From:	Suchecki, Joe [JSuchecki@ngelaw.com]
Sent:	Tuesday, January 12, 2010 9:36 AM
To:	Tanya Parise
Subject:	RE: Existing RICE NESHAP - Cost of Aftertreatment

Tanya,
 
Sorry it has taken a little while to get back to you.
 
After reviewing the background documents on the costs of aftertreatment, we would 
agree with the comment that the costs that were used are on the low side. In particular, 
the costs for addition of a DPF are very low - one would not expect the costs  of adding 
a DPF to be less than adding a DOC.  
 
Here are a couple of comments that I received from EMA members.
 
 
The costs for installation/construction appear to be low.  The background document 
assumes a construction/field cost of 5%. We believe it is more in the range of 10-15%.  
Also, the installation costs of a DOC or DPF on an existing engine should be higher 
than the cost of including those technologies on a new engine.  You have to retrofit 
and incorporate the control technology onto an engine that was not designed with that 
in mind, so costs are likely to be higher than to purchase an engine where the 
aftertreatment is designed into the engine configuration.
 
Regarding DPF costs, using the regression equation for retrofitting a 3000 hp 
engine comes to around $23,700.  One member provided information to indicate that a 
DPF installed on a 3000 hp engine would be around $90,000 - $100,000 (complete 
cost to the customer).
Again, one would not expect a DPF to cost less than a OC, so we would agree that the 
numbers are low and something is way off on those capital cost estimates.
 
Joe
 
  
 
Joe Suchecki 
Director, Public Affairs 
Engine Manufacturers Association 
Two North LaSalle Street, Suite 1700
Chicago, IL 60602
Tel:  312-827-8734 
Fax:  312-827-8737 
jsuchecki@emamail.org 
www.enginemanufacturers.org 
 
Confidentiality Notice:  This communication is confidential and may contain privileged information.  If you have 
received it in error, please notify the sender by reply e-mail and immediately delete it and any attachments without 
copying or further transmitting the same. 
 
 
All attachments are MS Office XP and are MIME encoded.  If you have any software compatibility issues, please 
contact EMA at (312) 827-8700 immediately. 
 

 

 
From: Tanya Parise [mailto:parise.tanya@ecrweb.com]  
Sent: Monday, January 04, 2010 1:30 PM 
To: Suchecki, Joe; WINKLEMAN_BRADY_L@cat.com 
Subject: Existing RICE NESHAP - Cost of Aftertreatment
Joe and Brady,

I’m hoping one or both of you can help us answer this question.  We got some comments on the 
proposed existing RICE NESHAP indicating that catalysts and associated equipment would be more 
expensive for larger diesel engines  than what EPA estimated for proposal.   Would you agree or 
disagree ?  Does EMA or Caterpillar have any information on the costs of applying DOC and DPF to 
larger stationary diesel engines, say 3,000 HP and above?  

Thanks again for your help on this rulemaking,
Tanya


Tanya Parise
EC/R Incorporated
501 Eastowne Drive, Suite 250
Chapel Hill, NC 27514
(919) 484-0417

