DAQ-2025-002133

REASONABLY AVAILABLE CONTROL
TECHNOLOGY ASSESSMENT FOR
OSHKOSH AEROTECH’S
OGDEN, UTAH FACILITY

OSHKOSH AEROTECH

TRINITY CONSULTANTS
4525 Wasatch Blvd.
Suite 200
Salt Lake City, Utah

September 2024

Project 244501.0089

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TABLE OF CONTENTS
1. INTRODUCTION 1-1
1.1 Description of Facility ................................................................................................. 1-1
1.2 Emission Profile .......................................................................................................... 1-1
2. RACT METHODOLOGY 2-1
2.1 Top-Down RACT Analysis Steps .................................................................................. 2-1
3. RACT ANALYSIS FOR PAINT/SPRAY BOOTHS 3-1
3.1 RACT Analysis for Paint Booth VOC Emissions ............................................................ 3-1
3.1.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 3-1
3.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 3-2
3.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 3-4
3.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 3-4
3.1.5 Step 5 – Select RACT ................................................................................................ 3-8
4. RACT ANALYSIS FOR SMALL GASOLINE ENGINES 4-1
4.1 RACT Analysis for Small Gasoline Engine NOx Emissions ............................................ 4-1
4.1.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 4-1
4.1.2 Step 2 - Eliminate Technically Infeasible Control Technologies ..................................... 4-1
4.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 4-2
4.1.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 4-2
4.1.5 Step 5 – Select RACT ................................................................................................ 4-2
4.2 RACT Analysis for Small Gasoline Engine VOC Emissions ........................................... 4-3
4.2.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 4-3
4.2.2 Step 2 - Eliminate Technically Infeasible Control Technologies ..................................... 4-3
4.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 4-4
4.2.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 4-4
4.2.5 Step 5 – Select RACT ................................................................................................ 4-5
5. RACT ANALYSIS FOR ENGINE TEST CELLS 5-1
5.1 RACT Analysis for Engine Test Cell NOx Emissions ...................................................... 5-1
5.1.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 5-1
5.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 5-1
5.1.3 Steps 3 – 5 Select RACT ............................................................................................ 5-3
5.2 RACT Analysis for Engine Test Cell VOC Emissions ..................................................... 5-3
5.2.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 5-3
5.2.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 5-3
5.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 5-4
5.2.4 Step 4 - Evaluate Most Effective Controls and Document Results .................................. 5-4
5.2.5 Step 5 – Select RACT ................................................................................................ 5-5
6. RACT ANALYSIS FOR STORAGE TANKS 6-1
6.1 RACT Analysis for Storage Tank VOC Emissions ......................................................... 6-1
6.1.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 6-1
6.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 6-2
6.1.3 Steps 3- 5 – Select RACT ........................................................................................... 6-4
7. RACT ANALYSIS FOR SOLVENT RECOVERY 7-1

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7.1.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 7-1
7.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 7-1
7.1.3 Steps 3 - 5 – Select RACT .......................................................................................... 7-2
8. RACT ANALYSIS FOR < 5 MMBTU/HR BOILERS AND HEATERS 8-1
8.1 RACT Analysis for <5 MMBtu/hr Boiler and Heater NOx Emissions ............................ 8-1
8.1.1 Step 1 – Identify All Reasonably Available Control Technologies ................................... 8-1
8.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 8-2
8.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 8-3
8.1.4 Step 4 - Evaluate Most Effective Controls and Document Results .................................. 8-3
8.1.5 Step 5 – Select RACT ................................................................................................ 8-4
8.2 RACT Analysis for <5 MMBtu/hr Boiler and Heater VOC Emissions ............................ 8-4
8.2.1 Step 1 - Step 1 – Identify All Reasonably Available Control Technologies ...................... 8-4
8.2.2 Steps 2 – 5 ............................................................................................................... 8-4
9. RACT ANALYSIS FOR GENERATORS 9-1
9.1 RACT Analysis for Generator NOx Emissions ............................................................... 9-1
9.1.1 Step 1 - Identify all Reasonably Available Control Technologies .................................... 9-1
9.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 9-1
9.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 9-2
9.1.4 Step 4 – Evaluate Remaining Control Technologies on Economic, Energy, and
Environmental Feasibility ...................................................................................................... 9-2
9.1.5 Step 5 – Select RACT ................................................................................................ 9-3
9.2 RACT Analysis for Generator VOC Emissions .............................................................. 9-4
9.2.1 Step 1 - Identify all Reasonably Available Control Technologies .................................... 9-4
9.2.2 Step 2 – Eliminate Technically Infeasible Control Technologies ..................................... 9-4
9.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ....................... 9-5
9.2.4 Step 4 – Evaluate Remaining Control Technologies on Economic, Energy, and
Environmental Feasibility ...................................................................................................... 9-5
9.2.5 Step 5 – Select RACT ................................................................................................ 9-5
10. ACTUAL AND POTENTIAL EMISSIONS 10-1
APPENDIX A. $/TON COST ANALYSES A-1

LIST OF TABLES
Table 1-1 Oshkosh Potential to Emit Emissions 1-2
Table 3-1 NWF Economic Feasibility Thresholds 3-5
Table 4-1 Cost Effectiveness of Installing Oxidation Catalyst on Small Gasoline Powered Engines for VOC
Control 4-4
Table 8-1 Oshkosh <5 MMBtu/Hr Heaters and Boilers 8-1
Table 9-1 Cost Effectiveness of Installing SCR on Diesel Generator Engines for NOx Control 9-3

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Table 9-2 Cost Effectiveness of Installing DOC on Emergency Diesel Engines for VOC Control 9-5
Table 10-1 Oshkosh Aerotech, Formerly JBT Aerotech – NOx and VOC 2017 Actual and PTE Emissions 10-1

FIGURES
Figure 3.1 Anguil Rotor Concentrator 3-6

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1. INTRODUCTION
The United States Environmental Protection Agency (US EPA) designated the Northern Wasatch Front (NWF),
which includes Salt Lake, Davis, Weber, and Tooele counties, as marginal nonattainment for the 2015 eight-
hour ozone (O3) National Ambient Air Quality Standard (NAAQS) on June 4, 2018. The NWF failed to achieve
the eight-hour O3 attainment date of August 3, 2021, and was reclassified to moderate status on November
7, 2022. The NWF is required to attain the O3 eight-hour standard by August 3, 2024; however, recent
monitoring data indicates that the standard will not be attained. As such, the NWF will be reclassified as
serious nonattainment in February 2025. The serious nonattainment classification will establish new thresholds
for major stationary sources. Specifically, as nitrogen oxides (NOx) and volatile organic compounds (VOCs)
are precursors to ozone, the reclassification from moderate to serious will establish major source potential to
emit (PTE) thresholds of 50 tons per year (TPY) of NOx or VOCs.

The Clean Air Act (CAA), Section 110 mandates states to develop State Implementation Plans (SIPs) to outline
strategies to achieve and maintain the NAAQS. Per 83 Federal Register (FR) 62998, the Ozone Implementation
Rule, SIPs must include Reasonably Available Control Technology (RACT) for all major stationary sources
located in nonattainment areas classified as moderate or higher.

The Utah Division of Air Quality (UDAQ) identified JBT Corporation, which was recently purchased by Oshkosh
Aerotech (Oshkosh), as a major stationary source located in the NWF O3 NAA since PTE VOC and NOx emissions
from the Ogden facility are 56.96 tons per year and 12.96 TPY, respectively, as indicated in JBT Corporations
air Approval Order DAQE-AN109250011-18. Thus, Oshkosh is required to submit a RACT analysis for all
emission units that emit NOx and or VOCs.
1.1 Description of Facility
Oshkosh, formerly JBT® Aerotech, supplies mobile ground support equipment, Jetway® passenger boarding
bridges, JetAire® preconditioned air units, and JetPower® 400Hz ground power in point-of-use, stand,
mobile, and military configurations. Additionally, Oshkosh supplies airport asset management, consulting, and
repair services. The Oshkosh facility is located north of the Ogden airport and west of Autoliv in Ogden, Utah.
The Universal Transverse Mercator (UTM) coordinates of this facility are 415.470 kilometers (km) east and
4563.119 km north.
1.2 Emission Profile
An emissions profile for the Ogden facility for VOC and NOx was developed based on Notices of Intent (NOIs)
submitted to the UDAQ in 2016 and 2018 which is summarized in Table 1-1. Actual emissions from 2017,
presented in Section 10, will be utilized in initial SIP planning.

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Table 1-1 Oshkosh Potential to Emit Emissions
Equipment Description PTE
(TPY)
NOx VOC
Military Test Cell Boiler 0.319 0.018
Military Test Cell Steam Generator 0.255 0.014
PC Air Commercial Test Cell 0.306 0.017
Bay D Drying Area 0.193 0.011
Small Parts Heating Unit 1.49 0.082
A2 Paint Heating Unit 1.36 0.075
Bay D Primer Heating Unit 1.70 0.094
Bay D Prep Area Heating Unit 1.06 0.058
Buff Prime Heater 0.41 0.023
Jetwalk Spray Booth 3
Bay D Paint Booth System 3
A2 System 3
Buff Prime System 3
Honda GX200 inverter engine (3 kW) 0.014 0.11
Engine Test Cell Production 2.671,2 --
Diesel storage tank 0.028
Emergency Generator (35 kW) 0.014 0.007
Generator Engine (176 kW) 0.110 0.050
Compressor Engine (4 kW) 0.021 0.031
Solvent Recovery -- 0.021
1 NOx + HC Emissions reported based on 6 hours of testing per unit
2 PTE based on number of projected units through 2020
3 AO DAQE-AN109250011-18 II.B.1.a – Paint booth emissions not to exceed 56.32 tons

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2. RACT METHODOLOGY
Under the Clean Air Act, all areas designated Moderate and Serious nonattainment for the 2015 8-hour ozone
standard are required to implement RACT for all existing major sources of VOCs or NOx as well as all VOC
sources subject to an EPA Control Technique Guideline (CTG). A RACT analysis requires implementation of
the lowest emission limitation that an emission source is capable of meeting by the application of a control
technology that is reasonably available, considering technological and economic feasibility. A RACT analysis
must include the latest information when evaluating control technologies. These technologies can range from
work practices to add-on controls. As part of the RACT analysis, current control technologies already in use
for VOCs or NOx sources were taken into consideration.
2.1 Top-Down RACT Analysis Steps
To conduct the RACT analysis, a top-down analysis was used to rank all control technologies. This approach,
as outlined by the UDAQ1, consists of the following steps:

1. Identify All Reasonably Available Control Technologies
2. Eliminate Technically Infeasible Control Technologies
3. Rank Remaining Control Technologies Based on Capture and Control Efficiencies
4. Evaluate Remaining Control Technologies on Economic, Energy, and Environmental Feasibility
5. Select RACT.

In Step 1 in a “top down” analysis, all available control options for the emission unit in question are identified.
Identifying all potential available control options consists of those air pollution control technologies or control
techniques with a practical potential for application to the emission unit and the regulated pollutant being
evaluated.

In Step 2, the technical feasibility of the control options identified in Step 1 are evaluated and the control
options that are determined to be technically infeasible are eliminated. Technically infeasible is defined where
a control option, based on physical, chemical, and engineering principles, would preclude the successful use
of the control option on the emissions unit under review due to technical difficulties. Technically infeasible
control options are then eliminated from further consideration in the RACT analysis.

The third step of the “top-down” analysis is to rank all the remaining control options not eliminated in Step 2,
based on capture and control effectiveness for the pollutant under review. If the RACT analysis proposes the
top control alternative, there would be no need to provide cost and other detailed information.

Once the control effectiveness is established in Step 3 for all feasible control technologies identified in Step 2,
additional evaluations of each technology, based on economic impacts, energy, and environmental feasibility
are considered in Step 4.

The economic evaluation of the remaining control technologies is analyzed. The capital cost of each control
technology, including the cost of device and materials, the one-time costs of delivery, engineering, labor,
installation, startup, annual operation and maintenance costs, and other indirect costs such as administration,
taxes, insurance are analyzed. The interest rates used are the current bank prime rate.

1 https://deq.utah.gov/air-quality/reasonably-available-control-technology-ract-process-moderate-area-ozone-sip

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The energy impact of each evaluated control technology which is the energy benefit or penalty resulting from
the operation of the control technology at the source will also be analyzed. The costs of the energy impacts,
such as additional fuel costs or the cost of lost power generation, impacts the cost-effectiveness of the control
technology.

The third evaluation to be reviewed for each control technology remaining in Step 4 is the environmental
evaluation. Non-air quality environmental impacts are evaluated to determine the cost to mitigate the
environmental impacts caused by the operation of a control technology.

In Step 5, RACT is selected for the pollutant and emission unit under review. RACT is the highest ranked
control technology not eliminated in Step 4.

In the preparation of the following RACT analyses, several sources of information were examined including
EPA’s RBLC RACT/BACT/LAER Clearinghouse, US EPA Technology fact sheets, South Coast Air Quality
Management District (SCAQMD) Lowest Achievable Emission Rate/Best Available Control Technology
(LAER/BACT) determinations, San Joaquin Valley Air Pollution Control District (SJVAPCD) BACT Clearinghouse,
state agency databases, vendor data, and Utah administrative code, R307-305.

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3. RACT ANALYSIS FOR PAINT/SPRAY BOOTHS
Oshkosh operates the following paint/spray booths at the Ogden, Utah facility:

► Jetwalk Spray Booth. The Jetwalk spray booth is heated and enclosed equipped with filters with dimensions
of 72’3’ length, 12’3” width, and 12’ height. Only water-based coatings are used in this booth.
► Bay D System. The Bay D system is comprised of a Primer booth, Finish paint booth, and Small Parts paint
booth. The Bay D primer booth has a design capacity of 16,000 cubic feet per minute (CFM), the Bay D
finish booth has a design capacity of 20,000 cfm, and the small parts paint booth has a design capacity of
38,000 CFM. All booths in the Bay D system are heated and enclosed. The dimensions of Bay D Primer
Booth are 65’0” length, 19’11” width, and 17’10’ height; the Bay D Finish booth has dimensions of 73’10”
length, 19’7’ width, and 19’3” height. The small parts paint booth has dimensions of 26’1” length, 17’11”
width, and 19’11” height.
► A2 System Paint Booth. The A2 System Paint Booth is heated and enclosed with a design capacity of
27,000 cfm. The dimensions of the A2 Paint Booth are 69’6” length, 18’10’ width, and 18’4” height.
► Buff Prime System. The Buff Prime System is heated and enclosed equipped with filters and has dimensions
of 72’6” length, 14’7’ width, and 12’0’ height. The design capacities of Buff Prime 1 and 2 are 27,000 cfm
and 30,000 cfm, respectively. Only water-based coatings are used in this booth.
3.1 RACT Analysis for Paint Booth VOC Emissions
A review of previous RACT analyses, the California Air Resources Board (CARB), San Joaquin Valley Air
Pollution Control District (SJVAPCD), Bay Area Air Quality Management District (BAAQMD), south Coast Air
Quality Management District (SCAQMD), EPA’s RACT/BACT/LAER (RBLC) Clearinghouse, and other state
databases was performed to identify possible VOC control technologies that are available on the market and
have been proven in practice.
3.1.1 Step 1 – Identify All Reasonably Available Control Technologies
Several add-on control technologies were identified to reduce VOC emissions from painting activities. These
add on control technologies include:

► Oxidizers
 Thermal Oxidizer (TO)
 Regenerative Thermal Oxidizer (RTO)
► Carbon Adsorption
► Reduced VOC content of product coatings,
► Application Methods, and
► Work Practice Standards.

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3.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.

Thermal Oxidizer

Thermal oxidizer (TO), or thermal incinerator uses a burner to destroy VOC emissions prior to release to the
atmosphere through a stack. This technology includes preheating the incoming air stream to obtain additional
fuel efficiencies. Time, temperature, turbulence (for mixing) and the amount of oxygen affect the rate and
efficiency of the combustion process. Thermal oxidizers can handle minor fluctuations in flow; however, excess
fluctuations require the use of a flare. Thermal oxidizers require a chamber temperature between 1200°F to
2000°F to enable the oxidation reaction and require sufficient flow velocities to promote mixing between the
combustion products and the burner.

In general, TOs are not well-suited to exhaust streams with highly variable flowrates, because the reduced
residence time and poor mixing resulting from high flowrates decrease the completeness of combustion, which
causes the combustion chamber temperature to fall and the destruction efficiency to drop.

Control efficiencies for TO range from 98 to 99.99%2. This technology is considered technically feasible.

Regenerative Thermal Oxidizer

Regenerative thermal oxidizers (RTO) can be used to reduce emissions from a variety of stationary sources.
RTOs use beds of ceramic pieces to recover and store heat. Solvent-laden air from a surface coating operation
passes through a heated ceramic bed before being combusted. The exhaust gases from the combustion
chamber are used to heat another ceramic bed. Periodically, the flow is reversed so the bed that was being
heated is now used to preheat the solvent-laden gas stream. Usually, there are three or more beds that are
continually cycled. Generally, flows greater than 2.4 standard cubic meters per second (sm3/sec) or 5,000
standard cubic feet per minute (scfm), and low VOC concentrations (less than 1000 parts per million by volume
(ppmv) but have been used effectively at inlet loadings as low as 100 ppmv or less) are best suited for RTOs.

An RTO uses natural gas to heat the entering waste gas, typically from 760°C to 820°C (1400°F to 1500°F),
however, it is capable of operating up to 1100°C (2000°F) for those cases where maximum destruction is
necessary. Particulate matter (PM) and condensable matter which can clog the RTO packed bed are removed
by an internal filter or some pretreatment technology prior to entering the reactor chamber.

RTOs are the most common type of thermal oxidizer technology. RTOs can achieve a VOC destruction
efficiency of 99 percent.3 RTO is considered a technically feasible control for painting/coating activities.

2 EPA Air Pollution Control Technology Fact Sheet, Thernal Incinerator, EPA-452/F-03-022
3 EPA (2017). Air Pollution Control Cost Manual, Section 3.2, Chapter 2 – Incinerators and Oxidizers.

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Carbon Adsorption

Carbon adsorption uses a filter bank of canisters that contain activated carbon which adsorbs the VOC
emissions as the emissions pass through before being released to the atmosphere. Carbon adsorption units
work best with lower-temperature operations. It is important to remove any entrained liquids and PM that
may be in the inlet gas prior to passing through a carbon adsorber to avoid plugging up the carbon bed and
reducing its adsorption efficiency. Periodic replacement of the activated carbon is required as buildup of
compounds on the filter media will occur.

Carbon adsorption units can be either onsite regenerable or non-regenerable. Regenerable systems have more
than one bed. While solvents are being adsorbed in one bed, those adsorbed onto another bed are desorbed
using steam or hot air. Desorbed solvents are condensed. Then, the solvents are decanted from the condensed
steam. Occasionally, distillation units are used to reclaim the solvents. The ability to reuse reclaimed solvents
is a major attraction of adsorption systems. For some industry sectors, they are very cost effective. In non-
regenerable systems, the carbon is discarded after its adsorption capacity is reached.

The efficiency of a carbon adsorption system depends upon the carbon adsorption efficiency for individual
solvents. Other factors important for the design of a carbon adsorption system include cycle time, the velocity,
the inlet concentration of the solvent-laden air and the temperature. For VOC concentrations between 500
and 2,000 ppmv, the control efficiency of carbon adsorption can be 95-99 percent4. This technology is
considered technically feasible.

Reduced VOC Content

Many air quality agencies have established VOC concentration or material vapor pressure limitations which
reduce the potential for VOC emissions from a facility. Often, these limits are established via process-specific
rules and limits given within the rule and are further specified to the exact type of application.5 Oshkosh is
subject to Utah Administrative Rule 307-350 Miscellaneous Parts and Product Coatings which contains a table
which establishes VOC content and vapor pressure limits for a variety of chemical use cases. The use of
chemicals with a reduced VOC content is technically feasible.

Application Methods

High-efficiency application methods ensure that VOC-containing substances are applied in ways that minimize
volatilization and usage. Oshkosh is subject to Utah Administrative Rule 307-350 Miscellaneous Parts and
Product Coatings which required the use of one of the following application methods:

1. Electrostatic application,
2. Flow coat,
3. Dip/electrodeposition coat,
4. Roll coat,
5. Hand Application Methods,
6. High-volume, low-pressure (HVLP) spray, and
7. Another application method capable of achieving 65% or greater transfer efficiency equivalent or
better to HVLP spray, as certified by the manufacturer.

4 EPA (2018) Carbon Adsorbers, Chapter 1.
5 Utah Administraive Code R307-304, R307-335, R307-342, and R307-344 through 355 limit the contenct of OVC and/or vapor
pressure of compounds.

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The use of these application methods is technically feasible.

Work Practice Standards

Work practice standards include operating procedures and company policies that, when implemented, have
the potential to limit VOC emissions. As mentioned previously, Oshkosh is subject to Utah Administrative Rule
R307-350, Miscellaneous Parts and Product Coatings which required the use of the following work practices:

a. Storing all VOC-containing coatings, thinners, and coating-related waste materials in closed
containers, containers with activated carbon or other EPA approved control method;
b. Ensuring that mixing and storage containers used for VOC-containing coatings, thinners, and coating-
related waste material are kept closed at all times except when depositing or removing these
materials, unless a container has activated carbon or other EPA approved control method;
c. Minimizing spills of VOC-containing coatings, thinners, and coating-related waste materials;
d. Conveying VOC-containing coatings, thinners, and coating-related waste materials from one location
to another in closed containers, containers with activated carbon or other EPA approved control
method; and,
e. Minimizing VOC emission from cleaning of application, storage, mixing, and conveying equipment by
ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent
solvent is captured in closed containers.

The use of work practice standards is technically feasible.
3.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Any control technologies not eliminated in Step 2 are ranked by overall control effectiveness. Ranking based
on control effectiveness is not required when all technologies have the same control efficiency or there is only
one option. The technically feasible control technologies presented above ranked based on control efficiencies
documented as being achieved in practice are as follows:

1. Thermal Oxidation (RTO) – 90 – 99% control (capture and control)
2. Carbon Adsorption – 95% (capture and control)
3. HVLP or equivalent, low VOC coatings, and work practice standards – variable control efficiencies.
3.1.4 Step 4 – Evaluate Most Effective Controls and Document Results
The most effective option is then evaluated based on energy, environmental, and economic impacts. If a
technically feasible control option is eliminated, the next most effective option is evaluated. This process will
continue until the control technology cannot be eliminated by environmental, energy, or economic impacts.6
UDAQ has published cost thresholds for different levels of emissions reductions for the purposes of RACT
analyses, which are provided in Table 3-1. 7The high end of these threshold ranges was utilized in the RACT
analysis to determine economic feasibility (i.e., a reduction of 2.50 tpy would have a cost effectiveness
threshold of $10,000/ ton removed). This table is presented in 2023 dollars and is intended to assist in RACT
determinations; however, additional discretion is applicable to all final RACT determinations.

6 New Source Review Workshop Manual (Draft): Prevention of Significan Deterioration and Nonattainment Area Permitting,
1990.
7 DAQ-061-23 Memorandum, Propose for Final Adoption: Amendment to Section R307-110-12; Incorporation of Utah State
Implementation Plan, Section IX.D.11:2015 Ozone NAAQS Northern Wasatch Front Nonattainment Area, UDAQ (September
12, 2023).

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Table 3-1 NWF Economic Feasibility Thresholds

Because of the low concentrations of emissions coming from paint booths, a RTO is the preferred technology
to capture and destroy painting process emissions. It is generally considered to be the most energy-efficient
oxidizer technology because of its ability to capture heat from the exhaust air and preheat incoming, untreated
airflow. The oxidation process is an exothermic reaction in which heat and energy are released. If there is
enough fuel value in the emissions, a RTO can be operated in a thermal self-sustaining way which means no
additional fuel input is needed to generate the required treatment temperatures.

Oshkosh obtained vendor data from Anguil Environmental Systems to install RTO’s at the facility to capture
and reduce VOC emissions from the paint booths. For this analysis, the vendor provided a quote for two (2)
Model 180 dual zeolite rotor concentrator systems in parallel, coupled to a Model 400 Regenerative Thermal
Oxidizer with 95% nominal thermal energy recovery to minimize gas usage. Anguil guaranteed the rotor
concentrator adsorption and the RTO to maintain a total system destruction efficiency of 98% or an outlet
concentration of 20 ppm as C1 (methane). The specifics for the proposed rotor concentration and RTO as
provided by Anguil, are presented here.

Concentrator

During the system operation, the VOC laden air will be exhausted from the process and drawn into the rotor
where VOCs are removed from the air by adsorption. The cleaned air passes through the rotor and is
discharged to atmosphere. The rotor turns to continuously transport adsorbed VOC into a desorption sector
and returning regenerated zeolite to the process. After desorption, the rotor is cooled with process air. This
small portion of VOC laden air, the cooling air, is captured in a separate outlet plenum. It is heated and
returned to the rotor’s regeneration sector to desorb the organics. The concentrated air stream is sent to the
RTO where the VOC’s are oxidized. The energy content of the VOC contributes to the oxidation process, thus
reducing the supplemental energy requirements. Figure 3.1 shows a depiction of the Anguil Rotor
Concentrator.

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Figure 3.1 Anguil Rotor Concentrator

The rotor concentrator system is an integrated air pollution control device which uses proprietary adsorbents
in a honeycomb structure to remove VOCs from dilute high volume air streams and concentrate the VOC into
a smaller concentrate stream for destruction by the RTO.

The purpose of concentrating the VOC is to reduce the capital and operating cost of treating the original high-
volume stream by removing the VOC in an adsorption rotor with very low pressure drop and continuous
operation, and deliver the VOC in a concentrated form so that the cost of further treatment - a RTO - is greatly
reduced. The VOC in the concentrate contributes a significant amount of energy required for oxidation.

The zeolite rotor concentrator is made from a mineral fiber honeycomb structure with a hydrophobic zeolite
adsorbents impregnated into the honeycomb structure. The detailed construction methods and actual
chemical constituents in the wheel are proprietary. The adsorbents are selected with a pore size for the best
performance for current and potential future use of the system. Zeolite adsorbents are characterized by well-
defined pore size distribution with a very high adsorption capacity at low inlet concentrations and a high
working capacity in relation to total adsorption capacity. They are inorganic chemicals, which are temperature
resistant, inert, non-flammable and resistant to most acids. The zeolites used for VOC adsorption are
hydrophobic and do not adsorb water from humid air to any significant degree and in this form are non-
catalytic.

The zeolites are incorporated into a honeycomb structure, which allows the VOC laden process air to pass
through the honeycomb channels at relatively high velocities with low overall pressure drop. As the process
air passes through the channels in the honeycomb structure, the VOC diffuses into the zeolite pores and is
adsorbed. The shape of the honeycomb is a flat disc rotor with the airflow and the channels parallel to the
rotor axis.

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The rotor is mounted in a housing with sealed compartments allowing segments of the rotor to pass through
adsorption, desorption, and cooling sectors as it slowly turns in the air stream. In this way each part of the
rotor continuously pass from adsorption to desorption and cooling before returning to adsorption again after
one complete revolution. The binders used to “glue” the structure together and to bind the adsorbent to the
honeycomb are entirely inorganic, with no flammable organic glues present. The binders are silicate type
materials, which do not interfere with the adsorption process.

Regenerative Thermal Oxidizer

The Anguil RTO destroys Hazardous Air Pollutants (HAPs), VOCs, and odorous emissions that are discharged
from industrial processes. Emission destruction is achieved through the process of high temperature thermal
or catalytic oxidation, converting the pollutants to carbon dioxide and water vapor while reusing the thermal
energy generated to reduce operating costs.

VOC and HAP laden process gas enters the oxidizer through an inlet manifold to flow control poppet valves
that direct this gas into energy recovery chambers where it is preheated. The process gas and contaminants
are progressively heated in the ceramic media beds as they move toward the combustion chamber.

Once oxidized in the combustion chamber, the hot purified air releases thermal energy as it passes through
the media bed in the outlet flow direction. The outlet bed is heated, and the gas is cooled so that the outlet
gas temperature is only slightly higher than the process inlet temperature. Poppet valves alternate the airflow
direction into the media beds to maximize energy recovery within the oxidizer. The high energy recovery
within these oxidizers reduces the auxiliary fuel requirement and saves operating cost. The Anguil oxidizer
achieves high destruction efficiency and self-sustaining operation with no auxiliary fuel usage at
concentrations as low as 3-4% LEL (Lower Explosive Limit). Anguil’s poppet valves are uniquely designed to
divert high volume process air into and out of the oxidizer, properly balance VOC loading, maintain destruction
efficiency, and optimize heat recovery. We custom-design, manufacture, and install these vital components
to ensure reliability and trouble-free operation.

Supplemental Fuel Injection System

The Anguil Supplemental Fuel Injection (SFI) system is designed as a high efficiency alternate means of
controlling the RTO reaction chamber temperature. During system operation, when appropriate safeties have
been satisfied, the burner and combustion air systems can be turned off and the RTO combustion chamber
temperature can be maintained by injecting natural gas directly into the VOC laden process stream – typically
at or near the inlet of the RTO system. Natural gas injection is an excellent means of reducing system operating
cost and providing a cleaner “burn” when properly designed and applied.

Energy Recovery Chambers

The RTO’s energy recovery chambers are rectangular cross-sections constructed of carbon steel. They are
reinforced to withstand the pressure requirement of the process air fan and all other applied loads. A carbon
steel support structure is also provided to support the oxidizer chambers, media support grid and the ceramic
heat recovery media itself. To allow for routine inspection of the heat recovery media, cold face and media
support grids and two hinged access doors complete with gaskets are included.

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Combustion Chamber

The combustion chamber is a rectangular cross-section constructed of carbon steel and reinforced to
withstand the pressure requirements of the process air fan and all other applied loads. The inverted “U” shape
design provides the retention time to obtain the specified VOC destruction efficiency. To allow for routine
inspection of the heat recovery media, insulation, and burner, access door(s) complete with gaskets and
trolley for door support are included.

The total direct cost to purchase the equipment and for installation was $4.37 million. Total indirect costs
added an additional $1.66 million dollars. Annual operating costs were estimated to be $2.54 million. This
results in $47,111/ton of VOCs removed. Based on this cost, it is economically infeasible for a RTO to be
installed and operated at the Ogden facility.

The installation of a carbon adsorption system was also reviewed. While activated carbon is widely used to
control VOC emissions and pilot scale project have been implemented with some success on small automotive
size paint booths, the review of other agency permits and the RBLC database didn’t reveal it being used on
paint booths the size being used at Oshkosh’s Ogden facility. In addition, in discussions with Oshkosh’s paint
manufacturer distributor, the paint distributor indicated that carbon absorption systems are not an option for
the paint booths at Oshkosh. Thus, for a control option to be feasible, it must have a practical potential for
application, and this has not been demonstrated in industry for facilities with booths as large and comparable
usage rates as Oshkosh. This option has been determined to be technically infeasible.

HVLP coating guns, low VOC coatings, and best management practices are considered the base case. High-
efficiency application methods include the use of high volume, low pressure (HVLP) spray guns, electrostatic
application, airless spray guns, air-assisted airless spray guns, or equivalent technologies. Water-based low
VOC coatings may be a viable option for high VOC solvent-based coatings. The use of HVLP coating guns is
also considered a Best Management Practice to prevent or reduce the discharge of pollutants to the air, soil
or water. Other Best Management Practices include the use of paint booths to capture overspray.
3.1.5 Step 5 – Select RACT
Oshkosh uses air assist and HVLP paint guns (Wagner GM 4700AC-H and Accuspray 26832) in enclosed
booths, VOC coatings which meet the requirements of R307-350 and keeping of VOC-containing materials in
closed containers, all of which are technically and economically feasible controls. Oshkosh proposes that the
paint booths at the Ogden facility meet RACT.

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4. RACT ANALYSIS FOR SMALL GASOLINE ENGINES
Oshkosh operates a 4-kW gasoline air compressor and a 3-kW gasoline inverter generator in support of
manufacturing operations at the Ogden facility. Gasoline engines are also known as spark‐ignition (SI)
engines. The proposed engines are air‐cooled four stroke engines. A four‐stroke cycle engine is an internal
combustion engine that utilizes four distinct piston strokes (intake, compression, power, and exhaust) to
complete one operating cycle. The piston makes two complete passes in the cylinder to complete one
operating cycle. An operating cycle requires two revolutions (720°) of the crankshaft. The four‐stroke cycle
engine is the most common type of small engine.
4.1 RACT Analysis for Small Gasoline Engine NOx Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible NOx control technologies that are available on the market
for small gasoline engines and have been proven in practice.

In gasoline engines, essentially all NOx formed is thermal NOx. Thermal NOx arises from the thermal
dissociation and subsequent reaction of nitrogen (N2) and oxygen (O2) molecules in the combustion air. Most
thermal NOx is formed in the high‐temperature region of the flame from dissociated molecular nitrogen in the
combustion air.
4.1.1 Step 1 – Identify All Reasonably Available Control Technologies
Four (4) control technologies were identified to reduce NOx emissions from SI engines which include:

► Selective Catalytic Reduction (SCR),
► Selective Non-Catalytic Reduction (SNCR),
► Lean burn technology, and
► Good combustion practices.
4.1.2 Step 2 - Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.

Selective Catalytic Reduction

Selective catalytic reduction (SCR) is a post‐combustion NOx control technology in which an aqueous urea
solution is injected in the exhaust air stream which evaporates into ammonia. The ammonia and NOx react on
the surface of the catalyst forming water and nitrogen. SCR reactions occur in the temperature range of 650°F
to 750°F. Precious metal catalysts are used to reduce NOx.

The operation of the gasoline engines at Oshkosh is limited to 1,200 and 500 operating hours per rolling 12-
month period8. Since it is unlikely that these units will achieve normal operating temperature for any period
of time, add-on control using SCR, which requires a consistent operating temperature to be effective, is
determined to be technically infeasible.

8 DAQE-AN109250010-18

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Selective Non‐Catalytic Reduction

Selective non‐catalytic reduction is a catalytic reactor that simultaneously reduces CO, NOx, and hydrocarbon
emissions. The catalytic reactor is placed in the exhaust stream of the engine and requires fuel‐rich air‐to‐fuel
ratios and low oxygen levels. Unlike for engines with a rich air/fuel ratio, NSCR cannot be used on engines
with a lean air/fuel ratio due to the composition of the exhaust stream. NSCR has been determined to be
technically infeasible.

Lean Burn Technology

NOx reduction in spark ignited engines can be reduced through leaning the air/fuel ratio of the engine and
use of good combustion practices. Although, as the air/fuel ratio gets leaner and the NOx emissions decrease,
VOC emissions will increase, and engine power decreases. Therefore, emission reduction when operating a
lean burn engine is a balance between these two pollutant levels and the engine power.

This control technology has been determined to be technically feasible.

Good Combustion Practices

Good combustion practices refer to both the engine design and the manufacturer’s recommended operating
practices. Procedures for startup and shutdown of the small gasoline engines at Oshkosh have been developed
and maintenance is performed at regular intervals according to manufacturer recommendations.

This control technology has been determined to be technically feasible.
4.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
The remaining control technologies, lean burn technology and good combustion practices are both effective
methods of reducing NOx emissions.
4.1.4 Step 4 – Evaluate Most Effective Controls and Document Results
In lean burn engines, the combustion process is enhanced by pre-mixing the air and fuel upstream of the
turbocharger before introduction into the cylinder. This creates a more homogeneous mixture in the
combustion chamber. The microprocessor-based engine will regulate the fuel flow and air/gas mixture and
ignition timing to achieve efficient combustion.

Combustion controls are integral in the combustion process as they are designed to achieve an optimum
balance between thermal efficiency-related emissions (VOC) and temperature related emissions (NOx).
Combustion controls will not create any energy impacts or significant environmental impacts. There are no
economic impacts from combustion controls because they are part of the design for modern engines.
4.1.5 Step 5 – Select RACT
RACT for NOx emissions from the 3 kW and 4 kW gasoline-fired engines is the application of lean burn engines
and good combustion practices. The equipment employs enhanced combustion air flow and improved ignition
systems. The engines meet EPA’s small SI non-handheld engine exhaust standards for Class I and Class II
engines which list NOx emission rates to be of 1.8 grams/HP-hr and 3.5 grams/HP-hr for the 3 kW and 4 kW
engines. Oshkosh proposes that the small gasoline engines at the Ogden facility meet RACT.

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4.2 RACT Analysis for Small Gasoline Engine VOC Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible VOC control technologies that are available on the market
for small gasoline engines and have been proven in practice.

VOCs, commonly classified as hydrocarbons, are composed of a wide variety of organic compounds which are
discharged into the atmosphere when some of the fuel remains unburned or is only partially burned during
the combustion process. Partially burned hydrocarbons can occur because of poor air and fuel homogeneity
due to incomplete mixing, before or during combustion; incorrect air/fuel ratios in the cylinder during
combustion due to maladjustment of the engine fuel system; and low cylinder temperature due to excessive
cooling (quenching) through the walls or early cooling of the gases by expansion of the combustion volume
caused by piston motion before combustion is completed.
4.2.1 Step 1 – Identify All Reasonably Available Control Technologies
Three potential control technologies were identified to reduce VOC emissions from small gasoline engines.
They are:

► combustion control techniques,
► oxidation catalysts, and
► use of alternative fuels.
4.2.2 Step 2 - Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.

Combustion Control Techniques

Combustion control techniques such as the optimization of the design, operation, and maintenance of an
engine are ways to reduce VOC emissions by maximizing the thermal oxidation of carbon which minimizes the
formation of VOC.

This control technology has been determined to be technically feasible.

Oxidation Catalysts

An oxidation catalyst is a flow through exhaust device that contains a honeycomb structure covered with a
layer of chemical catalyst. This layer contains small amounts of precious metal-usually platinum or palladium-
that interact with and oxidize pollutants in the exhaust stream (CO and unburned HCs), thereby reducing
emissions.

This control technology has been determined to be technically feasible.

Use of Alternative Fuels

Use of an alternative fuel is a method of reducing emissions from a small gasoline powered engine. For
Oshkosh, replacing the engine with a different type of engine that could use a cleaner fuel such as natural
gas is not practical; thus, the use of alternative fuels was determined to be technically infeasible.

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4.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
The remaining control technologies of good combustion control and oxidation catalysts are both effective
methods of reducing VOC emissions. The control effectiveness of each control is as follows:

► Oxidation catalyst – 70%
► Good combustion control – baseline
4.2.4 Step 4 – Evaluate Most Effective Controls and Document Results
Exhaust manifold air injection, thermal reactors, and catalytic converters control VOC emissions in the exhaust
of a gasoline powered engine. The gas temperature, oxygen concentration, and catalysts parameters are
import operating variables. Two kinds of thermal reactors have been developed for gasoline spark ignition
engines: the Rich Thermal Reactor (RTR) for fuel rich air/fuel ratios and the Lean Thermal Reactor (LTR) for
lean ratios. The thermal reactor is a container which, by its size and configuration, increased the residence
time and turbulence of the exhaust gases, thereby providing a changer for the high-temperature oxidation
reaction. High temperatures are maintained by the exothermic oxidation of HC in the exhaust gas. The RTR
operates at temperature from 1600 to 1800˚F and is designed for fuel rich operation. Secondary air injection
is normally injected into the thermal reactor for complete oxidation. The LFR operates at higher air/fuel ratios
and lower operating temperatures (1,400 to 1600˚F). Secondary air injection is not usually required.9

The air/fuel ratio of the combustible mixture is the most important variable for SI engines. When the air/fuel
radio is adjusted to low engine out VOC (HC) emissions, the NOx emissions produced by the engine can
increase.

Oxidation catalysts are used extensively to control CO and HC from gasoline engines. For oxidation catalysts
to be an effective means of controlling HC emissions, the engine must be properly tuned and unleaded fuel
must be used. Also, the control system should ideally be adjusted to preclude the formation of sulfate
emissions which can be formed in the catalyst due to excess oxygen in the exhaust gases and sulfur content
of the fuel.
Energy, Environmental, and Economic Impacts
The highest-ranking control option, oxidization catalysts, can reduce VOC emissions by up to 70%. A cost
evaluation for this top-ranking option, in costs per ton of VOC removed for the 3 kW and 4 kW engines was
determined. Oxidation catalyst costs obtained from Wheeler Machinery represent current costs. Table 4-1
presents the costs per ton of VOC removed for the small gasoline-powered engines.
Table 4-1 Cost Effectiveness of Installing Oxidation Catalyst on Small Gasoline Powered
Engines for VOC Control
Equipment Cost
Effectiveness
($/Ton)
3 kW Gasoline Inverter Engine $ 790,207
4 kW Gasoline Compressor $2,784319

9 Control Techniques for Carbon Monoxide Emissions, US Environmental Protection Agency, EPA-450/3-79-006.

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As seen from Table 4-1, it is economically infeasible to install oxidization catalysts on the small gasoline
powered engines and this control technology has been eliminated as RACT.
4.2.5 Step 5 – Select RACT
The remaining control technology, good combustion practices has been determined to be RACT for the
gasoline engines operated at Oshkosh. Maintenance will be performed on the engines in accordance with
manufacturer specifications. The 3 kW and 4 kW engines are limited to 1,200 and 500 hours of operation per
rolling 12-month period, receptively, per AO condition II.B.2.a, 1 & 2. Oshkosh proposes that the small
gasoline engines at the Ogden facility meet RACT.

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5. RACT ANALYSIS FOR ENGINE TEST CELLS
Oshkosh tests diesel-, JP-5- or JP-8-fueled mobile ground support equipment manufactured at the Ogden
facility in engine test cells. Diesel engines are classified as compression ignition (CI) internal combustion
engines. In diesel engines, air is drawn into a cylinder as the piston creates space for it by moving away from
the intake valve. The piston’s subsequent upward swing then compresses the air, heating it at the same time.
Next, fuel is injected under high pressure as the piston approaches the top of its compression stroke, igniting
spontaneously as it contacts the heated air. The hot combustion gases expand, driving the piston downward.
During its return swing, the piston pushes spent gases from the cylinder, and the cycle begins again with an
intake of fresh air.
5.1 RACT Analysis for Engine Test Cell NOx Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible NOx control technologies that are available on the market
for engine test cells and have been proven in practice.

The predominant mechanism for NOx formation from internal combustion engines is thermal NOx which arises
from the thermal dissociation and subsequent reaction of nitrogen and oxygen molecules in the combustion
air.
5.1.1 Step 1 – Identify All Reasonably Available Control Technologies
Only post-control technologies were identified for controlling NOx emissions from engine test cells. These
control technologies include:

► Selective Catalytic Reduction (SCR) with Ammonia Injection,
► Selective Non-Catalytic Reduction (SNCR),
► Reburn NOx Control Technology,
► NOx Sorbent Technology,
► Water or Steam Injection, and
► Good Combustion Practices.
5.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.

SCR Systems

Selective catalytic reduction (SCR) systems use a catalyst (commonly precious metals, vanadium, or zeolites)
and injection of a reductant (liquid ammonia or urea) to convert the NOx in the diesel exhaust to water (H2O)
and nitrogen (N2). The catalyst lowers the reaction temperature that NOx needs to convert to H2O and N2.
The temperature range is specific to each SCR system but in general it is between 260 °C to 540 °C (500° -
700°F). Once the exhaust temperature reaches the minimum operating temperature, the catalyst activates,
and the system begins to inject the reductant into the exhaust stream. The exhaust will then enter the catalyst
where the conversion will take place.

SCR systems have two key operating variables that work together to achieve the NOx reductions. These are
the exhaust temperature and the injection of the reductant (urea or ammonia). With respect to the exhaust
temperature, the exhaust temperature must be between 260°C to 540°C for the catalyst to operate properly.

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For this reason, SCR systems will not begin injection of urea or ammonia until the catalyst has reached the
minimum operating temperature. The urea or ammonia injection is also a critical component in determining
the control efficiency of a SCR. It must be injected into the exhaust stream upstream of the SCR system. In
the catalyst, it reacts to reduce the NOx to form N2 and H2O. The reaction is able to take place because the
catalyst lowers the reaction temperature necessary for NOx.

SCR has been demonstrated as a NOx control option with stationary gas turbine applications for power plants
but has not been demonstrated on engine test cells since the temperature of the exhaust gas temperatures
are below those required by SCR systems. SCR systems require an operating temperature between 500 °F to
1000 °F. Reaching these temperatures may be difficult in testing operations where the engine may be
operated at low load for short periods of testing. If this temperature is not met while the engine is running,
there will not be any NOx emission reduction benefits. In addition, besides temperature, other stable flue gas
characteristics (velocity, oxygen, NOx concentrations) are needed for a SCR to operate successfully.

Engine performance testing requires engines to operate under different loads and in extreme conditions. As
a result, flue gas characteristics can vary widely making it impractical to successfully operate a SCR. Thus,
SCR has been determined to be technically infeasible at reducing Oshkosh’s engine test cell NOx emissions.10

SNCR

Selective non-catalytic reduction (SNCR) systems use injection of chemicals such as ammonia or urea to the
exhaust gases, for non-catalytic reactions that result in formation of nitrogen and water. The desired reaction
for NOx reduction occurs in the temperature range of 1,800°F to 2,000°F.

Test cell exhaust stack gas temperatures are significantly below the 1,800°F to 2,000°F range where SNCR is
viable. To raise the temperature of the exhaust gas, a burner would be needed. 11Due to the high temperature
requirements, a burner would potentially create more NOx which would offset the NOx reduction of the SNCR
system. Therefore, Oshkosh has determined SNCR to be technically infeasible for engine test cell application.

NOx Sorbent Technology

NOx sorbent technology involves the use of a vermiculite bed impregnated with magnesium chloride. The
exhaust gases pass through the bed and the NOx is adsorbed on the bed and forms magnesium nitrate.

This technology has not been demonstrated on a full-scale working test cell and has been determined to be
technically infeasible for reducing NOx emissions from Oshkosh engine test cells.

Water or Steam Injection

Water/steam injection is an established NOx control technology for stationary gas turbines. The water or steam
injected into the primary combustion zone of a gas turbine engine provides a heat sink, which lowers the
flame temperature which results in reducing thermal NOx formation.

Water/steam injection has only been demonstrated for stationary gas turbines. Thus, water/steam injection
has been eliminated as technically infeasible for the diesel-, JP-5- or JP-8-fueled mobile ground support
equipment tested in the Oshkosh engine test cells.

10 SMAQMD BACT Clearinghouse
11 Ibid

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Good Combustion Practices

In direct atmospheric exhaust using good combustion practices, the engine exhaust is emitted to the
atmosphere without use of any NOx reduction technology.

This control technology has been determined to be technically feasible.
5.1.3 Steps 3 – 5 Select RACT
Oshkosh is proposing as RACT for NOx for the engine test cells is good combustion practices. No control
efficiency was estimated for direct atmospheric exhaust using good combustion practices.
5.2 RACT Analysis for Engine Test Cell VOC Emissions
The predominant mechanism for VOC formation is primarily the result of incomplete combustion of diesel or
aviation fuels. These emissions occur when there is a lack of available oxygen, the combustion temperature
is too low, or if the residence time in the cylinder is too short.
5.2.1 Step 1 – Identify All Reasonably Available Control Technologies
Three control technologies were identified for reducing VOC emissions. These include:

► Thermal oxidation,
► Catalytic oxidation, and
► Good combustion practice.
5.2.2 Step 2 – Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.

Thermal Oxidizer

As mentioned previously, a TO requires a chamber temperature between 1200°F to 2000°F to enable the
oxidation reaction and requires sufficient flow velocities to promote mixing between the combustion products
and the burner.

In general, TOs are not well-suited to exhaust streams with highly variable flowrates, because the reduced
residence time and poor mixing resulting from high flowrates decrease the completeness of combustion, which
causes the combustion chamber temperature to fall and the destruction efficiency to drop.

Oshkosh has determined this add-on control technology to be technically feasible.

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Catalytic Oxidation

Catalytic incinerators are very similar to thermal oxidation, with the primary difference that the gas, after
passing through the flame area, passes through a catalyst bed. The catalyst has the effect of increasing the
oxidation reaction rate, enabling conversion at lower reaction temperatures than in thermal incinerator units.
Catalysts typically used for CO incineration include platinum and palladium. The gas stream is introduced into
a mixing chamber where it is also heated. The waste gas usually passes through a recuperative heat
exchanger, where it is preheated by post-combustion gas. The heated gas then passes through the catalyst
bed. Oxygen and CO migrate to the catalyst surface by gas diffusion and are adsorbed onto the catalyst active
sites on the surface of the catalyst where oxidation then occurs. The oxidation reaction products are then
desorbed from the active sites by the gas and transferred by diffusion back into the gas stream.

Although catalytic oxidizers have lower fuel requirements than thermal oxidizers, the catalyst destroys CO in
waste stream, and lower NOx emissions than thermal oxidizers, the initial costs of the unit are high, plus
particulate often has to be removed prior to flue gas treatment. Capital, maintenance, operating and
annualized costs are typically higher than a thermal oxidizer. Thus, the cost of installing a catalytic oxidizer
has been determined to be economically infeasible.

Good Combustion Practices

Good Combustion Practices (GCP) are a group of several best practices for engines, including proper fuel/air
metering, fuel quality certification, and sufficient residence time for complete combustion. Engines are
designed to achieve high combustion efficiency when maintained and operated according to the
manufacturer’s written instructions.

Oshkosh has determined that GCP to be technically feasible.
5.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Effective control technologies for VOC emission reductions from engine test cells are listed below:

► Thermal Oxidation – 90% or greater
► GCP – Base option
5.2.4 Step 4 - Evaluate Most Effective Controls and Document Results
The most effective option is then evaluated based on energy, environmental, and economic impacts. If a
technically feasible control option is eliminated, the next most effective option is evaluated. This process will
continue until the control technology cannot be eliminated by environmental, energy, or economic impacts.12
UDAQ has published cost thresholds for different levels of emissions reductions for the purposes of RACT
analyses, which are provided in Table 3-1.13

12 New Source Review Workshop Manual (Draft): Prevention of Significan Deterioration and Nonattainment Area Permitting,
1990.
13 DAQ-061-23 Memorandum, Propose for Final Adoption: Amendment to Section R307-110-12; Incorporation of Utah State
Implementation Plan, Section IX.D.11:2015 Ozone NAAQS Northern Wasatch Front Nonattainment Area, UDAQ (September
12, 2023).

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In 2018, a cost-effective determination was performed by SMAQMD for an add-on thermal oxidizer to control
VOC emissions from an engine test cell and the cost was calculated to be over $1.6 million per ton14 of VOC
reduced. For 2024, this cost would be over $2 million per ton based on the CPI inflation calculator. The PTE
emissions for VOC from the engine test cells (See Table 1-1) were estimated to using EPA Tier III emission
factors for NOx + HC (where HC was assumed to be VOC). Based on the SMAQMD cost estimate, and relatively
small quantities of NOx +HC emissions, a TO was determined to be economically infeasible.
5.2.5 Step 5 – Select RACT
Oshkosh is proposing as RACT for VOC for the engine test cells GCP. In addition, all manufacturer engines for
the ground-support equipment will be compliant with EPA Tier 3 and Tier 4 emissions standards and hours of
testing will be limited.

14 SMAQMD BACT Clearinghouse

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6. RACT ANALYSIS FOR STORAGE TANKS
Oshkosh Aerotech AO DAQE-AN109250011-18, II.A.14, lists four (4) storage tanks at the Ogden, facility with
include:

► one (1) 250-gallon diesel, JP-5, or JP-8,
► one (1) 2000-gallon diesel, JP-5, or JP-8,
► one (1) 250-gallon gasoline or diesel,
► and one (1) 2000-gallon ethylene glycol.
6.1 RACT Analysis for Storage Tank VOC Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible VOC control technologies that are available on the market
for fixed roof storage tanks and have been proven in practice.

There are two general types of atmospheric storage tanks: fixed roof tanks and floating roof tanks. There are
three types of floating roof tanks: external floating roof, internal floating roof, and covered or domed floating
roof. Emissions from storage tanks result from displacement of headspace vapor during filling operations
(working losses) in the case of fixed roof or internal floating roof tanks, and from diurnal temperature and
heating variations (breathing losses).

Generally, lower vapor pressure liquids such as heating oils, diesel, jet fuels or kerosene are stored in fixed
roof tanks; crude oils and lighter products such as gasoline are stored in floating roof tanks. Typically, filling
losses constitute 80-90% of the total losses for fixed roof tanks.

The tanks at the Ogden facility are fixed roof tanks. Emissions from fixed roof storage tanks are a result of
evaporative losses during storage (known as breathing losses or standing losses) and evaporative losses
during filling operations (known as working losses). 15
6.1.1 Step 1 – Identify All Reasonably Available Control Technologies
When tanks are filled with diesel, JP-5, JP-8, gasoline or ethylene glycol, VOCs are displaced into the
atmosphere (working losses). In addition, breathing losses form the tanks occur from diurnal temperature
change. To minimize the vapors released to the atmosphere, the following controls were identified:

► Submerged filling,
► Vapor balance,
► Vapor recovery unit with carbon adsorption,
► Vapor recovery system with refrigerated condenser,
► Thermal oxidation with an open or enclosed flame,
► NSPS Subpart Kb, Volatile Organic Liquid Storage Vessels (Including Petroleum Storage Vessels) from
which Construction, Reconstruction, or Modification Commenced after July 23, 1984, and
► Good operating and maintenance practices.

15 AP-42, Fifth Edition, Volume 1 Chapter 7: Liquid Storage Tanks, June 2020.

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6.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies

The control technologies identified in Step 1 are discussed in this section.

Submerged filling

Submerged loading has much lower evaporation loss than splash loading. The submerged loading method
introduces the fuel into the bottom of the tank below the liquid level. This reduces liquid turbulence and vapor-
liquid contact.

There are two types of submerged loading methods: the submerged fill pipe method and the bottom-mounted
fill pipe method. In the submerged fill pipe method, the fill pipe descends to below the level of the liquid, and
the opening is almost at the bottom of the storage tank. In the bottom-mounted fill pipe method, the fill pipe
enters the storage tank from the bottom. The control efficiency from submerged loading – bottom fill pipe
loading is 60%16. Due to the low PTE VOC emission rates from tanks at Oshkosh which are estimated to be
0.028 TPY, it has been assumed that the retrofit of the existing tanks for submerged filling will be economically
infeasible.

Vapor Balance

Vapor balancing is a method where the vapors being vented from a storage tank being filled are directed to
the storage tank from which the fuel is being pumped. This technique is common at gas stations where the
vapors vented from the storage tank are returned to the tank truck. Vapor balancing can recover up to 98%
of vapors that would otherwise be vented to the atmosphere.

According to the Mid-Atlantic Regional Air Management Association’s (MARAMA) Assessment of Control
Technology Options for Petroleum Refineries in the Mid-Atlantic Region Final Report January 200717, Table 7-
5, the investment cost was $96,000 per tank (2003$) for vapor balancing. The current cost would be
approximately $162,067 per tank. This cost doesn’t include annual direct or indirect costs.

Thus, due to the low PTE VOC emission rates from tanks at Oshkosh which are estimated to be 0.028 TPY, it
was determined that vapor balancing is technically and economically infeasible for Oshkosh’s fixed roof storage
tanks.

16 Control efficiency estimated based on the unconcontrolled emission factor for submerged loading (dedicated normal service)
and splan loading (dedicatd normal service) as reference from US EPA AP-42, Section 5.2, Transportation and Marketing of
Petroleum Liquids (July 2008).
17 https://s3.amazonaws.com/marama.org/wp-content/uploads/2019/10/26123258/Refinery-Control-Options-2007.pdf

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Vapor Recovery with Carbon Adsorption

Carbon adsorption units can also be used for vapor recovery. Carbon adsorption processes typically involve
the use of activated carbon, which is suitable for collecting VOCs from high-volume, low-concentration gases
by adsorbing or binding the vapors onto the active carbon. Activated carbon is a processed material received
from a vendor and is produced by heating coal, coconut shells, or wood in a pyrolysis process to drive off the
VOCs, making the material “thirsty” for VOCs. VOCs collected in an adsorption unit can be recovered by
recycling the activated carbon or other adsorption material in a process designed to capture the adsorption
liquid, and the carbon or other adsorption material is regenerated and can be used again. Vapor recovery with
carbon adsorption has control efficiencies ranging from 95-99%.

According to the MARAMA Final Report January 2007, Table 7-5, the investment cost, using the median
estimate for carbon adsorption would be approximately $570,000. This cost doesn’t include annual direct or
indirect costs.

Thus, due to the low VOC PTE emission rates from tanks at Oshkosh which are estimated to be 0.028 TPY, it
was determined that carbon adsorption is technically and economically infeasible for Oshkosh’s fixed roof
storage tanks.

Vapor Recovery with Refrigerated Condenser

Vapor recovery systems are used to collect vapor emissions from storage tanks and condense them to a
recoverable liquid product using several techniques. Carbon absorption systems can include refrigeration and
compression cycles where highly concentrated vapors from storage tanks are piped to an absorption tower,
where chilled liquid is sprayed into a column filled with an inert packing media. The chilled liquid causes vapors
entering the bottom of the column to condense and absorb onto the inert packing media. Droplets of the
liquid eventually collect on the packing material and rain out into the bottom of the absorption column. The
liquid recovered from the bottom of the absorption tower is then sent back to storage. Vapor recovery system
control efficiencies using condenser units range from 50 to 90%, depending on the design of the condenser
unit, the type of equipment used, and the VOC concentration of the emission streams.

According to the MARAMA Final Report January 2007, Table 7-5, the investment cost, using the median
estimate for vapor recovery systems would be approximately $1,250,500 (2003$). This cost doesn’t include
annual direct or indirect costs.

Thus, due to the low PTE VOC emission rates from tanks at Oshkosh which are estimated to be 0.028 TPY, it
was determined that refrigerated condenser is technically and economically infeasible for Oshkosh’s fixed roof
storage tanks.

Thermal Oxidation with an Open or Enclosed Flare

Thermal oxidation systems can be used to destroy the vapors. Thermal oxidation systems consist of either
flares or incinerators. Flares are typically used to thermally destroy gaseous emissions from processes like
refining, in which waste gas is generated and the emission of the gas without thermal destruction would be
harmful. Flares may take different configurations, but they usually have a natural-gas-fired pilot that provides
the combustion source. Waste gas is piped to the flare and ignited by the pilot, after which the flame is
sustained until the waste gas diminishes. Destruction efficiency for most flares is greater than 95%, with the
resulting emissions being the by-products of combustion and residual unburned hydrocarbons.

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Incinerators are another form of thermal oxidation used for destroying waste gases that otherwise would be
harmful. Incinerators come in many different configurations and sizes, but as with flares, their primary purpose
is to destroy waste gas emissions. The vapor is injected through a burner manifold into the combustion
chamber of an incinerator. Thermal destruction efficiencies for incinerators can be as high as 99%. Generally,
incinerators are a more complex and expensive means of thermal oxidation than flares, but they achieve
higher destruction efficiencies.

According to the MARAMA Final Report January 2007, Table 7-5, the investment cost, using the low-end
estimate for incineration would be approximately $2.4 million (2003$). This cost doesn’t include annual direct
or indirect costs.

Thus, due to the low PTE VOC emission rates from tanks at Oshkosh which are estimated to be 0.028 TPY, it
was determined that thermal oxidation is technically and economically infeasible for Oshkosh’s fixed roof
storage tanks.

NSPS Subpart Kb – Volatile Organic Liquid Storage Tanks

Subpart Kb is the most recent emissions standard for petroleum liquid storage tanks. Subpart Kb applies to
any volatile organic liquid storage tank that is not located at a bulk gasoline plant or service station and that
has a capacity of over 75 cubic meters (19,810 gallons) that was constructed after July 23, 1984. Subpart Kb
requires tanks that store these more volatile liquids to be equipped with a vapor control system capable of
reducing VOC emissions by 95 weight percent, or with an equivalent method of VOC emissions control. Diesel
and other low volatility petroleum fuels may be stored in fixed roof tanks.

Subpart Kb does not apply to the storage tanks at Oshkosh since the size of tanks at the Ogden site are less
than 19,810 gallons. This control technology has been determined to be technically infeasible.

Good Operating and Maintenance Practices

The emission calculations for the tanks show that emissions from breathing and standing losses are minimal
(0.28 TPY based on PTE). Oshkosh minimizes the frequency of tank filling and uses good operating and
maintenance for all tanks.
6.1.3 Steps 3- 5 – Select RACT
All control technologies have been eliminated except for good operating and maintenance practices. Oshkosh
has reviewed the emissions from the storage tanks and will utilize good operating and maintenance procedures
to meet RACT requirements.

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7. RACT ANALYSIS FOR SOLVENT RECOVERY
According to AO DAQE-AN109250011-18, II.A.12, Oshkosh is permitted to operate a solvent recovery unit.
Solvents are being recovered which will emit small quantities of fugitive VOC emissions from leaks filling the
equipment, heating the unit, the recycling process, and from drumming the distilled contents.

A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible VOC control technologies that are available on the market
for solvent recovery units and have been proven in practice.
7.1.1 Step 1 – Identify All Reasonably Available Control Technologies
Four control technologies were identified for reducing VOC emissions from solvent recovery operations. These
include:

► Adsorption,
► Thermal oxidation,
► Catalytic oxidation, and
► Good operating practices.
7.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.

Adsorption

Adsorption is defined as the concentration of a substance on the surface of a solid adsorbent. Adsorption is
applied to control emissions when a solvent-laden air stream passes through a bed of high-surface-area solids
material and is captured into the surface of the material. The characteristics of an adsorption system include
high initial capital cost, moderate operating cost, and high maintenance and maintenance costs.

Adsorption systems, such as carbon adsorption systems generally work best with solvents which are
immiscible with water and preferred to those which are water soluble. In the case of miscible solvents,
distillation must be applied to separate solvent components from the water. Acetone, the substance being
recycled by Oshkosh, is 100% miscible with water. Thus, without further distillation, carbon adsorption is not
practical. Thus, adsorption has been eliminated as technically infeasible.

Thermal Oxidation

Thermal oxidizers use a burner to destroy VOC emissions prior to release to the atmosphere through a stack.
This technology includes preheating the incoming air stream to obtain additional fuel efficiencies. Time,
temperature, turbulence (for mixing) and the amount of oxygen affect the rate and efficiency of the
combustion process. Thermal oxidizers can handle minor fluctuations in flow; however, excess fluctuations
require the use of a flare. Thermal oxidizers require a chamber temperature between 1,200°F to 2,000°F to
enable the oxidation reaction and require sufficient flow velocities to promote mixing between the combustion
products and the burner.

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In general, TOs are not well-suited to exhaust streams with highly variable flowrates, because the reduced
residence time and poor mixing resulting from high flowrates decrease the completeness of combustion, which
causes the combustion chamber temperature to fall and the destruction efficiency to drop.

Since the solvent recovery process is run as batch operations twice a week, and since the emissions are
fugitive in nature which would lead to highly variable flowrates, a TO has been determined to be technically
infeasible.

Catalytic Oxidation

As mentioned previously, catalytic oxidation is very similar to thermal oxidation, with the primary difference
that the gas, after passing through the flame area, passes through a catalyst bed. The catalyst has the effect
of increasing the oxidation reaction rate, enabling conversion at lower reaction temperatures than in thermal
incinerator units. Catalysts typically used for CO or VOC incineration include platinum and palladium. The gas
stream is introduced into a mixing chamber where it is also heated. The waste gas usually passes through a
recuperative heat exchanger, where it is preheated by post-combustion gas. The heated gas then passes
through the catalyst bed. Oxygen and CO or VOC migrate to the catalyst surface by gas diffusion and are
adsorbed onto the catalyst active sites on the surface of the catalyst where oxidation then occurs. The
oxidation reaction products are then desorbed from the active sites by the gas and transferred by diffusion
back into the gas stream.

Although catalytic oxidizers have lower fuel requirements than thermal oxidizers, the catalyst destroys CO and
VOC in waste stream, and lower NOx emissions than thermal oxidizers, the initial costs of the unit are high,
plus particulate often has to be removed prior to flue gas treatment. Capital, maintenance, operating and
annualized costs are typically higher than a thermal oxidizer. Since the solvent recovery process is run as
batch operations twice a week, and since the emissions are fugitive in nature, catalytic oxidation has been
determined to be technically infeasible.

Good Operating Practices

Good operating practices include limiting the operation of the solvent recovery system where practical to
eliminate excess emissions, including a cover that will remain closed except ties during recovery operations
or when removing solvent. Used solvent will be kept in closed containers. The paint guns are removed from
the line and are flushed with the clean-up solvent into an enclosed 55-gallon waste drum. This control
technology is technically feasible and is implemented at the Oshkosh facility.
7.1.3 Steps 3 - 5 – Select RACT
All control technologies have been eliminated except for good operating practices. Oshkosh will utilize good
operating practices such as minimizing solvent recovery operations, storing used solvent in closed containers,
and flushing paint guns with a clean-up solvent into an enclosed waste drum to meet RACT requirements.

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8. RACT ANALYSIS FOR < 5 MMBTU/HR BOILERS AND HEATERS
The boilers and heaters and their rated capacities that are operated at the Oshkosh Odgen, Utah facility are
presented in Table 8-1.
Table 8-1 Oshkosh <5 MMBtu/Hr Heaters and Boilers
Description Design
Capacity
(MMBtu/hr)
PC Air Military Test Cell Boiler 0.75
PC Air Military Test Cell Steam Generator 0.60
PC Air Commercial Test Cell Steam Generator 0.72
Bay D Drying Area Heating Unit 0.46
Small Parts Heating Unit 3.5
A2 Paint Heating Unit 3.2
Bay D Primer Heating Unit 4.0
Prep Area Heating Unit 2.5
Buff Prime Heater 0.97
8.1 RACT Analysis for <5 MMBtu/hr Boiler and Heater NOx Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible NOx control technologies that are available on the market
for boilers and heaters with capacities of <5 MMBtu/hr or less and have been proven in practice.

Typically, NOx is formed from two mechanisms during combustion: thermal NOx and fuel NOx. For natural gas-
fired equipment, fuel NOx is relatively small, so thermal NOx is the main source of NOx emissions. The formation
of thermal NOx can be minimized by controlling the residence time, oxygen levels, and flame temperature.
8.1.1 Step 1 – Identify All Reasonably Available Control Technologies
Five control technologies were identified for reducing NOx emissions from <5 MMBtu/hr boilers and heaters.
These include:

► Flue gas recirculation (FGR),
► Selective catalytic reduction,
► Low-NOx burners (LNB),
► Ultra-low NOx burners (ULNB), and
► Good combustion practices.

Note, in UDAQ R307-315, NOx Emission Limits for Natural Gas-Fired Boilers, Steam Generators, and Process
Heaters 2.0-5.0 MMBtu, a limit of 9 ppmv has been established for the emissions of NOx for new,
reconstructed, or modified natural gas-fired boilers with a total rated heat input of at least 2.0 million British
Thermal Units per hour (MMBtu/hr) and not more than 5.0 MMBtu/hr. While this rule does not apply to existing
boilers, ultra-low NOx burners have been considered an option in this analysis.

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8.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.

Flue Gas Recirculation

FGR is a NOx control technology that involves the recycling of post-combustion air into the air-fuel mixture to
reduce the available oxygen and help cool the burner flame. External FGR required the use of ductwork to
route a portion of the flue gas in the stack back to the burner windbox. FGR can be wither forced draft (where
hot side fans are used) or induced draft. The NOx control efficiency of FGR is 30-60 percent.18 This technology
is listed in the RBLC search as technically feasible and is paired with LNB for the BACT determined control
technology. Since the boilers at Oshkosh are not equipped with low NOx burners, FGR is considered technically
infeasible as an add-on control and has not been demonstrated in practice for boilers with firing rates less
than 5 MMBtu/hr.

Thus, this NOx control technology has been eliminated as technically infeasible for the boilers <5 MMBtu/hr
at Oshkosh.

Selective Catalytic Reduction

SCR is a post-combustion technology that reacts the NOx in the boiler exhaust with ammonia or urea and
oxygen in the presence of a catalyst to form nitrogen and water. The ammonia injection grid is located
upstream of the catalyst. SCR technology requires optimal gas temperatures in the range of 480°F to 800°F.
NOx conversion is sensitive to exhaust temperature and performance can be limited by contaminants in the
exhaust gas that may poison the catalyst. A small amount of ammonia is not consumed in the reaction and is
emitted in the exhaust stream.

SCR is considered technically infeasible as an add-on control and has not been demonstrated in practice for
boilers with firing rates less than 5 MMBtu/hr.

Low NOx Burners

Low-NOx burner technology uses advanced burner design to reduce NOx formation through the restriction of
oxygen, flame temperature, and/or residence time. There are two general types of LNB: staged fuel and
staged air burners. In a staged fuel LNB, the combustion zone is separated into two regions. The first region
is a lean combustion region where a fraction of the fuel is supplied with the total quantity of combustion air.
Combustion in this zone takes place at substantially lower temperatures than a standard burner.

Low-NOx burner technology uses advanced burner design to reduce NOx formation through the restriction of
oxygen, flame temperature, and/or residence time. There are two general types of LNB: staged fuel and
staged air burners. In a staged fuel LNB, the combustion zone is separated into two regions. The first region
is a lean combustion region where a fraction of the fuel is supplied with the total quantity of combustion air.
Combustion in this zone takes place at substantially lower temperatures than a standard burner. In the second
combustion region, the remaining fuel is injected and combusted with leftover oxygen from the first region.
This technique reduces the formation of thermal NOx. LNB technology typically achieves emission rates of 30
ppm or 0.036 lb/MMBtu.

18 Pollution Online (2000). NOx Emission Reduction Strategies. https:// www.pollutiononline. com/ doc/ noxemission-reduction-
strategies-0001.

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This control technology is technically feasible for boilers < 5 MMBtu/hr fired on natural gas but is not available
for small (<1 MMBtu/hr) boilers and heaters.

Ultra-Low NOx Burners

Ultra-low NOx burners may incorporate a variety of techniques including flue gas recirculation, steam injection,
or a combination of techniques. These burners combine the benefits of flue gas recirculation and low-NOx
burner control technologies. ULNB technology can achieve an emission rate of 9 ppm or 0.011 lb/MMBtu.

This control technology is technically feasible for boilers < 5 MMBtu/hr fired on natural gas but is not available
for small (<1 MMBtu/hr) boilers and heaters.

Good Combustion Practices

Good combustion practices generally include the following components: (1) Proper air/fuel mixing in the
combustion zone; (2) High temperatures and low oxygen levels in the primary combustion zone; (3) Overall
excess oxygen levels high enough to complete combustion while maximizing boiler thermal efficiency, and (4)
Sufficient residence time to complete combustion. Good combustion practices are accomplished through boiler
design as it relates to time, temperature, and turbulence, and boiler operation as it relates to excess oxygen
levels.

Good combustion practices are technically feasible for boilers < 5 MMBtu/hr fired on natural gas.
8.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Effective control technologies for NOx emission reductions from the boilers and heaters <5MMBtu/hr are listed
below:

► ULNB,
► LNB, and
► Good combustion practice.
8.1.4 Step 4 - Evaluate Most Effective Controls and Document Results
The top-ranked control option involves the use of ULNB to achieve an NOx emission rate of 9 ppmv or less.
An analysis was performed to evaluate the technical feasibility and cost effectiveness of upgrading existing
heater/boilers <5 MMBtu/hr but > 2 MMbtu/hr with ULNB. The UDAQ conducted a cost analysis on the use
of ultra-low-NOx burners to determine if they were economically feasible. The UDAQ concluded that ultra-low-
NOx limits for boilers between 2-5 MMBtu/hr would generally cost between $2,567.57 and $7,208.79 per ton
of NOx reduced. This cost range was calculated based on cost estimates received from multiple companies.
Thus, UDAQ considers this technology to be economically feasible.

LNB does not meet the NOx limitation requirements of R307-315 of 9 ppmv for new or replacement of burners
on existing units; thus, this option has been eliminated as RACT.

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8.1.5 Step 5 – Select RACT
For the boilers and heaters currently operating at Oshkosh, only good combustion practices using natural gas
were identified to control NOx emissions from these units which is considered RACT. Until such a time when
Oshkosh needs to replace burners on the existing boilers/heaters or replace them with new units in the size
of 2-5 MMBtu/hr, Oshkosh at that time will meet the requirements of R307-315.
8.2 RACT Analysis for <5 MMBtu/hr Boiler and Heater VOC Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible VOC control technologies that are available on the market
for boilers and heaters with capacities of <5 MMBtu/hr or less and have been proven in practice.

The rate of VOC emissions from boilers and heaters depends on combustion efficiency. VOC emissions are
minimized by combustion practices that promote high combustion temperatures, long residence times at those
temperatures, and turbulent mixing of fuel and combustion air. Trace amounts of VOC species in the natural
gas fuel (e.g., formaldehyde and benzene) may also contribute to VOC emissions if they are not completely
combusted.
8.2.1 Step 1 - Step 1 – Identify All Reasonably Available Control Technologies
Control options for VOC generally consist of the following:

► Good Combustion Practice
► Fuel Specifications (use of natural gas)
8.2.2 Steps 2 – 5
The control options identified in Step 1 are the only control methods for reducing VOC emissions from natural
gas-fired boilers and heaters. A search of the RBLC along with other state databases reviewed required the
use of an add-on control system to reduce VOC emissions for the size of boilers operated at Oshkosh. RACT
for VOCs for natural gas combustion equipment is frequently listed in RBLC as proper operation or no control.
Good combustion practices involve fuel residence times, proper fuel-air mixing, and temperature control.
Thus, the use of good combustion practices and natural gas are proposed as RACT for VOC for the <5
MMBtu/hr heaters operated at Oshkosh.

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9. RACT ANALYSIS FOR GENERATORS
Per AO DAQE-AN109250011-18, II.A.8 and II.A.9, diesel generators at the Oshkosh facility consist of a 35 kW
emergency generator and a 176 kW generator.
9.1 RACT Analysis for Generator NOx Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible NOx control technologies that are available on the market
for generators less than 750 kW and have been proven in practice.

Diesel engines are classified as compression ignition (CI) internal combustion engines. In diesel engines, air
is drawn into a cylinder as the piston creates space for it by moving away from the intake valve. The piston’s
subsequent upward swing then compresses the air, heating it at the same time. Next, fuel is injected under
high pressure as the piston approaches the top of its compression stroke, igniting spontaneously as it contacts
the heated air. The hot combustion gases expand, driving the piston downward. During its return swing, the
piston pushes spent gases from the cylinder, and the cycle begins again with an intake of fresh air.

The predominant mechanism for NOx formation from internal combustion engines is thermal NOx which arises
from the thermal dissociation and subsequent reaction of nitrogen and oxygen molecules in the combustion
air.
9.1.1 Step 1 - Identify all Reasonably Available Control Technologies
The following technologies were evaluated for controlling NOx emissions from the CI combustion engines.
They are:

► Selective Catalytic Reduction
► Good combustion, operating, and maintenance practices
► Limiting hours of operation in accordance with NSPS Subpart IIII to less than 100 hours annual for
readiness (maintenance and testing) for emergency generators
► Use of a Tier-Certified Engine
9.1.2 Step 2 – Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.
Selective Catalytic Reduction
Selective catalytic reduction systems introduce a liquid reducing agent such as ammonia or urea into the flue
gas stream before the catalyst. The catalyst reduces the temperature needed to initiate the reaction between
the reducing agent and NOx to form nitrogen and water.

For SCR systems to function effectively, exhaust temperatures must be high enough (200°C to 500°C) to
enable catalyst activation. For this reason, SCR control efficiencies are expected to be relatively low during
the first 20 to 30 minutes after engine start up, especially during maintenance and testing. There are also
complications controlling the excess ammonia (ammonia slip) from SCR use.

This control technology is technically feasible for generator engines.

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Good Combustion, Operating, and Maintenance Practices

Good combustion practices refer to the operation of engines at high combustion efficiency, which reduces the
products of incomplete combustion, such as VOC and CO. Generator engines are designed to achieve high
combustion efficiency when maintained and operated according to the manufacturer’s written instructions.
GCP are considered technically feasible.

Limiting Hours of Operation in Accordance with NSPS Subpart IIII

One of the options to control the emissions of all pollutants released from the 35-kW emergency generator
engine is to limit the hours of operation for the equipment. Due to the designation of this equipment as
emergency equipment, only 100 hours of operation for maintenance and testing are permitted per NSPS
Subpart IIII.19 Therefore, limiting hours of operation is considered technically feasible.

Tier-Certified Engine

Tier-certified engines rely on combustion controls to comply with EPA Engine NSPS emission standards.
Installation of a tier-certified engine is considered technically feasible.
9.1.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
The remaining control options, SCR, GCP, limiting hours of operation and tier-certified engines will be
examined further. Combustion controls have been demonstrated to reduce NOx emissions from CI engines by
approximately 50%; the use of a SCR can reduce emissions in the range from 70 to 90%.
9.1.4 Step 4 – Evaluate Remaining Control Technologies on Economic, Energy, and
Environmental Feasibility
The top control option, SCR, uses a reducing-agent like ammonia or urea (which is usually preferred) with a
special catalyst to reduce NOx in diesel exhaust to N2. The SCR catalyst sits in the exhaust stream and the
reducing agent is injected into the exhaust ahead of the catalyst. Once injected the urea becomes ammonia
and the chemical reduction reaction between the ammonia and NO takes place across the SCR catalyst. With
the use of an SCR, there is the potential for some ammonia to “slip” through the catalyst.

SCR systems have two key operating variables that work together to achieve NOx reductions. These are the
exhaust temperature and the injection of urea or ammonia. The exhaust temperature must be between 260°C
and 540°C for the catalyst to operate properly. SCR systems will not begin injection of ammonia in the form
of urea until the catalyst has reached the minimum operating temperature. Urea is a critical component in
determining the control efficiency of the SCR. It must be injected in the exhaust stream upstream of the SCR
system. In the catalyst, it reacts to reduce NOx to from N2 and H2O. The reaction takes place because the
catalyst lowers the reaction temperature necessary for NOx.

19 40 CFR 60.4211(f)(2)

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Since SCR systems require an operating temperature between 260°C and 540°C, reaching these temperatures
may be difficult in routine maintenance and testing operations where the engine is typically operated at low
load for a short period of time. If the critical temperatures are not met while the engine is running, there will
be no NOx reduction benefit. To have NOx reduction benefit, the engine would need to be operated with higher
loads and for a longer period. This would be a challenge for Oshkosh since the 176-kW engine is limited to
1,440 operating hours per year and the 35-kW emergency generator engine is limited to 100 hours per year.

Urea handling and maintenance must also be considered. Urea crystallization in the lines can damage the SCR
system and the engine itself. Crystallization in the lines is more likely in emergency standby engines due to
their periodic and low hours of usage.
Energy, Environmental, and Economic Impacts
There are several downsides to using an SCR. First, an improperly functioning SCR system can create excess
ammonia emissions. SCR systems also add significant equipment to the engine system which increases the
possibility of failures and increases on-going maintenance costs.

Cost evaluations were prepared to determine the cost of control per ton of NOx removed from an SCR for the
generator and emergency generator. SCR retrofit information was obtained from Wheeler Machinery in Salt
Lake City. Based on the current cost information provided by Wheeler, the calculated costs per ton of NOx
removed are presented in Table 9-1 and in Appendix A.
Table 9-1 Cost Effectiveness of Installing SCR on Diesel Generator Engines for NOx Control
Equipment Cost Effectiveness
($/Ton)
35 kW emergency generator $ 85,854
176 kW generator $ 549,463

In addition to the costs presented in Table 3-7, the cost of urea is approximately $1.25 per kW and its shelf
life is approximately two years. This would increase the cost of operation of a SCR since the low number of
annual hours of operation could lead to the expiration of the urea. The urea would have to be drained and
replaced, creating an extra maintenance step and an increased cost to Oshkosh. Thus, the use of SCR on the
diesel generator at has been determined to be economically infeasible.
9.1.5 Step 5 – Select RACT
Based on the economic costs to install a SCR system, the likelihood that the generator engines would not be
at proper operating temperature for the SCR to be effective due to limited operating hours, and the extra
maintenance and disposal costs if urea were used, SCR has been eliminated as RACT.

The 35 kW and 176 kW generator engines installed after 2006 at Oshkosh meet NSPS standards and are EPA
tier-certified engines. Additionally, these units will operate for limited hours, using good combustion practices,
and fueled by ultra-low sulfur diesel.

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Periodic maintenance is performed on the engines in accordance with manufacturer specifications. The 35 kW
and 176 kW generator engines at Oshkosh are subject to Subpart ZZZZ, and as such, the oil is changed, and
hoses/belts inspected every 500 hours or annually. Thus, the only control technologies for the diesel generator
and emergency generator at Oshkosh are the work practice requirements to adhere to GCP and NOx Tier
standard for each engine and the best practice of performing periodic maintenance. These requirements have
been determined to be RACT. These control strategies are technically feasible and will not cause any adverse
energy, environmental, or economic impacts.
9.2 RACT Analysis for Generator VOC Emissions
A review of previous RACT analyses, CARB, SJVAPCD, BAAQMD, SCAQMD, RBLC Clearinghouse, and other
state databases was performed to identify possible VOC control technologies that are available on the market
for generators less than 750 kW and have been proven in practice.

VOC emissions are primarily the result of incomplete combustion of diesel fuel. These emissions occur when
there is a lack of available oxygen, the combustion temperature is too low, or if the residence time in the
cylinder is too short.
9.2.1 Step 1 - Identify all Reasonably Available Control Technologies
The following technologies were evaluated for controlling VOC emissions from the CI combustion engines.
They are:

► Diesel oxidation catalyst
► Combustion controls
9.2.2 Step 2 – Eliminate Technically Infeasible Control Technologies
The control technologies identified in Step 1 are discussed in this section.
Diesel Oxidation Catalyst
A diesel oxidation catalyst (DOC) is a flow-through metal or ceramic substrate coated with platinum or other
precious metals. The diesel oxidation catalyst sits in the exhaust stream and all exhaust from the engine
passes through it. The catalyst promotes the oxidation of unburned CO and HC (as VOC) in the exhaust
producing CO2 and water. Diesel oxidation catalysts are commercially available and reliable for controlling
VOC emissions from diesel engines.

This control technology is technically feasible for generator engines.
Good Combustion Practices
Good combustion practices refer to the operation of engines at high combustion efficiency which reduces the
products of incomplete combustion. The emergency generators are designed to achieve maximum combustion
efficiency. The manufacturer provided operation and maintenance manuals that detail the required methods
to achieve the highest levels of combustion efficiency.

This control technology is technically feasible for generator engines.

Oshkosh Aerotech / Reasonable Available Control Technology Assessment
Trinity Consultants July 2024 9-5
9.2.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
The control effectiveness of each identified control technology is as follows:
► Diesel oxidation catalyst – 95%
► Combustion controls – baseline
9.2.4 Step 4 – Evaluate Remaining Control Technologies on Economic, Energy, and
Environmental Feasibility
For diesel engines, oxidation catalysts are often combined with particulate filters. This can be done by applying
the catalysts, which are typically platinum based, to a particulate filter. Another common approach is to locate
the oxidation catalyst separately, upstream of the particulate filter. The oxidation catalyst creates heat by
oxidizing unburned hydrocarbons and shifts NOx, creating a favorable environment for the particulate filters
to regenerate.
Energy, Environmental, and Economic Impacts
The highest-ranking control option, DOC, can reduce VOC emissions by up to 95%. A cost effectiveness
evaluation for this top-ranking option, in costs per ton of VOC removed, is presented in Table 9-2 and in
Appendix A. Costs for DOCs were obtained from Wheeler Machinery and represent current costs.
Table 9-2 Cost Effectiveness of Installing DOC on Emergency Diesel Engines for VOC Control
Equipment Cost
Effectiveness
($/Ton)
35 kW emergency generator $ 578,899
176 kW generator $ 407,545

As seen from Table 9-2, it is economically infeasible to install DOC on the 35kW or 176 kW diesel generator
engines at Oshkosh.
9.2.5 Step 5 – Select RACT
The remaining control option, good combustion practices was determined to be RACT for the diesel emergency
generator and the generator that are operated at Oshkosh. According to Oshkosh’s approval order, the 176-
kW generator is limited to 1,440 operating hours per year. The 35-kW emergency generator is limited to 100
operating hours per year for testing and maintenance. A non-resettable hour meter is installed on this unit.

Periodic maintenance is performed on the engines in accordance with manufacturer specifications. For those
engines subject to Subpart ZZZZ, oil is changed, and hoses/belts inspected every 500 hours or annually. Thus,
the only control technologies for the generators at Oshkosh are the work practice requirements to adhere to
GCP for each engine and the best practice of performing periodic maintenance. These requirements have
been determined to be RACT. These control strategies are technically feasible and will not cause any adverse
energy, environmental, or economic impacts.

Oshkosh Aerotech / Reasonable Available Control Technology Assessment
Trinity Consultants July 2024 10-1
10. ACTUAL AND POTENTIAL EMISSIONS
A summary of the 2017 actual emissions for NOx and VOC emissions from the emissions inventory at Oshkosh
is presented in Table 10-1.
Table 10-1 Oshkosh Aerotech, Formerly JBT Aerotech – NOx and VOC 2017 Actual and PTE
Emissions
Equipment Description 2017 Actuals
(TPY)
PTE
(TPY)
NOx VOC NOx VOC
Military Test Cell Boiler 0.0066 0.00001 0.319 0.018
Military Test Cell Steam Generator 0.0023 0.00013 0.255 0.014
PC Air Commercial Test Cell 0.0028 0.00015 0.306 0.017
Bay D Drying Area 0.1237 0.00681 0.193 0.011
Small Parts Heating Unit 0.7372 0.04055 1.49 0.082
A2 Paint Heating Unit 0.5569 0.03063 1.36 0.075
Bay D Primer Heating Unit 0.8643 0.04753 1.70 0.094
Bay D Prep Area Heating Unit 0.5402 0.02971 1.06 0.058
Buff Prime Heater -- -- 0.41 0.023
Bay D Paint Booth -- 25.09 3
Small Parts Paint Booth -- 3.58 3
Bay D Primer Booth -- 8.63 3
Honda GX200 inverter engine (3 kW) 0.000004 0.00003 0.014 0.11
Engine Production 0.361 -- 2.671,2 --
Diesel storage tank -- 0.0003 0.028
Emergency Generator (35 kW) -- -- 0.014 0.007
Generator Engine (176 kW) -- -- 0.110 0.050
Compressor Engine (4 kW) -- -- 0.021 0.031
Solvent Recovery -- -- -- 0.021
1 NOx + HC Emissions reported based on 6 hours of testing per unit
2 PTE based on number of projected units through 2020
3 AO DAQE-AN109250011-18 II.B.1.a – Paint booth emission not to exceed 56.32 tons

Oshkosh Aerotech / Reasonable Available Control Technology Assessment
Trinity Consultants July 2024 A-1
APPENDIX A. $/TON COST ANALYSES

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Anguil Environmental Systems, Inc.
Proposal for Rotor Concentrator
Wheel Coupled with Regenerative
Thermal Oxidizer

Date: August 21, 2024
Proposal #: AES-12174

Prepared for:

Matthew Gregory
Sr. Environmental Manager
Oshkosh Vocational Segment
1512 38th Avenue E.
Brandenton, FL 34208

Phone: [phone]
Email: [e-mail]

Submitted by:

Will Weingart
Regional Sales Manager
[e-mail]

Jason Schueler
Applications Engineering Manager
[e-mail]

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Table of Contents

Executive Summary ...................................................................................................... 4
Customer Process Specifications ............................................................................... 5
ROTOR CONCENTRATOR Design Specifications ...................................................... 6
RTO Equipment Design Specifications ....................................................................... 7
Rotor Concentrator Specifications .............................................................................. 9
RTO Equipment Specifications .................................................................................. 13
Exceptions and Clarifications .................................................................................... 22
Items Not Included ...................................................................................................... 22
BUDGETARY Pricing and Delivery ............................................................................ 23
Operating Cost Summary ........................................................................................... 25
Field Service Rates ..................................................................................................... 26
Standard Terms and Conditions ................................................................................ 27
Institute of Clean Air Companies (ICAC) Guidance Method for Estimation of Gas
Consumption in an Regenerative Thermal Oxidizer (RTO) ..................................... 33

*Note: This proposal contains confidential and proprietary information of Anguil Environmental
Systems, Inc. and is not to be disclosed to any third parties without the express prior written
consent of Anguil.
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EXECUTIVE SUMMARY

Equipment Description Rotor Concentrator and Regenerative Thermal Oxidizer (RTO) to
control VOC emissions.
Facility to be Controlled An Oshkosh Aerotech facility located in Utah
Processes Controlled Solvent based painting operations
Proposed Equipment
Two (2) Model 180 (180,000 SCFM) Dual Zeolite Rotor Concentrator
systems in parallel, coupled to a Model 400 (40,000 SCFM)
Regenerative Thermal Oxidizer (RTO) with 95% Nominal Thermal
Energy Recovery to minimize gas usage
Results
Anguil guarantees the Rotor Concentrator adsorption and the
Regenerative Thermal Oxidizer to maintain a total system destruction
efficiency of 98% or an outlet concentration of 20 ppmv as C1
(methane), whichever is less stringent per EPA Method 25A.

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CUSTOMER PROCESS SPECIFICATIONS

Process Flow 360,000 SCFM
Process Temperature 70 °F
VOC Concentration
55 tons (12 month rolling total)
= ~12.5 lbs/hr
Design/Max: 100 lb/hr
VOCs*
*Assumed no halogenated, silicones,
phosphorus, sulfur, or sodium bearing
compounds are present
Assumed typical painting solvents
Facility Altitude ~4,300 FASL
Facility Operating Schedule Assumed 24/7
Facility Power 460V / 60 Hz / 3 Ph
Fuel Source Natural Gas
Site Electrical Classification General Area / Unclassified
Process Water Content Assumed to be no more than 0.01 lb water / lb air
Process Oxygen Content Assumed to be at least 18%
Process Particulate To be pre-filtered by others
Assumed to be negligible at the concentrator inlet
Performance Requirements 99% DRE
Oxidizer Location Onsite Assumed outdoors

Note: Equipment has been designed and sized based on these customer parameters. Any variation
from the above parameters may affect equipment selection and cost.
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ROTOR CONCENTRATOR DESIGN SPECIFICATIONS

SIZE AND WEIGHT
Maximum Airflow 360,000 SCFM
Number of Zeolite Rotors
Four (4) total in a two (2) x two (2) configuration:
Two (2) parallel modules each with two (2) rotor
concentrators in series
Each module of two (2) rotors in series is sized for
180,000 SCFM
Rotor Diameter / Depth 4.5m / 400mm
Adsorption Airflow 360,000 SCFM
Desorption Air / Concentrate Airflow Indoors within 50’ of furthest motor
OPERATIONAL INFORMATION
Adsorption Efficiency 99% (two rotors in series each achieving 96% conversion)
Concentration Ratio ~10:1
Design Temperature for Desorption
Air ~425°F
Concentrate Temperature ~140°F
Adsorption Fans HP
Two (2) fans provided, one per dual rotor concentrator
module
Each is 600HP motor derated for altitude to 500HP
Cooling Fan HP 150 HP motor derated for altitude to 125HP
Stage 2 Desorption Fan HP
Two (2) fans provided, one per dual rotor concentrator
module
100 HP motor derated for altitude to 75 HP
Concentrate Control Device Model 400 RTO

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RTO EQUIPMENT DESIGN SPECIFICATIONS

SIZE AND WEIGHT
Maximum Airflow 40,000 SCFM
Approximate Footprint / Weight 62’ x 25’ / 175,000 lbs (RTO only)
Suggested Foundation Size 68’ x 30’ (RTO only)
Stack Height / Diameter Not included at this time
Oxidizer Control Panel Location Indoors within 50’ of furthest motor
OPERATIONAL INFORMATION
Destruction Efficiency
99% conversion in the rotor concentrator coupled with
99% destruction efficiency in the RTO
Provides a guaranteed overall 98% DRE or an outlet
concentration of 20 ppmv as C1 (methane), whichever is
less stringent per EPA Method 25A
Maximum Processing Capacity
With Hot Side Bypass 7.3 MMBTU/hr (8.1 lbs/minute @ 15,000 btus/lb)
Nominal Thermal Efficiency (TE) 95%
System Fan Draft Design Forced
System / Stage 1 Desorption Fan HP 300 HP derated to 250 HP for altitude
Combustion Fan HP 15 HP derated to 10 HP for altitude
Operating Set Point 1,550-1,700°F

Note: All weights, dimensions, horsepower ratings, burner sizing, and specific engineering details
within the proposal are approximate and will be confirmed by Anguil Environmental following
order placement.

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UTILITY AND PROCESS CONNECTION REQUIREMENTS
Maximum Fuel Supply / Pressure
12.0 MMBTU/hr / 5 psig
Connection at oxidizer fuel train
Specific fuel flowrate to be determined during detailed
engineering
Electrical Power
460V / 60 Hz / 3 Ph
Power connection at oxidizer control panel
Interconnecting wiring between control panel and Anguil
supplied motors is not included, to be done in the fueld
during electrical installation
Required Compressed Air
80-100 psig (-40°F/C dewpoint), 5-10 SCFM, 3/4” NPT
Connection at oxidizer compressed air train
Specific flowrate to be confirmed during detailed
engineering
Process Connection
94” x 70” flanged connection at each absorption fan
Unit isolation is required for purging
Isolation damper is not included in Anguil scope at this time
Process ductwork to the connection point is by others
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ROTOR CONCENTRATOR SPECIFICATIONS

HOW THE ROTOR CONCENTRATOR WORKS
During the system operation, the VOC laden air will be exhausted from the process and drawn into the rotor
where VOCs are removed from the air by adsorption. The cleaned air passes through the rotor and is
discharged to atmosphere. The rotor turns to continuously transport adsorbed VOC into a desorption sector
and returning regenerated zeolite to the process. After desorption, the rotor is cooled with process air. This
small portion of VOC laden air, the cooling air, is captured in a separate outlet plenum. It is heated and returned
to the rotor’s regeneration sector to desorb the organics. The concentrated air stream is sent to the RTO where
the VOC’s are oxidized. The energy content of the VOC contributes to the oxidation process, thus reducing
the supplemental energy requirements.

The rotor concentrator system is an integrated air pollution control device which uses proprietary
adsorbents in a honeycomb structure to remove volatile organic compounds (VOCs) from dilute high
volume air streams and concentrate the VOC into a smaller concentrate stream for destruction by the RTO.

The purpose of concentrating the VOC is to reduce the capital and operating cost of treating the original
high volume stream by removing the VOC in an adsorption rotor with very low pressure drop and continuous
operation, and deliver the VOC in a concentrated form so that the cost of further treatment - a RTO - is
greatly reduced. The VOC in the concentrate contributes a significant amount of energy required for
oxidation.

LIMITATIONS OF CONCENTRATORS

• Polar molecules do not adsorb well (Methanol) since they are similar to water
• Any acetone present in process stream is not calculated into adsorption efficiency
• Process temperature should not exceed 105°F
• If the VOC is a liquid at room temperature, then it can adsorb (solvent boiling point cannot be less than
ambient temperature)
• Particulate in the process exhaust stream can mask the surface of the concentrator, reducing its
effectiveness

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CONCENTRATOR DESCRIPTION

The zeolite rotor concentrator is made from a mineral fiber honeycomb structure with a hydrophobic zeolite
adsorbents impregnated into the honeycomb structure. The detailed construction methods and actual
chemical constituents in the wheel are proprietary. The adsorbents are selected with a pore size for the
best performance for current and potential future use of the system. Zeolite adsorbents are characterized
by well-defined pore size distribution with a very high adsorption capacity at low inlet concentrations and a
high working capacity in relation to total adsorption capacity. They are inorganic chemicals, which are
temperature resistant, inert, non-flammable and resistant to most acids. The zeolites used for VOC
adsorption are hydrophobic and do not adsorb water from humid air to any significant degree and in this
form are non-catalytic.

The zeolites are incorporated into a honeycomb structure, which allows the VOC laden process air to pass
through the honeycomb channels at relatively high velocities with low overall pressure drop. As the process
air passes through the channels in the honeycomb structure, the VOC diffuses into the zeolite pores and is
adsorbed. The shape of the honeycomb is a flat disc rotor with the airflow and the channels parallel to the
rotor axis.

The rotor is mounted in a housing with
sealed compartments allowing segments of
the rotor to pass through adsorption,
desorption, and cooling sectors as it slowly
turns in the air stream. In this way each part
of the rotor continuously pass from
adsorption to desorption and cooling before
returning to adsorption again after one
complete revolution. The binders used to
“glue” the structure together and to bind the
adsorbent to the honeycomb are entirely
inorganic, with no flammable organic glues
present. The binders are silicate type
materials, which do not interfere with the
adsorption process.

INLET FILTER PLENUM (QUOTED AS SEPARATE LINE ITEM)

• Anguil recommends and can supply an inlet filter plenum with two stages of filters
• Access to these filters will be through a door on the plenum assembly.
• The filter system will be a two-stage design with a Medium Efficiency Pleated pre-filter followed by a
High Efficiency Pleated final filter capable of 95+% efficiency at 0.8 microns.
• Design velocity is to be no higher than 500 fpm at process exhaust temperature.
• Local indication and alarming of pressure drop across the filter plenum will be provided. • Maximum particulate loading prior to first stage filter changeout is 0.33 pounds for each 2,000 SCFM
of process flow through the filters.
• Further information on the nature of any particulate is required to confirm filter selection.

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ROTOR CONCENTRATOR WHEEL COMPONENTS

• Hydrophobic zeolite absorbent impregnated on a honeycomb substrate disc rotor
• Disc shaft mounted on grease lubricated self-aligning and sealed bearings
• Rotor housing with sealed compartments for adsorption, desorption and cooling
• Rotor housing manufactured from heavy gauge carbon steel
• Inorganic, non-flammable binder used
• Continuous duty gear motor drives power rotor
• Rotor driven with a variable frequency drive
• Internal wiring
• Modular, skid mounted design

SYSTEM ISOLATION AND BYPASS (NOT INCLUDED AT THIS TIME)

• Isolation and bypass of the oxidizer system allows the process exhaust flow to be redirected to atmosphere
in the event of an unexpected shutdown of the oxidizer or during startup of the process itself
• A means of isolating and bypassing the oxidizer system is currently not included in Anguil’s scope, but can
be quoted upon equipment selection and design of upstream process exhaust ductwork

ADSORPTION FANS

The Adsorption Fans are designed for –4” WC at the system inlets to accommodate dirty filters upstream
(filters by others). then the Adsorption Fans will push the process through the rotors and out the exhaust
stack.

• Each module of dual rotor concentrators has a dedicated Adsorption Fan
• Twin City Fan, New York Blower or equal
• VFD rated, TEFC motor
• Flexible connection on inlet/outlet of fan

COOLING FAN

The Cooling Fan is designed to move the process through the cooling sector of the rotors and through the
desorption heater assembly

• Twin City Fan, New York Blower or equal
• VFD rated, TEFC motor
• Flexible connection on inlet/outlet of fan

DESORPTION AIR HEATER ASSEMBLY

• A dedicated hot damper will be used to pull air from the RTO combustion chamber to be used as the heat
source for desorption of the Rotor Concentrator
• Hot air from the RTO combustion chamber will be combined in a mixing plenum with cooling air from the
concentrators to produce the desorption temperature required at the rotors

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STAGE 2 DESORPTION AIR FANS

The Stage 2 Desorption Air Fans will pull the VOC-laden concentrate air from the desorption section of the
respective stage 2 rotor and recirculate this to the inlet of rotor 1.

• Each module of dual rotor concentrators has a dedicated Stage 2 Desorption Air Fan
• Twin City Fan, New York Blower or equal
• VFD rated, TEFC motor
• Flexible connection on inlet/outlet of fan
• AMCA Type C spark resistant fan construction to meet NFPA 91 requirements for flows with potential VOC
concentrations above 10% LEL

STAGE 1 DESORPTION/SYSTEM AIR FAN

The Stage 1 Desorption / System Air Fan will pull the VOC-laden concentrate air from the desorption section
of each stage 1 rotor and push it through the RTO for oxidation.

• Twin City Fan, New York Blower or equal
• VFD rated, TEFC motor
• Flexible connection on inlet/outlet of fan
• AMCA Type C spark resistant fan construction to meet NFPA 91 requirements for flows with potential VOC
concentrations above 10% LEL

INTERCONNECTING DUCTWORK

• Ductwork between the adsorption fan and concentrator, and between the concentrator and exhaust stack
• Cooling air ductwork and desorption manifold
• Ductwork between RTO hot damper and mixing plenum to mix with cooling air
• NOTE: The Desorption Air duct, the Cooling Air duct and the Concentrate Air duct should all be insulated
and clad in the field to conserve energy in these gas streams and minimize water condensation. This
insulation and cladding is not included at this time. Anguil recommends this be done in the field by others
after installation.

PAINTING

• All welds caulked prior to painting
• All exposed surfaces of the concentrator will be primed and painted with two (2) shop coats of Anguil’s
standard coating.
• UV resistant polyurethane paint
• Paint color can be specified by the customer

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RTO EQUIPMENT SPECIFICATIONS

The Anguil Regenerative Thermal Oxidizer (RTO) destroys Hazardous Air Pollutants (HAPs), Volatile
Organic Compounds (VOCs), and odorous emissions that are discharged from industrial processes.
Emission destruction is achieved through the process of high temperature thermal or catalytic oxidation,
converting the pollutants to carbon dioxide and water vapor while reusing the thermal energy generated to
reduce operating costs.

HOW THE RTO WORKS
VOC and HAP laden process gas enters the oxidizer through an inlet manifold to flow control poppet valves
that direct this gas into energy recovery chambers where it is preheated. The process gas and contaminants
are progressively heated in the ceramic media beds as they move toward the combustion chamber.

Once oxidized in the combustion chamber, the hot purified air releases thermal energy as it passes through
the media bed in the outlet flow direction. The outlet bed is heated, and the gas is cooled so that the outlet
gas temperature is only slightly higher than the process inlet temperature. Poppet valves alternate the
airflow direction into the media beds to maximize energy recovery within the oxidizer. The high energy
recovery within these oxidizers reduces the auxiliary fuel requirement and saves operating cost. The Anguil
oxidizer achieves high destruction efficiency and self-sustaining operation with no auxiliary fuel usage at
concentrations as low as 3-4% LEL (Lower Explosive Limit).

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POPPET VALVES

Anguil’s poppet valves are uniquely designed to divert high volume process air into and out of the oxidizer,
properly balance VOC loading, maintain destruction efficiency, and optimize heat recovery. We custom-design,
manufacture, and install these vital components to ensure reliability and trouble-free operation. Anguil has
several poppet assemblies that have been operating continuously since 1993 and have required nothing but
regular maintenance.

SPECIFICATIONS
Vertical Stainless-Steel Shaft
• Orientation works with gravity, requiring no linear
bearings to support the weight of the assembly
Carbon Steel Disc & Seat
• Reliable metal to metal seal: 1MM+ cycles
• Removable machined seats: <0.25% leakage at 18”
W.C.
• Two-disc system minimizes valve switch distance,
maximizes component life, and enhances destruction
efficiency
• No gaskets required
Poppet Box Body: 3/16” Plate Steel
• Double acting, three-way air flow design
• Low pressure drop design
• Rectangular ports for inlet/outlet ducting
• Hinged access doors with latches for easier maintenance without bolts
• Over temperature protection for longer equipment life
Cylinder Actuator Supports: 1/4” Plate Steel
• Removable actuator mounting, for easier part maintenance
Heavy Duty Pneumatic Cylinder
• Minimal compressed air usage when solenoids switch from open to closed
• Lockout device for personnel safety
• 90 psi, 10 CFM, -40°F dewpoint
Heavy Duty, High Flow, 4-way Solenoid Valve
Solenoid Valve Exhaust Flow Control
• Soft seat provides quiet operation and reduced wear and tear
Bolted Actuator Mountings with Shaft Guarding
• Personnel protection and simplified maintenance
Connecting Duct Work to Fan and Exhaust Stack
Compressed air Accumulator Tank Included
• Moves valves to safe position on loss of air pressure
End of Stroke Switches
Verifies proper valve operation

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HEAT TRANSFER MEDIA

• Two (2) beds of high temperature chemical porcelain structured heat transfer media and ceramic saddles
• Both types of media are chemically and thermally stable for rapid heat up and cool down
• Ceramic media designed to provide optimum heat transfer surface area
• Media bed for proper air distribution and optimum RTO performance
• Low system designed pressure drop

BURNER(S)/FUEL TRAIN

The burner installed capacity is higher than required during normal operation. This allows the system to
respond rapidly to significant airflow increases, preventing loss of proper RTO operation temperatures. The
burner capacity is also sufficient to maintain system operating temperature during full airflow, VOC free
conditions.

• Maxon Kinemax burner
• Fuel Train fabricated to NFPA 86 and FM Global specifications
• Service platform and ladder
• 3” burner view port
• Fireye self-checking UV scanner with flame switch and flame strength signal
o Allows for continuous operation compared to non-self-checking varieties

COMBUSTION AIR FAN

• Twin City Fan, New York Blower or equal
• VFD rated, TEFC motor
• Flexible connection on outlet of fan
• Pre-piped with inlet filter

FRESH AIR/PURGE DAMPER

The Fresh Air / Purge Damper is used during RTO purging, start-up, shut down, or offline idle. It allows for
safe start-up and shut-down on ambient air. The damper is also used if dilution air is required during periods
of high VOC loading or low process flow. It is controlled by a signal from the PLC.

• Modulating damper with actuator
• Bird screen included
• Automatic isolation of RTO is required for purging, isolation damper provided for RTO
• Shipped loose for installation in interconnecting concentrate ductwork
Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
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ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

SUPPLEMENTAL FUEL INJECTION SYSTEM (SFI)

The Anguil Supplemental Fuel Injection (SFI) system is designed as a high efficiency alternate means of
controlling the RTO reaction chamber temperature. During system operation, when appropriate safeties
have been satisfied, the burner and combustion air systems can be turned off and the RTO combustion
chamber temperature can be maintained by injecting natural gas directly into the VOC laden process stream
– typically at or near the inlet of the RTO system. Natural gas injection is an excellent means of reducing
system operating cost and providing a cleaner “burn” when properly designed and applied.

The benefits of SFI are:

• Provides high fuel
efficiency by reducing
combustion air
• Provides ultralow NOx
emissions with
flameless operation
• Provides a more
uniform temperature
profile throughout the
RTO

All-natural gas injection
systems enjoy these benefits,
but not all systems are
created equally. To date,
Anguil’s level of safety and
controls for natural gas injection have been unmatched by our competitors.

A few of the highlights are:
• Some gas injection systems are designed as solenoid-type full-on or full-off systems. Anguil uses
modulating injection valves for more precise control.
• Some gas injection systems are not designed for proper mixing of the natural gas with the solvent
laden airstream. Anguil’s SFI system is designed with multiple levels of safeties and a custom designed
injection port to ensure a well-mixed airstream is delivered to the RTO chamber.

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
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ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

SYSTEM AUTOMATION AND CONTROLS

The system controls are located in a NEMA 12 control panel enclosure. In the event of a system shutdown,
the touch screen will indicate the cause of the shutdown via a digital message in English.
• NEMA 12 control panel to be mounted indoors in a temperature controlled environment (85°F)
• Allen Bradley Logix family PLC (Programmable Logic Controller) controls
• Safety PLC for burner management allows for easier troubleshooting with better diagnostic and status
information on the HMI
• Allen Bradley 10” Color Touchscreen HMI
• Digital chart recorder: data record of combustion chamber temperature and cold face temperatures.
• Ethernet communications for remote diagnostics and service support

VARIABLE FREQUENCY DRIVE (VFD)

The variable frequency drives regulate the airflow through the system. Controlled via pressure transmitters,
they aid in minimizing operating cost by providing fan turn-down during periods when only low airflow is
required.

• Mounted in a NEMA 12 panel located to be installed indoors within 50’ of the furthest motor
• VFDs are controlled by the system’s PLC
• VFDs are provided for the adsorption fan, desorption/system fan, and combustion fan
• Combination of VFDs and TEFC motors can result in a 50% energy savings as compared to an inlet
vane damper and a standard efficiency motor

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
18

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

ENERGY RECOVERY CHAMBERS

The RTO’s energy recovery chambers are rectangular cross-sections constructed of carbon steel. They
are reinforced to withstand the pressure requirement of the process air fan and all other applied loads. A
carbon steel support structure is also provided to support the oxidizer chambers, media support grid and
the ceramic heat recovery media itself. To allow for routine inspection of the heat recovery media, cold face
and media support grids and two hinged access doors
complete with gaskets are included.

Two (2) carbon steel energy recovery chambers
• Internally insulated: 6” thick, 8# density ceramic
module insulation
• Insulation rated for 2,300°F
• Insulation modules: shop installed with 310
stainless steel reinforcements and mounting
hardware
Support structure and media support grid
• Provides elevation of the media above the RTO
floor to allow proper airflow distribution
Two hinged access doors with gaskets and latches (no bolting required)

COMBUSTION CHAMBER

The combustion chamber is a rectangular cross-
section constructed of carbon steel and reinforced to
withstand the pressure requirements of the process air
fan and all other applied loads. The inverted “U” shape
design provides the retention time to obtain the
specified VOC destruction efficiency. To allow for
routine inspection of the heat recovery media,
insulation, and burner, access door(s) complete with
gaskets and trolley for door support are included.

Inverted "U" shaped oxidation chamber
• Internally insulated: 8” thick, 8# density ceramic module insulation
• Insulation rated for 2,300°F
• Insulation modules: shop installed with 310 stainless steel reinforcements and mounting hardware
Hinged access door(s) with gaskets, latches

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
19

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

EXHAUST STACK (NOT INCLUDED)

Due to the size of the stack diameter, Anguil would to like to understand the needed height and if there are
any other specifications that may apply, before a quote can be provided.

BAKE OUT

The oxidizer can be operated off-line from the process in a bake-out mode to allow for the removal of
organic build-up on the cold face of the heat exchange media. At a reduced airflow, the outlet temperature
is allowed to reach an elevated temperature before the flow direction is switched. This hot air vaporizes
organic particulate that may have collected on the cold face of the heat exchange media. The flow direction
is then switched, and the opposite cold face is cleaned. The area below the media support grid will be
insulated to prevent the temperature of the outer skin from increasing during bake-out.

PAINTING

All exposed surfaces of the oxidizer shall be primed coated with a high solids epoxy coating. The finish coat
shall be a gloss high solids polyurethane multi-function weather resistant coating. The natural gas and
compressed air piping will be primed and painted with one (1) coat of Anguil’s standard coating. All other
equipment will be the manufacturer’s standard paint and color. Prior to painting, all welds will be caulked.

• Surface preparation done to SSPC-1 standards
• UV-resistant polyurethane paint
• Paint color can be specified by the customer
• All purchased OEM equipment shall be the manufacturer’s standard paint and color
• Stainless steel components are not painted

OPERATION & MAINTENANCE MANUALS

• Anguil to provide a link to the comprehensive Operation and Maintenance manual, available for electronic
download. Paper hard copies available by request only.
• USB flash drive of all vendor bulletins

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
20

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

PRE-ASSEMBLY AND SHOP TEST

We pre-assemble and pre-test modular RTO components in our factory to provide significant savings of
time and money during installation and start-up. Units are prewired and pre-piped at the factory for improved
quality control and trouble-free start-up.

• Inspection of the unit for manufacturing quality
• Check fuel and electrical connections
• Warning labels are installed
• Test ports are installed
• Run electrical rigid conduit
• Fans and motors installed, cleared of debris, and
checked for quality
• Temporary wiring of components that are shipped
loose from the RTO skid
• Valves to be cycled and set
• Customer is invited to witness shop testing

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
21

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

OUTDOOR INSTALLATION SCOPE

The system shall be installed outdoors on a concrete pad. Installation is based on free and clear access to
the site, meaning the ability to pull crane and delivery trucks to the equipment pad. No landscape, physical
or overhead obstructions to set up crane or unload equipment directly from truck onto final equipment
location on grade. Installation assumes non-union labor cost.

INSTALLATION SUPERVISION
• An Anguil Project Installation Supervisor shall manage and supervise the oxidizer installation work
• Travel and living expenses included

MECHANICAL INSTALLATION
• Labor and material necessary to unload and set the equipment from shipping trucks
• Rental of all necessary equipment including crane, forklift and manlift
• Erection of Concentrator Modules and RTO on concrete pad
• Setting of energy recovery chambers, combustion chambers, poppet valves and transitions
• Installation of the absorption fans, cooling fan, stage 2 desorption fans, and system fan
• Setting control panel
• Loading of heat exchanger media and insulation
• Installation of interconnecting ductwork
• Mechanical reassembly of Anguil supplied oxidizer components, excluding shipped loose items
installed in customer ductwork
• Finish/touch-up painting as required after installation is complete

ELECTRICAL WORK
• Interconnecting wiring between RTO
junction box and control panel (control panel
located indoors) including up to 50 feet of
conduit run

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
22

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

EXCEPTIONS AND CLARIFICATIONS

All items, components, and equipment proposed within this document are Anguil standard unless
indicated otherwise. Any customer specifications not listed here or not provided to Anguil at the time of
bid issuance and that may alter the included device selections are not included at this time. Specifications
provided after issuance of this proposal or receipt of Purchase Order may impact the project schedule
and/or price.

ITEMS NOT INCLUDED

• HAZOP / PHA Participation (charged at daily rate plus T&L)
• Ductwork/dampers from process to oxidizer inlet connection
• Concrete pad / platform
• Mounting and wiring of shipped loose dampers and instrumentation
• Interconnecting wiring between control panel and Anguil supplied motors
• Power source to oxidizer control panel
• Interconnecting control wiring/cabling between control panel and customer controls
• Winterization of the pneumatic piping and sensing lines, if required
• Supply and installation of compressed air piping (if applicable) for dampers between process(es)
and oxidizer
• All compressed air piping to oxidizer air train (-40°F dewpoint requirement) and tee dampers
• All fuel piping to oxidizer fuel train
• Exhaust stack
• External insulation of ductwork, valves, fan, and exhaust stack
• Personnel protection, security fencing and lighting
• Moving of oxidizer obstructions, fencing, landscaping, etc.
• Multiple installation trips if delays beyond Anguil’s control
• All roof and building penetrations
• All fire suppression piping and controls
• All required sound abatement equipment
• Calibration certificates for instrumentation
• Seismic calculations
• Compliance testing
• Internet connection
• Taxes, permits
• Overtime, holiday, or weekend work
• Installation Supervision (Can be quoted as an option)
• Mechanical and electrical installation (Can be quoted as an option)
• Oxidizer startup and training (Can be quoted as an option)
• Fan alignment/balancing in the field (recommended for 200+ HP fans)
• UL Inspection & Label for Main Control Panel
• Budget Freight (Can be quoted as an option)

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
23

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

BUDGETARY PRICING AND DELIVERY

One (1) Anguil Model 3600 Rotor Concentrator Wheel coupled with One (1) Anguil Model 400
Regenerative Thermal Oxidizer to process up to 360,000 SCFM of VOC laden air, meeting the DRE
requirement as guaranteed in the Executive Summary

BASE EQUIPMENT TOTAL PRICE FCA-ORIGIN
Equipment only, does not include freight or packaging
Per Incoterms 2020, see shipment for list of origin locations
$ 3,500,000
FREE AND CLEAR INSTALLATION $ 450,000
PACKAGING
Equipment is subject to
packaging costs which shall
be calculated and billed to
buyer near time of shipment
STARTUP AND TRAINING $1,700/day
+ travel and living

Note: Alternate freight terms are available and can be quoted upon request. Any freight quote(s)
provided prior to the time of shipment are advisory only and will be confirmed on the day of booking.
Freight is billed at cost plus a handling fee.
Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
24

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

TERMS
• 40% down payment due upon order placement
• 30% due 8 weeks after receipt of purchase order, net 30
• 20% due prior to shipment or notification of readiness to ship
• 10% due upon start-up, not to exceed 60 days from shipment, net 30

SHIPMENT
38-42 Weeks after approval of drawings (7-9 weeks for submittal of General Arrangement and Process and
Instrumentation Diagram), to be determined based on current workload.

ORIGIN OF CARGO IS NOT AVAILABLE AT TIME OF PROPOSAL AND WILL BE CONFIRMED UPON
REVIEW OF PRODUCTION SCHEDULES OF EACH OF THE BELOW FACILITIES:

7000 W. CALUMET RD. MILWAUKEE, WI 53223
2111 N SANDRA ST, APPLETON, WI 54911
1215 HYLAND AVE, KAUKAUNA, WI 54130
3249 HEMPLAND RD, LANCASTER, PA 17601
3000 N 114TH ST, WAUWATOSA, WI 53222
421 S BUSINESS PARK DR, OOSTBURG, WI 53070
4460 N 124TH ST, MILWAUKEE, WI 53225
5521 RAILROAD AVE, HERMANSVILLE, MI 49847
1709 PEARL ST, WAUKESHA, WI 53186
6951 INDUSTRIAL LOOP, GREENDALE, WI 53129

ALL PRICES HAVE BEEN QUOTED IN US DOLLARS. ALL PRICES WILL REMAIN FIRM FOR 14 DAYS.
THEREAFTER, A RE-QUOTE MAY BE REQUIRED
The Contract Price and Contract Time have been calculated based on the prices and availability of the
component materials as indicated by Anguil’s suppliers as of the date of this Agreement. However, the
market for the materials necessary to complete the Work are considered to be highly volatile, and sudden
price increases and changes in material availability are likely to occur. Anguil agrees to use commercially
reasonable efforts to obtain the prices quoted herein within the time frames indicated in the project
schedule, but should there be an increase in the prices of these materials after execution of this Agreement,
or should any materials subsequently become unavailable or the delivery of such materials be delayed, the
parties shall enter into a Change Order to increase the Contract Price and extend the Contract Time
accordingly. For the avoidance of doubt, Anguil shall not be liable for cost increases or delay costs
(including, without limitation, any liquidated or consequential damages associated with delay) which result
from changes in the cost or availability of materials.

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
25

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

OPERATING COST SUMMARY

The operating costs are based on the following standards outlined by the Institute of Clean Air Companies
(ICAC) Guidance Method for Estimation of Gas Consumption in a Regenerative Thermal Oxidizer (see the
attachment):

Process Flow 360,000 SCFM
Assumed Inlet Temperature 70 °F
VOC Loading 12.5 lbs/hr
Assumed Electricity Price $0.05 per Kwh
Assumed Natural Gas Price $5.00 per MMBTU
Btu/lb Value 15,000 Btu/lb
PROCESS SUMMARY
VOCS
Typical painting VOCs

Process
Flow
(SCFM)
VOC
Load
(lb/hr)
Electrical
Usage
(kW)
Electrical
Cost*
($/hr)
Gas
Usage
(BTU/hr)
Gas
Cost*
($/hr)
Total
Cost*
($/hr)
360,000 12.50 603.29 $60.33 9,779,990 $48.90 $109.23

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
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ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

FIELD SERVICE RATES
Field Service Engineer and Installation Supervision *Weekdays, 8 hours/day; minimum of 4 hours
Straight Time* $1,700/day
International Labor Rate * $1,825/day
Emergency Service Rate* (site visit within 48 hours of call) $2,200/day
Overtime (more than 8 hours/day and Saturdays) $ 269/hour
Sundays and Holidays $ 297/hour
Travel Time $ 140/hour
Travel Time Saturday $ 175/hour
Travel Time Sunday and Holidays $ 200/hour
Trip Preparation $ 200/visit
Report Writing $ 140/visit
Technical Phone Support (minimum of 4 hours) $ 140/hour
Remote Safety Training (online or classroom) $ 120/hour
Drug Screening $ 150/visit

Engineering *Weekdays, 8 hours/day; minimum of 4 hours
Project Engineer* $1,900/day
Project Manager* $1,900/day
Electrical Engineer / Programming* $1,900/day

Travel and Living Expenses
Airline ticket, Hotel, Car rental, Car service and Expenses Cost + 15% Administrative fee
Meal allowance - Domestic $ 70/day
Meal allowance - International $ 90/day
Airport parking $ 35/day
Mileage $ 0.67/mile

Terms
Net 30 days (subject to change upon credit review)

Holiday Schedule
Memorial Day
Independence Day
Labor Day
Thanksgiving (Thursday and Friday)
Christmas Eve & Christmas Day
New Year’s Eve & New Year’s Day

• When an Anguil Employee is scheduled to work on-site but not granted access, due to no fault of Anguil,
the customer will be billed at the daily rate for 8 hours in addition to expenses.
• Pre-negotiated days off will not be billed for service labor unless reports/training are being compiled.
• If receipts or time sheets are required, a 10% handling charge will be applied to the total invoice for
report generation.
Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
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ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

STANDARD TERMS AND CONDITIONS

1. General
Anguil Environmental Systems, Inc.’s (Anguil) prices are based on these terms and conditions, which are incorporated
by reference into the Proposal for Customer (“Agreement”). These terms and conditions may not be modified unless
prior written agreement is reached between both Customer and Anguil and signed by an authorized representative of
both Parties.

2. Goods Warranty
Anguil warrants that the Goods provided shall: (1) comply with the agreed-upon requirements and specifications set
forth in the Agreement; and (2) be free from defects in material and workmanship.

3. Services Warranty
Anguil warrants that the Services shall be performed in a professional and workmanlike manner.
4. Performance Guarantee
Anguil guarantees the conversion efficiency as set forth in the Quotation or an outlet concentration of 20 ppmv as C1
(methane), whichever is less stringent, subject to the following conditions: (a) The test methods to be used to show
compliance shall be US EPA Method 25A or other agreed upon testing methods; (b) seven (7) days advanced notice
of the official testing to meet DRE guarantee shall be provided to Anguil; (c) Anguil reserves the right to review the test
protocol prior to official testing and to have personnel present at the official compliance testing; (d) Goods shall be
operated in accordance with Anguil’s written operating and maintenance instructions; (e) Anguil shall rely exclusively
on the process and chemical information and materials provided by Buyer or its agents to Anguil and shall not be liable
for undisclosed or unknown process or chemical information and materials.
5. Conditions to Validity of Warranties
The following constitute mandatory conditions to the validity of the Goods, Services and Performance Warranties: (a)
Buyer shall purchase and Anguil shall provide Start-up assistance services; (b) Buyer, its subcontractors, and the
project owner shall comply with any and all written operating and maintenance specifications and requirements for the
Goods supplied by Anguil to Buyer including, but not limited to, the specifications and requirements of manufacturers
or third-party vendors; and (c) Buyer, its subcontractors, or any other person responsible for performing recommended
routine maintenance of the Goods (including, but not limited to, regularly maintaining and replacing fan belts, fuses,
light bulbs, spark igniters, bearing, seals, and gaskets and lubricating and cleaning the Goods) shall do so in compliance
with Anguil’s instructions at Buyer’s cost. Failure to satisfy these conditions shall void the Goods, Services and/or
Performance Warranty.

6. Warranty Claim and other Claim Exclusions
Anguil shall have no obligation or liability with respect to any warranty claim or any other type of claim that is based
upon or arises out of any of the following: (a) Heat damage to the Goods due to improper use or due to a fire caused
by excessive buildup of organic matter in the process ductwork; (b) any problem or deficiency due to Buyer’s or its
subcontractors’ operation of the Goods including, but not limited to, abrasion or corrosion of the Goods; (c) process or
chemical materials that Buyer or its agents fail to disclose in writing to Anguil and that are not memorialized in the
Process Specifications section in Anguil’s proposal or quotation; (d) modification or alteration of the Services or the
Goods by any person other than Anguil or its representatives, unless provided for in the Agreement; or (e) Anguil’s
compliance with Buyer’s designs, specifications, or instructions.

7. Liability for Installation or Erection by Buyer or Third-Party
Buyer has the right to install or erect the Goods itself or to contract with a third-party to install or erect the Goods. Buyer
has the option to hire Anguil to supervise the Buyer’s or the third-party’s installation and erection of the Goods. In the
event that the Buyer does not exercise its option to hire Anguil to supervise the installation and erection of the Goods,
the Buyer shall be completely and fully responsible for the performance of any such services by Buyer or any third-
party, and Anguil shall have no responsibility or liability whatsoever to Buyer or to any person for any damage, claim,
loss, claim, or expense (“Loss”), arising from the provision of such services including, but not limited to, any impairment
of the performance of the Goods. Buyer shall defend and indemnify Anguil against any Loss arising out of installation
Environmental Solutions for Cleaner Air and Water
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Proposal For: Oshkosh Aerotech AES-12174
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ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

or erection of the Goods by Buyer or Third-party. In addition, if such installation or erection results in any impairment of
the performance of the Goods, the Goods and Services Warranties shall be rendered null and void.

8. Warranty Period
The Goods and Service Warranties shall run for a period of fifteen (15) months from the date of shipment of the essential
components of the Goods. The transfer of Goods title to Buyer will occur upon shipment of Goods to Buyer or to the
project owner’s site.

9. Disclaimer of Other Warranties
OTHER THAN THE GOODS, SERVICES, AND PERFORMANCE WARRANTIES EXPRESSLY STATED HEREIN,
ANGUIL PROVIDES NO OTHER EXPRESS OR IMPLIED WARRANTIES OR CONDITIONS AND EXPRESSLY
DISCLAIMS ANY IMPLED REPRESENTATIONS, WARRANTIES, OR CONDITIONS, INCLUDING, BUT NOT
LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE,
OR THOSE ARISING BY STATUTE OR OTHERWISE IN LAW. IF ANGUIL PROVIDES ANY GOODS COVERED BY
A THIRD-PARTY WARRANTY, ANGUIL EXPRESSLY DISCLAIMS ALL EXPRESS OR IMPLIED WARRANTIES
RELATED TO THIRD-PARTY VENDOR PRODUCTS. ANGUIL AGREES TO PASS THROUGH ANY THIRD-PARTY
WARRANTY THAT ANGUIL RECEIVES FROM THE THIRD- PARTY TO BUYER, WHICH IS BUYER’S EXCLUSIVE
WARRANTY REMEDY WITH RESPECT TO THIRD-PARTY MATERIALS. These disclaimers apply unless not
permitted by applicable law. Any warranties, guarantees or conditions that cannot be disclaimed as a matter of law run
for a period of twelve (12) months from the start of the Goods, Services or Performance Warranties.

10. Inspection and Written Notice of Deficiency
Upon delivery of the Goods or provision of the Services, Buyer shall inspect the Goods or Services. To receive warranty
remedies in the event of a deficiency, if any, Buyer must provide written notice and a report detailing any alleged
deficiency to Anguil within thirty (30) days of inspection. Failure to provide such written notice constitutes an irrevocable
acceptance of the Goods, and the Goods shall be deemed to comply with the specifications and requirements of the
Agreement, except if a deficiency is not capable of being reasonably discovered by Buyer at the time of the inspection
in which case the written notice and report shall be provided within thirty (30) days of discovery. Anguil shall have the
right to inspect the Goods at a reasonable, mutually agreed upon date and time to assess any warranty claim or other
concern of Buyer concerning the Goods or Services.

11. Exclusive Remedies
If the Goods or Services do not comply with the Goods, Services, or Performance Warranty during the Warranty Period,
and Buyer provides Anguil with written notice and a report of deficiency as set forth herein, then Buyer’s exclusive
remedy and Anguil’s entire liability shall be, at Anguil’s sole discretion: (1) Return of any payments made by Buyer to
Anguil for the specific Goods or Services; or (2) repair or replace the Goods or re-perform the Services, using
commercially reasonable efforts to correct any deficiency. If Anguil is unable to correct the deficiencies, Anguil shall
return the payments made by the Buyer to Anguil for the deficient portion of the Goods or Services. These are the
Buyer’s only remedies other than any remedy required to be provided under applicable law.

12. Prices / Taxes / Terms
All prices are quoted in the Agreement are in US dollars and Customer shall make all payments in US dollars. Payment
is payable unconditionally without abatement, set-off, diminution or other deduction. Anguil reserves the right to adjust
the price in the event of increases in the market price of metals, Customer requested order modifications, changes to
specifications, delays outside of Anguil’s control or other similar causes upon notice to Customer. Further, interest shall
begin to accrue on the invoice due date at the lesser rate of 1.5% per month or the higher rate permissible under
applicable law, calculated daily and compounded monthly. Customer shall reimburse Anguil for all costs incurred in
collecting any late payments, including, without limitation attorney’s fees and/or collection agency fees. Anguil shall be
entitled to suspend the delivery of any Equipment, performance, or service if Customer fails to pay any amounts due
hereunder and such fail continues for ten (10) days following written notice thereof.
Customer at the written request by Anguil, shall furnish to Anguil reasonable evidence that the Customer has made
financial arrangements to fulfill the Customer’s obligations under the Agreement. Anguil shall have no obligation to
commence or continue its services until the Customer provides such evidence.

13. Cancellations
Orders canceled by Customer must be canceled in writing and will be subject to a cancellation fee on the following
basis: (1) On any orders canceled prior to the procurement of material and the commencement of fabrication, the
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Proposal For: Oshkosh Aerotech AES-12174
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ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

Customer will be subject to a cancellation fee of 15% of Agreement value to cover costs incurred for engineering
services plus overhead and reasonable expenses including rep commission made or incurred by Anguil in the initial
processing of the order; (2) on orders cancelled after the initiation of production, payment shall be made on the basis
of actual cost of labor, materials, components (cancellation fees if applicable) and work in progress plus overhead
expenses. Upon written receipt of cancellation, Anguil will stop all work as soon as reasonably practicable. In addition
to the cancellation fee, Customer shall be responsible for all restocking costs incurred by Anguil. Both the restocking
fee and cancellation fee shall be paid promptly to Anguil upon demand.

14. Engineering Submittals
Anguil will provide general arrangement and process and instrumentation drawings to the Customer for approval.
Customer will be asked to comment on the drawings in regard to scope of work, dimensions, site interferences or
specifications agreed upon at the time of sale. Approval by Customer shall be made promptly and shall not be
unreasonably withheld. Final approved drawings will be used to prepare the fabrication drawings and procurement for
manufacturing.
All additional engineering associated with revising the drawings or P&ID as a result of changes requested by Customer
after approval will be considered a change order and quoted to the Customer at Anguil’s prevailing per hour rates. If
any such changes cause an increase in the cost or time required for performance, a change order will be submitted for
Customer approval. Upon receipt of written approval, Anguil will proceed with agreed upon changes.

15. Shipping Schedules
In the event Buyer suspends Seller’s performance of work, Buyer shall reimburse Seller for all cost incurred by Seller
as a result of the suspension including remobilization costs and material price escalations. If a delay in shipping is
requested by Customer less than six (6) weeks prior to Equipment shipment, Anguil will complete the system and
invoice any “prior to shipment” payment milestone which will be due at the time of the original scheduled ship date. A
Customer requested suspension will cause the warranty period to start on the original schedule ship date. Upon
completion of the Equipment, Anguil will place the Equipment in storage and the Customer will pay the cost of
transportation, storage, special handling fees and insurance. Equipment held in storage for the Customer shall be at
the risk of the Customer. If the suspension exceeds 90 days in duration, Buyer shall be permitted to terminate this
Agreement.

16. Force Majeure
In the event any obligation to be performed by Anguil is prevented or delayed due to acts of God, shipping delays,
inability to obtain labor or materials, governmental restrictions, governmental regulations orders or directives, health
epidemics, pandemics or quarantines, governmental ordered closures, governmental controls, civil commotion or other
causes beyond the reasonable control of such Anguil (collectively referred to herein as “Force Majeure”), Anguil shall
be excused from performing the same for a period of time equal to any aforesaid delay.

17. Risk of Loss
The terms of shipment are Free Carrier Agreement (F.C.A.), place of shipment, per Incoterms 2010, unless otherwise
noted. Anguil has no responsibility for any damage that occurs during shipment arranged by Customer.

18. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL ANGUIL’S AGGREGATE
LIABILITY ARISING OUT OF OR RELATED TO THIS AGREEMENT AND/OR THE EQUIPMENT, WHETHER
ARISING OUT OF OR RELATED TO BREACH OF CONTRACT, TORT (INCLUDING NEGLIGENCE) OR
OTHERWISE, EXCEED THE TOTAL OF THE AMOUNTS PAID TO ANGUIL FOR THE EQUIPMENT. CUSTOMER
FURTHER WAIVES ITS RIGHT TO CONSEQUENTIAL DAMAGES ARISING OUT OF OR RELATED TO THIS
AGREEMENT AND/OR THE EQUIPMENT.

19. Security Interest
Customer grants Anguil a security interest in the Equipment to secure payment of the balance due hereunder. Customer
authorizes Anguil to file this Agreement as a Financing Statement or similar document or to sign on behalf of Customer
and file any other Financing Statements or similar documents with respect to the Equipment in any place Anguil deems
necessary.

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
30

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

20. Disputes
Customer shall initiate all claims relating to this Agreement and/or the Equipment in writing to Anguil within seven (7)
days of the event giving rise to the claim, or such claim shall be deemed waived. The parties agree that all disputes
relating in whole or part to this Agreement and/or the Equipment, shall be subject to arbitration. If the Customer is
located in the United States, the arbitration shall be decided in accordance with the latest version of the AAA
Commercial Arbitration Rules and Mediation Procedures. If the Customer is located outside of the United States, the
arbitration shall be decided in accordance with the latest version of the AAA International Dispute Resolution
Procedures. Anguil shall be entitled to its actual costs, expenses, and fees (including attorneys’ fees) that it incurs to
enforce any aspect of the dispute resolution process. Further, Anguil shall be entitled to recover from Customer its
actual attorneys’ fees, expert fees, costs, and expenses that it expends during any dispute resolution proceedings. The
parties agree that the decision rendered may be enforced by any court of competent jurisdiction. To the extent
permissible by law, this Agreement shall be governed by the Laws of the State of Wisconsin. Additionally, to the extent
permissible by law, the parties agree that jurisdiction and venue for any arbitration arising out of this Agreement shall
be in Milwaukee, Wisconsin.

21. Permits; Licenses; Applicable Law
Any and all required licenses, certificates and operating permits for the Equipment will be the sole responsibility of the
Customer unless otherwise specified by Anguil.

Customer shall at operate and maintain the Equipment in accordance with all applicable Federal, state, local use
restrictions and requirements, including, without limitation, the continuing responsibility to ensure that the use of product
is in full compliance with all applicable environmental laws and regulations.

22. Reliance on Customer Information
Customer shall furnish to Anguil all information necessary to perform the services identified in the Agreement. Anguil
shall be entitled to rely on all information furnished to it by Customer, including process and chemical information
provided by Customer or its agents. Anguil shall not be liable for undisclosed or unknown process or chemical materials
(Please refer to Customer Process Specifications section in the Agreement for additional information).

23. Termination
If the Customer fails to make payment when due or breaches any other obligation of this Agreement, Anguil may, at its
option, terminate the Agreement and recover from the Customer payment for Equipment and services furnished and
for its damages, including attorneys’ fees.

24. Indemnification
To the fullest extent permitted by law, Customer agrees to indemnify, defend and hold Anguil and its successors,
assigns, employees, affiliates, shareholders, officers, partners and members (“Indemnitees”) harmless from and
against any and all liability, claims, losses, penalties, costs, expenses, damages and causes of action suffered or
incurred by any of them, including their attorneys’ fees and litigation expense, arising out of or resulting from the
Customer’s breach of this Agreement or possession, operation, maintenance and/or use of the Equipment, except to
the extent caused by the sole negligence of the Indemnitees.

25. No Solicitation
For a period of eighteen months from the date of this Agreement, Customer agrees that it will not: a.) directly or indirectly
solicit or attempt to solicit or hire or engage for employment, partnership, advisory, or consulting capacity, any person
who is, at the time of such solicitation, employed by Anguil; nor b.) directly or indirectly induce any such person to sever
their relationship with Anguil, including giving their names to recruiters or competitors.

26. Commodity Disruption
The Contract Price and Contract Time have been calculated based on the prices and availability of the component
materials as indicated by Anguil’s suppliers as of the date of this Agreement. However, the market for the materials
necessary to complete the Work are considered to be highly volatile, and sudden price increases and changes in
material availability are likely to occur. Anguil agrees to use commercially reasonable efforts to obtain the prices quoted
herein within the time frames indicated in the project schedule, but should there be an increase in the prices of these
materials after execution of this Agreement, or should any materials subsequently become unavailable or the delivery
of such materials be delayed, the parties shall enter into a Change Order to increase the Contract Price and extend the
Contract Time accordingly. For the avoidance of doubt, Anguil shall not be liable for cost increases or delay costs
Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
31

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

(including, without limitation, any liquidated or consequential damages associated with delay) which result from
changes in the cost or availability of materials.

27. Miscellaneous
• The terms and conditions contained herein, and any other terms and conditions stated in the Agreement constitute
the entire agreement between Customer and Anguil with respect to the subject matter referenced herein. The terms
and conditions stated herein are applicable to all orders accepted by Anguil unless otherwise specifically agreed to
by Anguil in writing. Any additional or different terms proposed by Customer shall be of no effect unless agreed upon
in writing, signed by Anguil and Customer.
• Any notice required by this Agreement shall be deemed given and effective if in writing and sent certified mail, with
return receipt requested (even if recipient refuses to sign for said delivery), addressed to the party to whom such
notice is intended to be given at the address on this Agreement. If Customer’s address changes it shall notify Anguil
in writing. Any new address is only effective after receipt of written notice.
• Anguil and Customer hereby binds themselves, their partners, successors, assigns, subsidiaries, parent companies,
affiliates, and legal representatives to all of their obligations under the Agreement. Customer shall not sublet, assign,
or transfer all or any part of its interest or transfer possession of the equipment covered by this agreement without
Anguil's prior express written permission.
• This Agreement may be executed in any number of counterparts, via facsimile or electronic transmission (as a PDF
attachment to electronic mail or otherwise), via electronic signature or otherwise, each of which shall be deemed an
original and all of which together shall constitute one and the same instrument and shall be binding upon all of the
parties.
• If any provision of this Agreement shall be invalid or unenforceable, in whole or in part, such provision shall be
deemed to be modified or restricted to the extent and in the manner necessary to render the same valid and
enforceable, or shall be deemed excised from this Agreement, as the case may require, and this Agreement shall be
construed and enforced to the maximum extent permitted by law as if such provision had been originally incorporated
herein as so modified or restricted, or as if such provision had not been originally incorporated herein, as the case
may be. No express or implied waiver by Anguil of any default shall constitute a waiver of any other default of
Customer, or a waiver of any of Anguil's rights.

28. Destination Control Statement
These commodities, technology or software will be exported from the United States in accordance with the Export
Administration Regulations. Diversion contrary to U.S. law is prohibited.

29. Confidentiality
“Confidential Information” shall mean all matters regarding any trade secret, patent application, drawing, design, client
list, customer business information, claim, price, technique, invention, idea, process, sample, compound, media,
formula or data, manufacturing techniques. know-how, work in process, future development, engineering,
manufacturing, marketing, servicing, or financing relating to the “Business Purpose” (defined as provision of the
Equipment as services required by this Agreement), whether in oral, written, graphic, or electronic form. Confidential
Information shall not be deemed to include information if: (i) the information has become generally known or available
to the public through no act or failure to act on the part of Customer; (ii) was known by Customer before receiving such
information from Anguil; (iii) has become known by or available to Customer from a source other than Anguil, without
any breach of any obligation of confidentiality owed to Anguil; (iv) has been independently developed by Customer
without use or reference to the Confidential Information by persons who had no access to the Confidential Information.
Customer agrees to hold the Confidential Information in strict confidence, and not disclose such Confidential Information
to any third party except as specifically authorized herein. Customer agrees to use all reasonable precautions,
consistent with Subcontractor’s treatment of its own Confidential Information of a similar nature, to prevent the
unauthorized disclosure of the Confidential Information. Customer shall not disclose any Confidential Information to
any third party without Anguil’s prior express, written consent. Customer may disclose the Confidential Information if
and to the extent that such disclosure is required by applicable law or court order, provided that Customer uses every
reasonable effort to limit the disclosure by means of a protective order or a request for confidential treatment and
provide Anguil a reasonable opportunity to review the disclosure before it is made and to interpose its own objection to
Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
32

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

the disclosure. Customer shall return all Confidential Information made available or supplied by Anguil to Customer,
and all copies and reproductions thereof, on request.

ORDER ACCEPTED BY:
ANGUIL: ANGUIL ENVIRONMENTAL SYSTEMS, INC. CUSTOMER:

BY: BY:

PRINT: PRINT:

TITLE: TITLE:

DATE: DATE:

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
33

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

INSTITUTE OF CLEAN AIR COMPANIES (ICAC) GUIDANCE METHOD
FOR ESTIMATION OF GAS CONSUMPTION IN AN REGENERATIVE
THERMAL OXIDIZER (RTO)

1. OBJECT AND SCOPE

Supplemental fuel consumption, typically natural gas, can be a significant consideration for the installation and
operation of a regenerative thermal oxidizer (RTO). Regenerative thermal oxidizers are used in a variety of
processes in the destruction of volatile organic compounds (VOC) and hazardous air pollutants (HAP). The
amount of fuel required will vary by application; however, within a single application an estimate of fuel
consumption should be consistent among RTO manufacturers and suppliers. As a result, the following
procedure developed by ICAC and its member companies describes an industry derived guidance method for
estimating gas consumption requirements of an RTO. Once fuel consumption has been estimated, fuel as part
of the operating cost can be calculated using current or projected fuel cost assumptions. Generally, this method
can also be used as a reference to confirm and compare manufacturers’ fuel consumption estimates. The
guidance method estimate will provide a reference for gas consumption estimates.

2. OVERVIEW OF GAS CONSUMPTION IN AN RTO

Fcc (Combustion Air) @ TA

F1 (Process Air + VOC) @T1 F0 (Process Air + Products of Combustion +
Combustion
Air) @ TO

Environmental Solutions for Cleaner Air and Water
8855 N 55th Street Milwaukee, WI 53223 USA 414.365.6400 414.365.6410 [e-mail]

Proposal For: Oshkosh Aerotech AES-12174
34

ANGUIL ENVIRONMENTAL SYSTEMS, INC. www.Anguil.com

3. GUIDANCE ESTIMATION METHOD

Energy consumed in the RTO can be determined by performing a heat balance as follows:

QT = QI + Qcc + QRL - QVOC
QI :Heat used to raise temperature of FI (BTU/hr)
Qcc :Heat used to raise temperature of FCC (BTU/hr)
QRL :Radiation Heat loss from RTO (BTU/hr)
QVOC :Heat Release from oxidation of VOCs (BTU/hr)

QI = FI X 1.10 x (TO – TI)

QCC = FCC X 1.10 X (TO – TA)

QVOC = VOC X HC X (% Dest / 100)

Where:

FI: Process air (SCFM)
FCC: Combustion air (SCFM)
TI: RTO inlet air temperature (oF)
TA: Ambient or Combustion air temperature (oF)
TO: Average RTO outlet temperature (oF)
1.10: 60 (min/hr) x 0.075 (lb/ft3, density of air at standard conditions) x 0.245 (Btu/deg F – lb, specific
heat of air), where 0.245 is the average heat capacity of air over the temperature range.
VOC: lbs/hr of VOC to the oxidizer
HC: Weighted Average for Heat of Combustion of VOCs
% Dest: Guaranteed VOC Destruction Rate

Since FI, FCC, TI, TO and TA can all be determined by data supplied with proposal, QI
and QCC can be determined.

To determine QRL the following guidelines can be used:

1. Determine surface area of the RTO shell
2. Multiply that area by heat loss factor (assume 200 Btu/ft2) to arrive at approximate QRL.

4. CALCULATION OF THERMAL EFFICIENCY (N)

N = ((FI + FCC) / FI ) X ((TC – TO) / (TC – TI))

Where:
N = Thermal Efficiency

TC = Temperature, Combustion Chamber

TO = Temperature, RTO Outlet (Average)

TI = Temperature, RTO Inlet

OshKosh Aerotech Ogden, Utah Facility
Cost Analysis to Install and Operate Regenerative Thermal Oxidizer
Incinerator Factor Basis for Cost
and Factor
Direct Costs:
Puchased Equipment:
Primary and Auxiliary Equipment (PE) 3,500,000$ Anguil estimate
Sales Tax 245,000$ 7%
Freight 175,000$ 5% of PE OAQPS Manual, Chapter 2 Table 2.10
Total Purchased Equipment Cost (PEC) 3,920,000$
Direct Installation
Electrical, Piping, Insulation and Ductwork 450,000$ Anguil estimate
Total Direct Installation (DI) 450,000$
Total Direct Cost (DC) 4,370,000$
Indirect Installation Costs
Engineering 437,000$ 10%OAQPS Manual, Chapter 2 Table 2.10
Construction and Field Expenses 218,500$ 5%OAQPS Manual, Chapter 2 Table 2.10
Contractor Fees 437,000$ 10%OAQPS Manual, Chapter 2 Table 2.10
Start-up 87,400$ 2%OAQPS Manual, Chapter 2 Table 2.10
Performance test 43,700$ 1%OAQPS Manual, Chapter 2 Table 2.10
Contingencies 437,000$ 10%OAQPS
Total Indirect Cost 1,660,600$
Total Installed Cost (TIC) 6,030,600$
VOC Emissions Before Control, tn/yr 55.00 Used by Anguil in quote
Control Efficiency (%) 98 Anguil estimate
VOC Emissions After Control, tn/yr 1.100
VOC Emission Reduction, tn/yr 53.90
Annual Costs, $/year (Direct + Indirect)
Direct Costs
Operating Labor 301,530$ 5% of capitol cost OAQPS Manual, Chapter 2 Table 2.10
Gas and electric 956,855$ $109.23/hr - Anguil
Total Direct Costs, $/year 1,258,385$
Indirect Costs
Overhead 180,918$ 60% of labor costs OAQPS Manual, Chapter 2 Table 2.10
Taxes, Insurance, and Administration 241,224$ 4% of total installed cost OAQPS Manual, Chapter 2 Table 2.10
Capitol Recovery 858,757$ 7%, 10 years, CRF-.1424
Total Indirect Costs, $/year 1,280,899$
Total Annual Cost 2,539,284$
Cost Effectiveness, $ per ton VOC reduction 47,111.02$
Cost to Retrofit Emergency Small SI Engines with Oxidation Catalyst
OshKosh Aerotech
Uncontrolled Controlled Emission Reduction Cost Effectiveness
Rating OX Cat Retrofit OX Cat Retrofit VOC 2017 VOC 2017 VOC ($/ton)
Gasoline Equipment (HP) Capitol Cost Annual Cost TPY TPY TPY VOC
4 kW air compressor 5.4 59,408$ 19,855$ 0.0307 0.0092 0.021 2,784,319$
3 kW inverter generator 4.0 59,319$ 19,834$ 0.1100 0.0330 0.077 790,207$
Assumptions:
Source - Memorandom - Control Costs for Existing Stationary SI Rice, June 29, 2010
70% control efficiency with CO oxidation catalyst (EPA)
Cost to Retrofit Emergency Diesel Engines with Diesel Particulate Filters, SCR, and Oxidation Catalysts
OshKosh Aerotech
Rating Rating DPF Retrofit1 SCR Retrofit1 OC Retrofit1 DPF Retrofit SCR Retrofit OC Retrofit NOX PTE VOC PTE NOX PTE VOC PTE NOX PTE VOC PTE
Diesel Emergency Equipment (HP) (KW) ($/KW) ($/KW) ($/KW) Cost Cost Cost TPY TPY TPY TPY TPY TPY NOx VOC
35 kW emergency generator 35.0 26.1 59 438 148 1,533$ 11,419$ 3,850$ 0.14 0.01 0.00700 0.0004 0.133 0.007 85,854$ 578,899$
176 kW generator 176.0 131.2 59 438 148 7,711$ 57,419$ 19,358$ 0.11 0.05 0.00550 0.0025 0.105 0.048 549,463$ 407,545$
Assumptions:
1 Includes component and installation costs
Source - Discussion with Steve Loci on 1/27/2023, Wheeler Machinery, 801-974-0511; costs have increased by 25% since 2017.
Diesel Particulate Filters - $47KW (2017 cost estimate) includes installation and labor costs
SCR - $300 KW plus $50 KW (2017 cost estimate) for installation and labor costs
Oxidation Catalysts - $118 KW (2017 cost estimate) which includes installation and labor costs
Urea - $1.25 KW (current cost estimate)
DPF - 85% reduction, 95% VOC reduction
SCR - 95% NOx reduction
Assumed maintenance and labor costs to be unchanged
Uncontrolled Controlled Controlled
OshKosh Aerotech
176 KW MQ Power Super-Silent WisperWatt Generator
EPA Reference:AP-42 Section 3.3 Gasoline And Diesel Industrial Engines
Pollutant Emissions Emissions Emissions
(lb/MMBtu) (g/KW-hr) (HP) (MMBtu/hr) (lb/hr)(lb/yr) (tns/yr)
PM10 NA 0.02 236 0.60 0.01 11.15 0.0056
PM2.5 NA 0.02 236 0.60 0.01 11.15 0.0056
SO2 0.290 NA 236 0.60 0.17 251.03 0.1255
NOx NA 0.40 236 0.60 0.15 223.03 0.11
CO NA 3.50 236 0.60 1.36 1951.49 0.98
NMHC NA 0.19 236 0.60 0.07 105.94 0.05
CO2 163.05 NA 236 0.60 98.01 141140.71 70.57
N2O 0.0013 NA 236 0.60 7.95E-04 1.15E+00 5.73E-04
CH4 0.0066 NA 236 0.60 3.98E-03 5.73E+00 2.86E-03
CO2e 70.81
Benzene 9.33E-04 NA 236 0.60 5.61E-04 8.08E-01 4.04E-04
Toluene 4.09E-04 NA 236 0.60 2.46E-04 3.54E-01 1.77E-04
Xylenes 2.85E-04 NA 236 0.60 1.71E-04 2.47E-01 1.23E-04
1,3 - Butadiene 3.91E-05 NA 236 0.60 2.35E-05 3.38E-02 1.69E-05
Formaldehyde 1.18E-03 NA 236 0.60 7.09E-04 1.02E+00 5.11E-04
Acetaldehyde 7.67E-04 NA 236 0.60 4.61E-04 6.64E-01 3.32E-04
Acrolein 9.25E-05 NA 236 0.60 5.56E-05 8.01E-02 4.00E-05
Naphthalene 8.48E-05 NA 236 0.60 5.10E-05 7.34E-02 3.67E-05
Total HAP 3.28E+00 1.64E-03
Assumptions:
1 HP = 2547.13 Btu/hr
176 KW or 236 HP
GHG emission factors from 40 CFR Part 98 Tables C-1 & C-2
Tier 4 emission factors for NOx, CO, PM, and HC
Diesel-fired unit
1440 operating hours per year
1440
Emission Factors Rating Operating Hours
(hr/yr)
1440
1440
1440
1440
1440
1440
1440
1440
1440
1440
1440
1440
1440
1440
1440
1440
OshKosh Aerotech
35 KW Cummings C35 D6 Diesel Emergency Generator
EPA Reference:AP-42 Section 3.3 Gasoline And Diesel Industrial Engines
40 CFR Part 98, Tables C-1 & C-2
Tier 3 Manufacturer Specifications
Pollutant Emissions Emissions Emissions
(lb/MMBtu) (g/HP-hr) (HP) (MMBtu/hr) (lb/hr)(lb/yr) (tns/yr)
PM10 NA 0.14 46.9 0.119 0.014 1.44 0.0007
PM2.5 NA 0.14 46.9 0.119 0.014 1.44 0.0007
SO2 0.290 0.18 46.9 0.119 0.035 3.46 0.0017
NOx NA 2.78 46.9 0.119 0.287 28.68 0.014
HC NA 1.35 46.9 0.119 0.139 13.93 0.007
CO NA 1.42 46.9 0.119 0.147 14.65 0.007
CO2 163.05 NA 46.9 0.119 19.48 1947.83 0.974
N2O 0.0013 NA 46.9 0.119 1.58E-04 0.02 7.90E-06
CH4 0.0066 NA 46.9 0.119 7.90E-04 0.08 3.95E-05
CO2e 0.977
Benzene 9.33E-04 NA 46.9 0.119 1.11E-04 0.011 5.57E-06
Toluene 4.09E-04 NA 46.9 0.119 4.89E-05 0.005 2.44E-06
Xylenes 2.85E-04 NA 46.9 0.119 3.40E-05 0.003 1.70E-06
1,3 - Butadiene 3.91E-05 NA 46.9 0.119 4.67E-06 0.000 2.34E-07
Formaldehyde 1.18E-03 NA 46.9 0.119 1.41E-04 0.014 7.05E-06
Acetaldehyde 7.67E-04 NA 46.9 0.119 9.16E-05 0.009 4.58E-06
Acrolein 9.25E-05 NA 46.9 0.119 1.11E-05 0.001 5.53E-07
Naphthalene 8.48E-05 NA 46.9 0.119 1.01E-05 0.001 5.07E-07
0.045 0.000023
Assumptions:
1 HP = 2547.13 Btu/hr
1440 operating hours per year
Diesel-fired unit
Emissions based on 1/2 standby
100 operating hours per year
100
Emission Factors Rating Operating Hours
(hr/yr)
100
100
100
100
100
100
Greenhouse Gases
100
100
100
Hazardous Air Pollutants
100
Total HAP
100
100
100
100
100
100