United States
Environmental Protection
Agency
Environmental Research
Laboratory
Athens GA 30613
vn
Research and Development
EPA-600/S3-82-057  Sept. 1982
Project  Summary
River  Basin Validation  of  the
Water Quality Assessment
Methodology for Screening
Nondesignated 208 Areas:
Volumes  I  and  II

Michael J. Davis, Michael K. Snyder, and John W. Nebgen
  Techniques for estimating diffuse
nutrient loads and their water quality
effects throughout large watersheds
were tested under various field situa-
tions for a wide range of data availability
circumstances, water quality param-
eters, and hydrologic-hydraulic condi-
tions. Loadings were calculated using
methods from Loading Functions for
Assessment of Water Pollution from
Nonpoint Sources (EPA-600/2-76-
151) for five river basins, including the
Sandusky River in Ohio, the Chester
and Patuxent Rivers in Maryland, and
the Ware and Occoquan Rivers  in
Virginia. Water quality response  to
these loads was calculated using
methods from Water Quality Assess-
ment — A Screening Method for
Nondesignated  208  Areas (EPA-
600/9-77-023)  for the Sandusky,
Chester, Patuxent, and Ware rivers
and estuaries.
  Obtaining sufficient data to operate
the model was the biggest problem in
applying the loading methodology  to
specific river basins. Given the inher-
ent inaccuracy in the basic Universal
Soil Loss Equation (USLE) approach,
use of the national data base provided
in the original document was justified,
especially if supplemented with speci-
fic county cover (R) factors. Despite
the inaccuracies  resulting from the
use of a national data base, two to
three person weeks of effort per basin
should produce useful inputs to water
quality screening assessments.
  The loading methods and the water
quality methods tested in this study
were highly compatible and gave rea-
sonably accurate predictions of in-
stream, lake, and estuary water
quality constituent concentrations.
The river modeling methods are the
most accurate, followed by the tech-
niques for estuaries and then impound-
ments. Low flow, steady state condi-
tions  are better predicted than  high
flow, unsteady loading situations.
Applying these techniques, the water-
shed management planner should be
able to recommend appropriate actions
to investigate pollutant problem areas
more closely in specific watersheds.
  This Project Summary was devel-
oped by EPA's Environmental Research
Laboratory, Athens, GA, to announce
key findings  of the research project
that is fully documented in  two
separate reports (see Project Report
ordering information at back).

Introduction
  In August 1977 the U.S. Environmen-
tal Protection Agency (EPA) published
Water Quality Assessment — A Screen-
ing Method for Nondesignated 2O8

-------
Areas (EPA-600/9-77-023) This docu-
ment is a compendium  of techniques
designed to aid in the assessment of
water quality problems  in large areas
that encompass a wide spectrum of
human  activities  and  water  quality
conditions These include  agriculture and
silviculture,  as  well as  industrial  and
municipal activities. In  this Water
Quality Assessment Methodology (WQAM),
Tetra Tech,  Inc.,  under  EPA contract,
brought together a number of methods
designed to accommodate both urban
and non-urban nonpomt  sources, as
well as  municipal and industrial point
sources of pollutants. In  addition to the
assessment of  effluent  water  quality,
WQAM  provided for systematic routing
of these pollutants through rivers  and
streams, impoundments, and  estuary
systems All algorithms were designed
to be used as hand calculation tools.
  In a separate study, Midwest Research
Institute, under EPA contract, developed
methods for  estimating diffuse loads
entering receiving waters.  The study
was described in Loading Functions for
Assessment of Water Pollution from
Nonpoint Sources (EPA-600/2-76-
151).
  The primary goal of the study described
in this Project Summary was to demon-
strate Midwest Research  Institute's
loading  functions and  Tetra  Tech's
water quality screening  procedures
under authentic field situations.  The
demonstration was designed to subject
the procedures to  a wide range of data
availability, water quality  parameters,
and hydrologic/hydrauhc situations. In
addition to the primary goal, secondary
goals were to:
  1. Provide a  report demonstrating
     the WQAM, to be used as a guide
     by  planners.
  2. Show the degree of compatibility
     between the nonpomt-loading
     methods and the  water  quality
     screening methods in the WQAM.
  3. Develop firmer  insight into  the
     strengths and weaknesses of the
     nonpoint loading methodology.
  4. Evaluate the sensitivity of  non-
     point load estimates  to  varying
     degrees of data availability.
  5. Determine how critical or neces-
     sary  the quality  and quantity of
     nonpoint source  details are with
     regard to  reliably modeling  in-
     stream  processes as  they  are
     affected by nonpoint loading.
  6. Demonstrate strengths and weak-
     nesses of  the WQAM screening
     methodology.
  Five river basins were examined.
These are the Sandusky River in Ohio,
the Chester and the Patuxent Rivers in
Maryland, and the Ware and Occoquan
Rivers in Virginia.  Loading analyses
were  also performed on the Potomac
River Basin and the Susquehanna River
Basin.
  This summary describes work reported
in two volumes —River Basin Validation
of  the  Water Quality Assessment
Methodology for Screening Nondesig-
nated 208 Areas,  Volume I. Nonpoint
Load Estimation; Volume II. Chesapeake-
Sandusky Nondesignated 208 Screening
Methodology Demonstration. Volume I
is a discussion of the application of the
nonpomt load assessment methodology
to a number of nx^er basins Volume II
considers the application of the water
quality screening methodologies to these
same basins. The nonpoint source load
estimates given in Volume I were used
as  inputs to the calculations involving
wet weather conditions that are  pre-
sented in Volume II The two volumes
are organized similarly; the river basins
were considered in the same order  in
both. There is  cross-referencing  in
Volume I to portions of Volume II so that
the  interested reader can see  how
results obtained in Volume I are used in
the second volume.
  Although the two volumes are related,
each  can stand alone as  a  separate
demonstration of the  different  meth-
odologies.

Volume I
  Data Availability — Application of the
nonpomt  source loading methodology
requires a large volume of data in spite
of the relative simplicity of the overall
approach Therefore, a major problem
in  this,  and probably in any  other,
application  was data  availability.  A
screening analysis should by its nature
not require the generation of significant
quantities of new data.  Those data that
are used in the analysis should already
be  available  and  should require a
minimum of manipulation prior to use.
For example, the Sandusky Basin  has
been well studied, but there was a
definite lack of applicable data readily
available for this study. Generally, the
available data  were aggregated to the
county level, e.g., land use information.
Also, as might be anticipated, in all the
basins there was a problem in estimating
sediment delivery  ratios.  Long-term
sediment yield data were generally not
available for  the  basins, therefore,
average  delivery ratios could not be
properly estimated. Furthermore, there
was a lack of the sediment yield data
needed to define variability within the
basins. Finally, there was generally, no
way to estimate how average delivery
ratios might vary with the season. Use
of a single average value for the delivery
ratio could  result in a  considerable
over-  or  underestimation of loads for
particular subbasins and seasons. This
difficulty was nearly universal It was, in
fact, a problem of  less  concern in the
Sandusky Basin than for most basins
because some sediment measurements
were  available  and because the  effi-
ciency of delivery is  thought to be
relatively uniform throughout the basin
Information  on  pollutant  loading  rates
and pollutant characteristics in urban
areas was also  not readily available. It
was  purely  a   matter of chance  that
actual  measurements  were available
for  use  in  one of the  urban areas
(Bucyrus) in one of the basins (Sandusky)
  Value  of  Parameter  Refinement —
The most important parameter refine-
ments involved  land use data and the R,
K, and C factors in the universal soil loss
equation The national  data base used
provided  R values by the Land Resource
Area  (LRA). These could easily be
replaced  by values that more  nearly
represent each  county  For example, in
the Sandusky, the change was from an
annual value of 150 to 125. (Of course,
individual event values were calculated
for use in the demonstration ) Cover (C)
factor values were also changed by the
refinement process. The C values used
for the  individual  counties reflect
changes  in  the stage of crop  growth,
which is an  improvement over the
average  annual C values in  the  data
base  The  level of resolution of soil
credibility values was  improved from
the LRA  level (in the data base) to the
county level. In some cases, resolution
was at the subbasin level. As much as a
20 to 40% decrease in  erodibility value
was  noted for  some subbasins in the
Sandusky due to refinements in the  K
values Land use changes in that basin
mostly increased soil loss in the interval
between 1967 (data base) and the base
year  used  in  the individual basin
calculations.
  On  balance then, as compared to the
data  base values,  the refinements for
the Sandusky led to decreases in R, K,
and C and, therefore, to a decrease in
annual soil loss over that which would
be obtained using the data base. Land
use changes partially offset the decrease.
Again, using the Sandusky Basin as an

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example, in six out of the eight counties,
average soil losses decreased by 20%or
more due to the refinements. Given the
level of effort  required to produce the
refinements and the inherent inaccuracy
in the approach, the use of the data base
is a cost-effective approach. For annual
soil  loss calculations in the basins
studied,  the original data  base would
provide useful results (as'compared to
the  refined  values) if  one  merely
modified the R factors for each county
and accounted for the major change in
cropland. That is, a significant improve-
ment was possible in this case with only
a limited amount of  effort.
  Certain  problems occurred  in the
attempt  to improve the estimates for
some  of the  parameters,  as  already
noted.  A particular  problem was esti-
mating  sediment delivery ratios,  a
problem that  was exacerbated in the
case of individual subbasins. Reasonable
estimates of delivery ratios  were
essential for  accurate estimates of
sediment delivered to a stream. Lacking
a general approach to the problem, the
delivery ratio issue will continue to
frustrate many applications  of the
methodology  Although less difficult,
problems  also occurred with  other
parameters as well  The LS and the  P
factors in the  USLE were not modified
and were used directly from the existing
national data base Improvement of the
estimates  used requires substantial
information on topography and soil
conservation  practices in  each basin.
As already noted, data on the loading
rates for pollutants on city streets were
generally lacking and recourse  must be
made to tabulated, crude averages
  Sensitivity Analysis — In the case of
urban  nonpomt loads, the  important
matter of  sensitivity to assumptions
was considered. The major problem
centered on determination of street
loading  rates  and  use  of  an annual
average  approach.  For rural nonpomt
loads,  the various factors used in
determining sediment of nutrient loads
(except rainfall inputs) were multiplied
together to  obtain  the  final  result.
Therefore,  uncertainties in the factors
were  multiplied   For example, for
sediment loads, a 20% error  in  each
factor  involved in determining the load
gave approximately  a 300% error  in
the load, assuming  no compensation
among the errors Similar errors in the
case of nutrient calculations yielded  a
total error of about 400%. Because most
of the  factors  could  not be determined
with an error of less than 20%, the
possible error in  the results could be
quite large unless there is compensation
among the errors. This fact indicated
that the  results obtained are always
rather uncertain.
  Uncertainties in land use information
in the present  application  related
primarily to  the resolution of the
information. Agricultural land use data
were generally available; however, they
were at the county level of resolution
Therefore, specifying land use conditions
in a subbasin was difficult The primary
need in land use data was for accurate
specification of the cropland — its area
and  type  of crop.  Land use affects
pollutant load  calculations through the
C factor in the USLE In an application in
which a pollutant Ipad was needed for a
subbasin that covers a fraction  of  a
county and in which land use and other
data were available only at the county
level of resolution or lower, the loads
may be grossly  overestimated.  This
overestimation could occur in a subbasin
for which a higher than average fraction
(for the county) is cropped, for which
slopes  are steeper than  average, or for
which there are no conservation prac-
tices applied (P =  1).  Poor resolution of
needed data can  result in substantial
errors for  particular locations within  a
basin
  Results were also somewhat sensitive
to errors in describing agricultural
practices in a basin. The significance of
errors in practices related primarily to
the problem  of timing  of agricultural
operations and, therefore, the degree of
cover on the ground at particular times.
  In summary, errors in results were
directly proportional  to errors  in the
various parameters used in the analysis
because they are multiplicative. Assess-
ment of  sensitivity  to  errors in the
description of  practices or land use, or
the degree or resolution in the available
data is an involved  exercise  that will
yield results that vary considerably from
basin to  basin.  Such  variability was
anticipated because of different rainfall
patterns and the degree of non-homoge-
neity of land use among basins.
  Level of Effort Required m an Applica-
tion — Application of the nonpoint load
estimation  methodology  to basins
such as those examined in this  study
should require on the order of two  to
three person weeks of effort per basin.
This estimate assumes  an analyst
familiar with the procedure and with the
general subject of rural nonpoint source
loads. It also assumes  familiarity with
use of the nonpoint calculator program
The availability  and  use of more
extensive data than considered in this
demonstration would increase the time
required  Report  preparation  is not
included in the time estimate
  Verification  of the  Load Estimation
Procedures — Considering the  lack of
measured  nonpoint  loads  (both rural
and urban) available for  comparison
and the long-term average nature of the
estimates  that have  been made, veri-
fication of  the  procedure by direct
comparison with measured loads was
quite difficult Comparison with measured
instream concentrations was  a more
promising 'approach  The  results pre-
sented in Volume II indicate the level of
verification that can be expected for the
approach used, particularly in the case
of the Sandusky Basin
   Future Applications — In the present
study, considerable effort was expended
in selecting a series of events for each
basin so that consistent flow data were
available   for use in the instream
assessment This effort was necessary
to assure compatibility and to allow an
attempt at verification of the results  In
actual  applications, such a selection of
actual  events  may be unnecessary. A
possible approach  would be to define
typical average events for  various
stages   in  cover occurring  throughout
the year These "typical" events could
be  equivalent  to events that produce
some fraction  of the total soil  loss that
occurs during some fraction of the year
The information needed to define such
an  event  is available in terms of the
annual distribution  of  the R  factor
Therefore, in an application it is possible
to consider design  storms with charac-
teristics that can be defined independently
of an actual watershed
  Load  Estimation in Specialized Appli-
cation — Volume I provides an example
of the application of much of the basic
rural nonpoint source methodology to
the problem of  estimating long-term
nutrient fluxes in streams. This applica-
tion showed that the procedures can be
applied in  ways that overcome some of
their fundamental weaknesses (e.g.,
the need  for  a  delivery ratio), while
providing useful results. It  is likely that
other specialized applications can be
developed also.
  Attainment  of Study  Goals — The
primary goal of  the study was to
demonstrate  the  nonpoint  loading
methodology under actual field condi-
tions This goal was accomplished. The
nonpoint loading procedures  and the
water  quality  screening methodology

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were  also  shown to  be compatible,
which was one of the subgoals of the
program.
  The application under field conditions
pointed out the primary strengths of the
methodology —  its relative simplicity
and the  ease with which basic calcula-
tions can be done — and its weaknesses
— dependence on a delivery ratio,  a
higher level of special aggregation in
the case of practical applications in
large  basins,  and the  need for  large
amounts of data. These characteristics
were well  demonstrated in the studies
of the various basins, which illustrated
the degrees of data availability likely in
practice. These applications indicated
that major parameter refinements tend
to be time consuming and, in many
cases,  of  limited value. They also
indicated the difficulty of determining or
assigning  sediment delivery ratios in
most cases.
  Impact of Methodological Shortcom-
ings —  Several  important features in
the rural nonpomt methodology limited
the accuracy that can be expected from
the results of an assessment. These
features include: (a)  a  high  level of
spatial aggregation in the analysis — an
important  fact  because the USLE  is
intended for rather small, homogeneous
areas, (b) the use of a delivery ratio to
account for sediment transport; (c) the
assumption that pollutants such as
phosphorus are  associated with  sedi-
ment, and  (d) the long-term average,
nonhydrologic  nature of the USLE
  An  attempt  was made to overcome
the lack of suitability of the USLE for
analyzing  actual  events  by averaging
over  many events. Dealing  with an
average event  in this manner was
acceptable, however, proper averaging
required many events occurring over a
long  period of time. Data were not
always  available to  carry out  such
averaging.
  Additional shortcomings occurred in
the urban  methodology  used, which
dealt  with annual loads and which
depended upon street loading rates that
were not well established.
  A screening methodology such as
was applied  here  is  intended for
relatively easy application using existing
data.  Overcoming some of the limita-
tions listed above would require greatly
increased  amounts of  data to reduce
spatial resolution problems, to provide
increased  information on sediment
transport, and to provide data on runoff
needed to allow soluble forms of
constituents to be included and to allow
                                        Table 1.
           Water Quality Simulation Results Summary for Rivers

                                                System
                                      Sandusky
                         Patuxent
  LOW FLOW
     Temperature
     BOD
     Dissolved Oxygen
     Coliforms
  HIGH FLOW	

     Sediment
     BOD
     Total N
     Total P
 o
 o
 Key:

  •  Results good to excellent
  Q  Results fair to good
   *  Simulation performed, no comparative data available
(blank) No simulation performed
a more hydrologically-based approach.
Because this demonstration illustrated
the fact that needed data may not be
available even for the screening
approach used,  it seems reasonable to
conclude that more rigorous approaches
can result in even more obstacles due to
data limitations, Especially when  large
areas must be considered.
  The users of the nonpoint methodol-
ogy should be well aware of its limita-
tions.  These  limitations,  however,
should  not prevent the use of the
approach. As the present study showed,
applications can be made that result in
useful  inputs to water  quality assess-
ments in spite of certain methodological
shortcomings of the procedures used
The user should always recall that the
methodology was intended for screening
purposes.

Volume II
  Applicability  of Techniques —  The
nonpoint source calculator and the non-
designated 208 screening methodology
were  highly compatible. Outputs from
the nonpoint source calculator  were
easily adapted and in some cases were
used  directly  in the  mass  balance
equations of the screening methods.
Event-based urban nonpoint loads were
not readily predictable by the nonpoint
calculator, but it is questionable whether
the non-designated  208  screening
methods are applicable  under these
high flow  - unsteady loading scenarios
except to  provide  approximate  upper
and lower limits of  mstream pollutant
levels.
  Loading predicted by the nonpoint
source calculator in conjunction with
mass balance techniques employed by
the non-designated 208  screening
methods provided reasonably accurate
predictions of  instream,  lake,  and
estuary water quality constituent con-
centrations No effects due to basin size
or location were noted that detracted
from either the applicability or accuracy
of the  methods. Generally,  loss of
accuracy due to a loss in resolution was
mitigated by the  averaging  effects
intrinsic to larger systems.
  A qualitative assessment of the
rivers, estuaries and impoundments
methods is shown in Tables 1, 2 and 3.
In general, the  tables imply  that the
river methods were the most accurate
followed by estuaries and then im-
poundments. Within each method it
should be mentioned that  low flow  -
steady  state conditions were  more
readily reproducible than high flow  -
unsteady loading situations.  The im-
poundment methods probably required
the least time and background skills to
apply  The riverine methods  usually
required more time to apply than the
estuary methods. The riverine results,
however, should be easier to interpret
for the uninitiated user than the results
of the estuary methods.
  Loadings predicted by the nonpoint
source calculator in which all parameters
were  assumed  to  be correlated with

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sediment loss were more accurate for
sediment  and  phosphorus  than for
nitrogen and BODs. This was an ex-
pected result.  In  general, predicted
nonpoint source nitrogen and BODs
loads were too low based on compari-
son of observed and predicted instream
concentrations.
  For conservative parameters, linear
increases  or decreases in load esti-
mates (either point or nonpoint) resulted
m approximately linear changes in the
concentrations of those constituents in
the water bodies. Therefore, an approxi-
mate error analysis could be performed
directly using  load  estimates.  For

Table 2.     Water Quality Simulation
            Results Summary  for Im-
           poundments
                      Occoquan

IMPOUNDMENTS
Temperature
BOD
Dissolved Oxygen
Sediment
Total N
Total P
©
o
Key:

 • Results good to excellent
 Q Results fair to good
nonconservative  parameters, changes
in stream, lake, or estuary concentra-
tions caused by increases or decreases
in loadings could only be determined by
routing the pollutants through the
receiving water system.  An error
analysis  using loading changes  and
assuming the constituents behaved
conservatively  gave  an upper limit for
the concentration changes likely to be
encountered.
  Although the methods appeared to be
a powerful  tool for  quickly  identifying
water quality problem areas, the use of
the predictive techniques in conjunction
with observed data further  added to
their effectiveness.  By  doing this, the
planner could identify specific problem
areas in which quality cannot adequately
be described by the simple techniques.
In most cases,  the planner will  be able
to recommend action, based on an
understanding  of the methods he has
already applied, to investigate the
problem  area  more  closely. These
further investigations may include
sampling programs or the use of a more
sophisticated analytical tool
  Rivers  and  Streams —  Hydraulic
characterization of rivers and streams
was one of the most error-prone steps
in the methods A major reason for this
was that flow, in many cases, was a
function of  phenomena that  could not
be estimated directly from the  surface
topography Unless the user had ground-
Table 3.    Water Quality Simulation Results Summary for Estuaries
                                            System
                         Chester
                    Patuxent
                              Ware
LOW FLOW
BOD
Coliforms
Total N
Total P
HIGH FLOW
Sediment
BOD
Total N
Total P
0
*


*
O
O
*
O

• •
•
o
o
0
0
 Key:
   •  Results good to excellent
   0  Results fair to good
   O  Results poor to fair
      Simulation performed, no comparative data available
(blank) No simulation performed
water measurements or detailed poten-
tiometric maps, these effects could not
be properly characterized.
  Dissolved oxygen prediction was far
more sensitive to errors in estimating
reaeration rates than m estimating
deoxygenation  rates  Predictive tech-
niques for stream reaeration deserve
additional  attention  Comparison of
predicted instream fecal or total cohform
concentrations with observed data was
impractical
  Impoundments —Thermal plots from
the impoundment thermal model accu-
rately described water temperature,
thermal gradients, and time of the onset
of stratification The greatest difficulty
in using the thermal profiles lay in the
selection of the correct plot to apply in a
borderline case In such cases, selection
of the maximum depth parameter was
aided by  also  considering  the mean
impoundment depth. The hydraulic
residence time strongly  affected  the
thermal profile of an impoundment.
  Accuracy  of sedimentation calcula-
tions for impoundments  depended
primarily on  accurate load estimates.
Although on-site data should be used,
the demonstration  watershed  results
indicated that the  Universal Soil Loss
Equation may be used with some
confidence. Adequate knowledge of
sediment diameters is required because
trapping efficiencies  were sensitive to
particle size
  The ability of the methods toquantita-
tively predict parameter values  associ-
ated with eutrophication was  limited
Plant growth could only be approximated
and seasonal  effects could  not  be
represented adequately
  The hypohmnion dissolved  oxygen
calculations for impoundments were
sensitive to  the BOD loading rate  and
decay rates  Qualitatively useful results
were predicted  by the simplified hypo-
limnion  dissolved oxygen model even
when  BOD  decay  rates  were  not
accurately known.
  Estuaries — The stratification-circu-
lation method was preferred for estuarme
classification, but the required data was
not  always  available  To  obtain  a
complete picture of the  hydrodynamic
variation that an estuary might undergo,
the surface velocity, the net freshwater
velocity,  and the surface and  bottom
salinity should be available for high and
low freshwater inflows  Use  of  the
flow ratio method  underestimated the.
degree of vertical stratification.
  The tidal  prism  and modified tidal
prism flushing times were related,  and

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their ratio seemed to depend on the
estuary volume. The fraction of fresh-
water method was fairly insensitive  to
the  number of segments  used  to
estimate  flushing times. For flushing
times derived by the  modified tidal
prism method that were similar at high
and low flows, mechanisms other than
advective flow were more important in
flushing  an estuary  The fraction  of
freshwater and the modified tidal prism
methods predicted more similar flushing
times for small estuaries
  Low flow predictions of pollutant
distributions in estuaries were good for
conservative constituents.  For non-
conservative constituents, the modified
tidal prism method must  be  used.
Pollutant distributions  predicted  for
unsteady flow or unsteady  loading
represented upper and lower limit
concentrations.  Contamination in the
estuary caused by replacement waters
could be estimated  by comparing
observed profiles to those predicted  by
the estuarme methods.
Michael J. Davis, Michael K. Snyder. and John W. Nebgen are with Midwest
  Research Institute. Kansas City. MO 64110.
Robert B. Ambrose is the EPA Project Officer (see below).
The complete report consists of two volumes, entitled "River Basin Validation of
  the Water Quality Assessment Methodology for Screening Nondesignated
  208 Areas:"
    "Volume I. Nonpoint Source Load Estimation," (Order No. PB 82-260 837;
    Cost: $15.00, subject to change}
    "Volume II. Chesapeake-Sandusky Nondesignated208 Screening Method-
    ology Demonstration," (Order No. PB 82-260 845; Cost: $19.50, subject to
    change)
The above reports 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:
        Environmental Research Laboratory
        U.S. Environmental Protection Agency
        Athens, GA 30613

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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
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