results, and the 2006 

technical paper

contains a graph showing the emissions removal efficiencies during two years 

of

operation.

Regarding the age of the engines to which these oxidation converters were 

applied:

1.•Most of these converter applications were for new engines, but some of 

these

new engines have now been operating for a few years with the converters.

2.•The first applications of these converters were done for engines which had

already been in service for about two years. These two converters have now

been in operation for more than five years, so these engines are now seven

years old.

3.•We can apply these converters to any of the 2SLB Ajax engines, regardless 

of

age.

Bruce

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

Sent: Wednesday, October 21, 2009 9:04 AM

To: Chrisman, Bruce

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Bruce,

Another thing that would be helpful to know as well is the age of the engines.

Tanya

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

Sent: Wednesday, October 21, 2009 9:36 AM

To: 'Chrisman, Bruce'

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Thanks again Bruce.

Do you have more detailed information on those actual installations that you 

mentioned, i.e., specific

location, engine model/size, etc.? Also, EPA wanted me to ask you if you 

have any data that you can

share that demonstrates what the catalyst achieved? I know you said they met 

the quoted emission

reduction, but if you have data that shows this, that would help us out 

greatly.

Tanya

From: Chrisman, Bruce [mailto:Bruce.Chrisman@c-a-m.com]

Sent: Friday, October 16, 2009 12:57 PM

To: Tanya Parise

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines
Tanya –

The converter & catalyst element costs which I provided are only for the 

equipment.

These costs do not include the labor for installation or the annual 

maintenance costs.

The cost for the labor involved with installing the muffler/converter 

combination is

about the same as it would be for the labor involved with installing a new 

muffler

without a converter.

The cost for the new muffler with converter and catalyst elements (row 3) 

would be

applicable for a new engine, or to a site where they were not able to use 

their old

muffler. The cost that will apply most of the time for retrofits will be the 

installation of the

converter and catalyst elements into the customer’s existing muffler. 

Mufflers usually

have a long life – typically more than 15 years. If the old muffler cannot be 

used for the

retrofit, then it was probably time for the customer to at least buy a new 

muffler to

replace the old one.

The cost for the muffler cannot be subtracted from the cost for the retrofit 

in row 4. For

this retrofit, we assume that the old muffler at the site will be converted 

to the

combination muffler/converter design. We have done this on an exchange basis 

in

which the customer sends us his muffler and we install the converter. The 

total cost for

this conversion is the cost in row 4.

The yearly operating and maintenance costs for the converter are difficult to 

estimate.

The cost for cleaning a catalyst element is $800. However in five years of 

supplying

these converters, only one customer has sent catalyst elements in to be 

cleaned, and

that was because they used the wrong engine oil, which contaminated the 

catalyst

elements. The main item associated with operating costs is the cost for 

emissions

testing, which varies a great deal depending on the local enforcement 

requirements.

Some of these sites with converters are checked for emissions on a quarterly 

basis,

while others are on an annual basis. Some of these customers have their own

analyzers, while others have to pay for a third party testing service.

The first two converters placed into service with the Ajax 2SLB engines were 

installed

in 2004 in Western CO. These converters have met the quoted emissions 

reduction

levels with no need to clean the catalyst elements after more than 40,000 

operating

hours. The Ajax converters are now in service on engines in the following 

states: CO,

WY, WV, ND, NM, TX, and OK.

Bruce

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

Sent: Friday, October 16, 2009 6:41 AM

To: Chrisman, Bruce

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Bruce,

Thanks for the information. It looks like the costs you provided are 

equipment costs only, is that

right? Do you have any information on yearly operating and maintenance 

costs? Also, which

cost would it be most appropriate to use for retrofitting engines, the cost 

in row 4? If so, would

the cost of a standard muffler be excluded from the price, i.e., making the 

total equipment cost

for the DPC-60 $9,661-$2,895 = $6,766? Or should we assume muffler 

replacement on most

engines?

Also, what are the locations of the installations of catalyst Ajax has done 

on 2SLB engines? The

more details you can give us on the actual installations you’ve been 

providing the oxidation

converters would be most helpful.

PS-Thanks for the agenda too.
Tanya

From: Chrisman, Bruce [mailto:Bruce.Chrisman@c-a-m.com]

Sent: Thursday, October 15, 2009 12:27 PM

To: Tanya Parise

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Tanya –

For the following table, I selected one of the smaller Ajax engines (58 BHP) 

and one of

the larger Ajax engines (600 BHP). This information provides an indication of 

the costs

for oxidation converters and catalyst elements as a function of the engine 

BHP ratings.

All of the Ajax engines are 2SLB engines, and the range of Ajax engines 

covers from

15 BHP to 850 BHP. This table contains the prices to the engine users for the 

standard

exhaust muffler and for the mufflers which contain converter boxes and 

catalyst

elements.

As an explanation of the row headings for this table:

1.•All engines require the standard exhaust muffler.

2.•The 3rd row includes the muffler price + the converter box + the catalyst

elements.

3.•The 4th row defines a retrofit of the converter & catalyst elements into 

the

engine user’s existing muffler.

DPC-60

DPC-2803LE

Rated Engine BHP

58

600

Standard Muffler

$2,895.

$17,590.

New Muffler with Converter &

Catalyst Elements

$12,191.

$51,378

Retrofit of Converter & Catalyst

Elements in a Used Muffler

$9,661.

$33,788.

The Exhaust Emissions Workshop is organized by the Southern Gas Association 

and

the Gas Machinery Research Council. This annual workshop is hosted by Ajax. 

It

includes the conducting of emissions testing on an engine running near its 

design

rating. Three emissions analyzer companies participate in this testing, and 

we collect

data from each of these companies. An agenda for this workshop is attached. 

The

afternoon sessions on Tuesday & Wednesday consist of engine emissions testing.

The Thursday morning session covers all of the recent air quality regulations.

Bruce

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

Sent: Thursday, October 15, 2009 7:12 AM

To: Chrisman, Bruce

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Sounds good.

The workshops sounds interesting. May I ask what the focus is? Will you be 

presenting emissions

data?

Tanya

From: Chrisman, Bruce [mailto:Bruce.Chrisman@c-a-m.com]

Sent: Wednesday, October 14, 2009 3:56 PM

To: Tanya Parise

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Tanya –

Great – that simplifies the response. I can send you that information for one 

of our
small engines and one of our large engines by Thur. morning. Normally I could 

get that

to you a bit quicker, but we have a large group of customers visiting our 

plant today for

an Exhaust Emissions Testing Workshop

Bruce

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

Sent: Wednesday, October 14, 2009 2:20 PM

To: Chrisman, Bruce

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Bruce,

I think that selecting a sample group of engines within that range would be 

adequate as long as we

have the low and high end of the HP range/costs.

Tanya

From: Chrisman, Bruce [mailto:Bruce.Chrisman@c-a-m.com]

Sent: Wednesday, October 14, 2009 2:33 PM

To: Tanya Parise

Subject: RE: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Tanya –

The cost for the oxidation converter for a 2SLB engine depends strongly on 

the power

rating for the engine. There are 2SLB engines operating in the U.S.A. with 

site ratings

ranging from 15 BHP to 13,500 BHP per engine. The Ajax division of Cameron

currently produces 2SLB engines ranging from 40 to 850 BHP per engine. We’ve 

been

providing the oxidation converters for these Ajax engines for the last five 

years.

I can provide the costs for new converters with catalyst elements and for 

field retrofit

converters with catalyst elements. If I were to select a couple of engines 

within that

BHP range and provide the converter costs for those engines, do you think 

that would

be an adequate response to your inquiry?

Best regards,

Bruce Chrisman

Manager of Engineering

Cameron’s Compression Systems

2101 S.E. 18th Street

Oklahoma City, OK 73129

Tel 405.619.5058

Bruce.Chrisman@c-a-m.com

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

Sent: Wednesday, October 14, 2009 9:55 AM

To: Chrisman, Bruce

Subject: Existing RICE NESHAP - Information for EPA for 2SLB Engines

Bruce,

I am a contractor working with Ms. Melanie King of the US EPA on the existing

RICE NESHAP. We are hoping you can assist EPA in providing additional cost

information on adding aftertreatment to existing stationary 2SLB engines and

verifying some available aftertreatment costs. I looked through your comments

on the proposal and didn’t see that you specifically commented on the cost of

aftertreatment for 2SLB engines, although I see that you had some input on the

feasibility and availability of controls.

In terms of retrofitting 2SLB engines with oxidation catalyst, do you have any

information on the total costs of these controls that you could share with

EPA? We have heard that retrofitting 2SLB stationary engines may be more

expensive than retrofitting other engines, for design and other technical

issues.

Comments received on the proposal suggested that EPA's costs were

underestimated and some commenters indicated that for 2SLB engines costs would

be higher at $64,000 in capital costs and $20,000 in annual costs to add

oxidation catalyst. Do you feel that these estimates are reasonable and

representative of the actual costs to retrofit?

Any information you can send us to either support or refute these numbers
would be greatly appreciated.

I look forward to your response.

Thanks,

Tanya

Tanya Parise

EC/R Incorporated

501 Eastowne Drive, Suite 250

Chapel Hill, NC 27514

(919) 484-0417