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OAR Box 1865 

Prepped by Charmelle Mathews 

Document Number: 

39) IV-E-27 

Docket Number: 

A-83-27 

Printed 12/3/2008 9:15:28 AM Sheet 39 of 105 
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Dllm „ H A-83-27 RADIAN 

CORPORATIO N 

TELEPHONE CALL REPORT 

DATE: October 29, 1986 

TO: Mr. Dan Allen 

New Hampshire Department of Natural Resources 

Water Supply and Pollution Control Division 

Hazen Street 

Concord, New Hampshire 03301 

(603) 271-2052 

FROM: Phillip A. May, Radian Corporation 

SUBJECT: Sodium Scrubber Discharge 

Mr. Allen stated that all discharges, whether they were from a scrubber 

unit itself or from a publically owned treatment works, must meet the state 

effluent guidelines. An effluent guideline is a concentration limit used in 

permitting a new source. The impact of a new source is evaluated by 

determining pollutant concentrations in the receiving water body if the 

discharge were to occur. The concentration limits are referred to as water 

quality criteria, and the state of New Hampshire presently has a sulfate 

limit of 100 mg/liter. 

Mr. Allen also stated that one of the facilities under his jurisdiction 

presently has problems with sulfate loadings at the discharge. This 

facility is the facility at Merimac and the contact there is Roger 

Descoteaux. The discharge there is into the Merimac River and the sulfate 

loading in that stream is already at or above the state limit. In addition, 

they have a problem with H«S reemission. He addded that he could see where 

there would be the potential for a problem with H2S reemission whenever the 

discharge of a concentrated sulfate stream took place at a point which was 

distant from the treatment facility. The reason stated was the'increased 

probability of stagnant areas along the way to the plant. 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park. N.C. 27709/(919)541-9100 
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ALDEN H. HOWARD 

COMMISSIONER 

WILLIAM A. HEALY. RE. 

DIRECTOR 

RUSSELL A. NYLANDER. RE. 

CHIEF ENGINEER 

State of New Hampshire 

DEPARTMENT OF ENVIRONMENTAL SERVICES 

WATER SUPPLY & POLLUTION CONTROL DIVISION 

6 Hazen Drive. P.O. Box 95, Concord, NH 03301 

603-271-3504 

July 13, 1987 

COUNCIL 

JOHN F. BRIDGES. Chairman 

MICHAEL G. LITTLE. Vice Chairman 

JOHN C. COLLINS. P.E. 

ALLEN F. CRABTREE III 

RUSSELL DUMAIS . 

RICHARD M. FLYNN 

WILBUR F. LaPAGE 

JAMES J. PAGE 

WAYNE L. PATENAUDE 

DAVID G. SCOTT 

JAMES VAROTSIS 

WILLIAM T. WALLACE. M.D.. M.P.H. 

Mr. Philip A. May, Chemical Engineer 

Radian Corp. 

P.O. Box 13000 

Research Triangle Park, N.C. 27709 

Subject: Sodium Scrubber Discharge 

Dear Mr. May: 

Your letter to me dated June 29, 1987, conveyed your Telephone Call 

Report related to a conversation you indicate we had on October 29, 1986. I 

must comment on that Report, since it does not accurately report the 

regulatory framework applicable to discharges in New Hampshire. My comments 

follow: 

1) The state does not currently have either "effluent guidelines" or 

"water quality criteria" which would provide the framework and 

standards for permitting discharges to receiving waters in New 

Hampshire. EPA does hold responsibility for the NPDES program in New 

Hampshire. The State concurs in ("certifies") EPA's permits, or 

issues parallel State permits in some cases. State certification of 

NPDES permits substitutes for issuance of separate State permits in 

the majority of cases. EPA has effluent guidelines and water quality 

criteria. The State has Water Quality Standards, due for overhaul in 

1987. 

2) The present State Standards include a limitation on-"substances 

potentially toxic" which, for Class Band C streams, reads "Not in 

toxic concentrations or combinations." Asked at what level sulfate 

might be limited, I suggested that the literature might support a 

water quality limit of 100 mg/l, unless occurring naturally at higher 

concentration. We do not presently have a specific limit on sulfate 

of 100 mg/l. 
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, 

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3) The Wastewater Treatment Facility in Merrimack does have a problem 

with H2S generation in the sludge holding tank and sludge press 

area. The largest industry in town does occasionally discharge 

sulfate at concentrations in excess of the local limit of 250 mg/l. 

However, there is no effluent limit on sulfate in the NPDES permit 

for Merrimack nor in state conditions in the permit certification. 

There have been instances in which a permit limit on pH was not met 

because of the industrial discharge, but sulfate in the municipal 

effluent has not been an issue. 

4) We do expect H2S to be generated from sulfate when the proper 

conditions obtain: low flow velocities (poor aeration), poor sewer 

ventilation, long retention times, low to moderate pH, and an 

adequate source of sulfate. Long, flat sewers, pump station wet 

wells, and inverted siphons are conducive to HpS buildup. Usually, 

H2S generation is not limited by sulfate concentration. 

5) Sulfate as a salt can cause destruction of concrete sewer structures 

when the concentration exceeds 500 mg/l for older sewers or 1000 mg/l 

for later sewers. 

6) There may be other parameters of concern, besides sulfate, in the 

wastewater from scrubbers. 

I believe the foregoing points should replace the Telephone Call Report 

of October 29, 1987. Please contact me or Lynn Woodard (603-271-2457), if you 

have questions about this letter or the State's perspective on industrial 

discharge of sulfate. 

Very truly yours, 

:\_/ti-*<r j 

Dan H. Allen, P.E., Supervisor 

Industrial Pretreatment Section 

DHA/cd 

cc: Lynn Woodard, WS&PCD