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Cemex Vernalis Quarry Mining and Reclamation Project • the Draft EIR's claim that additional retrofits would be cost prohibitive is unsupported by cost-benefit analysis. • the commenter also states that the use ofPuriNOx and the use ofselective catalytic reduction ("SCR') (urea injection)systems are feasible and have been successfully demonstrated on off-road equipment. The SJVAPCD measures listed by the commenter would be incorporated into the project to the maximum extent feasible per Regulation VIII,which is included in Mitigation Measure 4.6.1. See also Responses to Comments B-47 and B48 regarding additional retrofits. _ Response to Comment B-47 Commenter argues that PuriNOx is a viable control strategy to improve air quality in California for use in heavy-duty diesel engines including offroad engines. Use of PuriNOx is not a widely accepted control measure at this time. In addition to the additional _ fuel cost,use of PuriNOx reduces horsepower by 15"1 which could require larger equipment to accomplish certain operations. Finally,PuriNox may increase engine maintenance problems. Response to Comment B-48 Commenter argues that "selective catalytic reduction, using urea as a reducing agent, can reduce NOx emissions by 75 to 90 percent while simultaneously reducing VOC emissions by up to 80 percent and PM emissions by 20 to 30 percent." Selective catalytic reduction (SCR) is not considered feasible as it is not readily available in U.S. diesel engines.New diesel engine standards (2010)will require SCR. These future reductions have been taken into account in the future NOx emissions. Response to Comment B-49 Commenter argues that lean NOx catalyst("LNC') technology can achieve a 10 to 40 percent reduction in NOx emissions and has been demonstrated and commercialized for a variety of off- road retrofit applications, including heavy-duty earthmoving equipment. LNC is an experimental alternative to SCR,discussed above. LNC is not recommended because it is cost prohibitive and not readily available. CARB has not recommended LNC as a feasible — mitigation measure. Response to Comment B-50 — Commenter argues that exhaust gas recirculation ("EGR') reduces NOx by reducing the temperature at which fuel burns in the combustion chamber, and that "engine retrofits with low _ pressure EGR in conjunction with a DPF can achieve NOx reductions ofover 40 percent and PM reductions of more than 90 percent and have been successfully demonstrated on off-road equipment." Comex Vemlis(quarry Mining andl Reclamation Project 3-18 ESA 1303015 Final Environmental Impact Report June 2008