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 removal for the first 16,000 hours while maintaining an SO2 

conversion of <0.4%, so approx. 0.2% per layer. Typically the SO2 conversion will not change much during the 16,000 hours. 

2. After the first 16,000 hours an additional layer would be added. Once you add the additional layer you have added 50% more catalyst. Therefore, typically you would 

get an additional 4+ years before needing to replace 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 management plan or CMP would be implemented to keep track of these required change outs. 

3. Once the third layer is added, the SO2 conversion would add by 0.2% (or whatever the SO2 conversion of the third layer is) because that figure is cumulative. 

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

4. For a 3+1 configuration, a 4th 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 questions.

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 confidential and proprietary to Hitachi Power Systems America, Ltd. and may not be 

reproduced, published, or disclosed to others without 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 work with the SO2 conversion and performance hour guarantee - so, with a 

2+1 reactor, the first 16,000 hours is based on operation with the first 2 layers, with <0.4% (0.33%, or 0.167% per layer?) SO2 conversion, and then after 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 16,000 hours, then is the additional layer deployed, and how long does the additional layer last? Is each layer roughly 0.167% 

conversion? 

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

thanks so much! I really appreciate all of the help 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.hitachi.com>

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

History: This message has been replied to and forwarded. 

Archive: This message is being viewed in an archive. 

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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 confirmed 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/MMBtu of outlet NOx, we could do this with a 3+1 design and a 0.5% SO2 conversion rate for 16,000 hour performance 

guarantee. These numbers again, are based on the information 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 questions 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 confidential and proprietary to Hitachi Power Systems America, Ltd. and may not be 

reproduced, published, or disclosed to others without 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 Lundy Report generated for the facility in 2010. These values apply to 

the 3 equivalent units at the facility. The S&L report 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 permit limit of 0.05 lb/MMBtu - would Hitachi typically design down to 0.03 lb/MMBtu to meet a 0.05 limit? 

Thank you!

anita 

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

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 figures, but they’ve requested that I request some additional information. Is there any way we can get the operating conditions 

(i.e. Temperature, SO2 concentration, O2, H2O, poisons, etc.) and the performance guarantee requirement period (i.e. how many hours?)? Please let me know and we will 

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

Regards,

Stephen Guglielmo

SCR Product Manager

Hitachi Power Systems America

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

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

Date: 03/02/2011 01:29 PM 

Subject: 

RE: CX catalyst question

Page 3 of 6

file://C:\Documents and Settings\ALEE07\Local Settings\Temp\notesBAAA25\~web370... 12/28/2011
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 confidential and proprietary to Hitachi Power Systems America, Ltd. and may not be 

reproduced, published, or disclosed to others without 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 counterparts in Japan to get an answer. We should have 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 confidential and proprietary to Hitachi Power Systems America, Ltd. and may not be 

reproduced, published, or disclosed to others without written company authorization. 

 

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

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

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

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

Date: 02/23/2011 08:45 AM 

Subject: 

RE: CX catalyst question

Page 4 of 6

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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 alternative contact. Hopefully he might be able to help with my question?

Hope you are doing well Rick, and hope you are enjoying 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 currently 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 proprietary to Hitachi Power Systems America, Ltd. and may not be reproduced, published, or disclosed to others 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 (located in the Navajo 

Nation and one of the largest NOx emitters in the country) - this is the facility I have been focused on in all my questions to you (and I really appreciate 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" <Anthony.Favale@hal.hitachi.com> 

Date: 02/23/2011 08:31 AM 

Subject: 

RE: CX catalyst question

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

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

This is a facility with three 750 MW PC units, firing western low S bituminous coal, in dry bottom, tangential fired, boilers with LNB + SOFA (emission limit 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 layers of catalyst differ 

from a limit of 0.05 lb/MMBtu?

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

needed to meet 0.08), or would it require more frequent catalyst change out? I am wondering whether there are NOx/sulfuric acid tradeoffs between 0.05 and 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% with 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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