United States
                                  Environmental Protection
                                  Agency
                                  Municipal Environmental Research -_
                                  Laboratory
                                  Cincinnati OH 45268
SEPA
                                  Research and Development
                                  EPA-600/S2-82-090  Dec. 1982
Project  Summary
                                  Sources  of  Urban  Runoff
                                  Pollution and  Its  Effects on  an
                                  Urban  Creek
                                  Robert Pitt and Martin Bozeman
                                   Sources and impacts of urban runoff
                                  were studied for the Coyote Creek
                                  near San Jose, California. The 3-year
                                  monitoring study included three tasks:
                                  (1)  identifying and  describing
                                  important sources of urban runoff
                                  pollutants; (2) describing the effects
                                  of  those pollutants on  water  and
                                  sediment quality, aquatic organisms,
                                  and associated beneficial uses of the
                                  creek; and (3)  assessing  potential
                                  measures for controlling the problem
                                  pollutants in urban runoff.
                                   Results indicated that various urban
                                  runoff  constituents  (especially
                                  organics and heavy metals) may be
                                  responsible for many of the adverse
                                  biological conditions  observed in
                                  Coyote Creek. But adequate control of
                                  pollutants would require extremely
                                  high removals that would be difficult
                                  as well as costly  to achieve.
                                   This Project Summary was developed
                                  by  EPA's Municipal Environmental
                                  Research Laboratory, Cincinnati. OH,
                                  to  announce  key findings of the
                                  research project  that  is fully
                                  documented in a separate report of the
                                  same title (see Project Report order-
                                  ing information at back).

                                  Introduction
                                   A  3-year monitoring  study was
                                  conducted to evaluate the sources and
                                  impacts of urban runoff on water quality
                                  and  biological conditions in Coyote
                                  Creek near San Jose, California.  The
                                  three  major elements of this study
                                  included: (1) identifying and describing
                                  important  sources of urban runoff
                                  pollutants; (2) describing the effects of
                                  those pollutants on water and sediment
                                  quality, aquatic organisms, and associ-
                                  ated beneficial uses of the creek; and (3)
                                  assessing   potential  measures  for
                                  controlling the problem pollutants in
                                  urban  runoff. In many  cases,  very
                                  pronounced  gradients  of water and
                                  biological  quality   indicators  were
                                  observed.  Though  cause-and-effect
                                  relationships cannot be  conclusively
                                  proved in  a  study such  as this,  the
                                  degraded conditions in Coyote  Creek
                                  may be the results of several factors,
                                  including urban runoff, stream flows,
                                  (associated or not with urban runoff),
                                  and natural conditions such as drought,
                                  stream  gradient,  groundwater
                                  infiltration, etc. Information developed
                                  during this study implies that various
                                  urban  runoff constituents (especially
                                  organics and heavy metals in the water
                                  and  polluted  sediment)  may  be
                                  responsible for many of the adverse
                                  biological conditions observed.

                                  Site Description
                                   The Coyote Creek watershed (Figure
                                  1) is near San Jose, California. Coyote
                                  Creek is a small stream, about 130 km
                                  (80 mi) long, originating in a wilderness
                                  area that is virtually free of pollutant
                                  sources.  The  upper  reaches  and
                                  headwaters of Coyote  Creek  have
                                  extremely  rugged, chaparral-covered
                                  terrain with slopes commonly exceeding
                                  30 percent. Much of this land is within
                                  the Henry Coe State Park; nonpark land

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                            v      Oakland
                        San1
                        Fran-
                        cisco^  Sari
                              Francisco\ Hayward
                                Bay
Pacific Ocean
Figure 1.  Location of the Coyote Creek watershed in relation to
          the San Francisco Bay Area.
                                                        0   5  10   15
                                                            miles

                                                       Q 5  10152025
                                                         kilometers
is used primarily for low-intensity cattle
grazing. The Coyote Creek watershed is
about 70 km (45 mi) long and 15 km (10
mi) wide, and it contains about 80,000
ha (200,000 acres). About 15 percent of
the watershed (all in the downstream
reach) consists of parts of the San Jose
urban area. The upstream waters pass
through two  manmade flood  control
reservoirs  (Coyote   Lake  and  Lake
Anderson) that control the creek flow
during  most  of the year. The lower
reaches of the watershed are in broad
plain. Most of the 24-mile-long study
area  was  located  between   Lake
Anderson in the nonurban area and the
first major creek confluence within the
                                   city of San Jose (where Coyote Creek
                                   meets Silver Creek).
                                   Field Program
                                     In this study, water quality, sediment,
                                   and biological characteristics of the
                                   creek were measured in the urban and
                                   nonurban  reaches of Coyote Creek.
                                   Differences  in  these characteristics
                                   were  evaluated  to  quantify  any
                                   degradation and to identify the pollutant
                                   sources. Early in the study (spring  of
                                   1977), a pilot water quality survey was
                                   conducted along  Coyote  Creek  from
                                   Anderson Dam to San Francisco Bay.
                                   Water quality samples were obtained at
10 sites and analyzed for major constit-
uents. The full-scale sampling program
was designed and carried out after this
pilot survey was completed.
  The  beginning  of  the  3-year
monitoring project followed 2 years of
severe drought, during which precipi-
tation was only about half its normal
average.  Normal  rains are about 33
cm/yr (13 in./yr) in the area below Lake
Anderson and 50 to 70 cm (20 to 28 in.)
in the watershed above Lake Anderson.
The first major rains ending the drought
occurred  in November  1977, and rains
during  the study period were close to
normal. Typical summer flows in the
urbanized creek sections were less than
1.5 mVs (53 ftVs).
  During  the field program, 41 stations
were   sampled  in  both   urban  and
nonurban perennial flow stretches of
the creek. Short- and long-term samp-
ling techniques were used to evaluate
the effects of urban runoff on water
quality,  sediment  properties,  fish,
macroinvertebrates,  attached  algae,
and  rooted aquatic vegetation.  The
program   was  designed   to  define
receiving water conditions in the urban
and nonurban areas during dry weather
conditions.


Sampling Methods
  Creek  flow  rates  were either
measured by the field personnel using a
digital  current  meter,  or  they  were
estimated  with   floats.  All stream
sampling  on this project was conducted
manually  with  submerged,  plastic,
wide-mouthed bottles. The samples
were preserved and analyzed according
to the  requirements  of  the  U.S.
Environmental  Protection Agency
(EPA).
  Sediment samples were  obtained by
scooping  bottom material into glass jars
and sealing the containers underwater.
The  samples were then  frozen and
delivered  to the  laboratory for EPA-
approved   analyses.  Sediment   core
samples  (for  examining stratification)
were  obtained  with a liquid carbon
dioxide freezing core sampler.
  Biological  samples  (mosquitofish,
filamentous algae, crayfish, and cattail
plant   segment)  were  obtained  at
selected  sampling stations and were
chemically digested and analyzed for
total lead and zinc concentrations.
  Fish  were collected by seining and
electroshocking representative pool and
riffle   habitats.   Captured   fish  were
identified and counted. The total length

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and weight were recorded for each
specimen. Where numerous individuals
of a particular species were encoun-
tered, only length range and aggregate
weight were recorded.
  Replicate benthic macroinvertebrate
samples were collected from natural
substrates (e.g., cobbles, gravel, sand)
in both pool and riffle habitats by means
of  an  Ekman  dredge or  a  Surber
sampler. Also  used were replicate pairs
of artificial substrate samplers (Hester-
Dendy) constructed of multiple, parallel
plates of Masonite.* These samplers
were left in the stream  for 8 weeks and
then removed and  examined  in  the
laboratory.
  Qualitative benthic collections were
also made with the  use of a D-frame
sweep net. The benthic samples were
washed  through a sieve with a mesh
size of 500 /urn. Organisms retained on
the  screen were removed, preserved,
identified to the lowest possible taxon,
and enumerated.
  Attached   algae  samples  were
obtained from  both natural and artificial
substrates  throughout  the  various
reaches  of Coyote  Creek. Qualitative
samples   of  attached  algae  were
collected by scraping uniform areas of
natural  substrates such as logs and
rocks.   Qualitative  collections  of
attached algae were made with the use
of  artificial substrates consisting  of
diatometers equipped with glass slides.
These were suspended  in the  water
column for 8 weeks and then removed
and examined in the  laboratory. The
qualitative samples were preserved and
identified. The  quantitative samples
were prepared, identified, and enumer-
ated using the proportional count
method.
  Rooted aquatic plants were sampled
qualitatively   whenever   they   were
encountered in  the study area. Plant
specimens were collected, pressed or
preserved,  and identified.

Sources of  Runoff Pollutants
  Urban runoff studies must determine
how much of  the total pollutant yield
observed at the watershed  outfall is
attributable to each source. Sources far
from the inlet to the storm sewerage
system require overland flow. Accord-
ingly, they contribute relatively small
amounts  of  pollutants  (based  on
observations at the outfall). Conversely,
parking   lots  or street surfaces are

•Mention of trade  names or commercial products
does not constitute endorsement or recommend-
ation for use.
 impervious to water and are typically
 located adjacent  to  the  storm sewer
 inlets. Hence the pollutants from these
 areas  contribute  most to  the outfall
 yield.
  One  important  project  phase
 examined  potential   sources   of
 pollutants. Runoff  samples  and  dry
 particulate samples were collected from
 various source  areas in  San  Jose,
 including  roofs,  parking areas,  and
 gutters. Rainfall  samples and outfall
 samples were also analyzed. Rain was
 found to have the lowest pollutant con-
 centrations, whereas the  parking lot
 and gutter flows had the highest levels
 (for most  of the constituents studied).
 Puddles in a city park were  found to
 have  much  greater  specific
 conductance and concentrations of total
 solids  and  nitrates than  any  other
 samples.  The observed  lead  concen-
 trations ranged widely, from less than
 0.01 for the rain to more than 1.0 mg/L
 for gutter  flows.
  Particulate samples from  the  San
 Jose area  had typically greater pollutant
 concentrations than the corresponding
 levels  in  local soils. Most constituent
 levels  increased  with the degree  of
 urbanization. Rooftops are  thought to
 contribute the least pollutants. Parking
 lots, street surfaces, and sidewalks are
 expected to contribute most of the heavy
 metals and bacteria, and some nutrients
 to  the  total  runoff yield. Landscaped
 areas and vacant lots contribute most of
 the solids, oxygen-demanding materials,
 and other nutrients.

  The amount and character of runoff-
borne  pollutants  from  a  given  site
depend on factors such as the volume of
the storm  event and the  length of the
antecedent dry period (i.e., the period of
pollutant accumulation). Large storms
(those  with high intensities   and/or
large  rainfall  volumes)  result  in
contributions  from  impervious areas
(street surfaces and other paved areas)
that are small relative to the total runoff
particulate yield. This pattern  is more
pronounced when the antecedent dry
periods   are  short.  During such
conditions, the paved surfaces stay
relatively clean because of the frequent
rains. A large rainfall will result in sig-
nificant erosion from the surrounding
saturated  pervious  areas,  however.
Thus  areas  with  moderate  rainfall
intensities  and  long  periods  of
accumulation (i.e., dirty paved surfaces
and dry surrounding soil conditions)
would have most of their urban runoff
output  associated  with  pavement
washoff.
  Of the total solids deposited in an
urban area, only about a third would
ever reach the outfall. And only about
10 percent of the nutrients and oxygen-
demanding materials deposited might
affect the receiving water quality. But
most of the heavy metals deposited in
the area  would  affect the receiving
waters.  The  remaining  deposited
pollutants  that  are  washed  off the
source areas but do not reach the outfall
would accumulate in other areas of the
urban environment. The most signifi-
cant of such pollutant sinks in the urban
area are probably soils, groundwater,
plants, and animals.

Coyote Creek Water Quality
  The  purpose  of the  water quality
monitoring program on Coyote Creek
was  to  define  receiving water
conditions in the urban and nonurban
areas during dry weather. Dry weather
conditions were studied because they
reflect long-term water quality charac-
teristics  in  the  creek  and  are  less
influenced by any specific urban runoff
event.  Data  on  wet-weather water
quality conditions were obtained from
previous studies.
  Dry-weather concentrations of many
constituents  exceeded  the expected
wet-weather concentrations by factors
of 2  to  5.  For example, during dry
weather, concentrations of many of the
major constituents (e.g.,  major  ions,
total  solids,  etc.) were  significantly
greater in both the urban and nonurban
reaches. These constituents  were all
found in substantially lower concentra-
tions in the urban runoff and in the rain.
The  rain   and   the  resulting runoff
apparently  diluted the  concentrations
off  these  constituents in the creek
during wet weather. Within the urban
area, many constituents were found in
greater  concentrations  during   wet
weather  than  during  dry weather—
COD,  organic nitrogen, and especially
heavy metals such as lead, zinc, copper,
cadmium, mercury, iron, and nickel.
Similar  differences between  wet  and
dry weather were also noted for the
nonurban  areas, but the wet  weather
concentrations  were  typically much
higher  in  the  urban  than  in  the
nonurban area.
  Values  for   dry-weather  samples
obtained from the urban and nonurban
reaches  of  Coyote   Creek  were
summarized in Table 1. Lead concentra-

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tions were  more  than seven  times
greater in the  urban reach than in the
nonurban reach during dry weather,
with a confidence level of  75 percent.
Other significant increases in  urban
area concentrations  occurred  for
nitrogen,  chloride,  orthophosphate,
COD, specific conductance, sulfate, and
zinc. The dissolved oxygen  measure-
ments were about 20 percent less in the
urban reach than in the nonurban reach
of the creek.
  Lead  concentrations exceeded  the
water quality criteria for both livestock
and aquatic life. During dry weather, the
water  was  also  hard to  very hard
(typical of Santa Clara County surface
and  ground waters). Chloride concen-
trations  at the furthest downstream
station (Dixon) were high  because of
tidal influences that caused mixing with
San  Francisco  Bay water. About  half of
the  observed  ammonia values were
equal to or greater than the established
               criteria for aquatic  life  (0.02 mg/L).
               Total  coliform  bacteria  populations
               were also high at most of the sampling
               sites.  Water quality upstream  of the
               urbanized  area was fairly consistent
               from site to site, but the quality changed
               markedly as the creek  passed through
               the urbanized area.
                 Selected wet-weather samples were
               also analyzed for priority pollutants as a
               special part of this study.

               Coyote Creek Sediment Quality
                 Coyote  Creek sediment quality  is
               summarized in Table 2. Lead concentra-
               tions in the urban area sediments were
               greater than those from the  nonurban
               area by a factor of about 6, which is the
               widest  margin  for  any constituent
               monitoring. Large differences were also
               found between the urban and nonurban
               area data  for both sulfate and phos-
               phate. Average zinc  concentrations  in
               the urban sediments were  about 1.5
                                          times those of nonurban sediments, but
                                          with a high degree of confidence.
                                            During  the  first  survey,   the
                                          differences  between   urban  and
                                          nonurban  sediment  concentrations
                                          were much greater:  sulfur, lead,  and
                                          arsenic  levels  were 4  to 60  times
                                          greater  in urban area sediments. Sea-
                                          sonal and  yearly changes in relative
                                          sediment concentrations can therefore
                                          be significant.

                                            Selected sediment samples were also
                                          analyzed for many elements using mass
                                          spectrographic procedures.  Other
                                          sediment samples were  also analyzed
                                          for priority pollutants.
                                            The ratio of sediment concentrations
                                          (mg/kg) to  water  concentrations
                                          (mg/L)   was   also   calculated.  This
                                          sediment-to-water ratio  (S/W) would
                                          be low for readily soluble constituents.
                                          and  it  would be  high  for  relatively
                                          insoluble constituents. The S/W ratios
Table 1.    Summary of Coyote Creek Water Quality Conditions in Dry Weather
                                Nonurban Area Stations
                             Below Anderson Dam (mg/l)
                                       Urban Area Stations
                                    Above Silver Creek (mg/l)
Parameter
     Mean
   Min
  Max
 Mean
Min
Max
   Urban/'Nonurban
     Differences

Ratio*    % Confidence f
Total solids
Chloride
Dissolved oxygen
COD
Total phosphate
Total Kjedahl nitrogen
Lead
Zinc
270
<20
8.6
17
<0.2
<0.3
<0.005
0.019
244
<20
6.5
12
<0.02
<0.05
0.001
0.019
299
<20
10.6
23
0.59
0.50
0.002
0.019
590
43
6.8
30
0.25
0.45
0.036
0.033
280
30
1.5
19
<0.02
<0.05
0.003
0.010
1200
60
11.0
53
0.54
0.78
0.10
0.075
2.2
>2.2
0.8
1.8
>1.3
>1.7
>7
1.7
98
98
>99
98
65
85
75
80
* Ratio of urban to nonurban mean values.
t Percent confidence that urban does not equal nonurban values.
Table 2.    Summary of Coyote Creek Sediment Quality Conditions

                             Nonurban Area Stations
                         Below Anderson Dam (mg/kg)*
                                       Urban Area Stations
                                    Above Silver Creek (mg/kg)
Parameter
Mean
Min
Max
Mean
Min
  Max
    Urban/'Nonurban
      Differences

   Ratio}    % Confidence^
COD
Total phosphate
Total Kjeldahl nitrogen
Lead
Zinc
Median particle size (u)
35,500
148
6,500
18.8
64
4,350
7,400
7.5
138
6.7
14
210
98,000
344
29.000
37
90
8.760
39.300
168
2.490
114
96
4,480
4,600
14
146
20
30
70
131.000
406
14.000
400
170
8.600
1.1
1.1
0.4
6.1
1.5
1.0
<60
<60
85
96
97
<60
* Units are in milligrams of constituent per kilogram of total solids, except for the median particle size, which is measured in microns.
t Ratio of urban to nonurban mean values.
I Percent confidence that urban does not equal nonurban mean values..
                                  4

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were found to be very high for most of
the constituents monitored. The largest
difference  between  urban  and
nonurban S/W  ratios  was  for lead,
where the S/W ratio was more than
3,000 for the urban area and only about
400 for the nonurban area.  The total
Kjeldahl nitrogen S/W ratio was about
5,500  for the  urban  area,  but  it
exceeded 22,000 for the nonurban area.
For the other constituents studied, the
S/W ratios for urban  and nonurban
areas were much closer. Urban runoff
constituents  could be present in  the
creek  water column  at  acceptable
concentrations even  when  interstitial
waters in the sediments were polluted.
Unfortunately,  little  information   is
available  concerning the effects  of
polluted   sediments  on  benthic
organisms.

Effects of Pollutants on
Aquatic Organisms in
Coyote Creek

Bioaccumulation of Lead and
Zinc in  Selected Coyote Creek
Organisms
  Some evidence of bioaccumulation of
lead and zinc was found in many of the
samples of algae, crayfish, and cattails.
The measured metal concentrations in
                             the organisms exceeded  those in the
                             sediments  by a  maximum  factor of
                             about six. Concentrations of lead  and
                             zinc in the organisms exceeded water
                             column concentrations by factors of 100
                             to 500. Lead concentrations in urban
                             area samples of  algae, crayfish,  and
                             cattails were two to three times as high
                             as those in nonurban samples, and zinc
                             levels in urban algae and  cattails were
                             about three times as high as those of
                             nonurban samples. Lead and zinc con-
                             centrations  in fish  tissues were not
                             noticeably different  in urban and  non-
                             urban samples.

                             Species of Fish Found in
                             Coyote Creek
                              The  relative  abundance   of  fish
                             species observed in  the urban  and
                             nonurban  reaches of Coyote Creek is
                             shown in Table 3.  Introduced fish often
                             cause radical changes in the nature of
                             the fish fauna present in a given water
                             body. Often they become the dominant
                             fish  because of a superior  ability to
                             compete with the native species for food
                             or  space,  or because of  a greater
                             tolerance  to  environmental  stress.
                             Introduced species are generally most
                             abundant  in aquatic habitats modified
                             by man,  whereas native  fish tend to
                             persist mostly  in undisturbed areas.
Table 3.
Relative Abundance of Fish Species Collected from Coyote Creek
Between Anderson Dam and Silver Creek
                                             Nonurbanized
                                                Reach
                                                   Urbanized
                                                    Reach
          Species
Native fish:
    Hitch
    Threespine stickleback
    Sacramento sucker
    Prickly sculpin
    Sacramento blackfish
    California roach

Introduced fish:
    Mosquitofish
    Fathead minnow
    Threadfin shad
    Green sunfish
    Bluegill
    Largemouth bass
    White crappie
    Black crappie
    Goldfish
    Carp
    Golden shiner

Total number of fish collected
                                      34.8
                                      27.3
                                      12.6
                                       8.2
                                       4.3
                                       1.8
                                       5.6
                                       0.6
                                       0.2
                                       0.1
                                       0.1
                                       0.1
                                       3.5
                                       0.9
                                    2,379
   4.9
   0.8
   0.1
   0.1
   1.0
   0.3
  66.9
  20.6
   2.4
   1.2
   1.0
   0.4
   0.3
   0.1
2.899
 Such  is apparently the case within
 Coyote Creek.
   Samples from the nonurban portion
 of the study area were dominated by an
 assemblage of native fish species such
 as  hitch, threespine  stickleback,
 Sacramento sucker, and prickly sculpin.
 Rainbow  trout,  riffle  sculpin,  and
 Sacramento squawfish were captured
 only in  the  headwater  reaches and
 tributary  streams  of  Coyote Creek.
 Collectively, native species constituted
 89 percent  of the  number  and  79
 percent of the biomass of the 2,379 fish
 collected from the upper reaches of the
 study area. By contrast, native species
 accounted  for only 7 percent of the
 number and 31  percent of the biomass
 of the 2,899 fish collected  from the
 urban reach of the study area.
  Hitch was the most numerous native
 fish  species  present. Hitch  generally
 exhibit a preference  for quiet water
 habitat and are  characteristic of warm,
 low  elevation lakes, sloughs,  sluggish
 rivers,   and   ponds.  Mosquitofish
 dominated  the  collections from the
 urbanized section of the creek and
 accounted for more than two-thirds of
 the total  number of fish collected from
 that  area. This fish is particularly well
 adapted to  withstand  extreme
 environmental  conditions,   including
 those imposed by stagnant waters with
 low  dissolved oxygen concentrations
 and elevated temperatures. The second
 most abundant  fish  species  in the
 urbanized reach of  Coyote Creek, the
 fathead  minnow,  is  equally  well
 suited  to  tolerating extreme
 environmental conditions. The species
 can  withstand  low dissolved oxygen,
 high temperature,  high  organic
 pollution, and high alkalinities. Often
 thriving in unstable environments such
 as intermittent  streams,  the  fathead
 minnow can survive in a wide variety of
 habitats.

Benthic Macroinvertebrates
 Observed in Coyote Creek
  The abundance  and diversity of taxa
generally  appear to  be  greatest  in
nonurbanized  sections of the stream
(Figure 2). The  overall  increase  in
number  and  diversity  of   benthic
organisms encountered  in the  1979
samples  as compared with the 1978
samples  may  be attributed to further
recovery  from the drought conditions
that preceded  this study. The benthos in
the upper reaches of the creek consisted
primarily  of amphipods and a diverse

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   30-
   25-
   20-
I

    10-\
    5-
                 . 1978 Samples
                  1979 Samples
                     Urbanized
              Nonurbanized
                     Q>

                    I
!
«
CO
                               I
                               CO
 
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follows: lead, 75 to 98 percent; zinc, 35
to 50 percent; suspended and settleable
solids,  40 to 90 percent; and oxygen-
demanding materials (e.g.,COD, BOD,
total organic  carbon) and  phosphate,
about 85  percent. Depending  on  the
location  of  acceptable   biological
conditions, total  urban runoff  control
would have to be more than  80 percent
effective. These removal goals are all
very high and would be difficult to meet.
  The  full report was  submitted in
fulfillment of  Grant No. R-805418 by
Woodward-Clyde  Consultants  under
the  sponsorship  of  the  U.S.
Environmental Protection Agency.
Robert Pitt is  a private consultant. Blue Mounds, Wl 53517; and Martin
  Bozeman is with Woodward-Clyde Consultants, San Francisco, CA 94111.
Richard Field is the EPA Project Officer (see below).
The complete report, entitled "Sources of Urban Runoff Pollution and Its Effects
  on an Urban Creek," (Order No. PB 83-111 021; Cost: $16.00,  subject to
  change) 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:
        Storm and Combined Sewer Section
        Municipal Environmental Research Laboratory—Cincinnati
        U.S. Environmental Protect/on Agency
        Edison, NJ 08837
                                                                                 U. S. GOVERNMENT PRINTING OFFICE: 1983/659-095/557

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

RETURN POSTAGE GUARANTEED
                                                                                      Third-Class
                                                                                      Bulk Rate
      PS   0000329
      US  ENVIR  PROTECTION  A6ENCY
      Kfc&lON  5 LltfRAKY
      l$Q  S DEARBORN STREET
      CHICAGO IL 60604

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