September 29, 2014

Ron Jordan

1201 Constitution Ave NW Washington DC
USEPA Office of Water Engineering & Analysis Division

Re: Follow up to Liberty Hydro visit on September 23, 2014

Dear M r. Jordan

Liberty Hydro Inc. appreciates the opportunity to provide follow up comments to our meeting with the Environmental Protection Agency on the dr aft effluent limits for FGD wastewater at coal burning power pl ants.

Based on empirical evidence and results obt ained from recent pilot plant testing, it appears that the
solution lies with a thre e

- stag e treatment train consisting of:

1) physical /chemical treatment

, f ollowed by 2) biological nitrate removal and anchored by 3) zero valent iron technology,

spe cifically ZVI Blue TM technology developed by Liberty Hydro

.

We are hopeful that EPA and the power industry will use such available technology to clean up the nation’s rivers and proceed to confirm th at the proposed limits are achievable.

We understand that EPA is generally aware of zero valent iron technology , which is referenced in your e

mail to me o n September 17, 2014 . The latest news is that Liberty Hydro’s ZVI BlueTM technology
achieved the best treatment results at recent pilot testing sites when us ed as the anchor technology on a staged t reatment train. For example, certain biological systems alone did not achieve the propo sed

ELG limits (as EPRI noted in its submi ttal re Merrimack to Sharon DeMeo on August 14, 2014 ), but when
one of those bio systems was followed by ZVI BlueTM in the treatment train, the proposed ELGs were

met. Certain other technologies did not work on their own , but a treatment train that include drudimentary primary treatment followed by biological treatment and zero valent iron tec hnology was

successful.

At another testing site, the proposed ELGs were met with a com bination of extensive physical chemical treatment followed by ZVI BlueTM. In that case, even a simple bio system was not required due to the
low levels of nitrate in the raw water. Nonetheless, we have proposed to re

- run the test wi th a biological system included, with the expectation of showing even better results.

Given this reassuring evidence, we submit that the power industry should be focused on the following path to compliance:

1. Always start with phys ical/ chem ical primary treatment. This is an established method in the

water treatment industry to redu ce the majority of pollutants. The absence of phys ical/chemical treatment ( what the drinking water industry calls primary treatment: lime softening, coagulation and clarification) will give any single technology a low probability of

success. The inclusion of phy s ical chem ical treatment is so basic to water treatment

– a given prerequisite of serious attention

-- that the cost of installing the phys ical chem ical treatment system could arguably be excluded from the cost analysis.

2. Establish a meaningful and focused budget to extend testing on promising technologies . O ver the next several months, c ontinue testing with technologies that have been shown to work and refine the technology to meet the specific need s of the power plant industry. Failure to fund
the promising and proven technol ogies should raise questions.

3. In all future testing, the testing should include a baseline treatment train consisting of 1) physical chem ical

, 2) simple bio and 3) ZVI BlueTM. That is the best combination curr ently
available , having achieved the best results in recent testing. This t echnology solution should be refined and scaled up. If the power industry wants to test other technologies, they should be set up in a parallel test to the baseline approach to provide comparison results.

We are prepared to work with EPA and the power industry to conduct additional testing. We are also prepared to enter joint development agreements to scale our technology to a full scale solution s

.

If you have any questions please feel free to contact me directly at 419

- 346

- 8848 phil.farina@libertyhydro.com

Sincerely

Phil Farina
Sales Executive Liberty Hydro Inc.