### 1 Attachment

Anita,

I can respond to your questions as follows:



### 1. The first two layers would be installed at startup of the SCR. They would achieve the required NOx re moval for the first 16,000 hours while maintaining an SO2

conversion of <0.4%, so approx. 0.2% per layer. Ty pically the SO2 conversion will not change much dur ing the 16,000 hours.



### 2. After the first 16,000 hours an additional layer wo uld be added. Once you add the additional layer yo u have added 50% more catalyst. Therefore, typical ly you would

get an additional 4+ years before needing to replac e one of the original layers of catalyst. Then you would start replacing layers on 2-4 year intervals . These of course

tie into the plant’s outage schedule. A catalyst m anagement plan or CMP would be implemented to keep track of these required change outs.



### 3. Once the third layer is added, the SO2 conversion w ould add by 0.2% (or whatever the SO2 conversion of the third layer is) because that figure is cumulat ive.

Therefore the overall SO2 conversion of the reactor would go from 0.4% to 0.6%.



### 4. For a 3+1 configuration, a 4 th layer would be added at 16,000 our 24,000 hours. The time intervals are slightly different, but the concepts of activity and SO2 conversion

would be the same.

Please let me know if you have any additional quest ions.

Regards,

Stephen Guglielmo

SCR Product Manager

Hitachi Power Systems America

645 Martinsville Rd.

Basking Ridge, NJ 07920

O: 908-605-2823

C: 610-417-2724

F: 908-604-6211

http://www.hitachipowersystems.us

CONFIDENTIALITY : The information contained in this document and the contents of this material are con fidential and proprietary to Hitachi Power Systems America, Ltd. and may not be

reproduced, published, or disclosed to others witho ut written company authorization.

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

Sent: Monday, March 07, 2011 11:06 AM

To: Stephen Guglielmo

Subject: RE: CX catalyst question

Thank you so much Stephen.

One additional question I have is rather basic - I' m not sure I understand how the different layers wo rk with the SO2 conversion and performance hour gua rantee - so, with a

2+1 reactor, the first 16,000 hours is based on ope ration with the first 2 layers, with <0.4% (0.33%, or 0.167% per layer?) SO2 conversion, and then afte r the first 16,000 hours,

is an additional layer deployed? How long does that additional layer last? an additional 8000 hours? Does the SO2 conversion then increase to 0.5% with the use of an

additional layer? Or is the 16,000 hours based on use of all layers of the 2+1 configuration?

For the 3+1 - similar questions, 3 layers for 16,00 0 hours, then is the additional layer deployed, and how long does the additional layer last? Is each l ayer roughly 0.167%

conversion?

Is the deployment of an additional layer normally r equire just a minor outage?

thanks so much! I really appreciate all of the hel p I have received from you and Tony,



### {In Archive} RE: CX catalyst question

Stephen Guglielmo

to:

Anita Lee

03/07/2011 08:39 AM

Hide Details

From: Stephen Guglielmo <stephen.guglielmo@hal.hita chi.com>

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

History: This message has been replied to and forwa rded.

Archive: This message is being viewed in an archive

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image001.gif 

# Page 1 of 6

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...anita

- - - - - - - - - Anita Lee, PhD

ph: (415) 972-3958

fax: (415) 947-3579

US EPA, Region 9

Air Permits Office

75 Hawthorne Street (AIR-3)

San Francisco, CA 94105

Anita,

Based on the information provided, we have confirme d that we would be able to meet the 0.08lb/MMBtu of outlet NOx with a 2+1 reactor. The SO2 conversion for this would

be less than 0.4%. If the requirement is 0.05lb/MM Btu of outlet NOx, we could do this with a 3+1 desi gn and a 0.5% SO2 conversion rate for 16,000 hour p erformance

guarantee. These numbers again, are based on the i nformation provided and some assumptions.

All of our designs are based on the required NOx at the end of the guarantee period, so I do not think that in order to meet the 0.05lb/MMBtu requirement we would be required

to design for a 0.03lb/MMBtu requirement.

Please let us know if you have any additional quest ions or require any additional information.

Regards,

Stephen Guglielmo

SCR Product Manager

Hitachi Power Systems America

645 Martinsville Rd.

Basking Ridge, NJ 07920

O: 908-605-2823

C: 610-417-2724

F: 908-604-6211

http://www.hitachipowersystems.us

CONFIDENTIALITY : The information contained in this document and the contents of this material are con fidential and proprietary to Hitachi Power Systems America, Ltd. and may not be

reproduced, published, or disclosed to others witho ut written company authorization.

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

Sent: Wednesday, March 02, 2011 5:38 PM

To: Stephen Guglielmo

Subject: RE: CX catalyst question

hi Stephen,

I am attaching some information about this facility , based on an SCR design basis from a Sargent and L undy Report generated for the facility in 2010. Th ese values apply to

the 3 equivalent units at the facility. The S&L re port stated they were designing the SCR system to 0 .05 lb/MMBtu NOx to meet an anticipated NOx permit limit of 0.07-0.08

lb/MMBtu (30 day rolling). I am interested in a pe rmit limit of 0.05 lb/MMBtu - would Hitachi typical ly design down to 0.03 lb/MMBtu to meet a 0.05 limi t?

Thank you!

anita From: Stephen Guglielmo <stephen.guglielmo@hal.hitachi.co m>

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

Date: 03/07/2011 06:59 AM

Subject: RE: CX catalyst question 

# Page 2 of 6

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...- - - - - - - - -

Anita Lee, PhD

ph: (415) 972-3958

fax: (415) 947-3579

US EPA, Region 9

Air Permits Office

75 Hawthorne Street (AIR-3)

San Francisco, CA 94105

Anita,

I’ve talked to our engineers. They have some figur es, but they’ve requested that I request some addit ional information. Is there any way we can get the operating conditions

(i.e. Temperature, SO2 concentration, O2, H2O, pois ons, etc.) and the performance guarantee requiremen t period (i.e. how many hours?)? Please let me kno w and we will

continue to work on this. This information would b e very helpful. Thank you.

Regards,

Stephen Guglielmo

SCR Product Manager

Hitachi Power Systems America From: Stephen Guglielmo <stephen.guglielmo@hal.hitachi.co m>

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

Date: 03/02/2011 01:29 PM

Subject: RE: CX catalyst question 

# Page 3 of 6

12/28/2011 file://C:\Documents and Settings\ALEE07\Local Setti ngs\Temp\notesBAAA25\~web370

...645 Martinsville Rd.

Basking Ridge, NJ 07920

O: 908-605-2823

C: 610-417-2724

F: 908-604-6211

http://www.hitachipowersystems.us

CONFIDENTIALITY : The information contained in this document and the contents of this material are con fidential and proprietary to Hitachi Power Systems America, Ltd. and may not be

reproduced, published, or disclosed to others witho ut written company authorization.

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

Sent: Monday, February 28, 2011 12:52 PM

To: Stephen Guglielmo

Subject: RE: CX catalyst question

hi Stephen,

Any word back yet on this?

Thank you very much!

anita

- - - - - - - - - Anita Lee, PhD

ph: (415) 972-3958

fax: (415) 947-3579

US EPA, Region 9

Air Permits Office

75 Hawthorne Street (AIR-3)

San Francisco, CA 94105

Anita,

We received your email and are working with our cou nterparts in Japan to get an answer. We should hav e something for you shortly.

Regards,

Stephen Guglielmo

SCR Product Manager

Hitachi Power Systems America

645 Martinsville Rd.

Basking Ridge, NJ 07920

O: 908-605-2823

C: 610-417-2724

F: 908-604-6211

http://www.hitachipowersystems.us

CONFIDENTIALITY : The information contained in this document and the contents of this material are con fidential and proprietary to Hitachi Power Systems America, Ltd. and may not be

reproduced, published, or disclosed to others witho ut written company authorization.

From: Lee.Anita@epamail.epa.gov [ mailto:Lee.Anita@epamail.epa.gov ] From: Stephen Guglielmo <stephen.guglielmo@hal.hitachi.co m>

To: Anita Lee/R9/USEPA/US@EPA, Rick Hellebuyck <Rick.He llebuyck@hal.hitachi.com>

Cc: "Anthony C. Favale" <Anthony.Favale@hal.hitachi.com >

Date: 02/23/2011 08:45 AM

Subject: RE: CX catalyst question 

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...Sent: Wednesday, February 23, 2011 11:37 AM

To: Rick Hellebuyck

Cc: Anthony C. Favale; Stephen Guglielmo

Subject: RE: CX catalyst question

Thanks for the update Rick!

I got Tony's out of office message, so I forwarded my email to Stephen, who is listed as an alternativ e contact. Hopefully he might be able to help with my question?

Hope you are doing well Rick, and hope you are enjo ying your vacation Tony!

thank you,

anita

- - - - - - - - - Anita Lee, PhD

ph: (415) 972-3958

fax: (415) 947-3579

US EPA, Region 9

Air Permits Office

75 Hawthorne Street (AIR-3)

San Francisco, CA 94105

Hello Anita,

I hope all is well with you! FYI, Tony is currentl y on vacation with his wife...not exactly sure where? ? I think he may be back in the saddle so to speak sometime next week.

Best,

Rick

Rick Hellebuyck

Western Regional Sales Manager

Hitachi Power Systems America, Ltd.

4951 S. Amaro Dr.

Evergreen, CO 80439

Office/Cell: 303-349-5343

FAX: 303-953-0742

rick.hellebuyck@hal.hitachi.com

www.hitachipowersystems.us

The information contained in this document and the contents of this material are confidential and prop rietary to Hitachi Power Systems America, Ltd. and may not be reproduced, published, or disclosed to o thers without written company authorization.

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

Sent: Tuesday, February 22, 2011 5:31 PM

To: Anthony C. Favale

Cc: Rick Hellebuyck

Subject: CX catalyst question

hi Tony,

In case you are interested, EPA recently put out a proposal to require SCR (80% control from SCR only, without LNB) at the Four Corners Power Plant (loca ted in the Navajo

Nation and one of the largest NOx emitters in the c ountry) - this is the facility I have been focused on in all my questions to you (and I really appreci ate all of your help).

Here is the link: From: Rick Hellebuyck <Rick.Hellebuyck@hal.hitachi.com>

To: Anita Lee/R9/USEPA/US@EPA, "Anthony C. Favale" <Ant hony.Favale@hal.hitachi.com>

Date: 02/23/2011 08:31 AM

Subject: RE: CX catalyst question 

# Page 5 of 6

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...http://www.epa.gov/region9/air/navajo/index.html#pr oposed

I actually also have another question for you, rela ted to another facility on the Navajo Nation.

This is a facility with three 750 MW PC units, firi ng western low S bituminous coal, in dry bottom, ta ngential fired, boilers with LNB + SOFA (emission l imit of 0.24 lb/MMBtu),

with hot side ESPs, and wet FGD. If we wanted this facility to meet a limit of 0.08 lb/MMBtu for NOx, how would the SO2 to SO3 conversion across all lay ers of catalyst differ

from a limit of 0.05 lb/MMBtu?

Would the SCR be designed with an additional cataly st layer to meet the more stringent 0.05 lb/MMBtu l imit (i.e., 3 layers + one spare versus 2 layers + one spare if they only

needed to meet 0.08), or would it require more freq uent catalyst change out? I am wondering whether t here are NOx/sulfuric acid tradeoffs between 0.05 a nd 0.08 lb

NOx/MMBtu?

So, I'm wondering if would SO2 to SO3 conversion be 0.5% with the NOx limit 0.05 lb/MMBtu (essentially 80% NOx removal efficiency), and maybe 0.3-0.4% wi th a NOx limit

of 0.08 lb/MMBtu (67% NOx removal efficiency)?

Thanks so much for your help!!

anita

- - - - - - - - - Anita Lee, PhD

ph: (415) 972-3958

fax: (415) 947-3579

US EPA, Region 9

Air Permits Office

75 Hawthorne Street (AIR-3)

San Francisco, CA 94105 

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