United States
Environmental Protection
Agency
Industrial Environmental Research
Laboratory
Research Triangle Park NC 27711
Research and Development
EPA-600/S7-81-071b Dec. 1981
Project Summary
Environmental Assessment:
Source Test and Evaluation
Report Coal Preparation
Plant No. 2
J. Buroff, A. Jung, L. McGilvray, and J. Strauss
This Project Summary presents the
results and conclusions of a Source
Test and Evaluation Program
conducted at a coal preparation
facility. The major objective of the test
program was to perform a screening
Environmental Assessment (Level 1)
on the discharge streams and fugitive
emissions of the facility.
Results from the Source Analysis
Model IA(SAM/IA)evaluation for the
multimedia streams sampled
indicated that all streams, except for
fugitive particulates, contained some
constituents which may have a
potentially harmful health or
ecological effect. For streams which
showed potential for ecological
effects, manganese was found to be of
concern; for streams which showed a
large health-related value, manganese
and chromium were of prime concern.
The leachate .results showed high
ammonia concentrations. Further
investigation of the ammonia source is
warranted.
The Ames assay test results for all
fugitive particulates were negative.
However, the health-related RAM
assay produced moderate effects. The
fine refuse sedimentation pond
waters, and fine refuse slurry samples
indicated a moderate biological effect.
For leachates, all health-based
bioassay tests showed a low or
nondetectable effect; however, the
coal and coarse refuse leachate
composite and the pond sediment
composite produced a moderate
effect on the ecological-related algae
test.
The results of this environmental
assessment and future Level 1
Environmental Assessments
performed on other coal preparation
facilities will identify those
substances in a given waste stream
that are the most potentially harmful
and will determine the need for further
characterization of the discharge
streams and development of control
technology.
This Project Summary was devel-
oped by EPA's Industrial Environ-
mental Research Laboratory.
Research Triangle Park. NC. to
announce key findings of the research
project that is fully documented in a
separate report of the same title fsee
Project Report ordering information at
back).
Introduction
Versar, Inc., of Springfield, Virginia,
under contract to the U.S.
Environmental Protection Agency -
Industrial Environmental Research
Laboratory (EPA-IERL) at Research
Triangle Park, North Carolina, is
performing a comprehensive
environmental assessment of coal
preparation technologies. A significant
part of this assessment involves Source
-------
Fine
Refuse
Desi/tiny
and
Feedwater I Transfer
Pond
Coarse Coal Coal
J Storage
S//o
\28M x 0.28M x 60M
Lj ^*Y Disc
Filter
*Streams sampled for Source Test and Evaluation Task
Figure 1. Schematic flow diagram of coal preparation Plant No. 2.
Test and Evaluation (STE) programs at
operating coal cleaning facilities. The
primary objective of each STE program
is to perform a screening (Level 1)
Environmental Assessment that char-
acterizes multimedia emissions from
the source, assesses the data on a
health and ecological basis, and
evaluates the effectiveness of pollution
control systems.
The field testing program is designed
to determine the physical, chemical,
and relative toxicological character-
istics of coal preparation plant effluent
streams sampled at their respective
sources. The results of the Level 1
testing and analysis provide the
quantities of pollutants in process and
effluent streams and identify those
areas of the process needing additional
control technology development. The
field testing program is not designed to
assess the environmental quality of the
general vicinity of the cleaning plant.
Therefore, results of the present testing
program cannot be used to evaluate
cause/effect relationships between
discharge stream characteristics and
ecological effects observed in the field.
General Plant Description
The coal cleaning plantchosenforthe
second assessment is representative of
a group of cleaning plants that
processes run-of-mine (ROM) coal with
high pyritic sulfur (>2 percent) content,
uses high technology coal cleaning
processes, operates in an environment
with high rainfall [> 60 cm/yr (> 25
in./yr)],and has a low soil
neutralization potential (pH > 6.0). A
schematic flow diagram of coal
preparation plant No. 2 is shown in
Figure 1.
Preparation plant No. 2 is a 1,088
Mg/h (1,200 tph) coal washing plant. Its
yield is approximately 888 to 912 tph of
clean coal (i.e., 74 to 76 percent yield).
The plant cleans Illinois No. 6 coal to a
yield product that has an average sulfur
content of 2.7 percent (as received) and
an energy content of about 27,000
kJ/kg (11,600 Btu/lb). Proximate and
ultimate analyses for ROM coal, clean
coal, and coarse refuse are shown in
Table 1.
The plant processes the coal by first
screening the stored ROM coal over a
I
To Fine
Refuse Sump
stationary primary screen. Everything
above 5 in. is sent to the rotary breaker,
and the underflow from the screen is
blended with the product from the rotary
breaker and placed on the incoming raw
coal distribution belt. The 5 in. xOcoal is
then fed to a two-stage Baum Jig for
primary washing. The clean coal from
the Baum Jig is dewatered on a 3/16-
in stationary screen, and the overflow
goes through a double-deck washed
coal screen. The product of the top
screen is 5 x 1-Vi in. clean coal.The
clean coal is fed to a crusher to produce
a top size of 1-1/2 in. and then fed onto
the clean coal load-out belt, The over-
flow from the bottom screen (1 -Vz x 3/s-
m. coal) is dewatered in centrifuges and
loaded onto the clean coal belt The
underflow from the washed coal
screens, which is predominantly 3/a-in.
x 0 material, goes to the washed coal
sumps.
The middlings product from the two-
stage Baum Jig is sent to a middling
screen for size separation. The overflow
in the middling screen is fed to a crusher
that reduces the material to 1-in. top
size and then blends it back into the feed
-------
to the Baum Jig. The underflow in the
middling screen, which isVi-m.xOcoal,
is then routed to the fine coal refuse
slurry sump. The rejects from the two-
stage Baum Jig are dewatered on a
refuse screen and sent to a refuse
bin container for load-out by truck. The
underflow from the coarse refuse
screens is combined with other fine coal
refuse products of the plant and sent to
the fine coal slurry sump.
The refuse streams in the plant
consist of:
Coarse refuse from the Baum Jig
which is dewatered on screens
and sent to the coarse refuse
hopper.
Fine refuse collected in a sump
from the underflow of the
polishing cyclones, froth flotation
cells, and Baum Jig.
The fine refuse slurry collected in the
fine coal sump is pumped to a desilting
pond. The pond water overflows into a
transfer pond from which water is
recycled for makeup in the plant.
Test Program Description
Samples of 16 process and waste
streams were obtained to meet the
objective of this STE program. Because
the pond waters and slurry streams
were split into two samples (solid and
liquid states) and non-fugitive solid
samples were analyzed as the solid and
a leachateof the solid, 30 samples were
analyzed to characterize facility waste
streams, raw materials, and product.
Samples collected at the coal
preparation facility included:
Fugitive particulates and gases
from coal and coarse refuse
storage areas.
Fine refuse sedimentation ponds
and a runoff pond
Runoff from ROM coal storage
area.
ROM coal, clean coal, and coarse
refuse.
Fine refuse slurry.
These samples were selected based on
their potential for pollution.
The following chemical analyses
were performed:
Spark Source/Mass Spectro-
scopy for inorganic element
determinations (all streams).
Inductively Coupled Argon
Plasma for inorganic element
determinations (liquid streams
only).
Total Chromatographable
Organics and Gravimetric
Analysis for assessing total
organic content (all gaseous,
liquid, and sediment streams).
Atomic Absorption Spectroscopy
for mercury (all streams).
The following tests were conducted:
AMES test for mutagenesis (all
streams).
A second, suitable biological
assessment test for cytotoxicity or
toxicity, such as rabbit alveolar
macrophage (solids), Chinese
hamster ovary assay (liquids),
rodent acute toxicity (liquids), or
an aquatic bioassay on algal,
daphnia, or the fathead minnow
(all liquid streams and leachates).
In addition, classical water quality
parameters were measured for each
liquid stream: pH, conductivity,
temperature, dissolved oxygen,
hardness, alkalinity, acidity, ammonia,
nitrates, nitrites, cyanide, phosphorus,
sulfate, sulfite, fluoride, and chloride.
Methods for Characterizing
Waste Streams
Three methods were used to evaluate
the characteristics of the coal
preparation plant samples:
Table 1. Properties of Rom Coal, Clean Coal, and Coarse Refuse
Rom Coal Clean Coal
Proximate Analysis As Received Dry Basis As Received
Coarse Refuse
Dry Basis
As Received
Dry Basis
(% Weight)
Moisture
Ash
Volatile
Fixed Carbon
Btu/lb
Sulfur
Ultimate Analysis
Moisture
Carbon
Hydrogen
Nitrogen
Chlorine
Sulfur
Ash
Oxygen (by difference)
3.87
28.66
31.68
35.79
J 00.00
9,657
4.35
3.87
53.93
3.79
1.23
0.08
4.35
28.66
4.09
100.00
29.81
31.96
37.23
100.00
10,046
4.52
56.10
3.94
1.28
0.08
4.52
29.81
4.27
100.00
4.14
12.74
36.62
46.50
100.00
12,120
2.79
4.14
67.61
4.64
1.28
0.08
2.79
12.74
6.72
100.00
13.29
38.20
48.51
100.00
12,643
2.91
_
70.53
4.84
1.34
0.08
2.91
13.29
7.01
100.00
2.52
65. SO
19.77
12.21
100.00
4,078
8.03
2.52
22.84
1.64
0.56
0.03
8.03
65.50
-1.12
100.00
67.19
20.28
12.53
100.00
4,183
8.24
23.43
1.68
0.57
0.03
8.24
67.19
-1.14
100.00
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Source Assessment Model
(SAM)/IA evaluations for inorg-
anic constituents.
Water quality parameter compar-
isons with existing standards.
Bioassay screening tests.
Source Assessment Models
The Energy Assessment and Control
Division of the EPA's Industrial
Environmental Research Laboratory at
Research Triangle Park (EACD/IERL-
RTP) has developed a standardized
methodology for interpreting the results
obtained from environmental
assessment test programs. This
methodology uses the Source Analysis
Model which represents prototype
approaches to multimedia, multipollut-
ant problem identification and control
effectiveness evaluation for complex
effluents.
The simplest member of the Source
Analysis Models, SAM/IA, was used for
this STE program. SAM/IA provides a
rapid screening technique for
evaluating the pollution potential of
gaseous, liquid, and solid waste
streams. In performing a SAM/IA
evaluation, an index, the Discharge
Severity (DS), is determined for each
substance in a discharge stream.
The DS is calculated by dividing the
detected concentration of a compound,
or class compounds, by its Discharge
Multimedia Environmental Goal
(DMEG) value (for both health and
ecological effects) as reported in the
Multimedia Environmental Goals for
Environmental Assessment, Volume II
(EPA-600/7-77-136b; NTIS PB
276920). The MEGs are concentration
levels of contaminants in air, water, or
solid waste effluents that will not evoke
significant harmful responses in
surrounding populations or ecosystems.
For example, the estimated
concentration of aluminum in the fine
waste slurry filtrate sample was 190
/i/g/l. The health-based DMEG value for
aluminum in a liquid discharge is 8.0 x
104 yug/l. The discharge severity for
aluminum is calculated to be:
DS =
190/yg/l
8.0 x 104,ug/l
= 2.4x 10~3 /jg/\
A DS value greater than 1.0 indicates
a potential hazard, while a value less
than 1.0 indicates little or no potential
hazard. A total stream discharge
severity (TDS) is calculated by summing
the DS values for all constituents found
in a sample.
The total concentration of organic
extractables in each sample was given
as the sum of the gravimetric (Grav) and
total chromatographable organics
(TCO) determinations. These results
were not evaluated using the SAM/IA
methodology because the MEG values
are specific to individual organic
compounds, which are not identified by
Grav and TCO analyses, and most Grav
and TCO values were at or below
detection limits.
Water Quality Comparisons
Water quality tests were performed
on the runoff and filtrate samples. The
test concentrations were compared to
the most stringent state effluent water
regulations for eastern and midwestern
states. The applicable water quality test
concentrations for runoff and leachate
samples were also compared to the
Resource Conservation and Recovery
Act (RCRA) Extraction Procedure-Toxicity
Concentrations for determining hazard-
ous wastes, although a neutral leachant
procedure was used.
Bioassay Screening Tests
The use of biological assays in
conjunction with physical and chemical
analyses provides a comprehensive
data base from which to prioritize
streams relative to further study and/or
control technology needs.
Biological test result evaluations are
based on an interpretation of the data in
terms of low, moderate, or high effects
of each test. These interpretations are
based on the biological responses of
highly sensitive cellular and whole-
organism cultures. Since highly-
sensitive cells or organisms are tested,
a positive response may not indicate
actual field impacts. "Lowor nondetect-
able effects" means that the material
will not have any adverse health or
ecological effects. "Moderate or high
effects" means that the material may be
potentially hazardous and more rigor-
our testing should be initiated.
Results
Fugitive Particulates
and Vapors
The ambient Total Suspended
Particulates (TSP) concentrations and
the concentration of particles less than
15/ug/m3 were highest adjacent to the
ROM coal storage pile and the rotary |
breaker. This was expected because of
the continual coal handling activity in
those areas. The contribution of plant
fugitive emissions to the ambient air
quality can be measured as the
downwind TSP value minus the upwind
TSP value. When the high ambient air
TSP value is subtracted from the
downwind results, the contribution to
the ambient air 600 m downwind from
the preparation plant was found to be 70
fjg/m3. Although 600 m downwind is
still within the plant boundary, this
value is significantly less than the 24-
hour primary ambient air quality
standard of 260/ug/m3 for TSP and also
considerably less than the secondary
ambient air quality standard of 150
fjg/m3. Paniculate morphology tests
showed that downwind particulates
were primarily quartz-like material
rather than coal particles. However,
downwind particulates show a slightly
higher concentration of coal dust than
the upwind sample.
The TCO + GRAV analyses of the
fugitive vapors were determined to be
40 fjg/m3 after subtracting the upwind
contribution. It can be concluded that
the preparation plant and specific coal
and refuse piles contribute little or no
organic vapors to the environment. The A
TDS values for organic vapors were less *
than 10 for health criteria and less than
1.0 for ecological criteria. Chromium
and nickel were the only elements with
a DS greater than 1.0; however, for two
of the chromium concentrations and
two of the nickel concentrations, the DS
value can be attributed to
contamination m the XAD-2 resin blank.
The fugitive particulate sample
results indicate a low potential for
hazard according to the low TDS values;
however, the results show a potential
hazard based on health-related
bioassay test results (RAM test results
showed moderate effects). The bioassay
test results for the organic vapor
samples were negative (i.e., low or
nondetectable effect)
Liquids
The filtrate sample from the fine
waste slurry had health- and ecological-
based TDS values greater than 1.0. The
health-based TDS of 2 and the ecologi-
cal-based TDS of 10 is largely due to
selenium. The low total extractable
organic concentration shows that there
was very little dissolved organic
4
-------
material in the fine coal waste slurry
filtrate.
The waters from the desilting, trans-
fer, and runoff ponds exhibited low
potential for effect based on the health-
based TDS value and a relatively higher
potential for hazard based on the
ecological-based TDS value. There were
no chromatographic organics detected;
however, gravimetrically determined
organic concentrations were 300, 400,
and 300pg/l for the desilting, transfer,
and runoff ponds, respectively. The bio-
assay test results for the desilting pond
water were mixed. The Chinese hamster
ovary clonal assay and the aquatic
bioassay with algae produced moderate
effects. However, the Ames assay, the
rodent acute in vivo test, and the aquatic
bioassays with fish and invertebrates
indicated low or nondetectable effects.
The ROM coal storage pile runoff
sample is similar to the pond water
results; i.e., low potential for hazard on
a health-related basis and a greater
potential on an ecological-related basis.
The total extractable organic concentra-
tions were relatively low (200jug/l). The
biological tests (Ames and CHO clonal
assays) showed negative results for
both samples.
Solids and Leachates
The inorganic analyses for the fine
refuse waste solids had a health-based
TDS value of approximately 500 and an
ecological-based TDS value of 10,000.
The high ecological-based TDS value
was primarily due to a high phosphorus
DS value. The results for the health and
ecological bioassays were mixed The
Ames assay, rodent acute in vivo test,
and the aquatic bioassays with fish and
invertebrates all produced negative
effects. However, the Chinese hamster
ovary clonal assay produced a high
effect, and the aquatic bioassay with
algae produced a moderate effect.
The ecological-based TDS values for
the coarse refuse solids sample were of
the same magnitude as those for the
fine refuse (i.e., 10,000). However, the
health-based TDS was an order of
magnitude greater (i.e., 2,000). The
health-related bioassays, however,
produced low or nondetectable effects.
The coarse refuse leachate had a
health-based TDS of 10 and an
ecological-based TDS of 200. The
coarse refuse leachate also produced
negative results for the health-related
bioassays.
The TDS values for the ROM coal and
clean coal leachate are of the same
order of magnitude. The health-based
TDS for ROM and clean coal leachates
are 4 and 2, respectively. The ecological-
based TDS values of 67 and 35,
respectively, indicate a relatively higher
potential for hazard. The extractable
organic concentrations for both ROM
and clean coal leachate samples were
below the detection limit. The results of
the health-related bioassays were
negative for both the ROM and clean
coal leachate samples.
A composite of coarse refuse, ROM,
and clean coal leachates was used for
the aquatic bioassays. The results
showed low or nondetectable effects on
fish and invertebrates and moderate
effects on algae.
The TDS values for the pond sedi-
ments were fairly high (health TDS
values >100 and ecological TDS values
>1,000), with the highest health TDS
for desilting pond sediment (2.1 E3) and
the highest ecological TDS for runoff
pond sediment (1 .OE4). The TDS values
for the pond sediment leachates were
significantly lower (health TDS >1.0;
ecological TDS >10). The concentra-
tions of chromatographable and
gravimetric organics in the sediments
were all 20 mg/g. The extractable
organic concentrations for the sediment
leachates were below the detection
limit.
The pond sediments and sediment
leachates produced negative effects
when evaluated by the Ames assay.
However, a composite of desilting and
transfer pond sediments, and the runoff
pond sediment sample produced a high
effect when evaluated by the rabbit
alveolar macrophage assay. The aquatic
bioassays performed on a composite of
the leachate samples showed no effect
on fish and invertebrates and a moder-
ate effect on algae.
Summary and Conclusions
A summary of the multimedia
chemical and biological stream charac-
teristics and control strategy recom-
mendations is provided in Table 2.
Table 2. Summary of Environmental Results
Major Contributors
Total Discharge
Severity
(Discharge Severity
Biological Results
Waste Stream
Health Ecological Health Ecological Health Ecological
Conclusions
Recommendations
ROM Coal Storage Pile
Fugitive Particulates 7.35-2 2 OE-3
Rotary Breaker Fugitive
Particulates 1 1E-2 6.05-3
Upwind Fugitive
Particulates
1.2E-2 2.05-2
Downwind Fugitive
Particulates LIE-2 3 OE-3
ROM Coal Storage
Pile Vapors 7.950 3.05-7
Rotary Breaker Vapors 6750 705-7
Upwind Vapors 7750 375-7
Downwind Vapors 7.257 9.05-7
M
M
M
M
L/N
UN
L/N
L/N
NC
N.C
NC.
NC.
NC
Low potential for hazard
according to TDS values;
however, potentially
hazardous based on health-
. related bioassay test
results.
Paniculate morphology shows
coal in all but upwind samples.
TSP values for fugitives
below primary standard, except
rotary breaker
Improve techniques for
control of fugitive emissions.
9 Low potential for hazard
according to TDS values
N. C and bioassay test results.
NC.
N.C.
-------
Table 2. (Continued)
Waste Stream
Fine Waste Slurry Filtrate
(bio. tests conducted on
raw slurry)
Desilting Pond Water
Filtrate (bio. tests
conducted on raw
pond water!
Transfer Pond Water
Filtrate (bio tests
conducted on raw pond
water)
Runoff Pond Water
Filtrate (bio.
tests conducted on
raw pond water)
ROM Coal Storage
Pile Runoff
Major Contributors
Total Discharge (Discharge Seventy
Severity >10/
Health Ecological Health Ecological
2.0EO 1.0E1
1.4EO 8.0EO
1.4EO 1.5E1 -
26EO 1.8E1 - -
2.0EO 1.6E1
Biological Results
Health Ecological Conclusions
H M Uncertain potential hazard
according to ecological-
based SAM/IA evaluation.
Potentially hazardous based
on bioassay test results
M M
L/N N.C. Low potential for hazard
according to health-
based criteria.
Uncertain hazard potential
according to ecological TDS
L/N values.
UN N.C Low potential for hazard
Recommendations
Should not discharge directly
to off site surface waters.
should be treated onsite.
Should not discharge directly
to offsite surface waters;
should be treated onsite.
Collect runoff for treatment
according to health-based
criteria.
Uncertain hazard potential
according to ecological TDS
values.
Clean Coal Leachate 2.2EO
ROM Coal Leachate 4.0EO
Coarse Refuse Leachate I.OEt
Desilting Pond Sediment
Leachate 4. JEO
Transfer Pond Sediment
Leachate 8.4E-1
Runoff Pond Sediment
Leachate 9.2EO
Desilting Pond Water 6.5EI
Filtered Solids
Transfer Pond Water
Filtered Solids 4.1E2
Runoff Pond Water
Filtered Solids 4.2E1
Desilting Pond
Sediment 1.6E3
Transfer Pond
Sediment 1.2E3
Runoff Pond
Sediment 4.3E2
Coarse Refuse 2. 1E3
3.55?
6.7E1
2.0E-2
2.0E1
1.2E1
33E1
4.1 EJ
6.1 El
3.1 El
3.1 E3
8.1E3
1.0E4
1 OE4
NH3-N
NH3-N
- NH3N. Mn. Ni
- Mn
Mn.Hg P
Hg P
Mn.Hg P
Mn.Ba.As. P,Mn.V
Cr.Pb.Li.
Ni.P.V
Cr.Mn,As. P.Mn
Ba.Cd.Pb.
LiMP.V
Ba.As.Co. P.Cd.Ni
Pb.LiM
P,V
Mn.Pb.Se. P.Pb.Mn
As.Ba.Cd.
Cr.Li.Ni.
P.V
L/N
L/N
L/N
L/N
L/N
L/N
M
L/N
L/N
H
H
H
L/N
M
M
M
M
M
M
N.C.
N.C.
N.C.
N.C.
N.C
N.C.
N.C.
Uncertain hazard potential
according to ecological-based
criteria
Chemical constituents
are more teachable in
the coarse refuse than
other solids.
Coarse refuse already
stored in closed system.
Uncertain hazard potential
according to SAM/IA
evaluation and health-
based bioassay test results.
Moderate potential for hazard
based on SAM/IA evaluation.
No or low hazard based on
health-related bioassay test
results.
High potential for hazard
based on SAM/IA evaluation
and health-related bio-
assay test results
High potential for hazard
based on SAM/IA evaluation.
Low or no hazard based on
health-related bioassay
results.
Use RCRA's EP Method for
teachability to investigate
leaching potential under
acid conditions.
Should not discharge pond
waters directly to offsite
surface waters.
If discharged, treat for
trace metals control
Check origin of nitrogen
compound in samples
Retain material onsite via
sedimentation.
Check forms of phosphorus
Retain material onsite via
sedimentation
Check forms of phosphorus
Retain material onsite
Check forms of phosphorus
Further characterization
during level 2 testing
Store coarse refuse in a
closed system.
Check forms of phosphorus.
N.C. = Not conducted.
L/N = Low or nondetectable effect.
M = Moderate effect,
H = High effect.
-------
For air samples there is a low
potential for hazard from both the
fugitive participates and fugitive vapors.
Improved dust control measures are
recommended to decrease fugitive
particulate emissions.
For liquid streams the major constitu-
ents of concern were manganese and
nickel. These two metals would require
control if the pond waters were
discharged or runoff water was col-
lected and then discharged.
The solid samples showed the highest
potential for hazard. However, the
leachates from the solids had consider-
ably lower discharge severity values
than the solids themselves. The recom-
mendation is to retain solids onsite via
sedimentation or filtration.
J. Buroff, A. Jung, L McGilvray, andJ. Strauss are with Versar, Inc., Springfield,
VA 22151.
David A. Kirchgessner is the EPA Project Officer (see belowj.
The complete report, entitled "Environmental Assessment: Source Test and
Evaluation Report Coal Preparation Plant No. 2," {Order No. PB 82-103 5 73;
Cost: $23.00, 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:
Industrial Environmental Research Laboratory
U.S. Environmental Protection Agency
Research Triangle Park. NC 27711
TfrU. S. GOVERNMENT PRINTING OFFICE: 1982/559-092/3369
-------
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Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
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Fees Paid
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Agency
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Penalty for Private Use $300
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