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 Mr. Jordan

Liberty Hydro Inc. appreciates the opportunity to provide follow up comments to our meeting with the 

Environmental Protection Agency on the draft effluent limits for FGD wastewater at coal burning power 

plants. 

Based on empirical evidence and results obtained from recent pilot plant testing, it appears that the 

solution lies with a three-stage treatment train consisting of:

1) physical /chemical treatment, 

followed by 

2) biological nitrate removal 

and anchored by 

3) zero valent iron technology, 

specifically ZVI BlueTM 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 that the proposed limits are achievable. 

We understand that EPA is generally aware of zero valent iron technology, which is referenced in your email to me on 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 used as the anchor technology on 

a staged treatment train. For example, certain biological systems alone did not achieve the proposed

ELG limits (as EPRI noted in its submittal 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 included
rudimentary primary treatment followed by biological treatment and zero valent iron technology was 

successful. 

At another testing site, the proposed ELGs were met with a combination 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 with 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 physical/chemical primary treatment. This is an established method in the 

water treatment industry to reduce the majority of pollutants. The absence of 

physical/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 physical chemical treatment is so basic to water treatment – a given 

prerequisite of serious attention -- that the cost of installing the physical chemical treatment 

system could arguably be excluded from the cost analysis.

2. Establish a meaningful and focused budget to extend testing on promising technologies. Over 

the next several months, continue testing with technologies that have been shown to work and 

refine the technology to meet the specific needs of the power plant industry. Failure to fund 

the promising and proven technologies should raise questions. 

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

physical chemical, 2) simple bio and 3) ZVI BlueTM. That is the best combination currently 

available, having achieved the best results in recent testing. This technology 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 solutions. 

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.