United States Environmental Protection Agency Water Engineering Research Laboratory Cincinnati OH 45268 Research and Development EPA/600/S2-86/004 Mar. 1986 4>EPA Project Summary Evaluation of Activated Carbon for Enhanced COD Removal from Pharmaceutical Wastewater Richard Osantowski and Richard Wullschleger Two activated carbon technologies were evaluated for pharmaceutical wastewater treatment: powdered acti- vated carbon (PAC) added to an acti- vated sludge system (PACT®) and granular activated carbon (GAC) treat- ment of pharmaceutical plant second- ary effluent. The lack of information on applicable removal technologies for total chemical oygen demand (TCOD) prevented promulgation of best avail- able technology economically achiev- able (BAT) limitations and new source performance standards (NSPS) for TCOD for pharmaceutical manufactur- ing plants in 1983 (EPA/440/1-83/ 084). The purpose of this study was, therefore, to evaluate the ability of these technologies to achieve con- sistent reductions in the effluent TCOD of pharmaceutical wastewaters. Pharmaceutical wastewaters from a manufacturing plant that produces fermentation products (Subcategory A) and chemical synthesis products (Sub- category C) were treated in trailer- mounted pilot plants. The biological treatment train consisted of three activated sludge systems operated in parallel. PAC was added to two of the units in selected dosages. The third unit was used as a control. The physical- chemical treatment train consisted of chemical coagulation with alum and anionic polymer, pH adjustment with caustic (when needed), clarification, multi-media filtration, and GAC ad- sorption. The PAC-enhanced biological treat- ment train reduced effluent TCOD well below the level required by best practi- cable control technology currently available (BPT). PAC also improved the settling rate of the mixed liquor sus- pended solids over that of the control. However, a viscous floating mass of mixed liquor solids developed in the PAC units (but not in the control) and resulted in premature termination of the study. The GAC physical-chemical treatment train also reduced pharma- ceutical plant effluent TCOD below the average BPT level. This Project Summary was devel- oped by the EPA's Water Engineering Research Laboratory, Cincinnati, OH, to announce key findings of the re- search project that is fully documented in two separate volumes of the same title (see Project Report ordering infor- mation at back). Introduction In November 1982, the U.S. Environ- mental Protection Agency (EPA) pro- posed effluent limitations and standards (EPA/440/1-82/084) for the pharma- ceutical manufacturing point source category. Some of the proposed regula- tions limited the discharge of TCOD, a nonconventional pollutant, from existing and new pharmaceutical manufacturing facilities. However, because of a lack of information on applicable TCOD removal technologies, limitations and standards for TCOD were not promulgated along with the other regulations on October 27, 1983. In April 1984, EPA decided to conduct pilot-scale performance evaluations of ------- activated carbon treatment technologies using actual pharmaceutical waste- waters. The purpose of these studies was to evaluate the ability of these technolo- gies to achieve consistent reductions in the effluent TCOD of pharmaceutical wastewater. At a Subcategory A and C pharma- ceutical manufacturing plant that used secondary treatment and reported high TCOD concentrations in their discharge monitoring report, two technologies were evaluated: 1. PAC addition to the activated- sludge aeration basin, and 2. GAC treatment of the secondary effluuent. Quality Assurance/Quality Control Methods Sample analyses were conducted on- site in a field laboratory and in a base laboratory in another state. All samples were collected by the pilot plant op- erators using prelabeled containers. Analyses for TCOD, soluble chemical oxygen demand (SCOD), total biochemi- cal oxygen demand (TBOD), nitrogen- inhibited biochemical oxygen demand (NIBOD), nitrogen-inhibited soluble bio- chemical oxygen demand (NISBOD), chloride, total suspended solids (TSS), and volatile suspended solids (VSS) were performed at the onsite laboratory. All other analyses were performed at the base laboratory. The base laboratory also provided computer support to the field and base laboratories for analytical scheduling, sample labeling, chain of custody, and other quality assurance/ quality control (QA/QC) functions. All samples were refrigerated after collection and were iced during shipment to the base laboratory. Samples that were analyzed onsite were analyzed the same day they were collected, and no addi- tional chemical preservation methods were required. Samples sent to the base laboratory for phosphate, nitrogen, and total organic carbon (TOC) analyses were preserved with sulfuric acid addition to pH2. TCOD and SCOD analyses were per- formed by the Hach* colorimetric method (Federal Register, Vol. 45, No. 78, April 21, 1980). All other analyses for the conventional parameters were per- formed according to the procedures de- scribed \r\Methods for Chemical Analysis of Water and Wastes (EPA/600/4-79/ 020, U.S. Environmental Protection 'Mention of trade names or commercial products does not constitute endorsement or recommendation for use. 2 Agency, Cincinnati, Ohio, 1979). At least 10 percent of all samples were analyzed in replicate for all conventional para- meters. At least 5 percent of all samples were spiked with appropriate reagents for analysis of all conventional para- meters except TSS and VSS. Blanks and reference samples were analyzed for each analytical run or sample lot. QA/QC objectives for precision were to have a maximum of 20 percent dif- ference between replicates for TBOD, NIBOD, NISBOD, and VSS. A maximum of 15 percent difference between repli- cates was sought for all other conven- tional parameters. Accuracy objectives were ± 20 percent spiked sample re- covery for TBOD, NIBOD, and NISBOD, and ±15 percent spiked sample recovery for other parameters. Of 652 replicate samples, 618 (94.8 percent) were within the precision per- cent difference criteria. Of 322 spiked samples, 303 (94.1 percent) were within the percent recovery objectives. In all, 3,732 analyses were performed, with 1.5 percent of the analytical results deleted for QA/QC reasons. The project had a 98.1 percent completion rate. Biological Study From September to December 1984, an 83-day study was conducted using one biological pilot plant as the control and two biological pilot plants as the experimental (PAC-fed) systems. The three activated sludge units were op- erated in parallel. System Operation Raw pharmaceutical wastewater was collected just before it entered the full- scale aeration basins and was used as the feed to the pilot plants. This flow consisted of neutralized and equalized pharmaceutical waste combined with a nominal amount (=* 6 percent) of mac- erated, chlorinated sanitary waste. The two experimental activated sludge systems were identified as biological treatment system nos. 1 and 2 (BTS-1 and BTS-2). Each system consisted of an aeration tank (5,940 L in BTS-1 and 5,560 L in BTS-2) and a 2,840 L circular center feed clarifier. Each aeration tank had three aeration cells in series, and the air flow to each cell was controlled in- dependently. Pumps were used to supply wastewater, return sludge, and add chemicals to each system. PAC slurry was pumped to the first cell of the ex- perimental systems, and sodium hydrox- ide was pumped to all three systems as needed to maintain an adequate pr range. The control pilot plant (BTS-3) con sisted of an aeration tank with three aeration cells in series (total volume o 180 L) and a 47-L secondary clarifier Peristaltic pumps were used to fee< wastewater to the system, to recirculat< settled sludge, and to waste sludge. Th< raw wastewater was pumped to a mixei equalization tank that served as the feei reservoir for each of the three pile plants. The targeted aeration basin hydrauli retention times (HRT's) and solids re tention times (SRT's) were 3 and 10 days respectively, for all systems. Thesi values were similar to those used in th full-scale plant before the start of th pilot plant tests. Solids were wasted fror the third cell of each aeration basin t allow a more positive contrrsttest perioc 208 and 827 mg/L of PAC were added t the influents of BTS-1 and BTS-2, re spectively, and in the second test perioc 496 and 1,520 mg/L of PAC were adde to BTS-1 and BTS-2, respectively. Daily composite samples were take from the raw feed wastewater and fror the three clarifier effluents using autc matic sampling equipment, and from th wasted mixed liquor obtained from th waste solids holding tanks. Test Phases The planned pilot plant operation wa scheduled for a series of five phases a described below: Phase 1 — Start-up The three biological pilot plants wer operated for 10 days after being seede with mixed liquor from the full-seal aeration basins. The objective of th phase was to determine whether th effluents were comparable for each < the three pilot plants. Phase 2 — Acclimation Following Phase 1, PAC addition to th influents was initiated for BTS-1 ar BTS-2 at rates of 208 mg/L and 82 mg/L, respectively. Single doses of PA (as a 10-percent slurry) were added each aeration cell of BTS-1 and BTS each day for the first 10 days to reach th calculated equilibrium PAC concentr tion, and the operation of all three uni was continued for an additional 13 day Phase 3 — Intensive Test Perio Pilot plant operation continued for 1 days with Phase 2 operational cone tions, but the frequency of sampling ai analysis was increased. ------- Phase 4 — Transition and Acclimation PAC feed to the influent of BTS-1 and BTS-2 was increased to 496 and 1,520 mg/L, respectively. Single doses of PAC (as a 10-percent slurry) were again added to each aeration cell of BTS-1 and BTS-2 for each of the first 10 days to reach the calculated equilibrium PAC concentra- tions. Operation was planned to continue until steady state conditions were achieved based on effluent SCOD mea- surements. Following equilibrium attain- ment, a second 2-week intensive sam- pling period (Phase 5) was to be con- ducted; but as discussed below, Phase 5 was not initiated. Operational Problems During Phase 3, the pH began to de- crease significantly in all three systems. Samples collected for nitrogen analyses confirmed that nitrification was occuring in the three systems and the addition of caustic was initiated to maintain the mixed liquor pH near 7. BTS-1 and BTS-2 also showed evidence of significant denitification in the clarifiers, which caused some of the sludge to float. The sludge recycle rates for these systems were increased in an attempt to maintain amall sludge inventories in the clarifiers and thereby minimize the floating sludge in the experimental clarifiers. Near the end of Phase 4, a viscous floating layer of mixed liquor suspended solids (VFMLS) formed on the surface of the clarifiers and the aeration basins of the two PAC-fed systems. This layer re- sulted in significant reductions in the mixed liquor suspended solids (MLSS) in the aeration basins of BTS-1 and BTS-2. The VFMLS developed first in BTS-1 and about 10 days later in BTS-2. The phenomenon did not occur in BTS-3, the control system. As a result of this problem, the Phase 5 intensive test period was cancelled. However, data generated during Phase 4, just before the onset of the viscous layers, were used to evaluate the effects of the 496 and 1,520 mg/L PAC feed rates to BTS-1 and BTS-2, respectively. Also, during Phase 4 (prior to the VFMLS formation), the aera- tion basin effluent line plugged and the MLSS overflowed the aeration basin of BTS-2; this resulted in a significant loss of both volatile MLSS (MLVSS)and PAC. As a result, the data presented later for the 1,520 mg/L PAC system were col- lected when the system was not in equilibrium, at least as far as the MLSS concentration was concerned. Test Results Feedwater Quality TSS averaged 639 mg/L for 83 samples. The raw waste TCOD was quite variable, ranging from 2,260 to 12,000 mg/L, and it averaged 7,030 mg/L. The average TBOD concentration was 2,830 mg/L, with a range from 1,700 to 4,400 mg/L. Nitrogen and phosphate were present in adequate amounts in the raw wastewater (BOD:N and BOD:P ratios were less than 20 and 100, respectively). Pilot Systems During Phase 1, the effluent SCOD from BTS-1 and BTS-2 averaged 754and 770 mg/L, respectively, whereas the effluent from BTS-3 averaged 849 mg/L. This variation did not result from design differences between the pilot plants but from an initial problem created by the use of a different (colder) air supply for aera- tion of BTS-3. Once this fact was recog- nized, heaters were installed in the aera- tion basin of BTS-3 to raise the tempera- ture to that of the other two systems. The average Phase 2 temperatures of 31°, 32°, and 30°C for BTS-1, BTS-2, and BTS-3, respectively, demonstrated that this problem was corrected. Table 1 summarizes the average op- erating parameters and effluent quality during Phases 3 and the latter part of Phase 4. Average HRT's ranged from 3.0 to 3.1 days, and average SRT's ranged from 9.4 to 10.0 days. During Phase 3, average aeration basin temperatures ranged from 31.5° to 32.5°C, and during Phase 4, they ranged from 27° to 28°C and from 24° to 27°C for the two interim test periods, respectively. Average MLSS for the control system (BTS-3) during the three time periods ranged from 4,770 to 4,790 mg/L. For the experimental systems (BTS-1 and 2), the average MLSS concentrations ranged from 5,850 to 8,830 mg/L as the PAC addition to the influent was increased from 208 to 1,520 mg/L. The addition of PAC resulted in some improvement in sludge settleability; however, the MLSS settling rate re- mained at very low levels (from 0.01 to 0.05 cm/min). The effect of the PAC on the average effluent SCOD concentra- tions is also shown in Table 1. During Phase 3, PAC feed rates of 208 and 827 mg/L resulted in effluent SCOD'sof 459 and 265 mg/L, respectively, compared with 825 mg/L for the control. During Phase 4, a PAC feed of 496 mg/L re- sulted in an effluent SCOD of 314 mg/L compared with 670 mg/L for the control. A PAC feed of 1,520 mg/L to BTS-2 in Phase 4 produced an effluent with 194 mg/L of SCOD, and the control effluent contained in 583 mg/L. As discussed earlier, the MLSS in BTS-2 during Phase 4 was not in equilibrium. If it had been, the effluent SCOD would probably have been less than the reported 194 mg/L. Physical-Chemical Study Concurrent with the biological study, final effluent from the full-scale treat- ment system was treated in trailer- mounted pilot plants. The physical- chemical treatment train consisted of chemical coagulation with alum and anionic polymer; pH adjustment with caustic (when needed); clarification; multi-media filtration; and GAC adsorp- tion. The TSS removal technologies were used for pretreatment of the wastewater before carbon adsorption because of the high TSS concentrations (an average of 341 mg/L and a range of 65 to 1,560 mg/L. Pretreatment for TSS removal was necessary, but optimizing this pretreat- ment was not an objective of this study. Initially, an attempt was made to op- erate the carbon columns in the down- flow mode. However, a combination of rapidly changing chemical demand of the feed water plus poor performance of the multi-media filter created a large carry- over of TSS to the carbon column system. As a result, the carbon columns had to be backwashed several times during this run. A review of the first run's results determined that design deficiencies in the backwash system of the carbon columns were causing the bed to be mixed during this procedure, so the re- sults were not representative. Design changes were implemented, and a sec- ond run was initiated in the upflow mode. Feed Wastewater Characteristics Table 2 summarizes the pilot plant feed wastewater characteristics during the entire study as determined from 24- hr composite sample analyses. Pretreatment Results The pilot-scale clarifier and filter were run continuously throughout the testing program. The feed rate to the pilot clarifier was 17 to 23 L/min (4.5 to 6.0 gpm). This was equivalent to an overflow rate of 9 to 13 m3/day-m2 (230 to 305 gal/day-ft2). Chemical treatment before clarification consisted of alum, anionic polyelectrolyte, and caustic addition (as needed for pH control). Chemical feed concentrations were based on onsite jar testing. Required alum and polymer 3 ------- Table 1. Operating Parameters and Average Effluent Quality During Phase 3 and the Latter Part of Phase 4 Phase 3 Latter Part of Phase 4 Pay 34-47 Day 62-65 Day 71-76 Operating Parameter BTS-1 BTS-2 BTS-3 BTS-1* BTS-3 BTS-2" BTS-: Operational data: Feed flow, L/min PAC flow, L/min RS flow, L/min^ Waste ML flow, PAC dosage, mg/L F/M, g COD/g MLSS-day** HRT, days SRT, days Mixed liquor data: Temperature, °C pH (range) DO, mg/Lft TSS. mg/L Effluent data: TCOD. mg/L SCOD, mg/L TOO. mg/L NIBOD. mg/L NISBOD, mg/L TSS, mg/L VSS. mg/L Removals: A verage feed TCOD, mg/L TCOD removal, % 1.34 0.018 3.01 0.420 208 3.1 9.5 32.5 4.1-7.5 3.3 5850 585 459 158 16 <6 85 60 8120 92.8 1.26 0.018 408 0.367 827 ND 3.1 10.0 32 4.5-7.7 3 4 7690 532 265 110 15 <5 190 158 8120 93.4 0.044 0 0.163 0.013 0 0.64 3.0 9.4 31.5 6.0-8.7 4.3 4790 1070 825 290 27 <8 143 109 8120 86.8 1.38 0.031 3.80 0.419 496 ND 3.0 9.7 27 6.0-7.2 3.6 7000 454 314 115 NA NA 59 50 7420 93.9 0.045 0 0.092 0.013 0 0.69 3.0 9.8 28 6.6-8.1 5.0 4770 770 670 NA NA 44 46 7420 89.6 1.27 0.032 6.37 0.374 1520 ND 3.0 10.0 24 6.7-7.5 3.4 8830 334 194 NA 12 3 108 76 6810 95.1 0.04' C 0.09' o.oi: ( 0.7i 3.C 9.t 2. 6.1-7.' 4.i 4781 68! 58: to It 9i 7( 681 ( 89.. * Data for periods just before onset of VFMLS on surfaces of aeration basins and secondary clarifiers t Return sludge ft Mixed liquor ** Food to microorganism ratio t Not determined ji Dissolved oxygen § Not analyzed dosages ranged from 200 to 1,340 mg/L and from 0.2 to 3.0 mg/L, respectively. About 0.8 m3 (200 gal) of sludge was produced for every 3.8 m3 (1000 gal) of wastewater treated based on 30-min settling tests. Following chemical treatment and clarification, the pharmaceutical plant effluent was filtered using a downflow granular multi-media filter with an effec- tive filtering area of 0.1 m2 (1.0 ft2). The filtration rate during the study ranged from 100 to 120 L/min-m2 (2.5 to 3.0 gpm/ft2). Filter media consisted of two grades of garnet sand (15 cm each) covered by silica sand (38 cm) and a top layer of anthracite coal (51 cm). Table 3 summarizes the pretreatment efficiency. All analyses except temperature (grab) were performed on 24-hr composite samples. At the end of the study, exami- nation of the multi-media filter revealed that 41 cm (16 in.) of media had been lost and that some intermixing of the media had occurred. The conclusion was that this situation was created by a design deficiency in the filter backwash system, and therefore, the filter removals were not representative. GAC Results Four columns were operated in series in the upflow mode. Each of the four columns had an effective area of 0.1 m2 (1.0ft2). Insufficient time was available to select an optimum carbon. Calgon's Filtrasorb 300 was chosen because of its successful application on similar waste streams. Virgin carbon was used in each of the four columns. Clarified and filtered pharmaceutical plant final effluent was pumped through the activated carbon columns. Each of the four GAC columns was loaded with 1.3 m (4.3 ft) of carbon. The system was operated at a hydraulic flow rate of 37 L/min-m2 (0.9 gpm/ft2), which resulted in an empty bed contact time (EBCT)of 35 min per column, or 140 min total. Grab samples were collected once per day from five locations around the activated carbon columns during the GAC run. These included the influent anc effluent from each column. The sample: were analyzed for SCOD. This GAC run was conducted over 42 days of operation. During this period 199,830 L (52,795 gal) of pretreatec pharmaceutical plant effluent was treatec by the GAC columns. Each day during the study, the time and cumulative flow totalizer readings were recorded at the time of sampling. This information was used to prepare SCOD breakthrough curves. Breakthrough is defined as the pro cessing time (or volume) after which the impurity concentration in any of the carbon column effluents is no longei acceptable. From each curve, the time and volume processed to reach an SCOC breakthrough of 300, 400, and 500 mg/1 were calculated. The carbon usage rate in kg/1,000 I (lb/1,000 gal) can be determined b] ------- dividing the weight of carbon in each column by the volume processed to breakthrough. Pilot study results showed that the carbon use to maintain an effluent SCOD concentration of 300 mg/L or less decreased from 3.1 to 2.1 kg/1,000 L (26 to 18 lb/1,000 gal) as the EBCT was increased from 35 to 140 min, respectively. For a 400 mg/L or less SCOD effluent, the carbon use ranged from 2.6 to 1.7 kg/1,000 L (22 to 14 lb/1,000 gal), and for a 500-mg/Lor less effluent SCOD, the. carbon use ranged from 1.9 to 1.2 kg/1,000 L (16 to 10 Ib/ 1,000 gal) as the EBCT was increased from 35 to 140 min. Daily 24-hr composite samples were also collected of the GAC influent and final effluent and analyzed for TSS, TBOD, TCOD, and SCOD. Table 4 sum- marizes the removal efficiencies for each of these parameters. Note that the averages in Table 4 are for the entire run and not for some specific effluent SCOD concentration. Identification of Specific Organic Compounds To identify the specific organic con- stituents in the pharmaceutical plant effluent, a series of mass spectral and infrared studies was carried out by several laboratories. A composite sample of biologically treated pharmaceutical plant final effluent was collected on March 14, 1984, and submitted to three independent laboratories for gas chro- matography/mass spectrometry (GC/ MS) low-resolution analysis. Approxi- mately 17 peaks were observed by each of the laboratories. An extract of a composite sample made from the control pilot plant effluent collected from October 17 to 21, 1984, resulted in a chromatogram with approxi- mately 9 of the 17 major peaks having mass spectra similar to those determined from the March 14 sample. A major component in the gas chro- matogram of the biologically treated effluent from the pilot plant control was tentatively identified as 2-butyl-4-amino- 5-pyrimidyl-carbinol by a combination of high-resolution GC/MS, low-resolution GC/MS, gas chromatography/Fourier transform infrared spectrophotometry, and chemical information concerning the manufacturing processes at this plant. The concentration of this component was approximately 4 mg/L. Dimethylphenol was also identified as a minor component. Conclusions Conclusions regarding the biological pilot study are as follows: Table 2. Summary of Feed Wastewater Characteristics Parameter Average Range TBOD. mg/L TSS. mg/L TCOD. mg/L SCOD. mg/L pH, units Temperature, °C 151 (33)* 341 (8JJ 1410 (57) 830 (551 24 (57) 61-360 65-1560 730-3180 412-1330 7.7-8.6(80) 14-40 *Parenthesis indicate number of observations. Table 3. Pretreatment Efficiency Parameter Influent Effluent % Removal TSS. mg/L TBOD. mg/L TCOD. mg/L SCOD, mg/L pH , units Temperature, °C 301 158 1360 828 7.7-8.6(67) 14-37 (42) 121 81 877 657 6.4-8. 1 (67) 15-36 (42) 60 (70)* 49 (29) 35 (43) 21 (51) ^Parenthesis indicate number of observations. Table 4. Average Removal Efficiencies for Activated Carbon Parameter Influent (mg/L) Effluent (mg/L) i Removal TSS TBOD TCOD SCOD 87 121 914 651 75 >85 432 25 1 14 (38)* <30(14) 53 (42) 61 (42) 1. PAC addition to the activated sludge process can increase the SCOD removal from pharmaceuti- cal manufacturing wastewater. 2. The PAC/activated sludge process cannot be recommended as a viable process for this plant's wastewater until the cause of the VFMLS is identified and adequate safeguards against its occurrence are demonstrated. The results of the physical-chemical study are as follows: 1. GAC treatment can reduce the secondary effluent SCOD to 200 to 400 mg/L. 2. The chemical clarification and multi-media filtration technologies provide adequate pretreatment for operation of the downstream GAC. 3. The combination of biological treat- ment and GAC can reduce the in- fluent TCOD from 7,060 mg/L to an average effluent SCOD of 200 to 400 mg/L. 4. Carbon use is a function of the effluent SCOD concentration and the EBCT. A summary of the carbon use rates determined from the pilot study is shown in Table 5. Table 5. Carbon Use. kg/1.000 L Design Effluent SCOD. mg/L EBCT, min 300 400 500 35 70 105 140 3.1 2.1 2.8 2.1 2.6 2.1 2.1 1.7 1.9 1.9 1.5 1.2 The full report was submitted in fulfill- ment of Contract Numbers 68-02-3928 to Rexnord and 68-01-6675 to E.G. Jordan Company with Rexnord and Environmental Science and Engineering, Inc., acting under a subcontract to E.G. Jordan Company under the sponsorship of the U.S. Environmental Protection Agency. "Parenthesis indicate number of observations . S. GOVERNMENT PRINTING OFFICE:1986/646-l 16/20789 ------- Richard Osantowski and Richard Wullschleger are with Rexnord, Inc., Milwaukee, WI43214. Clyde R. Dempsey is the EPA Project Officer (see below). The complete report consists of two volumes entitled "Evaluation of Activated Carbon for Enhanced COD Removal from Pharmaceutical Wastewater:" "Volumel. Final Report," (Order No. PB86-148 160/AS; Cost $16.95, subject to change). "Volume II. Appendices,"(Order No. PB 86-148 178/AS; Cost $28.95, subject to change). The above reports will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Water Engineering Research Laboratory U.S. Environmental Protection Agency Cincinnati, OH 45268 United States Environmental Protection Agency Center for Environmental Research Information Cincinnati OH 45268 u.s.ornc!AL MAL Official Business Penalty for Private Use S300 EPA/600/S2-86/004 ft V OH '" -' •' • ^- '^Kb--\ : Q 3 t * - W -J • - 0000329 PS ------- |