BHEL point wise replies to NTPC comments
Sl.
NTPC Comments
No.
Vendor Drawing No: Null
NTPC DRAWING NO: 9591-102-102-PVM-U-009
Revision: 02
Drawing Title: NOx Calculation
Comments on replies to NTPC comments – Pg 2 of 2
As per discussion in TCM, Indicate the
1. predicted NOx for each coal
Comments on Nox calculation - sheet 2 of 7
Please explain any impact on Water wall
2. tube like corrosion and erosion due to having
low Nox system in Telangana.
What if sulphur content increases significantly?
What is your observation with high FeS2 or
Alkali Metals?
Pl. indicate max values for FEs2 and Alkali
metal for which these will not any impact on
corrosion.
Comments on sheet 2 of 6 – Attachment -1
Signature Not
BHEL/GE has not replied what is the basis
3. for stoichiometry set point and flow through
H-SOFA, L-SOFA & CC-OFA? How it will
remain same independent of Unit load and
coal quality from the range of coal specified?
BHEL Reply
Provide the predicted NOx value for
each coal, different mill combination
Predicted NOx emissions
and variousfollow
loadcoal
asranking
per discussion in
classification.TCM
The design, best and worst domestic
coals are all closely grouped – and ranked as Sub-
bituminous coals. As a result – we anticipate the
NOx emissions will have a similar close grouping –
below the 300 mg/Nm3 emission limit.
No adverse impact on Water Wall erosion is
expected with the Telangana Low NOx Firing
System. As the pulverized coal trajectory remains
4° off the furnace diagonal.
As advised previously:
CFS Nozzles reduce WW corrosion tendencies by
providing an oxidizing layer along the waterwall.
This oxidizing environment near the waterwalls can
reduce the quantity of waterwall ash deposits, and
the deposit adherence tenacity. And in-turn also
reduce corrosion potential when firing coals with
higher corrosion potential. Especially coals with
high concentrations of Sulfur, Iron (FeS2 – pyrite)
and Alkali Metals, (K, Na).
However, we do not anticipate corrosion related
thinning of the waterwalls on Telangana, regardless
of the Main WB firing zone stoichiometry or CFS
vs No CFS operation - given almost no pyrite
(FeS2), or Alkali Metals (K or Na) inherent in the
indigenous India coals. Same expected with the
import / domestic blends.
Digitally signed
Verified
by deepak jindal
Operationally - furnace NOx emissions are
Date: 2018.05.07
controlled via the15:21:00 IST build-up, starting at
stoichiometry
the Main Burner Reason: CAT
Zone, with the progressive release
IVR
of combustion from the
Location:CC-OFA, L-SOFA and H-
SOFA compartments.NTPCEOC
These 3 levels of OFA are ramped with total unit
airflow. Thus result are load dependent.
Refer to drawing 9591-102-102-PVI-L-005– for
these Secondary Air Damper Control System
characteristic function curves. Controlling the MBZ
stoichiometry set-point demand, CC-OFA damper
pg. 1 of 3

Comments on sheet 3 of 6 – Attachment -1
How the stoichiometry set points are
4. measured and maintained?
Is it measured by some flowmeter/
device?Support your reply with empirical
calculation for better understanding for
explanation given.
5. Please check the no. of L-SOFA and H-
SOFA burner elevations, as it is three in the
windbox arrangement.
6. How these two Stochiometric Set point
characteristic ramps are adjusted?
Comments on Sheet 4 of 6 – Attachment -1
Aux air dampers are 85-90% open.
5. So, what 10-15% represents?
Comments on Sheet 6 of 6 – Attachment -1
6. What is meant by SOFA separation and how
it impacts NOx?
7. NOx variation in super critical boiler of
Barh-II due to change in BT is significant.
Than how it can be negligible for
Telangana? Pl enclose the predicted curve
for NOx Vs BT for Design, Best and Worst
coal as discussed in the TCM.
What is the basis that BT will be with in +20
to -20 deg.
8. Comment in previous revision, that whether
the relation between Fuel Nitrogen and
Furnace NOx is always linear is not replied?
What are the parameters which may effect
the slope of the curve or may result in its
shifting?
position with unit airflow, and L-SOFA / H-SOFA
damper positions with stoichiometry flow demand.
This set of function curves – are field tuned during
commissioning for unit operation, across the boiler
operating load range – and range of fuels fired.
The Main Burner Zone stoichiometry is resolved by
subtracting the measured L-SOFA and H-SOFA
airflows from the total unit airflow – derived from
the economizer exit 02. Likewise the stoichiometry
above the L-SOFA is resolved and controlled by
subtracting the H-SOFA measured airflow from the
total unit airflow.
Refer to drawing 9591-102-102-PVI-L-005 for this
closed loop control logic
No of elevations of L-SOFA and H-SOFA are
corrected in revised document.
Field tuning of these function ramps – both during
commissioning and later as necessary - is
accomplished via the engineering station.
Again – effective damper control of the WB/Furn
dp - was advised as those dampers controlling dp
are modulating between 10%-15% open, to 85%-
90% open.
When continually positioned outside this range –
we effectively are no longer controlling the
WB/furn dp to the set-point. How about control through
CFS air?
As advised previously - the staged residence time –
or residence time between the Main Burner Zone
and SOFA flow will influence the NOx emissions.
This staged residence time can be reduced – if for
example the Main WB nozzle tilts move from 0° to
+20°, and the SOFA tilts remain at 0°.
NOx variation due to tilt position is expected to be
similar to Bahr II.
As advised earlier – this line is a general trend
line – showing the order of magnitude -typical
relationship between fuel nitrogen and NOx
emissions.
YES - this order of magnitude curve “holds
true” - with the basic understanding that each
coal, design, best and worst coal may start with
a different base NOx emission.
Difficult to determine whether this same
relationship always “holds true“. As there are
pg. 2 of 3
many factors which can impact NOx emissions
– some to a greater extent. For example:
1) Fuel reactivity (Ratio of Fixed Carbon to
Volatile Matter)
2) Ratio of Primary Air Flow to Coal Flow
3) Ignition Point Location (relative to burner)

pg. 3 of 3
 NTPC DRG. No.: 9591-102-PVM-U-009

JOB NO : NTPC LIMITED

STATUS: CONTRACT TELANGANA SUPER THERMAL POWER PROJECT PHASE-I
DISTRIBUTION 2 x 800 MW
STEAM GENERATOR ISLAND PACKAGE
TO Dept Name Sign Date
Code
No. of BHARAT HEAVY ELECTRICALS LTD. DRN
REV. Date ALTD CHD APPD UNIT : HIGH PRESSURE BOILER PLANT DESN VRK/SKD -Sd- 04.04.17
01 12.05.17 VRK PVP BMM TIRUCHIRAPPALLI – 620 014 CHD PVP -Sd- 04.04.17
Revised based on discussion in APPD BMM/GV -Sd- 04.04.17
TCM dated 20-21st April 2017 at TITLE:
Trichy. NOx CALCULATION
DEPT. SCALE BHEL DRG. NO.
SIGN.
DATE. SHEET 1 OF 7 REV 01
CAUTION: THIS DRAWING IS THE PROPERTY OF BHARAT HEAVY ELECTRICALS LTD., AND IS NOT TO BE REPRODUCED OR USED TO FURNISH ANY INFORMATION FOR
MAKING OF DRAWINGS OR APPARATUS EXCEPT WHERE PROVIDE FOR AGREEMENT WITH SAID COMPANY.
 NOx Predictions

In a Modern Low NOx Tangential Firing System Design, the predicted Furnace NOx is influenced by
the properties of the fuel, the geometric design of the furnace and firing system, and the operation of
the boiler itself.

Furnace NOx refers to the NOx leaving the furnace/boiler (also the NOx entering the SCR) as
opposed to Stack NOx or Plant NOx which refers to the NOx leaving the stack and includes the effect
of the SCR. In order to make a Furnace NOx prediction and guarantee, several parameters must be
considered. The first factor is the type of coal being burned.

In the GE/BHEL method for predicting NOx, each coal is grouped “NOx classification groupings”
based on the Dry, Ash Free Fixed Carbon in the Coal and the As Received, Ash Free Higher Heating
Value of the Coal. This “NOx grouping” is the first factor considered in the NOx prediction. A second
factor is achievable lower furnace stoichiometry. Physically, this coincides with the various Firing
System arrangements offered by GE/BHEL including those systems with no Over fire Air, 1 Level of
Close Coupled Overfire Air, 1 Level of Separated Over-Fire Air, and 2 Levels of Separated Over-Fire
Air. These arrangements allow the combustion air to be staged both vertically (using OFA
compartments, residence time) as well as horizontally (using Concentric Firing, Yawing
Tips). Typically, a greater staging of combustion air combined with a reduction in the lower furnace
stoichiometry will result in a reduction in the NOx released from the furnace. This is the basis of the
firing system design process on modern steam generators.

Generally, with GE/BHEL’s Low NOx Tangential Firing Systems, the NOx may be improved
anywhere from 20-35% by using a two-level SOFA arrangement over a single-level SOFA
arrangement. It is worth noting that the NOx predictions are based upon physical arrangements which
are proprietary to GE and have been correlated with test data from hundreds of operating units
worldwide using Low NOx Tangential Firing Systems. This also means that the same process cannot
be directly used to predict the Furnace NOx in a Wall Fired boiler nor can a purely fundamental
calculation be used to calculate the NOx in a boiler with a GE/BHEL Low NOx Tangential Firing
System.

The various arrangements used in GE/BHEL Firings Systems are designed to stage the
combustion air in different amounts to achieve the lowest Furnace NOx possible. In some cases, there
can be limitations in the amount of air staging possible and hence the lower furnace
stoichiometry. These limitations are typically related to the fuel composition. For example, fuels with
a very low Heating Value or a very high Fuel Ratio may impose limitations on the minimum lower
furnace stoichiometry that can be achieved.

Customer / Plant: NTPC / Telangana STPP 2x800MW

Engineer VRK/SKD Title : NOx CALCULATION
Reviewer PVP Drg. No. : 9591-102-102-PVM-U-009
Approver BMM/GV SHEET: 2 OF 7 Rev.01
 NOx Predictions

On a given project, if the required Plant NOx value is low enough that an SCR is required, then the in-
furnace NOx reduction is usually maximized. This is accomplished by minimizing furnace
stoichiometry and maximizing the combustion air staging to the greatest extent possible while
maintaining an acceptable combustion efficiency. This approach minimizes the physical size of the
SCR and minimizes the ammonia consumption required to reach the guarantee NOx levels out of the
stack while maximizing the boiler efficiency and thus plant heat rate.

There are other factors can impact the NOx generated in the furnace. One is the Nitrogen in the
Fuel. A general relationship for coal is that for every 0.1% increase in Fuel Nitrogen (on a dry, ash
free basis), the Furnace NOx would increase by ~1.5%.
The burner tilts can also have an impact on the Furnace NOx. In general, a horizontal tilt
position (0°) will minimize the Furnace NOx. As the tilts are modulated away from 0°, the Furnace
NOx will tend to increase. It should be noted that changes in tilt also impact the residence time which
also impacts the Furnace NOx.
The methods used by GE and BHEL to calculate the NOx generated in the furnace are based
upon both fundamental theory as well as empirical data from existing units utilizing Low NOx
Tangential Firing Systems. The actual NOx generated is impacted by the specific coal properties as
well as the operation of the boiler. GE and BHEL consider the complete range of fuel properties and
operational parameters on each project when designing the firing system to either attain the required
Furnace NOx for a given project (without an SCR) or a minimum Furnace NOx possible on project
where an SCR is required to achieve the Plant NOx guarantee.

Customer / Plant: NTPC / Telangana STPP 2x800MW

Engineer VRK/SKD Title : NOx CALCULATION
Reviewer PVP Drg. No. : 9591-102-102-PVM-U-009
Approver BMM/GV SHEET: 3 OF 7 Rev.01
 NOx Predictions

NOx emissions have been measured at two Supercritical Units shown below.
Emissions data was collected over a wide range of operating conditions and the results are tabulated
below.

NOx Field Measurements:

Unit NOx Emission (mg/Nm3)

Barh – 5 219 - 349
Krishnapatnam - 2 220 - 265

The above Units use a single-level SOFA arrangement.

Telangana uses a two-level SOFA arrangement.

A two-level SOFA arrangement will further improve NOx emissions by 20-35% over a single-level
SOFA arrangement, ensuring Telangana achieves the guarantee level of 300 mg/Nm3 leaving the
steam generator over the entire operating envelope and fuel range.

Refer sheets 5, 6 and 7 for graphs showing impact of critical parameters on NOx emissions.

Customer / Plant: NTPC / Telangana STPP 2x800MW

Engineer VRK/SKD Title : NOx CALCULATION
Reviewer PVP Drg. No. : 9591-102-102-PVM-U-009
Approver BMM/GV SHEET: 4 OF 7 Rev.01
 Graph showing impact of Firing Zone stoichiometry on NOx emissions.

The firing zone stoichiometry is defined as the ratio between the actual air flow in the firing zone and
the stoichiometric air flow required to burn the coal entering the firing zone.

Variation of NOx with overfire air i.e with and without SOFA (separate over fire air)
compartments is indicated in the above figure. Range indicated is for the variation in coals specified.

The effect of excess air can be seen in the graph showing predicted NOx for 0, 1, and 2 SOFA
arrangements. For a fixed over-fire air flow, an increase in excess air will increase the Firing Zone
Stoichiometry, which will increase NOx production.

Customer / Plant: NTPC / Telangana STPP 2x800MW

Engineer VRK/SKD Title : NOx CALCULATION
Reviewer PVP Drg. No. : 9591-102-102-PVM-U-009
Approver BMM/GV SHEET: 5 OF 7 Rev.01
 Graph showing impact of tilt and mill combination on NOx emissions.

Customer / Plant: NTPC / Telangana STPP 2x800MW

Engineer VRK/SKD Title : NOx CALCULATION
Reviewer PVP Drg. No. : 9591-102-102-PVM-U-009
Approver BMM/GV SHEET: 6 OF 7 Rev.01
 Graph showing impact of Fuel Nitrogen on NOx emissions.

Customer / Plant: NTPC / Telangana STPP 2x800MW

Engineer VRK/SKD Title : NOx CALCULATION
Reviewer PVP Drg. No. : 9591-102-102-PVM-U-009
Approver BMM/GV SHEET: 7 OF 7 Rev.01
 Attachment - 1

BHEL/GE Responses to NTPC’s question raised during Auguat’17 TCM regarding

Nox control

NTPC August 2017 – Firing System Questions:

1. Residence time. Please calculate the residence time for Telangana, then predict NOx
impact with an increase in residence time and decrease in residence time.

Windsor Response:

Please keep in my mind and understand the academic nature of this question.

Tangential Firing residence time is a function of flue gas volumetric flow, boiler cross section and
height.

For a Main WB design stoichiometry selection, fixed boiler arrangement and TMCR boiler load –
the residence times are fixed and there are no practical or viable means to independently adjust
the staged residence time.

Telangana staged residence time is on the order of 1 second.

Given this understanding – on a hyper-theoretical, academic basis - the following order of

magnitude impacts to the Telangana base NOx emissions with differences to the staged
residence time are offered:

¼ sec. Staged Residence Time – Predicted NOx emissions increase by roughly 25%.
½ sec. Staged Residence Time – Predicted NOx emissions increase by roughly 10%.
1 ½ sec. Staged Residence Time – Predicted NOx emissions decrease by roughly 5%.
1 ¾ sec. Staged Residence Time – Predicted NOx emissions decrease by roughly 5%.

2. CFS Compartments:

A. Please estimate CFS Impacts on NOx Emissions – 100% open, 40% open, and closed.
B. Please explain how CFS helps reduce waterwall corrosion.

1
Windsor Response:

A. As advised previously to a similar question concerning CFS impacts on NOx advised - a Max 5%
NOx impact would be anticipated – when “turning on” or “turning off” the CFS air – by swapping
or selecting between the 22° offset CFS Aux Air compartments vs the Straight Aux Air
compartments.

BACKGROUND: Local Secondary Air Staging is accomplished with 22° horizontal offset
Concentric Firing System (CFS) air nozzles. This local air staging technique re-directs a portion of
the main windbox secondary air, horizontally away from the coal stream towards the waterwall,
with offset auxiliary air nozzles, aimed tangent to a larger diameter firing circle. With this
arrangement, near burner stoichiometry is reduced as compared with non-concentric firing
auxiliary air nozzles, minimizing prompt NOx generation, while at the same time maintaining
appropriate oxidizing conditions along the waterwall.
Is operation here refers to simultaneous?
Upto
NOTE: The Main WB Aux Air – active compartment free area was whatfor
selected limit the the
EITHER Main WB
stoichiometry can be maximized.
straight aux or the CFS air. Not both – while also utilizing both the H-SOFA and L-SOFA boxes.

Operation with BOTH straight aux air and CFS aux air compartments on dp control is only
recommended when maximizing the Main WB stoichiometry by minimizing the SOFA flows.

Without SOFA air diverted to the Main WB - we would have insufficient Main WB airflow for all
these Aux Air compartments now effectively on dp control. And thus - holding the WB/furn dp
set point may be difficult.

B. CFS Nozzles reduce WW corrosion tendencies by providing an oxidizing layer along the
waterwall. This oxidizing environment near the waterwalls can reduce the quantity of waterwall
ash deposits, and the deposit adherence tenacity. And in-turn also reduce corrosion potential
when firing coals with higher corrosion potential. Especially coals with high concentrations of
Sulfur, Iron (FeS2 – pyrite) and Alkali Metals, (K, Na).

Worth Noting: In practice, corrosion by sulfuridation or other waterwall deposit mechanisms

can be largely controlled by minimizing the potential for direct fuel impingement on the
waterwalls. This potential is addressed via conservative heat release parameters, furnace
geometries, as well as improved fineness control. Last - we do not anticipate corrosion related
thinning of the waterwalls on Telangana, regardless of the Main WB firing zone stoichiometry or
CFS vs No CFS operation - given almost no pyrite (FeS2), or Alkali Metals (K or Na) inherent in the
indigenous India coals.

3. H & L-SOFA and CCOFA dampers:

A. Please advise what controls the H & L-SOFA and CCOFA dampers? NOx?
Stoichiometry? Providing a brief explanation.
B. Are damper positions affected by coal quality? Unit load?

2
Windsor Response:

A. The H-SOFA and L-SOFA damper are controlled on an elevation basis via the SOFA airflow
demand.
The SOFA airflow demand – or Stochiometric Control philosophy applied for Telangana relies on
multiple zone, actively controlled global staging of the combustion air, for controlling NOx
emissions independent of the specific unit load, outlet excess air levels, and operating
conditions, over the boiler load range. Striving to maintain minimal in-furnace NOx emissions
thru the boiler operating load range.
This SOFA management system uses eight (8) air-flow-meters – one for each L-SOFA and H-SOFA
box – along with the control system logic - to control stoichiometry build-up and combustion
process over the boiler operating envelope.
By utilizing the measured LSOFA and HSOFA airflows coupled with the measured total Primary
and Secondary airflows, total fuel flows and boiler outlet O2, the stoichiometry at the main
windbox firing zone can be calculated and controlled - by varying the total SOFA airflows.
Likewise, the stoichiometry above the LSOFA can be calculated and controlled by varying the
HSOFA airflows.
SOFA airflow measurement and the SADCS (secondary air damper control system) logic are
utilized to hold a stoichiometry set point defined via Main WB the L-SOFA Stoichiometric Set
point f(x) total unit airflow demand dependent characteristic function curves.
With this approach the control system logic maintains and actively controls two intermediate
stoichiometric zones, effectively controlling the Main WB burner zone stoichiometry, the
stoichiometry build-up and overall combustion process.
Implementing this Active Zone Control scheme, the one (1) CC-OFA damper is stagger ramped
open with total measured airflow. And the three (3) L-SOFA elevations and three (3) H-SOFA
elevations are stagger ramped with L-SOFA total demand and H-SOFA total demand,
respectively.
All function curves and set points are subject to field tuning based on actual unit
operating characteristics.

B. With this Stoichiometric Control philosophy - day-to-day or month-to-month minor coal quality
changes will have relatively minimal impacts on operation and NOx emissions.
But large coal rank changes or even significant unit operational changes – such as operating with
too many mills in service or monsoon seasonal driven variable bumps in the PA flow ramp can
require adjusting or tweaking these 2 Stochiometric Set point f(x) characteristic ramps to
minimize furnace outlet NOx emissions and hold effective control of the WB to furnace dp.
Again – all SADCS function curves including these 2 Stoichiometric Set point f(x)
function curves are subject to field tuning during commissioning.

3
4. Telangana – Advise impacts anticipated with the following variables:

A. Operation with only 1 SOFA.

B. Predicted NOx impacts - H-SOFA vs L-SOFA

Windsor Response:

A. Telangana firing system was selected and designed assuming Min NOx operation requiring
utilizing of both the L-SOFA and H-SOFA. Further the control system logic was also designed
around operating both SOFA boxes.

Throttling back and effectively closing either the H-SOFA or L-SOFA, for 1 SOFA operation at
BMCR – can be accommodated via our flexible WB design – by using both the Straight Aux Air
AND the CFS compartments, and changing the 2 stoichiometric set-point characteristic curves.

These operational changes will allow for 1 SOFA operation – and effective control of the WB to
furn dp set point, with the Aux Air dampers on dp control modulating between 10 to 15% and to
85 to 90% open.

B. With only 1 SOFA – the predicted NOx impacts are significant. The Main WB stoichiometry will
rise from roughly 0.80 to 1.00. And this stoichiometry change – will effectively double the
predicted NOx emissions.

Further - if only using the L-SOFA, the overall staged residence time will also be negatively
impacted by almost ½ second – resulting in an additional 10% predicted NOx increase.

5. The prior NOx emission reply for Telangana - advised the “NOx Predictions generated in the
furnace are based upon both fundamental theory as well as empirical data”. NTPC has
asked for clarification of what we meant by “fundamental theory”?

Windsor Response:

NOx – FUNDEMENTAL THEORY – LITERATURE & LABORATORY RESEARCH BACKGROUND

Nitrogen monoxide (NO) and Nitrogen Dioxide (NO2) are combustion by-products of all fossil
fuels. In recent years, oxides of nitrogen have been implicated as one of the elements
contributing to the generation of smog and acid rain. Today, the emission of NO and NO2,
collectively referred to as NOx, is regulated by federal and state, and in many cases local
authorities. Collectively, these regulations have become an important consideration in both the
fuel firing system and overall boiler design.

4
The nitrogen source producing the NOx by-products is often utilized to define the complex
combustion process. If the N2 originates from the atmospheric air, the NOx is referred to as
“Thermal NOx”. If the N2 originates as organically bound Nitrogen in the coal the resulting NOx is
referred to as “Fuel NOx”. The chemical reaction kinetics defining the “Thermal NOx” process
were originally described by Zeldovich. This Zeldovich mechanism defines the rate of “Thermal
NOx” as exponentially dependent on temperature, proportional to the square root of the oxygen
concentration, while linearly dependent with both the nitrogen concentration and time. In
other words, “Thermal NOx” can be decreased by reducing time, concentrations of N2 and O2
and temperature, with temperature having the largest impact. In practice the Zeldovich
Thermal NOx equations define trends, and at best only potentially predict NOx emissions
immediately downstream of the flame front.

As although only a fraction of the coal bound nitrogen is ultimately converted to NOx, “Fuel NOx”
typically represents the major portion of NOx emissions generated in a conventional utility
boiler. The NOx generated within the flame front region, due to the relatively short residence
time has been labeled as “prompt NOx. Within this flame front region, pyrolysis or volatile
matter evolution occurs, followed by volatile matter combustion, and finally residual char
ignition. The conversion of coal bound nitrogen therefore can be also regarded as a multiple
stage process:, coal-nitrogen devolitization, volatile-nitrogen combustion, and char-nitrogen
combustion. While these individual stages may overlap, it is clear the combined volatile matter
devolatization and combustion process is generally of much shorter duration than char
combustion.

Based on laboratory drop tube furnace research efforts, it is also evident the extent of coal
bound nitrogen released during each stage significantly varies between coals. Further, based on
this combustion research, it is evident that both the amount of nitrogen released during
devolatization, as well as the local temperature and stoichiometry will strongly influence the
furnace outlet NOx emissions. During devolatization, this fuel bound nitrogen is released as NH3
and HCN compounds. Under sub-stoichiometric staged conditions, at sufficiently high
temperatures, these volatile matter released nitrogen compounds will reduce to N2. The
remaining fuel bound nitrogen is released during char combustion. For char combustion to
approach completion, an oxygen rich process is required. As with the volatile released NOx, the
eventual fate of char released nitrogen is dependent on the specific time, temperature and
stoichiometric history.

Based on these laboratory findings, the minimum NOx firing system design would include
providing sufficient air initially mixed with the coal to match the specific volatile matter
requirements, promote rapid heat-up and strong devolatilization at these sub-stoichiometric
conditions, and judiciously mix in successive stages the minimum required air to sustain and
reach complete combustion.

Inherently, tangential firing exhibits these low NOx combustion traits, while the TFS2000 -
Double SOFA Firing System arrangement applied for Telangana - was specifically designed with
these guidelines in mind.

5
6. NTPC has asked for further definition of the relationship between NOx and Tilt Position.
Specifically, when the tilts drop below horizontal.

Windsor Response:

Our prior reply showed NOx emission trend increasing for the Barh II site, comparing Horizontal
Tilt Position and +20° position.

This trend - NOx increasing with tilt position – is explained as our ability to maintain adequate
separation with the OFA can diminish with increases in the Main WB tilt position. Especially if
the SOFA tilts are not following the Main WB tilts. It is not clear where the SOFA tilts were
positioned for the Barh II data.

With the Main WB tilts dropping below horizontal – SOFA separation is easier to maintain. And
historically – this reducing NOx emission trend continues with negative tilt position down to the
minus 15 to 20° tilt position.

Beyond minus 15° to 20° tilt position, the downward NOx emission trend levels off.
And pushing past minus 20° - the fireball swirl strength can begin to weaken. And thus – SOFA
separation diminishes and NOX emissions begin to trend upward.

It should be noted – for sliding pressure super critical boiler operation – Telangana for example
is less dependent on WB tilts – as compared with a sub-critical unit. And we do not expect to
operate outside of the +/- 20° WB tilt range.

7. NTPC has asked if the curve relating change N2 to change NOx hold true for design coal,
best coal, worst coal? Is it independent of load?

Windsor Response:

The curve provided earlier was a general trend line – showing the order of magnitude -typical
relationship between fuel nitrogen and NOx emissions.

YES - this order of magnitude curve “holds true” - with the understanding that each coal, the
design, best and worst coal may start with a different base NOx emission.

Whether this relationship “holds true“ – fully independent of load is hard to empirically
determine or confirm. As there are many factors which can impact NOx emissions – to a far
greater extent.