United States
                                  Environmental Protection
                                  Agency
                                  Municipal Environmental Research
                                  Laboratory
                                  Cincinnati OH 45268
&EPA
                                  Research and Development
                                  EPA-600/S2-81-098  July 1981
Project  Summary
                                  Effect  of  Flue  Gas
                                  Cleaning  Sludges on
                                  Selected  Liner  Materials

                                  Clarence R. Styron, III, Zelma B. Fry, Jr., and Gordon L. Carr
                                    This project examines the effects of
                                  two flue gas desulfurization (FGD)
                                  sludges on 18 liner materials used to
                                  contain them.  Seventy-two special
                                  test cells were constructed  1 ft in
                                  diameter by  2 ft high. Devices were
                                  installed to collect the leachate from
                                  each test cell to determine the leakage
                                  and the leakage rate (permeability)
                                  and to provide storage for subsequent
                                  chemical analyses.
                                    Ten admix liner materials were mixed
                                  with a clayey silt and compacted in the
                                  bottom 6 in. of the test cells. Six
                                  spray-on and two prefabricated mem-
                                  brane liners were placed over 6 in. of
                                  compacted  silty sand. Four gal of
                                  sludge was then added to each test
                                  cell along with enough tap water to
                                  bring the liquid to within 4 in. of the
                                  top. Each test  cell was covered and
                                  pressurized to simulate a disposal area
                                  approximately 30 ft deep.
                                    Physical tests of the 18 liner materials
                                  were conducted before exposure to
                                  the FGD sludges and  after 12 and 24
                                  months of exposure.  Chemical tests
                                  for determining heavy metals were
                                  conducted on the two  sludges as
                                  received and on the sludge liquor that
                                  passed through the  lined test cells
                                  after 12 and  24 months.
                                    This Project Summary was devel-
                                  oped by EPA's Municipal Environmen-
                                  tal Research Laboratory, Cincinnati,
                                  OH, to announce key findings of the
                                  research project that is fully docu-
                                  mented in a separate report of the
                                  same title (see Project Report ordering
                                  information at the back).
                                  Introduction
                                    Ground and surface water contami-
                                  nation resulting from improper disposal
                                  of hazardous wastes is a growing public
                                  concern. Controlling the leachate from
                                  such wastes by providing an impervious
                                  liner for the disposal area could be a
                                  solution to  the problem, and it would
                                  allow for the use of more sites as
                                  disposal areas. The use of liners for
                                  such purposes is not a new concept, but
                                  knowledge is lacking on the compatibility
                                  of liner materials with certain toxic
                                  wastes and, particularly, on the  life
                                  expectancy of such liners. Much infor-
                                  mation is needed tosupply guidance and
                                  possible future regulations for using
                                  liners in waste disposal areas.
                                    The objectives of this study were to
                                  determine the compatibility of liner
                                  materials with flue gas  desulfurization
                                  (FGD) sludges, to estimate liner life, and
                                  to assess the economics of purchasing
                                  and placing various liners. To meet
                                  these objectives, specimens of a variety
                                  of potential liner materials were exposed
                                  to selected FGD sludges over a period of
                                  time under  conditions that simulated
                                  disposal areas and changes  in the
                                  physical properties of the liner material
                                  with exposure time were determined.
                                    Considerations in selecting liner
                                  candidates were low cost  and ease of
                                  placement and construction. Primary

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 attention  was focused on the use of
 admixed or stabilized in situ liner mate-
 rials. Spray-on  materials were also
 considered, and some use was made of
 prefabricated membrane liners (the
 latter are being  tested extensively in
 other projects.1'3
  The first step was to select two FGD
 sludges representative of those that
 would be found in disposal areas. Next,
 18 types of liners (Table 1) were selected
 as potentially usable with FGD sludges.
 Test cells were then designed  and
 constructed to simulate disposal condi-
 tions involving a sludge depth of at least
 30 ft so that sludge could be applied in
 increments over time. Liners were then
 exposed for 12- and 24-month periods,
 after which  physical tests were con-
 ducted to determine liner behavior over
 time. Any accumulated leachate was
 collected and measured for quantity and
 quality.  Finally, cost data were devel-
 oped for the liners.
Table 1.     Selected Liner Materials
   ID
  No.
Material Name and Type"
                           Methods and Materials

                           Design and Construction of
                           Test Cells and Ancillary
                           Equipment

                           Design  Factors
                             Factors considered in the design  of
                           the test  cells were construction  or
                           installation methods,4 size or amount of
                           specimen required  for physical tests
                           after exposure periods, cell volume
                           sufficient to contain the  liner and
                           sludge, and means of simulating a 30-ft
                           sludge depth.
                             A decision was made to test each liner
                           with 6 in. of compacted soil—the mini-
                           mum practicable for stabilizing admixes
                           and for limiting differential soil move-
                           ment under spray-on and membrane
                           liners. The size of each liner specimen
                           was determined by the  number and
                           types of tests following the exposure
                           period. Duplicate specimens were also
Percent/Description/ Type
       Admix Liner Material:

   12      Lime
   10      Port/and cement
   15      Cement with lime

   11      M179
  08      Guartec UF
  09      Asphaltic concrete

   14      TACSS 020
   16      TACSS 025
   17      C400
   18      CST

       Spray-on Liner Material:

  03      DCA-1295
  04      Dynatech
  05      Uniroyal
  06      Aerospray 70
  07      AC40
   13      Sucoat

       Prefabricated Membrane Liner:

  01      Total Liner
  02      T16
                           HydratedASTM C 747-67J
                           Type I ASTM C 150-78%
                           4 percent Type I Portland cement
                           6 percent hydrated lime
                           4 percent polymer, bentonite blend
                           4 percent light gray powder
                           11 percent asphalt cement
                           1/2 in. (max.) aggregate
                           6 percent blackish-brown liquid
                           6 percent blackish-brown liquid
                           15 percent finely ground powder
                           15 percent finely ground powder
                           3/4 gal/yd2 polyvinyl acetate
                           3/4 gal/yd2 natural rubber
                           3/4 gal/yd2 natural latex
                           3/4 gal/yd2 polyvinyl acetate
                           3/4 gal/yd2 asphalt cement
                           As-supplied molten sulphur
                           As-supplied elasticized polyolefin
                           As-supplied black chloroprene-coated
                           nylon
 * For manufacturer/address, see Appendix A of full report.
 t Standard Specifications for Hydraulic Hydrated Lime for Structural Purposes.
  In:  1978 Annual Book of ASTM Standards, Part  13^ Designation: C141-67
  (rev 78). Philadelphia, Pennsylvania, 1978.
 ^Standard Specifications for Portland Cement In: 1978 Annual Book of ASTM
  Standards, Part 14, Designation: C150-78. Philadelphia, Pennsylvania, 1978.
used for  determining unusual tesl(
results. Pressurization was considered
the most feasible approach to simulating
a 30-ft sludge depth. The use of pressure
(20 psi) permitted minimum amounts of
other materials to be used, including
sludge.

Test Cell Construction
  Seventy-two test cells were fabricated
from polyvinyl  chloride (PVC), which
was selected as an inert material that
would not react chemically  with  the
FGD sludge. Schedule 80 PVC pipe (ID
11-3/16 in.) with a pressure  tolerance
of 130 psi was selected for the pressure
cells. The PVC base was 2-1 /2 in. thick
and  15 in. square. The PVC top was 15
in.  in  diameter and  3/8 in. thick. A
schematic view of the test cell is shown
in Figure  1. An additional top plate of
1/4-in. aluminum  was required to
prevent buckling of the PVC top as
pressure was increased in the cell.

Ancillary Equipment
  Ancillary equipment consisted of a
system for pressurizing the test cells
and a system for collecting the leachate
(Figure 1).

FGD  Sludge Selection and    \
Characteristics
  Sludges were selected from an eastern
coal lime-scrubbed process (Sludge A)
and  from  an eastern  coal  limestone-
scrubbed process (Sludge B). Samples
were obtained from disposal  ponds at
the  plant sites. Sludge A had 47.6
percent solids  and a  pH of 10.3,  and
Sludge B had 34.2 percent solids and a
pH  of  9.0. A chemical analysis of the
sludges appears in Table 2 along with
EPA allowable limits.  With  few excep-
tions, the two sludges are very similar in
composition.

Soil Material and Liner
Selection and Properties
  Soil selections were based  primarily
on results of previous investigations. A
highly  permeable soil  was  considered
most applicable for evaluating membrane
and spray-on liners because it would
permit  any leakage of  the liners to be
readily detectable. But the admix mate-
rials required a less  permeable soil to
minimize the amount of admix needed.
A silty sand was thus selected to evaluate
the membrane and spray-on liners, and
a clayey silt was used to evaluate  the
admix  liners. These soil types are con-
sidered representative of typical soils!)

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                                           Regulator
                                                                  Air
                                                                Pressure
                                   Gage
Silicone Seal —


  Liner Test
  Material  -

 Porous Disk.
Pressure
Port
r- 	 —^
t;


^-
P






Plastic
/ Tubing

11-13/16"
S/u
dge
Under
Pres
Comp
So
^
r ^
Drain Port *^

sure
acted
il






3



6"
— i ,
r^^
\^
N^ Plastic
                                                      ( ) Check Valve
                                                                   Manifold
                                                  26%'
                                       Tubing
                                         Leachate
                                                               • Plastic
                                                                Container
Figure 1.
Schematic of a test cell section with  a spray-on or membrane liner
depicted and ancillary equipment.
that might be encountered in a disposal
area.
  Liner selection was based on  results
of permeability tests. Admix liner mate-
rials were prepared and compacted in a
Harvard  miniature test apparatus.5
                           Spray-on liners were applied to the
                           surface of soil specimens that had been
                           prepared and compacted in the Harvard
                           miniature mold. Both admix and spray-
                           on liners were allowed to cure for 7 days
                           under humid conditions. A 2-ft constant
 head was maintained on the liners, and
 permeability was measured by collecting
 water that permeated through the spec-
 imen over a period of time. The prefabri-
 cated membrane materials were tested
 for leakage (pinholes) or  other abnor-
 malities by covering the bell-shaped end
 of a 21-in. standpipe with a sample of
 each liner and allowing water to stand
 in it for  15 to 20 days. Leakage was
 collected in a container  beneath the
 device.

 Results

 Physical Tests
   Unconfined compression (UC) tests
 were used to study the effects of 12- and
 24-month inundation/pressurization of
 the admix liners,  and  grab tests were
 used to study these effects on the spray-
 on and prefabricated membrane liners.

 Admix Liners
   Physical tests of the admix liners were
 made for the 0-, 12-, and 24-month
 exposures. Two of the materials (Guartec
 UF and M179*) suffered a complete
 breakdown at the end of 12 months and
 further testing was discontinued.
   Moisture contents in  all samples
 increased slightly during the first 12
 months and generally remained about
 constant at 24 months, indicating some
 initial liquid  infiltration.  But  the  dry
 density remained about the same during
 the 2-year period, which would indicate
 that the soil structure had  not changed.
   During the  first 12  months, the UC
 strength  of the Portland cement, Port-
 land cement plus  lime, C400, and CST
 almost doubled, whereas the lime
 strength  increased nearly six times. At
 24 months, the UC strength of the Port-
 land cement  and CST remained  un-
 changed; but  the Portland cement plus
 lime and the  C400 increased an addi-
tional 8 to 10 percent, and the lime
 increased an additional  20 percent.
Thus the results indicated that  the
performances of the  C400 and CST
 liners were similar to  that of Portland
cement.
  Increases in UC strength after curing
time would be expected for silty clay and
lime as well as for other soil types, but
the TACSS 020 and 025 lost 14 and 12
percent UC strengths, respectively, at
the end of 12  months. At the end of 24
'Mention of trade names of commercial products
does not constitute endorsement or recommenda-
tion for use by the U S Environmental Protection
Agency

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Table 2.    Chemical Analysis of Sludges and EPA Allowable Limits
Sludge A
Parameter
Arsenic
Beryllium
Cadmium
Chromium
Cyanide
Copper
Mercury
Magnesium
Manganese
Nickel
Lead
Selenium
Zinc
Sulfite
Sulfate
Boron
Chloride
Vanadium
Nitrite, nitrogen
Nitrate, nitrogen
Sludge
Solids
(mg/kg)
0.28
6.8
0.005
133.0
-§
O.S5
0.44
3030.0
84.8
0.84
1.08
1.38
135.0
190.0
—
385.0
1330.0
162.0
<0.04
3.0
Sludge
Liquid
(mg/L)
0.003
0.005
0.001
0.001
0.012
0.009
0.002
10.1
2.3
<0.003
<0.003
<0.003
0.002
<1.0
1281.0
14.0
675.0
—
<0.01
0.5
Sludge B
Sludge
Solids
(mg/kg)
0.16
1.25
0.007
33.3
—
0.35
0.84
5160.0
43.7
0.38
0.68
2.15
278.0
200.0
68750.0
185.0
300.0
53.0
<0.04
3.0
Sludge
Liquid
(mg/L)
0.003
<0.005
<0.001
<0.001
0.018
0.010
0.002
13.8
0.95
0.003
0.003
0.007
0.002
<1.0
2100.0
71.2
670.0
—
<0.01
0.51
EPA
Allowable
Limits*
(mg/L)
0.05
<0.0/7t
0.0?
0.05\
0.005
0.2**
0.002
/v/m
0.05
on
0.05
0.01
5.0**
NA
250.0
0.75M
250.0**
NA
10.0
10.0
   *From References 9 and 10 in full report.
   •\Freshwater aquatic life criteria.
   ^Freshwater and marine organisms criteria.
   §— = Insufficient sample to analyze for all parameters.
  **Secondary standards proposed for drinking water criteria (EPA).
  ]]NA = Not available.
  ^Irrigation criteria
months, the TACSS 020 lost an addi-
tional 11 percent (a total of 25 percent,
based on zero-time data), and the TACSS
025 dissociated when cored, thus yield-
ing no data.
  The penetration of the asphaltic
concrete  increased approximately 10
percent at  12 months and  remained
constant at 24 months. The viscosity,
however, increased approximately 13
percent at  12 months but decreased
more than 16 percent after 24 months.
Extensive surface  cracks developed  in
this liner after 12 months.

Spray-On and Prefabricated
Membrane Liners
  Physical test results of the spray-on
and  membrane liners indicated that
after 12 months of exposure, the break-
ing strength of all the liners decreased,
and the DCA-1295 continued to lose
strength  at 24 months. Although the
overall strength of the  liners had de-
creased considerably by the end of the
24-month period,  values were slightly
higher at the end of 24 months than
they had been at 12 months for the Total
Liner, T16, Uniroyal, and Dynatech.
  The percent of elongation values for
the Total Liner material increased  ap-
proximately 400  percent the first year
and remained constant during the
second year. The elongation values for
the T16, Dynatech, and Uniroyal gener-
ally remained constant throughout  the
2-year test period. At 24 months,  the
Aerospray 70 reversed its  12-month
pattern by increasing,  and the DCA-
1295 continued decreasing the second
year.

Chemical Tests
  The first 32 oz  of liquid issuing from
each test cell was collected and analyzed
chemically to assess the gross effects of
liner behavior and liner composition.
These initial liquid samples consisted of
a mixture  of soil  pore water, material
from the liners, and sludge liquor.
  Material lost from the liners cannot be
seen in most cases because of the con-
centrated liquor from the FGD sludges
and  normal background chemistry of
the water associated with the soils.
Some exceptions, however, include
Guartec UF, TACSS 020, and TACSS
025, all of which  released levels of
magnesium and manganese higher
than those observed in most samples.
This release may have resulted from
acidic conditions  that developed in
these admixes because of decay (in the
case of Guartec) or from reactions with
plasticizers (in the cases of TACSS 020
and 025).
  The concentration of a  chemical
constituent such as chloride, which is
not effectively attenuated by soil, is an
important  indicator of  how the  sludge
liquor is moving through the membrane.
Low chloride levels suggest that  the
sludge liquid is moving uniformly through
the membrane along the entire cross
section of  the test cell. This hypothesis
is  borne out by observations made on
the liner conditions after 12  months.

Permeability
  Because some leakage was caused by
the silicone seals,  permeability values
were influenced and in many cases
invalidated. Thus the only permeability
data reported are those for  liners that
permitted no leachate to pass or for
liners that were obviously attacked by  '
the chemical sludges.


Summary of Liner Performance
   Recorded data for physical tests  and
chemical  analyses indicate that the
following comments are valid and per-
tinent.
    1. Total Liner. The density increased
      26.2 percent following exposure,
      and the breaking strength de-
      creased 72 percent. These figures
      indicate that the polymer was
      compacted and  its strength was
      greatly reduced. The liner mate-
      rial  was still  soft and pliable, and
      it appeared  to be in  good con-
      dition.
    2. T16. The density increased 14.5
      percent, indicating some com-
      paction of the polymer; but there
      was little or no change in the
      breaking strength. Some small,
      crusty formations were observed
      on the liner/sludge interface.
    3. DCA-1295. The average density
      of this liner material decreased
      slightly (3.3 percent), but both the
      elongation and the breaking
      strength decreased significantly.
      Visual inspection revealed that  ,
      this liner was discolored and very  \

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   thin. The liner was very easily
   torn while it was being removed
   from the test cell.
4. Dynatech. A 17.3-percent increase
   in density indicates some sludge
   infiltration into the sprayed ma-
   terial or compression of the poly-
   mer, but the other physical data
   remained essentially unchanged.
   Discoloration noted could be due
   to chemical attack during the
   testing.
5. Uniroyal. A 17.2-percent increase
   in density indicates some com-
   pression of the  polymer and  in-
   corporation of sludge; the breaking
   strength decreased 40 percent.
   Liner  discoloration noted could
   indicate susceptibility to chemical
   attack.
6. Aerospray 70. A 33.3-percent  in-
   crease in density indicates con-
   siderable sludge incorporation
   and polymer compaction. The
   breaking strength decreased  57
   percent, although one of these
   test cells did not pass any leachate.
   Discoloration and thin spots were
   observed throughout the liner.
   Decomposition was noted on the
   membrane/soil interface.
7. AC40. The physical tests per-
   formed on  this  liner material
   made  it difficult to detect any
   chemical degradation of the liner.
   The average viscosity appeared
   to be very high at the end of the
   first 12 months,  but this figure
   had returned to nearly the original
   value by the end of 24 months.
   Leachate from these test cells
   was passing through the liner
   material  itself.  Chemical data
   indicate that this leachate con-
   tained four to six times the con-
   centrations of chromium, seleni-
   um, boron, and sulfate at 24
   months than at 12 months.
8. Asphaltic concrete. These physi-
   cal tests were identical to those
   for AC40  and essentially the
   same comments are appropriate.
9. Portland cement.  The density  of
   this liner  material remained es-
   sentially unchanged, but the DC
   strength increased 175 percent.
   Chemical data  indicate that
   leachate from the test cell con-
   tained approximately seven times
   higher concentrations of sulf ite
   and sulfate at 24 months. The
   liner was  soft and friable in iso-
   lated areas.
10. Lime. The 1.1 -percent increase
    in density of this liner material
    may indicate slight sludge infil-
    tration or compaction of the liner,
    but  it is more likely that this
    change represents a normal vari-
    ation in density across the speci-
    men. The DC values of this liner
    increased 464 percent. Chemical
    data indicate the leachate from
    the test cell contained 5 to 20
    times higher concentrations of
    chromium and boron after 12
    months, whereas the concentra-
    tions of magnesium, sulfate,
    nitrite, and nitrate were as much
    as 150 times lower.
11. Sucoat. This liner  was supplied
    preformed by the manufacturer,
    and it apparently suffered no
    chemical decomposition. One
    test cell ruptured under pressure
    and was discontinued. Chemical
    data indicate that leachate from
    the test cell contained twice the
    concentrations of magnesium
    and sulfate, five times the con-
    centration  of boron, and  100
    times the concentrations of nitrite
    and nitrate at 24 months than at
    12 months. The breaking strength
    was reduced 16 percent at  the
    end of 24 months.
12. TACSS 020 and  TACSS 025.
    Neither of these two liner mate-
    rials  evidenced any change in
    density other than the change
    normally expected  during a typi-
    cal construction procedure. Sludge
    penetrated the surface  of the
    liner more than 3/8 in. on each
    liner type.
13. Portland cement plus lime. No
    significant change in density oc-
    curred during the 24-month test
    (+0.3   percent).  Chemical data
    indicate that the leachate through
    the liner contained approximately
    40 times the concentration of
    chromium at 12 months than atO
    months, whereas the concentra-
    tion of magnesium decreased ap-
    proximately 0.01 times, and  the
    concentrations of nitrite, nitrate,
    and sulfate decreased 0.01  to
    0.001  times. The UC  strength
    increased 187 percent.
14. C400. No significant change in
    density occurred during the 24-
    month test (+0.3 percent). The UC
    strength increased 106 percent.
    The chemistry of  the  leachate
    through the test cell indicates
    that approximately three times
      the concentrations of arsenic and
      boron and 20 times the concen-
      trations of chromium and seleni-
      um were detected at 24 months
      than at  12 months.  Indications
      were that the copper and lead
      concentrations also increased.
  15. CST. No significant change in
      density occurred during the 24-
      month test (+0.3  percent). The UC
      strength increased 63 percent.
      The chemical concentration of
      the  leachate at  12  months in-
      creased  approximately 20 to 100
      times for sulfate and nickel,
      respectively.  Concentrations de-
      creased  by a factor of 0.001 for
      nitrite and nitrate and by approxi-
      mately 0.01 for magnesium.
  No definite trends were  established
from these tests that would permit the
projection of liner life with any degree of
accuracy.

Economic Assessments
  Assessments were  made of costs
involved with purchase and placement
of various  liner materials. Estimates
were based on  a typical 15-acre lagoon
that can accommodate 30  ft of water.
The* cost of the land  and the initial
preparation (grubbing, clearing, digging,
etc.) are not considered here, as they are
site specific. For the 15 acres, costs for
admix liner materials ranged from
$150,000 for  Portland cement, lime,
and  Portland cement plus lime to
$4,300,000 for TACSS 025.  Costs for
spray-on and membrane liner materials
ranged from  $33,000 for  AC40  to
$1,350,000 for Sucoat.  Total installation
cost for placing the  prefabricated mem-
brane liners was estimated  at $38,154.
This  cost included  laborers, operators,
equipment, fuel, and mobilization. The
largest part of this cost  occurred in
unfolding, stretching,  and  placing the
liners—30 laborers  at a cost of $10,080.
Construction costs for admix liners vary
with  the type of material and location.
  The full  report was submitted in ful-
fillment of Interagency Agreement EPA-
IAG-D5/6-0785 between the U.S. Envi-
ronmental Protection Agency and the
U.S. Army Engineer Waterways Experi-
ment Station.

References
1. Haxo,  H.E., and R.M. White. First
   Interim Report;  Evaluation of Liner
   Materials Exposed to Leachate (un-
   published). U.S.  Environmental Pro-
   tection Agency, Cincinnati, Ohio,
   1974.

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2. Haxo, H.E., and R.M. White. Second
   Interim Report;  Evaluation of Liner
   Materials Exposed to Leachate. EPA-
   600/2-76-255,  U.S. Environmental
   Protection Agency, Cincinnati, Ohio,
   1976.
3. Haxo, H.E.,  R.S. Haxo, and R.M.
   White. First Interim Report; Liner
   Materials Exposed to Hazardous and
   Toxic Sludges. EPA-600/2-77-081,
   U.S. Environmental Protection Agency,
   Cincinnati, Ohio, 1977.
4. Geswein, AJ. Liners for Land  Dis-
   posal Sites;  An Agreement. EPA-
   530/SQ-137, U.S. Environmental
   Protection Agency, Cincinnati, Ohio,
   1975.
5. Wilson, S.D.  Small Soil Compaction
   Apparatus Duplicates  Field Results
   Closely.  Soil Testing Services,  Inc.,
   Chicago, Illinois (undated).
Clarence R. Styron, III, Zelma B. Fry, Jr., and Gordon L. Carr are with the U. S.
  Army Engineers Waterways Experiments Station, Vicksburg, MS 39180.
Robert E. Landreth is the EPA Project Officer (see below).
The complete report, entitled "Effect of Flue Gas Cleaning Sludges on Selected
  Liner Materials," (Order No.  PB 81 -213 365; Cost: $9.50, subject to change)
  will be available only from:
        National Technical Information Service
        5285 Port Royal Road
        Springfield, VA 22161
        Telephone:  703-487-4650
The EPA Project Officer can be contacted at:
        Municipal Environmental Research  Laboratory
        U. S. Environmental Protection Agency
        Cincinnati, OH 45268
                                                                           > US GOVERNMENT PRINTING OFFICE 1981  757-012/7246

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United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Postage and
Fees Paid
Environmental
Protection
Agency
EPA 335
Official Business
Penalty for Private Use $300

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