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

