Hi Anita,

As I mentioned in my previous note, we have been discussing options for obtaining additional certainty

regarding the potential performance of SNCR at NGS. After a great deal of consideration, we have decided to 

proceed with a demonstration test for SNCR at NGS, despite that the cost of urea has increased substantially 

over the last several months. 

The previous work that was done by Fuel Tech that formed the basis for the NOx emission rate range in the 

January 2012 BART report (0.15-0.18 lb/MMBtu) was primarily theoretical. We expect that the demonstration 

test will provide greater certainty regarding the potential performance of SNCR at NGS.

We expect to be able to provide the results of the test to EPA sometime in the next several weeks. In the 

meantime, if you have any questions or would like to discuss further, please let me know.

Thanks,

Grant

From: Anita Lee [mailto:Lee.Anita@epamail.epa.gov] 

Sent: Wednesday, April 18, 2012 1:02 PM 

To: Smedley Grant M 

Cc: Colleen McKaughan 

Subject: Re: Voicemail

RE: Voicemail 

Smedley Grant M 

to: 

Anita Lee 

04/25/2012 03:37 PM 

Cc: 

Colleen McKaughan, Barr Kelly J 

Hide Details 

From: Smedley Grant M <Grant.Smedley@srpnet.com> 

To: Anita Lee/R9/USEPA/US@EPA 

Cc: Colleen McKaughan/R9/USEPA/US@EPA, Barr Kelly J <Kelly.Barr@srpnet.com>

History: This message has been forwarded. 

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Hi Grant,

Thank you for your email response to our SNCR question. We understand from your email that you cannot 

provide specific information on the emission rate you expect would be achievable with SNCR. 

The most recent information we have is that SRP used a range of 0.15-0.18 lb/MMBtu for cost effectiveness 

calculations and modeling based on "information that FTI has provided to date". For our record, can your provide 

the FTI information they provided SRP "to date" (as of January 2012) to support the 0.15-0.18 lb/MMBtu range?

Thanks again, and please feel free to call if you have any questions or concerns! 

anita 

- - - - - - - - - 

Anita Lee, PhD 

Environmental Scientist 

US EPA, Region 9, Air Planning Office 

75 Hawthorne Street (AIR-2) 

San Francisco, CA 94105 

ph: (415) 972-3958 

fax: (415) 947-3579 

 

From: Smedley Grant M <Grant.Smedley@srpnet.com> 

To: Anita Lee/R9/USEPA/US@EPA 

Date: 04/13/2012 07:12 AM 

Subject: Voicemail 

Hi Anita, 

 

I wanted to follow up with you on your voicemail message. You referenced the nitrogen oxide (NOx) emission rate range of 

0.15-0.18 lb/MMBtu that we specified for Selective Non-Catalytic Reduction (SNCR) in our January 2012 Best Available 

Retrofit Technology (BART) report for Navajo Generating Station, and asked whether we could be more specific about the 

emission rate that might be achievable. You specifically asked whether the Computational Fluid Dynamics (CFD) modeling 

that Fuel Tech conducted would allow us to more accurately define the NOx emission rate that might be achievable in 

practice. 

 

The CFD modeling provides some preliminary information that would be utilized in designing an SNCR installation (e.g., 

where to position injectors) and some indication of potential performance. Unfortunately, the CFD modeling does not in 

any way guarantee that an emission rate in that range would be achievable in practice. 

 

We are discussing options for obtaining additional certainty regarding the potential performance of SNCR, but at this point, 

we cannot provide more specific information on the emission rate that would be achievable in practice. 

 

If you have any questions or would like to discuss further, please let me know. 

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Thanks,

Grant 

 

--------------------------------------------------------- 

Grant Smedley 

Manager, Environmental Policy & Innovation 

Salt River Project 

Tel: (602) 236-2928 

Fax: (602) 236-6690 

grant.smedley@srpnet.com 

--------------------------------------------------------- 

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