United States
                   Environmental Protection
                   Agency
                   Research and Development
Industrial Environmental
Research Laboratory
Cincinnati OH 45268
EPA-600/S2-84-150  Nov. 1984
SEPA          Project Summary
                    Environmental  Characterization
                    of  Disposal  of Waste  Oils by
                    Combustion  in  Small
                    Commercial  Boilers
                    Paul F. Fennelly, Mark McCabe, Joanna M. Hall, Mary F Kozik, Marilyn P. Hoyt,
                    and Gary T. Hunt
                     In this project, air emission tests
                    were conducted on seven boilers in the
                    size range 0.4 to 15 x 10' Btu/hr while
                    these boilers were firing waste oil. The
                    main purpose of the project  was to
                    document the extent to which chemical
                    contaminants  in  waste  oil are  de-
                    stroyed during the  combustion pro-
                    cess. These data are of interest because
                    one of the  more common and wide-
                    spread practices for disposing of waste
                    oils is burning as a supplemental fuel.
                     Chemicals which were spiked into
                    the waste oil before combustion  in-
                    cluded: chloroform,  1,1,1-trichloroeth-
                    ane, triehloroethylene, tetrachloroethy-
                    lene, trichlorobenzene,  1-chloronaph-
                    thalene,  2,4,5-trichlorophenol,   and
                    chlorotoluene. Destruction efficiencies
                    ranged from 99.4 to 99.99 percent. Con-
                    centrations of these chlorinated hydro-
                    carbons in the flue gas ranged  from 40
                    to  400 M-g/m3. The concentrations of
                    lead and zinc in the flue gas ranged be-
                    tween  5,000 and 72,000  M.g/m3  and
                    3,000 and 34,000 |xg/m3, respectively.
                    The average emission rate of HCI from
                    the seven boilers was 2.6 Ib/hr.
                      This Project  Summary  was  de-
                    veloped by EPA's Industrial Environ-
                    mental Research Laboratory, Cincin-
                    nati, 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 back).
Purpose and Scope of the
Project
  In recent years the environmental im-
pact of the disposal of used oils has
been a growing  concern.  Numerous
studies conducted by state and Federal
agencies have documented the pres-
ence of contaminants such as polynu-
clear aromatics (PNAs), chlorinated hy-
drocarbons and heavy metals in sam-
ples of used motor oils. One of the more
common and widespread practices for
disposing of used oils is burning as a
supplemental  fuel.  In  some  cases,
waste oil is burned directly; in others, it
is blended with other fuel feedstocks.
  The  disposal of waste materials in
boilers is of particular interest because
to date, there has been little documen-
tation of the extent to which chemical
contaminants in waste oil are destroyed
during the combustion process.
  In this project, tests were conducted
on boilers in the size range of 0.4 to 25
x 106 Btu/hr. These are commonly clas-
sified  as commercial sources, as op-
posed to industrial or electric utility
sources. Commercial boilers are of par-
ticular interest with regard to waste oil
disposal for  several reasons. These
units generally would use untreated or
poorly characterized waste fuels. They
could be expected to provide less effi-
cient combustion because of the gener-
ally intermittent mode of operation.  In
addition, their widespread distribution
and their low stack heights makes their
emissions more proximate to the gen-
eral population.

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  Seven  boilers were designated for
testing in the program. The units were
selected  so as to provide a representa-
tive  cross section of the  commercial
boiler population. A 4000-gallon lot of
used  automotive oil  was  obtained in
order to  maintain  a consistent supply
of waste  fuel for the program. Portions
of the base  stock oil were spiked with
predetermined amounts of selected or-
ganic compounds which  are  typically
found in  waste oil and  in  some cases
are considered hazardous waste mate-
rials.  The selected  compounds  were
chloroform,  1,1,1-trichloroethane, tri-
chloroethylene, tetrachloroethylene, tri-
chlorobenzene, 1-chloronaphthalene, 2,
4,5-trichlorophenol, and chlorotoluene.
  Table 1 shows data comparing a typi-
cal spiked waste oil feed in this project
with data from a cross section of repre-
sentative waste oils.
  Measurements  were  conducted at
each of the sites to determine the atmo-
spheric emissions of particulate, inor-
ganic compounds (principally lead and
HCI),  and volatile organic and semi-
volatile organic material.  The destruc-
tion and  removal efficiencies (ORE) for
each  of  the spiked  components were
also determined. A listing of the boilers
and a summary of the tests conducted
at each site are presented in Table 2.

Test Results

Destruction and Removal
Efficiencies
  In  general, the data of  the  principal
atmospheric emissions indicate that the
emission rates of  the  principal inor-
ganic components, lead and HCI, were
substantially higher than  the organic
emissions from the  six  boilers tested.
The  average paniculate emissions for
the six boilers tested was determined
to be 0.7  Ib/hr (0.3 lb/106 Btu heat input).
Combustion efficiencies, calculated for
each of the  boilers, ranged from 99 to
greater than 99.9 percent.
  The flue gas emissions of the organic
compounds of interest  correspond to
destruction and removal efficiencies of
99.4 to  99.99  percent as indicated in
Table 3.  There were no  strong correla-
tions between  destruction  efficiency
and boiler size or firing technique. One
trend that is apparent from the data is
that the  destruction efficiencies for the
semivolatile  compounds   are  consis-
tently higher than  those of the volatile
compounds.  The  fact  that  generally
higher DREs  were  achieved for the
semivolatile components,  trichloroben-
Table 1.    Concentrations of Selected Contaminants in 24 Representative Waste Oils—
          Compared With a Typical Spiked Oil Used in This Project

                                              Concentration
                                       Representative oils3
Contaminant
Average
  Flange
Typical "spiked oil,'
   (this project)
Elements

  Aluminum
  Arsenic
  Barium
  Cadmium
  Chlorine
  Chromium
  Iron
  Lead
  Magnesium
  Vanadium
  Zinc

Volatile Organics

  Trichlorotrifluoroethanes
  1,1,1-trichloroethane
  Trichloroethylene
  Tetrachloroethylene
  Toluene
  Chloroform

Semivolatile Organics
   45
    12
   66
     1
  2260"
     6
   240
  1100
   260
     3
   800
   410
   700"
   600
   400"
  3100
   1-640
 < 1-100
  10-160
 < 1-2.8
  50-27,000
 <1-37
  60-980
350-2060
   5-590
 <1-13
  90-1550
<20-1900
<20-14,800
<20-4900
<20-13,000
380-12,000
        10.2
        14.0
        59.5
         2.2
     12,000
         7.1
       168
      1,520
       200
         2.2
       743
      3,500
        50
      3,100
      2,800
      2,500
Phenol
2,4,6-trichlorophenol
N-nitrosodiphenylamine
Benz(a)anthracene
Benzofajpyrene
4,4'-DDE
PCBs
Trichlorobenzene
1-chloronapthalene
25
<5
<5
20
<5
<5
<5
—
—
<5-70
<5-< 10
<5-< 10
<5-40
<5-30
<5-< JO
<0. 1-65
—
—
10
1,000
<10
16
—
—
<6
1,800
1,500
a Taken from U.S. DOE Report. No. DOE/BC/10375-6, Oct. 1983.
*Average value does not include maximum value shown in range.
—Denotes data not available or not investigated.
zene, 1-chloronaphthalene and trichlo-
rophenol, is consistent with the ranking
of the spike compounds on  the  EPA
Hierarchy of Waste Incinerability.
  Generally  the  lowest  DREs  were
found in site A, the only boiler rated at
less  than 1 x 106  Btu/hr. This  unit nor-
mally fires a No. 2 fuel oil  and  its adap-
tion  to firing waste oil proved difficult.
Eventually dilution of the waste oil on a
1:1 basis with No. 2 oil was required for
acceptable operation.  Even with  this
modification, the combustion efficiency
and  destruction efficiencies were sig-
nificantly lower than the other units.

Concentrations of
Contaminants in Combustion
Gases
  The concentration ranges in the stack
gas  of the compounds  studied within
the program are given in the full report.
   In general, concentrations ranged from
   40 to 400  |xg/m3 for the volatile com-
   pounds and from about 10 to 50 M-g/m3
   for the  semivolatile compounds. On  a
   volume/volume (v/v)  basis,  these  are
   very low concentrations. As an exam-
   ple,  a range of 40 to 400  jjig/m3 for  a
   compound  such  as  trichloroethylene
   corresponds to a  concentration of 7.4
   to 74 parts per billion (ppb) on a vol-
   ume/volume basis. Conducting emis-
   sion tests  at these low concentrations
   required extensive refinement of avail-
   able    emission    source    testing
   techniques.


   Lead and Other Metal Emissions
     The samples of flue gas particulate
   collected at each site were  analyzed for
   a  total of 27  metals  by  Inductively
   Coupled   Argon   Plasma    Emissions
   Spectroscopy (ICAP)  techniques. Lead

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Table 2.    Boiler Descriptions
Rated
Site capacity Method of
description KfBtulhr Boiler type atomization
A 0.5 Cast iron Mechanical
B° 1.0 Scotch firetube 2 pass Rotary cup
C 2.4 Horizontal return tube Rotary cup
D 2.7 Scotch firetube 3 pass Air
E 3.4 Scotch firetube 4 pass Rotary cup
F 4.2 Scotch firetube 3 pass Air
G 12.5 Scotch firetube 4 pass Air
'Boiler not available for testing in the program due to problems with the burner
Table 3. Calculated Destruction and Removal Efficiencies (%)
A C D
Volatile Compounds
Chloroform 99.65 99.91 99.96
Trichloroethane 99.78 99.95 99.97
Trichloroethylene 99.45 99.92 99.89
Perchloroethylene 99.74 99.91 99.86
Semivolatile Compounds
Trichlorobenzene 99.84 99.98 99.96
1-chloronaphthalene 99.95 99.95 99.95
2,4,5-Trichlorophenol >99.97 >99.99 —
and zinc were present at concentrations Other metals that receive
substantially higher than any other tention were arsenic, ca
trace metals. The lead concentrations in chromium. These were gen
the flue gas samples ranged from 5,380 enough concentrations in t
jxg/m3 to 72,400 |o,g/m3 corresponding to so that when diluted in the
Site
description
Office building
Dairy complex
Greenhouse
Office building
Greenhouse
Greenhouse
Greenhouse
assembly and fuel feed system.

E F

99.90 99.94
99.37 99.80
99.85 99.92
99.73 99.85

99.90 » 99.96
> 99.94 99.98
^99.92 »99.98
Spike level
of each Total
component number of
(ppm) test runs
1,500, 3
3,000 3

3,000 3
3,000, 3
1 0,000 3
3,000, 3
5,000 3
3,000 3
5,000 3
3,000 3
10,000 1


Average by
G compound

99.95 99.88
99.93 99.80
99.87 99.82
99.96 99.84

99.89 >99.92
99.92 >99.95
— >99.97
d special at- sistent with the much higher ash con-
dmium and tent of waste oil, which can range from
erallyatlow 0.15 to 1.5 percent. Particulate sizing
ie stack gas measurements conducted at four test
atmosphere sites indicated that 80 to 90 percent of
an average emission rate of 0.12 Ib/hr.
Calculations based  on  simplified mod-
els have  shown  in some cases, lead
emissions at these levels could cause
violations of ambient  air quality stan-
dards  for lead. The concentrations of
zinc in the flue gas ranged from 3,100
to 34,000 fJLg/m3, corresponding to an
average emission rate of 0.06 Ib/hr. The
ratio between lead  and zinc emissions
was generally 2:1, consistent with their
concentration in base  stock oil, which
was 1,550 ppm and  760 ppm by weight,
respectively. Lead and  zinc compounds
are commonly found in waste automo-
tive  oil and result  from  both gasoline
and oil additives.
they should not cause major problems,
but the situation is still of some concern
as the concentration  of these metals
could be substantially higher  in other
waste oil base stocks (e.g., see Table 1).
  The  results of  metal emissions are
summarized in Table 4.

Particulate and Chloride
Emission
  Particulate  emission rates at the six
sites ranged from 0.07 to 1.2 Ib/hr with
an average value of 0.73 Ib/hr (0.34 Ib/
106 Btu heat input).  This is significantly
higher than the literature value of 0.09
lb/106 Btu for commercial boilers firing
residual oil, but the  higher value is con-
the particulates containing lead are sub-
micron in nature and would be readily
inhalable.
  The flue gas emissions of HCI from
the six boilers averaged 2.6 Ib/hr. This
is  a  relatively high emission rate for
such small units, but it is below the 4.0
Ib/hr air emission standard established
for hazardous waste incinerators, which
would typically burn large quantities of
chlorinated compounds similar to those
used in this program.
  Mass  flow calculations  indicate that
50 to 60 percent of the lead and chloride
introduced into the boilers exists from
the system in the flue gas streams. The
analysis of samples of firetube ash col-

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lected at a single site indicates concen-
tration levels of lead and chloride in the
ash on the order of 1 to 2 percent. Data
from the stack gas  emissions coupled
with the chemical analysis of the  fire-
tube fly ash and the waste oil provide
for material balance closures at about
65  percent for  the  total system.  This
was considered  a  reasonable  closure
for the  purpose  of this project  and
further  investigative work on  the re-
maining 35 percent was not performed.

Products of Incomplete
Combustion
  The flue  gas samples from each site
were screened by gas chromatography/
mass spectrometry (GC/MS) for addi-
tional organic components considered
to be potential  products of incomplete
combustion. The types of compounds
which were identified are given in the
full report.  In general, the components
were nonchlorinated in nature and were
representative of  the  types of com-
pounds that result from the combustion
of traditional fossil fuels. These com-
pounds were also  very typical of  con-
taminants  sometimes  found  on the
blank sample adsorbing medium, XAD-
2 resin.  The extent to which these com-
pounds, when detected, resulted from
combustion byproducts or  from resin
contaminants could not be determined;
hence,  the concentrations  could be
viewed  as upper limits for many of the
nonchlorinated  products of incomplete
combustion. During the course of this
program,  there  were  some baseline
runs done  on conventional  No. 4 fuel
oil. As expected, no chlorinated hydro-
carbons were detected in the stack gas,
with  detection  limits being 8  jjig/m3.
With  conventional No. 4 oil, combus-
tion products such as naphthalene and
similar  PAH compounds were  100 n-g/
m3 or less.
  Chlorinated  dibenzofuran  (PCDF) or
chlorinated dioxin (PCDD) species were
detected in 15 of the 25 samples anal-
yzed as shown in Table 5. The concen-
tration  of  these  compounds  ranged
from 0.07 to 17 (ig/m3. On a volume/vol-
ume basis, this corresponds  to a range
of 7 to 470 parts per trillion (ppt).
  Bulk samples of firetube ash collected
at one of the sites contained parts per
billion  levels of 11 PCDF  and PCDD
isomers on a weight by weight basis.
Because chlorinated dioxins and chlori-
nated dibenzofurans were found in the
flue gas, tests were also conducted on
the waste oil base stock, both  spiked
Table 4.    Concentrations of Metals in Flue Gas (\>.g/m3)

Site               A         C          D          E
Arsenic
Cadmium
Chromium
Lead
Zinc
11.2
31.2
62 2
9,680
5.150
655
102
166
72,400
33,700
26.1
8.3
112
5.390
3.134
106
182
230
20,300
12.100
251
350
205
49.800
26,800
286
81
263
51,000
27,000
Table 5.    Average Concentrations in Stack Gas of Dibenzofuran and Dioxin Species from
          Tests Exhibiting Detectable Levels fog/m3)
Dibenzofuran
Chlorodibenzofuran
Dich/orodibenzofuran
Trich/orodibenzofuran
Tetrachlorodibenzofuran
Dibenzodioxm
Chlorodibenzodioxin
Dichlorodibenzodioxin
Tetrachlorodibenzodioxin
Octach/orodibenzodioxin
62(5)
0.8(3)
1.9(2)


1.3(3)




5.4(2) 3.4(5)
0.52(1)" 0.7(3)
0.07(1)
0.43(2)


0.27(1)
0. 18(1)

4.5(1)"
8.0(5) 16(3)
0.4(2) 2. 1(1)"
0.24(1)

0. 17(1)
0.73(1)

1.6(1) 2.4/1)

17(1)"
2.7(3)







1.4(1)

'Samples from 5 tests analyzed.
''Samples from 2 tests analyzed.
'Samples from 3 tests analyzed.
"Quality assurance samples indicate potential loss.
() number of tests in which component was detected.
and unspiked to determine the extent
to which  these  types  of  compounds
might be present in the oil. No chlori-
nated dioxins or chlorinated dibenzofu-
rans were found  in either the spiked or
unspiked oil.

Test  Methods

Waste Oil Analysis
  Waste feed samples were analyzed
for chloride,  metals and  the  organic
spike components. The chloride content
of the fuel was determined  by Parr Oxy-
gen Bomb Combustion followed by Ion
Chromatography (1C) analyses.  Metals
concentrations  were  determined  by
means of ICAP. The samples were pre-
pared for ICAP analysis by a controlled
dry ashing procedure utilizing IR lamps.
  The volatile organic  analysis of  the
waste fuel was accomplished by extrac-
tion followed  by purge and trap GC/MS
techniques in accordance with  EPA
Method 624 procedures. Sample prepa-
ration followed procedures as given in
Method A101B5, with the  substitution
of tetraglyme (tetraethylene glycol di-
methylether)   for   the   polyethylene
glycol normally specified. Tetraglyme is
similar in nature to polyethylene glycol,
but was found to contain fewer poten-
tially interfering contaminants.
  The analysis of the waste oil for the
semivolatile  components  of  interest
was performed using a gas chromato-
graph equipped  with an electron  cap-
ture detector (GC/ECD). Initial analysis
of the waste oil employing silica gel
chromatographic cleanup  and GC/MS
techniques was determined to be inap-
propriate due to the unacceptable sam-
ple recoveries for trichlorobenzene and
trichlorophenol.

Combustion Gas Sampling and
Analysis
  The determination of volatile organic
concentrations in the flue gas was car-
ried out  using a  gas chromatograph
equipped with an electron capture de-
tector (GC/ECD). Duplicate, integrated
samples of flue  gas were collected in
nonreactive Tedlar bags and injected
into the instrument using a heated gas
sampling  loop. Each  of the  samples,

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were analyzed in duplicate, with replica-
tion sample values to within  ±10 per-
cent as the criterion for acceptance. The
accuracy of the calibration standards
developed for the analysis were verified
by comparison  of NBS traceable stan-
dards.
  A modified Method 5 train equipped
with an XAD-2  resin trap was used to
collect particulate, semivolatile organic
compounds,  metals  and HCI  compo-
nents from the  flue gas of  the boilers.
The particulate, XAD-2 resin and flue
gas condensate samples from the train
were  combined and solvent extracted;
analysis  of solvent extracts was con-
ducted using capillary GC/MS. Aliquots
of these  sample aliquots were further
concentrated for subsequent analysis
for polychlorinated dibenzofuran and
polychlorinated dibenzodioxin species.
The  analysis was  conducted using  a
quadrupole  Hewlett Packard 5985 GC/
MS system fitted  with  a fused silica
capillary  column.
  A single set  of  Method 5 samples
from  each  site  was subjected to  inor-
ganic analysis for chloride and particu-
late metal determinations.  Samples of
the collected   gas  condensate  were
analyzed for chloride by direct injection
on an Ion  Chromatograph. Particulate
samples  from the train were prepared
for metal determinations by a hot nitric
acid leach followed by ICAP analysis.
  Additional  samples of  particulate
were collected at four sites using an An-
dersen High Capacity Sampling System
(HCSS) for particle size determinations.
The size fractionated particulate (10 (xm,
10-3 fxm, 3-1 (Jim and 1  n-rn) were ex-
tracted using 3M nitric acid and ana-
lyzed  for lead using atomic absorption
spectrophotometry.
  Samples of  firetube ash were col-
lected for chloride, metals and  semi-
volatile organic analysis.  The methods
for the trace metal and organic determi-
nations  are as described  above. Ali-
quots of  the samples were subjected to
a hot aqueous  leach to extract soluble
chloride  species followed by 1C analy-
sis. Additional  samples were analyzed
by EP Toxicity  in accordance with the
procedures  outlined  in  §260.20 and
§260.21

Quality Assurance Procedures
  Quality control  checks  were  per-
formed to ensure the collection of rep-
resentative samples and the generation
of valid  analytical  results.  Blank sam-
ples including field  biased  blanks and
method blanks, were used to assess the
possible contamination of the samples.
Duplicate  and  spiked samples were
routinely employed during the program
to verify the precision and accuracy of
the analysis.
  EPA quality control concentrates and
NBS  Standard  Reference  Materials
were used where appropriate to assess
the analytical work.  A comprehensive
systems audit was  conducted  during
the program to ensure that the  project
goals and  requirements set forth in the
Quality Assurance Plan were  met.

Conclusions
  Although a sample population of six
boilers is very limited, several general
conclusions  can  be reached regarding
the combustion  of waste automotive
fuels in boilers in this size range.
  1. It is possible to achieve combus-
    tion efficiencies greater than 99.9
    percent for small commercial boil-
    ers firing waste oils.
  2. Destruction  and removal efficien-
    cies of  greater than 99.9 percent
    can be obtained for chlorinated or-
    ganic contaminants typically pres-
    ent in waste oils. For the volatile
    compounds studied (chloroform,
    trichloroethylene,  trichloroethane
    and perchloroethylene), destruc-
    tion and removal efficiencies were
    on  the order of 99.9 percent. For
    the semivolatile compounds, (tri-
    cnlorobenzene,  1-chloronaphtha-
    lene,  and  trichlorophenol), de-
    struction and removal efficiencies
    were on the order of 99.95 percent.
  3. For boilers  above 1 x  106 Btu/hr
    input, there were no apparent cor-
    relations between boiler size or fir-
    ing method and destruction effi-
    ciency of organic contaminants.

  4. Inorganic  components,  as  op-
    posed to organic components of
    waste   oil,   have   substantially
    greater mass emission rates to the
    atmosphere as a result of the com-
    bustion  of automotive waste oils.
    The principal inorganic compo-
    nents of concern are lead,  hydro-
    chloric acid and total particulate.
    Also of potential concern are arse-
    nic, cadmium and chromium. The
    particulate lead  emissions from a
    source may, during the peak heat-
    ing season,  affect the compliance
    with the primary ambient air stan-
    dard for lead. A significant percen-
    tage of  the  particulate lead emis-
   sions is submicron  in nature and
   would be readily inhalable.
5. Detectable levels of emissions of
   polychlorinated    dibenzofurans
   and   polychlorinated   dibenzo-
   dioxins compounds were found in
   some of the boilers tested. These
   compounds, when present,  were
   usually at levels less than 5 (xg/m3,
   which is less than 0.5 part  per bil-
   lion by volume in the  stack gas.
   The extent to which these  com-
   pounds pose a hazard at these low
   levels is undetermined.
   Tests were done on the base  stock
   waste oil, with and without the
   spiked contaminants, to determine
   the extent to which the oil  may
   have  contained trace   levels  of
   dioxin. No dioxin or dibenzofuran
   compounds were  detected in any
   of the oil samples; detection limits
   were 200 ppb by weight for TCDD
   and TCDF.  If dioxin compounds
   were present at or below their de-
   tection limits,  such  a quantity
   would not be large enough to ac-
   count for the observed levels in
   the stack gas even with zero per-
   cent destruction. Therefore, dioxin
   and  dibenzofuran  found  in the
   stack  gas  most  probably  was
   formed  during the  combustion
   process.
6. The fly ash deposited  in the fire-
   tubes  of the boilers may contain
   percent levels of lead and parts per
   billion levels of chlorinated diben-
   zofuran and dioxin compounds.
   The ash has the potential for being
   classified  as  hazardous on  this
   basis, and  may  be  subject  to
   hazardous waste  regulations for
   disposal.
                                                                                         '•USGPO: 1984 — 559-111/10724

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    Paul F. Fennelly, Mark McCabe, Joanna M Hall, Mary F. Kozik, Marilyn P Hoyt,
      and Gary T Hunt are with GCA Corporation, Bedford, MA 01730
    Harry Freeman and Michael Petruska are the EPA Project Officers (see below)
    The complete report, ent/tted  "Environmental  Characterization of Disposal of
      Waste Oils by Combustion in Small Commercial Boilers, "(Order No PB85-105
      880, Cost: $17.50, subject to change) will be available only from:
            National Technical Information Service
            5285 Port Royal Road
            Springfield, VA 22161
            Telephone. 703-487-4650
    Harry Freeman can be  contacted at-
            Industrial Environmental Research Laboratory
            U.S. Environmental Protection Agency
            Cincinnati, OH 45268
    Michael Petruska can be contacted at:
            Office of Solid Waste
            U.S Environmental Protection Agency
            Washington, DC 20460
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
     BULK RATE
POSTAGE & FEES P
        EPA
   PERMIT No  G-35
Official Business
Penalty for Private Use $300

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