United States
                    Environmental Protection
                    Agency
Hazardous Waste Engineering
Research Laboratory
Cincinnati OH 45268
                    Research and Development
EPA/600/S2-87/017 May 1987
v>EPA         Project  Summary
                    Characterization  of Hazardous
                    Waste  Incineration  Residuals

                    Donald Van Buren, Gary Poe, and Carlo Castaldini
                      The Office of Solid Waste and Emer-
                    gency Response (OSWER-EPA) is con-
                    sidering establishment of a criterion for
                    land disposal of waste or residue. This
                    criterion is based on the achievement of
                    residue quality equivalent to that from
                    effective incineration. The purpose of
                    this study was to provide data on the
                    quantities and characteristics of solid
                    and liquid discharges from hazardous
                    waste incineration facilities. A total of
                    10 facilities were  sampled comprising
                    major incineration designs and flue gas
                    treatment devices. All inlet and outlet
                    liquid and solid streams were sampled
                    and subjected to extensive analyses for
                    organic and inorganic pollutant concen-
                    trations. Laboratory analyses for solid
                    discharge streams also included
                    leachate  evaluations using standard
                    EPA toxicrty tests for metals and a draft
                    Toxicity Characteristic Leaching Proce-
                    dure (TCLP) for  volatile and
                    semivolatile organics and metals. Mon-
                    itored data on incinerator facility opera-
                    tion was  then used to determine the
                    discharge rates of detected pollutants.
                      This Project Summary was devel-
                    oped by EPA's Hazardous Waste Engi-
                    neering 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 infor-
                    mation at back).

                    Introduction
                      Under the 1985 amendments to the
                    Resource  Conservation and Recovery
                    Act (RCRA), the Environmental  Protec-
                    tion Agency (EPA) is required to ban the
                    land disposal of many hazardous
                    wastes unless their safe disposal can be
                    demonstrated. The  Office of Solid
                    Waste and  Emergency Response
(OSWER) is considering the establish-
ment of a criterion to require residue
quality equivalent to that from effective
incineration before residue land dis-
posal of waste or residue. EPA's Office
of Research and Development (ORD)
characterized stack gas emissions from
incinerators under a field testing pro-
gram in.support of OSWER's regulation
development process. This testing, con-
ducted at eight full-scale operating in-
cinerators,  assessed the incinerator's
achievement of a required destruction
and removal efficiency (ORE) of 99.99
percent(1). Previously, some analysis of
bottom ash, flyash, and scrubber dis-
charge liquid was conducted. The latter
effort, described herein, was under-
taken to achieve a more comprehensive
characterization of  incinerator bottom
ash and flyash from a greater number of
hazardous waste incineration facilities.
In addition to meeting OSWER's quality
criterion for  residues,  the Office of
Water's (OW) pretreatment discharge
standards will apply to facilities that
treat, store, or dispose of hazardous
wastes (TSDs). There exists, therefore, a
need to characterize any wastewater
discharged from an  incinerator burning
hazardous wastes.

Approach
  Criteria for candidate test site selec-
tion were based on site availability, op-
erational status and types of wastes in-
cinerated.  Preference was given to
those facilities incinerating solid
wastes, generating ash and employing
air pollution  control devices and to
those previously tested for air emis-
sions and thermal destruction. Ten sites
were selected, representing a broad
range of design and operating practice.
Six employed rotary kilns; three, fixed

-------
hearths;  and one, a fluidized bed. The
six rotary  kilns burned  liquid wastes
downstream of rotary combustors. Air
pollution control equipment (APCE)
ranged from uncontrolled to primarily
wet controls. Two sites had no control
equipment. All except those two had a
quench system and  a scrubber. Two
sites had wet scrubbers and also em-
ployed wet electrostatic precipitators.
Table 1 summarizes the ten incineration
configurations.
  During the site visits, the wastes fired
were typical  of those normally inciner-
ated.  In  two cases, solid hazardous
wastes were selected to provide a more
uniform feed to promote production of
a more  representative sample. The
wastes were not spiked  as is usual in
source testing operations. Table 2 sum-
marizes the sampled input and output
streams  and the analyses performed.
The typical test involved sampling non-
             gaseous incinerator inlet and outlet
             streams during a 2- to 4-hour period of
             operation. At Sites 2, 7, and 8, not all
             streams were sampled due to safety
             and/or proprietary concerns. Wastes
             not sampled included lab packs, hospi-
             tal wastes, nitrites magnesium scrap,
             and,  at one site, all drummed wastes.
             Concurrent with sampling, system op-
             erating information was also obtained
             to substantiate normal operation.
               The  samples were  analyzed for
             volatile and  semivolatile organics and
             priority pollutant metals in accordance
             with  EPA/OSWER procedures (2). Ash
             samples were also analyzed for
             leachate organics and metals. Two ex-
             traction procedure (EP) toxicity test
             methods were used, namely Method
             1310 in SW-846, the EP Toxicity Test
             Procedure, and a draft TCLP using the
             EPA draft protocol (3). Extracts from the
             former were analyzed for priority pollu-
                                        tant metals. Extracts from  the latter
                                        were analyzed for  priority pollutant
                                        metals and semivolatile organics, and
                                        for volatile organics, using a zero-head
                                        extraction vessel (ZHEV).

                                        Results

                                        Volatiles and Semivolatile
                                        Organics
                                          A total of 19 volatile organics and 24
                                        semivolatile organics were detected in
                                        the ash residual samples. Those present
                                        in the highest concentrations were
                                        toluene  (120 ppm), 2-butanone (34
                                        ppm), 4-methyl-2-pentanone (29 ppm),
                                        and  tetrachloroethane (16 ppm). Even
                                        the  low  volatiles concentrations re-
                                        ported in the ash would generally not be
                                        expected. However, these levels might
                                        be due to the ash adsorbing volatiles
                                        from quench water (Sites 1, 2, 3, 7, 8,
                                        and  9), flue gas, or air; products of in-
Table 1.   Hazardous Waste Incinerator Configurations and Waste IDs
Site No. Incinerator type    1
                     Rotary kiln with
                     secondary com-
                     bustor in parallel
                     with a liquid
                     waste-fired boiler
        2           34
        Rotary kiln    Rotary kiln Fluidized
        with secondary with sec-  bed incin-
        combustor in  ondary   erator
        parallel with a  combustor
        liquid injection
        combustor
                        5        67
                        Fixed hearth Fixed  Fixed
                        (2 separate hearth hearth
                        incineration       with sec-
                        systems)         ondary
                                                                                        8
                                     Rotary kiln with
                                     (secondary) liq-
                                     uid injection
                                     combustor.
                             combustor Drums also con-
                                     veyed through
                                     combustor
                                          9        10
                                          Rotary kiln Rotary kilr,
                                          with sec-  with sec-
                                          ondary    ondary
                                          combustor combustoi
EPA Waste identification no.
Incinerator ash quench
D001
F001
F002
F003
F005
X
D001 0001 None
D008 F001
F002
F003
F005
X X
0007
F001
F002
F003
F005

D001 D001
F003 F001
F005 F002
F003
F005
X
D001
D002
D006
D007
D008
D009
F001
F002
F003
F005
U002
X
(rotary kiln only)
0007
F001
F002
F003
FOOS
X
0007
F001
F002
F003
FOOS
X
(But no
ash during
testing)
Secondary combustion
  chamber with liquid
  waste injection

Hot-gas cyclones

Quench

Scrubber + demister

Acid absorbers
X

X

X
X

X

X
Waste heat recovery boiler        X
                     (liquid-waste fired)

Wet ESP's

No control device
  (Constraints on fuel and
  firing rates)

Selective material reburning
X

X



X


X
X

X

X
X

X
X

X
X       X

X       X

        X
                                                                  X
                                                              (drums and
                                                                residue)

-------
 Table 2.   Summary of Samples Collected and Analyses Performed for 10 Hazardous Waste Incineration Facilities

                                                                               Analyses
       Stream description
Site numbers
Volatiles    Semivolatiles
 Priority
pollutant
 metals
  EPII
procedure
Draft
TCLP
  PCB
identity3
Input Streams
  APCE aqueous supply                   8            X
  Aqueous or low-Btu waste             1 and 5          X
  Coating waste solids                    7            X
  Chloroprene catalyst sludge              2            X
  CS tear gas powder                     4            X
  DCS coke solids                        2            X
  Drum feed liquids                      3            X
  Drum feed solids                    3 and 9          X
  Lacquer chips                          6            X
  Lacquered cardboard waste              5            X
  Latex coagulum solids                   7            X
  Liquid injected waste fuels           1, 3, 5 to 10        X
  PCB-contaminated dirt                   1            X
  PCB liquid waste                        1            X
  Unused automotive paint                2            X
  Vacuum filter solids                     2            X

Output Streams
  APCE aqueous effluent              1 to 4, 7 to 10       X
  Boiler tube soot blowdown               3            X
  Cyclone ash                         1 and 4          X
  Incinerator bottom ash                 5 to 8           X
  Wastewater treatment facility belt
    filter cake residue                  3 and 7          X
  Rotary kiln ash                     1 to 3,8,9         X
  Stack condensate                       4
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X
                               X

                               X
                               X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X
                             X

                             X
                             X
                X
                X
                X

                X
                X
              X
              X
              X

              X
              X
"Site 1 only.
APCE = Air polution control equipment
  CS = O-chlorobenzalmalonitrile
 DCS = 1,4-Dichlorobutene-2
complete combustion (PICs) (especially
possible with Site  4) or  early  ash
quenching  before  completed  ash
burnout  (possible with Sites 3 and 8).
Except for Site 4, where the feed mate-
rial was  a relatively pure chemical, o-
chlorobenzalmalononitrile (CS), the
volatile organics found  also appear in
the waste feed. The cyclone ash from
Site 4 shows several compounds  that
appear to be PICs. Because the cyclone
ash was  periodically  emptied, and al-
lowed to fall freely  during the cyclone
draining  procedures,  it was likely  that
the volatiles observed were  adsorbed
while the ash was in the cyclone and/or
during the free fall upon draining.
  In general, most organic compounds
were detected at  less  than 10 ppm.
Since most sites quench ash with water,
especially if a rotary kiln discharges
solid waste feed too quickly, it is possi-
ble for some of the organics to not be
subjected to high enough temperatures
for complete destruction (thus, the ap-
pearance of the organics in  the ash).
     Also, the quench water is often recycled
     plant wastewater which  may experi-
     ence a  buildup of these organic com-
     pounds and contaminate  the  ash (c.f.,
     wet and dry ash from Site 8).
       The total organic content in  each ash
     stream, calculated by  adding  the con-
     centrations of all hazardous organic
     compounds (RCRA, Appendix VIII) de-
     tected,  indicated that  kiln and bottom
     ash have similar semivolatile organic
     content with  average concentrations
     measured approximately 100 mg/kg.
     Average volatile organic  content was
     higher for the kiln ash. The bottom ash
     average would be increased, however,
     if values were deleted for  Site 5's large
     incinerator  (since  that incinerator
     burned only liquid waste) and Site  8's
     bottom ash (since that ash was predom-
     inantly  generated from liquid waste).
     Average teachable volatiles and
     semivolatile organics for  each type of
     ash were less than 1  mg/L  or 1  ppm.
     RCRA organics with the highest concen-
     tration in the TCLP leachates were
                              toluene (1.7 ppm), phenol (1.8 ppm),
                              methylene chloride and dimethyl phtha-
                              late (each at about 0.6 ppm), and MEK
                              (0.3 ppm).
                                Volatile and semivolatile organics,
                              detected in various APCE effluents, indi-
                              cate that the highest concentrations of
                              volatile organics were in the APCE efflu-
                              ent at Site 5. Since the cyclone ash sam-
                              ple at this site also contained volatile
                              organics, these compounds may be at-
                              tributed to  byproduct emissions from
                              the incinerator. Site 1 and 8 practice ex-
                              tensive water recirculation in compari-
                              son to the  other sites which practice
                              only some APCE effluent  recirculation
                              prior to discharge to an onsite  waste-
                              water treatment facility. Because of this
                              higher recirculation, Site 1  and 8 APCE
                              effluents are expected to  have  higher
                              than average organic content in agree-
                              ment with results of this study.

                              Priority Pollutant Metals
                                Analytical results for metals concen-
                              trations in all ash residual  samples are

-------
summarized in Table 3. Figures 1 and 2
show the ranges in total priority pollu-
tant metals experienced in ash and ash
leachate samples. The kiln ash indicates
an average priority pollutant metal con-
centration of about 1  percent (10,000
ppm). The same average is lower for the
bottom  ash. Boiler ash from Site 3 has
the highest concentration of metals, as
indicated in Table 3. The small ash parti-
cle size at  this site resulted in a high
surface-to-mass ratio which favors
metals condensation.
  EP and TCLP metal analysis results il-
lustrated in Figure 1 indicate that
leachate concentrations are highest for
boiler ash.  Kiln ash leachate would be
expected to have more metals than bot-
tom ash leachate, but one very low zinc
concentration  apparently substantially
skewed the EP toxicity kiln ash data.
  Table 4 shows the highest metals con-
centrations experienced in  all leachate
test  samples. EP leachate concentra-
tions are also compared with applicable
EP toxicity limits (standards set forth in
Table 4 of 40 CFR 261.24).  The results
indicate that only 1  metals measure-
ment of the EP leachate, out of 84 meas-
urements performed for  the whole
study, exceeded the maximum concen-
tration of  contaminants for  characteris-
tics of EP toxicity. Hence, only the boiler
ash at Site 3 (see Table 3),  with a cad-
mium content of 8.6 mg/L versus an al-
lowable standard of 1  mg/L, would be
considered  a  hazardous waste for
metals not already listed in 40 CFR Sub-
part  D. The TCLP leachate,  if subjected
to the  same standards, would  have 3
measurements  out of 84 exceeding an
allowable concentration. Site 3 boiler
ash would exceed the standards for cad-
mium at 6.7 mg/L, and selenium at 1.4
mg/L versus  an allowable standard of
1 mg/L. Site  6 ash would exceed the
standard for lead at 12 mg/L versus an
allowable 5 mg/L. In general, the results
from the two  different extraction proce-
dures were within a factor of three.
  For leachate analysis, approximately
20 units of acidic water are used  for
each unit of ash. Thus, leachate concen-
trations  (in mg/L) are expected to be
about 20 times less than reported ash
values (in mg/kg) for 100 percent solu-
ble metals. Although several metals in
ash concentrations are at less than de-
tectable  limits and cannot be further
evaluated, solubility generally ranged
from 1 to 10  percent. Metal concentra-
tions greater than 1000 mg/kg of ash,
included chromium  (Site 3), copper
 Table 3.   Concentration of Priority Pollutant Metals in Incinerator Residuals
Site number
Stream
description
1
Kiln ash
2
Kiln ash

3
Kiln ash


3
Boiler ash

4
Cyclone ash
5
Large incinerator
bottom ash
Concentration'

Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Tnsllium
Zinc
Comments
Wet or Dry Ash
Site number
Stream
description
(mg/kg)/ (mg/L) /(mg/L)
2 / <0.05 / 0.04
4 / 0.23 /<0.01
<1 / <0.01 /<0.01
<2 / <0.01 / <0.01
120 / 0.10 / 0.22
6900 / 8.6 1 16
220 / 2.3 / 3.5
<0.05/<0.001/<0.001
190 / 0.49 / 0.45
<1 /<0.05 / 0.02
11 /<0.01 /<0.01
160 / 0.14 / 0.42

Wet
5
Small incinerator
bottom ash
(mg/kg) / (mg/L) / (mg/L)
6 K0.01 /<0.01
2 / <0,01 / <0.01
<2 / <0.01 / <0.01
<1 / <0.01 / <0.01
110 / 0.09 / 0.10
840 / 3.7 / 7.9
100 / <0.01 / <0.01
1.5/<0.001/<0.001
7300 / 6.9 / 6
6 / 0.02 / 0.05
8 / 0.05 /<0.01
640/1.8/2

Wet
6
Incinerator
bottom ash
(mg/kg)
18
3
<7
<7
660
400
610
<0.1
240
13
4
•J
21000

Wet



/ (mg/L) /
/ 0.06 /
/ <0.01 /
/<0.01 /
/<0.01 I
/ 0.03 /
I 0.02 /
/ 0.04 /
KO.OOM
I 0.79 /
/ 0.17 /
1 0.02 /
/ 27 1


7
Incinerator
bottom ash
(mg/L)
<0.01
<0.01
<0.01
<0.01
0.06
0.09
<0.01
<0.001
13
1.4
0.05
<0 02
300





(mg/kg)/
190 /
14 /
6 I
61 /
1800 /
780 /
5000 /
0.2 /
4700 /
13 /
190 /
9 /
32000 /

Wet



(mg/L) /
<0.01 /
<0.01 /
<0.01 /
8.6 /
0.03 /
31 /
4.4 /
<0.001 /
20 /
<1 /
0.09 1
0 7^ /
1400 /


a
Kiln ash

(mg/L)
<0.01
<0.01
0.08
6.7
0.36
21
4.5
<0.001
13
1.4
0.05
<0 02
1200





(mg/kg)/ (mg/L) / (mg/L)
<1 /<0.01 /<0.01
< 1 / <0.07 / 
-------
 1000,000
   10,000
    1,000
     100
                                                            Average
                                                        Legend
                  Kiln
                  Ash
Bottom
Ash
Boiler
Ash
Cyclone
Ash
Figure 1.    Total and a verage priority pollutant metals concentrations in ash.
    1,000
     100
      Wi
0 £/>///



v///////
A
i i
LJ

7

\\x\x\\\x\\xx
~u
^ Average

Legend
<



V///////////.
X
\
X
/
/
/
',
-
f-f^
••*

Kiln Bottom Boiler Cyclone
Ash Ash Ash Ash
Figure 2.    Total and average metals concentrations in ash leachate.
 (Sites 1, 7, and 8) lead (Sites 3, 5, 6, and
 8), nickel (Sites 2 and 3), and zinc (Sites
 3 and 8). Most of the leachate measure-
 ments for antimony, arsenic, beryllium,
 cadmium, lead, selenium, silver,  and
 thallium yielded values less than the de-
 tectable limits nominal of 0.01  to 0.05
 mg/L of leachate. Mercury leachate
 measurements were all less than 0.001
 mg/L of leachate.
  These high concentrations in the ash
 did not always yield a good mass bal-
 ance. Most notably, the calculated dis-
 charge  rate for chromium (Site 3), cop-
 per (Site 1), and lead (Site 6), exceeded
 the calculated feedrate to the incinera-
 tor by a factor of 10.  Copper (Site 7)
 showed a discharge rate 100 times the
 feedrate accountable by the waste feed
 samples. There are several possible rea-
 sons for these results. First, process
 data were not available for Site 5, and
 all streams were not sampled for Sites 7
 and 8; thus these mass balances cannot
 be accurately  made for those sites. In
 general, to improve representativeness
 of the samples, and to better close a
 metals  mass balance,  would have re-
 quired more sampling (and analysis) of
 input and output streams over a longer
 test period.
  APCE water effluents were also ana-
 lyzed for priority pollutant metals. The
 results are summarized in Table 5. Two
 sites  which  most effectively limit dis-
 charging a wastewater effluent
 (through high recirculation), Sites 1 and
 8, have the highest concentration of
 metals, 2,475 and 51 mg/L, respectively.
 The wastewater effluents for these sites
 were also found to contain higher than
 average organic levels. A comparison of
 these metals  concentrations with EP
 toxicity limits reveals that the Site 1 ef-
 fluents would  be considered  toxic for
 cadmium (3.5 mg/L), chromium (11 mg/
 L), and lead (860 mg/L), while the efflu-
 ent from Site  8 would be  considered
 hazardous for cadmium (2.8 mg/L), lead
 (31 mg/L), and  selenium (2.1  mg/L).
 Sites with an apparent low effluent re-
 circulation rate, such as Site 9, appear to
 have  low metals concentration in  the
APCE effluent (2.3 mg/L).

 Recommendations
  On the  basis of the  data presented
above, Acurex recommends that more
sampling  and analysis of hazardous
waste incinerator  residues be under-
taken. Specifically,  we recommend:
  • Retesting,  intermittently over a pe-
    riod of perhaps 4 to 6 months, two
    or three of the sites already tested.

-------
This will allow EPA to evaluate the
variations in residue quality over
time at one site.
• Testing incinerator sites which
have dry APCE systems in place.
Two of the sites already tested will
have their wet systems removed,
and dry systems installed. The "dry
sites" could also be new incinerator
facilities.
• Testing sites which typically burn
more chlorinated wastes,
• Testing some younger (in age) in-
cinerators and those with more
state-of-the-art equipment and con-
trols
• Testing enough new incinerator
sites to increase the data base to at
least 20.
Table 4.




Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc


Highest Metals Concentrations


Toxicity
limit
5
—
1
5
—
5
0.2
1
5

—


in Ash Leachate in mg/L
EP


Concentration
0.49
0.23
<0.01
8.6
0.98
31
4.4
<0.001
20
0.17
0.09
0.05
1400





TCLP
Concentratic
0.36
0.54
0.08
6.7
0.36
21
12
<0.001
13
1.4
0.05
0.18
1200


References
1. Trenholm,  A.,   P.  Gorman,   and
  G. Jungclaus. Performance Evalua-
  tion of Full-Scale Hazardous Waste
  Incinerators. Midwest Research Insti-
  tute, Kansas City, Missouri.
2. "Test Methods for Evaluating Solid-
  Waste-Physical/Chemical Methods,"
  SW 846 Second Edition, U.S.  EPA,
  April 1984.
3. "Toxicity  Characteristic  Leaching
  Procedure (TCLP)," U.S. EPA draft re-
  vised, December 20, 1985.
Table 5.    Concentrations of Priority Pollutant Metals in APCE Aqueous Effluents, in mg/l

Site number     1234        78"       9        10
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total
0.1
0.2
<0.01
3.5
11
550
860
0.06
<0.02
0.09
<0.01
<0.01
950
2380
<0.01
<0.01
<0.01
<0.01
<0.05
<0.04
<0.01
0.013
23
<0.01
<0.02
1.3
0.02
24.3
0.61
<0.01
<0.01
0.04
0.1
0.26
2.6
0.013
0.17
<0.01
0.04
16
16
35.7
<0.01
<0.01
<0.01
<0.01
0.06
<0.04
<0.01
<0.001
0.05
<0.01
<0.02
0.02
0.27
0.4
1.7
0.06
<0.01
0.08
0.28
0.64
2.6
<0.005
0.75
0.6
0.05
0.16
6.7
13.6
4.1
0.4
0.01
2.8
3.8
2.2
31
<0.005
1.5
2.1
0.15
1.6
1.6
51.3
<0.03
<0.1
<0.01
<0.01
0.27
0.46
0.38
<0.005
0.07
<0.1
0.61
0.31
0.16
2.26
0.1,
<0.1
<0.0
<0.0
0.2
0.0
0.1
<0.0
0.4
0.2
<0.0
0.0
0.1
1.3
                                        'Highest values used for aqueous effluent recirculated from two cooling ponds.
                                           Donald VanBuren, GaryPoe. and Carlo Castaldini are withAcurex Corporation,
                                             Mountain View, CA 94039.
                                           Paul Warner is the EPA Project Officer (see below).
                                           The complete report, entitled "Characterization of Hazardous Waste Incineration
                                             Residuals,"(Order No. PB 87-168 159/AS; Cost: $18.95, 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:
                                                   Hazardous Waste Engineering Research Laboratory
                                                   U.S. Environmental Protection Agency
                                                   Cincinnati,  OH 45268

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United States                        Center for Environmental Research
Environmental Protection               Information
Agency                             Cincinnati OH 45268
Official Business
Penalty for Private Use $300

EPA/600/S2-87/017
          0000329   PS
                                           60604

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