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 EnginesTanya –

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 oursmall 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 numberswould 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