United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/S2-90/042 Sept. 1990
vvEPA Project Summary
EPA Mobile Incineration System
Modifications, Testing and
Operations - February 1986 to
June 1989
J.P. Stumbar, G.D.Gupta, R. Sawyer, A. Sherman, K.E. Hastings, J. DeHaan,
G. King, and M. Szynalski
The report summarized here cov-
ers the field demonstration activities
of the U.S. Environmental Protection
Agency's (EPA's) Mobile Incineration
System (MIS) from February 1986 to
June 1989 at the Denney Farm site,
Missouri. These activities were the
culmination of a project sponsored
by the EPA Office of Research and
Development, Office of Solid Waste
and Emergency Response, and Re-
gion VII to demonstrate the feasibility
of incinerating hazardous wastes on-
site in mobile incineration systems.
The initial part of the field demon-
stration was discussed in an earlier
Project Summary and associated
report.*
The activities discussed in the
current report include: modifications
made to the MIS to double its
capacity and to improve its reliability;
the 1987 trial burn for Resource
Conservation and Recovery Act
(RCRA) and Toxic Substances Con-
trol Act (TSCA) wastes; tests to show
the feasibility of processing bromin-
ated sludge and canceled pesticides,
including testing for metals emis-
sions; delisting tests for the
biominated sludge; site and incin-
erator closure activities; and the
accomplishments, problems encoun-
tered, and solutions implemented
during the operation of the MIS. In
* "Destruction of Dioxm Contaminated Solids
and Liquids by Mobile Incineration,"
EPA/600/S2-87/033, NTIS PB87
188512/AS.
addition, a system availability analy-
sis is presented. The information
contained in the full report is of
benefit to those in the public sector
who are considering or are currently
applying incineration technology as a
remedial alternative.
This Project Summary was
developed by EPA's Risk Reduction
Engineering Laboratory, Cincinnati,
OH, to announce key findings of the
research project that is fully doc-
umented in a separate report of the
same title (see Project Report
ordering information at back).
Introduction
The development of the EPA MIS
began in the mid-1970s as a research
effort to demonstrate the ability to
incinerate oil and hazardous materials on-
site. After several years of design and
construction, shakedown testing of the
unit began in 1981. The MIS successfully
demonstrated its capability for incin-
erating PCBs and other chlorinated
organic liquids in trial burn tests
conducted in New Jersey in 1982 and
1983. Upon successful completion of
these tests, the MIS was modified to
handle solid waste materials and was
subsequently brought to the Denney
Farm site in southwestern Missouri for a
field demonstration. The purpose of the
MIS field demonstration was to demon-
strate the feasibility of using mobile
incineration for the on-site treatment and
disposal of hazardous wastes.
The Denney Farm site was one of
eight southwestern Missouri sites con-
-------
laminated with 2,3,7,8-tetrachlorocliben-
zo(p)dioxin (2,3,7,8-TCDD) and related
compounds. Successful completion of
the dioxin trial burn conducted in April
1985 allowed the MIS to become the first
fully-permitted hazardous waste treat-
ment facility for dioxin in the United
States. In addition, the delisting tests
conducted at that time declared the ash
and water generated during incineration
of dioxin-contaminated soils in the MIS to
be nonhazardous. Between 1985 and
1989, the incinerator treated over
12,500,000 Ib of solids and 230,000 Ib of
liquids from the eight southwestern
Missouri dioxin sites.
The field demonstration, which began
in July 1985, was suspended in February
1986 pending reauthorization of Super-
fund. When funding from the Superfund
became available, modifications were
made to the system before the start of
operations. These modifications improved
the system's on-line factor and capacity.
Shakedown testing of the modified
system was conducted and operations
resumed during the summer of 1987.
From that time until April 1989, the
incinerator treated the remaining dioxin-
contaminated materials from the eight
southwestern Missouri dioxin sites. In
addition to processing these wastes, a
trial burn, delisting tests, feasibility tests
of brominated sludge and vermiculite,
and metals emissions tests were suc-
cessfully conducted. These activities are
all discussed in the project report.
The results of the all trial burns
conducted on the MIS and engineering
data showing the final configuration of the
MIS are presented in the fact sheets
included in this Project Summary.
System Modifications
Major modifications were installed on
the system during 1987 before the restart
of operations. In addition, some system
modifications were made during main-
tenance periods in 1988. The mod-
ifications and resulting improvements to
the system are discussed below.
The incorporation of a Linde "A"®*
Oxygen Combustion System in the rotary
kiln was primarily responsible for
increasing the MIS capacity for treating
soils by more than a factor of two. This
was the first application of oxygen in a
hazardous waste incineration system.
The microprocessor-based controls of the
oxygen system have exhibited excellent
* Mention of trade names or commercial
products does not constitute endorsement or
recommendation for use.
response, which has reduced the number
of feed shutdowns due to low oxygen and
high carbon monoxide contents in the
stack gas.
Modifications to the air pollution
control system consisted of adding a
cyclone, replacing the Cleanable High
Efficiency Air Filter (CHEAF) with a wet
electrostatic precipitator (WEP), and
adding a Monarch® CPI separator. The
cyclone alleviated the problem of
particulate accumulation in the secondary
combustion chamber (SCC). The frequent
clean-outs of the accumulation, which
previously occurred on a weekly basis,
and the associated downtimes were al-
most eliminated. The unit was able to
operate over a period of several months
before a clean-out was required. The
WEP demonstrated excellent perfor-
mance in particulate removal and solved
the extensive maintenance requirements
associated with the CHEAF. The WEP
did, however, have a tendency to
occasionally short out, causing some
downtime. The Monarch® CPI separator
minimized the suspended particulate
matter in the process water system and
required little maintenance.
Modifications to the feed system
consisted of increasing the size of the
ram feed trough and adding a conveyor
belt system, an adjustable roller, and a
television camera. The larger trough
helped to increase the system's capacity
by increasing the amount of material
entering the kiln with each stroke of the
ram. The conveyor belt system, which
was installed in March 1988 and was
used to feed material to the shredder,
successfully increased production by re-
ducing the frequency of handling feed
materials. This permitted sustained feed-
ing of material at twice the original feed
rates. An adjustable roller installed in the
feed system in January 1988 reduced the
frequency and severity of feed system
blockages. A television camera placed at
the discharge end of the conveyor belt
provided prompt detection of feed
system jams. These modifications
increased the reliability of the MIS.
Other modifications that improved
reliability were redesigning the ash gates
and the SCC exit. The repair and
redesign of the ash gates reduced
slagging incidents. Replacement of the
metal venturi SCC outlet with a
refractory-lined outlet duct eliminated the
frequent failures in this area of the MIS.
A mist eliminator was installed in the
MX scrubber to reduce the particulate
emissions, which was necessary at high
organic halide loadings. Knock-out ports
installed in the ducts between the rotary
kiln and SCC permitted hot clean-outs of
ash deposits that accumulated in these
areas when the MIS processed bromin-
ated sludge. The ability to clean out the
ducts without needing to first cool down
the system minimized the interruption in
operation. The hot clean-out took minutes
to complete, whereas a cold clean-out
took days.
Shakedown and Compliance
Testing on Modified System
A series of tests including the
RCRA/TSCA trial burn showed that the
MIS could process almost any organic
hazardous waste in an environmentally
acceptable manner. These tests were
conducted as a research effort and also
in an effort to qualify for a permit that
would allow the MIS to incinerate the
canceled pesticides, 2,4,5-T and silvex,
and a dioxin-contaminated brominated
sludge.
The trial burn for both the RCRA and
TSCA compounds was conducted during
the summer of 1987. The principal organ-
ic hazardous constituents (POHCs) for
the trial burn that were regulated under
RCRA were carbon tetrachloride,
hexachloroethane, and trichlorobenzene,
which are among the most difficult RCRA
compounds to incinerate. PCBs were the
TSCA POHCs. This trial burn demon-
strated the MIS's ability to exceed the
required 99.9999% destruction and
removal efficiency (ORE) for PCBs and
the required 99.99% (ORE) for the RCRA
compounds.
A series of tests were conducted with
brominated sludge and with mixtures of
brominated sludge, soil, and sodium
sulfate (Na2SO4) to determine the com-
position most suitable for feeding. These
tests showed that it was best to incinerate
pure brominated sludge, and they
determined the proper operating
conditions for this difficult-to-incinerate
material. The critical operating conditions
defined by the tests were: a low 0.8 rpm
kiln rotation speed to provide adequate
solids residence time for burn-out; a kiln
temperature of 1650°F to 1700°F to
maintain ignition and prevent combustion
oscillations; and water injection to control
kiln temperature and maximize through-
put.
As a result of slagging in the kiln and
troublesome ash deposits in the duct
system, tests to ascertain the ash fusion
characteristics and chemical analyses of
the slag and ash deposits were con-
ducted. The results of the tests showed
that slagging was promoted when sodium
and potassium content of the ash ex-
ceeded 3.5 wt% and that troublesome
-------
ash deposits occurred when the ash
contained large quantities (50 wt%) of
calcium and sulfur.
A metals testing program was
conducted to determine the quantity of
metals being emitted from the stack
during incineration of the brominated
sludge because of its high content of
lead, chromium, and other metals. The
tests showed that the metal emissions
were below the Tier II emissions
screening levels presented in the
proposed amendments to the hazardous
waste incinerator regulations. Since the
Tier II emission levels are health based,
this finding showed that health risks from
metal emissions were acceptable.
Testing of heavy metals emissions
and of the residue streams showed how
mercury, cadmium, lead, arsenic,
hexavalent chromium and total chromium
were partitioned among the various
residue streams. Mercury did not appear
in the kiln or cyclone ash in measurable
quantities and was probably volatilized. A
small amount was captured by the air
pollution control system and wound up in
the separator sludge. Most of the
mercury measured was found in the
particulate portion of the stack effluent at
concentrations that were 90 times those
in the original feed material. Most of the
lead and cadmium were volatilized and,
after condensation, were contained in the
separator sludge. Furthermore, the con-
centrations of lead, cadmium, and
mercury in the separator sludge and the
stack were an order of magnitude higher
than in the other solid residue streams.
Total chromium concentrations were ap-
proximately the same in all solid streams,
but significant levels of hexavalent chro-
mium were found only in the cyclone ash.
Delisting tests for the residues
generated during incineration of the
brominated sludge were conducted.
These tests showed that residual concen-
trations of less than 15 parts per trillion of
dioxin in the solid residue and less than
120 parts per quadrillion of dioxin in the
scrubber water were achievable.
Operating Experiences
The operation of the MIS has shown
constant improvement as engineering
solutions to the operating problems have
been applied. From 1985 to 1989,
capacity was doubled from 2000 Ib/hr to
4000 Ib/hr, and the system availability
increased from 40% to 80%.
The increased capacity and reliability
greatly reduced incineration costs
between 1985 and 1989. During closure,
materials were processed for $1100/ton
compared with a $2800/ton cost for
similar materials at the start of operations
in 1985. Since incineration costs are
directly related to throughput, however,
they were widely variable. Materials with
high heat contents cost more to process
because of the low processing rates
achievable with these feeds. Note that
these costs do not reflect costs of doing
mobile incineration commercially; this
project was one task conducted under an
EPA research contract. The relative costs
of the various operating periods are
significant.
The performance capabilities of the
MIS on a variety of feed materials have
been ascertained. Operational experience
during 1987, 1988, and 1989 has shown
that feed rates vary widely depending on
the feed characteristics. Relatively dry
soil (less than 20% moisture) could be
processed at 4000 Ib/hr. Feed moisture
contents of about 35% produced muddy
soil that could be fed at only 2000 Ib/hr.
The heat and moisture contents as well
as slagging tendencies of the feed
material were the most important
variables affecting feed rates. With a
2650 BTU/lb minimum heat content,
brominated sludge could be incinerated
at only 2000 Ib/hr. Pure trash with a
heating value up to 18,000 BTU/lb could
only be processed at rates of 200 Ib/hr.
Denney Farm Site and MIS
Closure
The closure at the Denney Farm site
provides a benchmark example for the
clean closures of other incinerator sites.
Closure at Denney Farm entailed decon-
tamination of Denney Farm soil, decon-
tamination of the hot zone buildings used
for storage and handling of hazardous
waste, decontamination of hot zone
equipment, decontamination of the feed
system, and disassembly and transport
of the MIS. Target compounds and the
associated action levels were approved
by the Missouri Department of Natural
Resources.
The initial closure activities involved
sampling and analysis of the site soils to
determine the extent of contamination.
The data showed that contamination had
spread to areas outside the hot zone. The
contaminated soils from inside and
outside the hot zone were excavated and
incinerated.
Lessons learned from this movement
of contamination are as follows:
• The number of waste handling steps
should be minimized to prevent
spillage of the material, and contam-
inated material should only be handled
within diked areas.
• The hot zone areas should be graded
so that rainwater cannot carry contam-
ination into clean areas.
• Periodic sampling of the site should
be conducted to identify contamination
and thus permit prompt action to
prevent its spread.
Equipment and buildings on the site
were wipe tested to determine the extent
of contamination. All contaminated equip-
ment was decontaminated and wipe test-
ed before leaving the site. This procedure
ensured that all equipment leaving the
site from both inside and outside the hot
zone was free of contamination. The in-
dividual components of the buildings
(sheet metal walls, concrete foundations,
and wood framework) were sampled sep-
arately because of their different action
levels. The contaminated building and
equipment surfaces were decontaminated
by scrubbing with brushes and rinsing
with high pressure water or steam
cleaning. This was preceded by scraping
when necessary.
The MIS was disassembled to the
degree that all components could be
mounted on over-the-road equipment and
transported. The equipment was trans-
ported to the EPA Edison, New Jersey,
facility in May and June 1989. The
government-owned equipment required a
total of 21 trailers for transport.
Recommendations
EPA does not plan to sponsor further
field demonstration of the MIS. EPA is,
however, seeking a technology partner to
sponsor further development of the MIS
under the Federal Technology Transfer
Act (FTTA). This law allows the federal
government to seek a technology part-
nership with a commercial or other
governmental organization for further
development of such equipment to
advance the state of the knowledge.
Should the MIS be operated again under
the FTTA, the following modifications can
be made to improve the economics of the
system by reducing the number of
operators and utility costs:
1. Automate ash handling.
2. Consolidate all controls into a central
control room. This should include the
Continuous Emission Monitoring
equipment.
3. Install a larger quench sump to ensure
sufficient water holdup for all the
pumps, quench elbow, and WEP.
The full report was submitted in
fulfillment of Contract 68-03-3255 by
Foster Wheeler Enviresponse, Inc., under
the sponsorship of the U.S. Environ-
mental Protection Agency.
-------
MIS Facts
Following is a summary of facts and
figures pertaining to the operation of the
EPA Mobile Incineration System. In-
cluded in this summary are the operating
conditions for the system, drawings of its
major components, its overall dimensions
and utility requirements, and the results
of its various trial burn tests.
U.S. EPA Mobile Incineration System Facts and Figures
Description and Operating Summary
Operating Summary
Description
Overall Length: 150 ft
Stack Height: 40 ft
Overall Heat Duty: 13.5 MMB TU/hr
Electrical Requirements: 130 KW
Temperature (°F)
Pressure (in w.c.)
Gas Residence Time (sec)
Kiln
1450
-0.3
3.0
Cyclone
1450
-2.5 est
1.5 est
sec
2200
-3.0
2.0
minimum
Quench
195
-7.0
NA
Stack
175
-15 at fan
NA
Feed Rates:
Air (SCFM)
Oxygen (SCFM)
Fuel Oil (gph)
Waste Solids (Ib/hr)
Waste Oil (Ib/hr)
Water (gpm)
Dischaiges:
Ash (Ib/hr)
Scrubber Water (gpm)
Flue Gas (SCFM)
560
118
41
4000
150
1.5
24002
1150
NA
NA
NA
NA
NA
NA
4002
1150
1200
NA
60
NA
NA
NA
NA
2400
NA
NA
NA
NA
NA
61'
50
2 to 123
4300
500
(leakage)
NA
NA
NA
NA
NA
NA
5800
' Cooling water injected into Quench area about 10 gpm is evaporated by the SCC flue gas; the remainder is recirculated.
2 For a typical soil. This is variable depending on waste characteristics.
3 The blowdown was adjusted to maintain 20.000 ppm total dissolved solids at the MX Scrubber. This is variable depending upon the organic
halogen and sulfur contents of the waste
Trial Burns
Description
ORE Achieved
Particulate
Emissions
(gridscf)
HCI Removal C%
Initial Tests:'
September 1982 through January 1983 (Liquid Wastes Only)
1. Diesel Fuel/Iron Oxide for particulates
2. Diesel Fuel/Carbon Tetrachloride/Dichlorobenzene
Carbon Tetrachloride
Dichlorobenzene
3. PCBs/Trichlorobenzene/Tetrachlorobenzsne
Trichlorobenzene
Tetrachlorobenzene
PCBs as Aroclor 1260
4. PCBs/Trichlorobenzene/Tetrachlorobenzene
Trichlorobenzene
Tetrachlorobenzene
PCBs as Aroclor 126O
Oioxin Trial Bum: (Solids and Liquids)
(February and April 1986)
1. 2,3,7,8-TCDD Run#2
2. 2,3,7,8-TCDD Run*3
3. 2,3,7,8-TCDD Run#4
4. 2,3,7.8-TCDD RuntS
5. 2,3,7,8-TCDD/brominated sludge
NA
> 99.99996
> 99.99998
> 99.9998
> 99.9994
> 99.9998
> 99 99993
> 99.99985
> 99.99991
99.99997
99.99998
99.99999
99.9999S
NA
0.011
0.029
0.016
0.019
0.060
0.065
0.065
0.090
NA
NA
99.95
99.98
99.99
NA
NA
NA
NA
99.0
' The ORE and particulate data are averaged over three test runs.
-------
U.S. EPA Mobile Incineration System Facts and Figures
Description
ORE Achieved
Paniculate Emissions
HCI Removal
RCRA/TSCA Trial Burn:
July, August 1987
Run 2 Solids Only
PCBs
Carbon Tetrachloride
Low Vost
High Vost
1,2,4- Trichlorobenzene
Hexachloroethane
Run 3 Solids and Liquids
PCBs
Carbon Tetrachloride
Low Vost
High Vost
1,2.4- Trichlorobenzene
Hexachloroethane
Run 5 Solids, Liquids and Trash
PCBs
Carbon Tetrachloride
Low Vost
High Vost
1,2,4- Trichlorobenzene
Hexachloroethane
0.065
99.9999996
NA
NA
99.99997
99.99984
0.066
99.9999995
99.99968
99.99958
99.99968
99.9987
0.085
999999965
9999976
9999869
99.99996
99.999976
99.97
99.98
99.99
Rotary Kiln
Dimensions
Trailer Length (ft)
Kiln Length (ft)
Kiln I.D. (in)
Kiln Volume (ft3)
45
15
52
235
Description
Exit
Duct:
Carbon Steel Shell with Dual
Refractory Lining (5-in
Combustion Engineering Blue
Ram" plus 2-in CE Lite Weight 58)
Inconel 607
Burners: 7 -LJnde A* Oxygen Burner with
Propane Pilot (8 MMBTU) 1-
Maxon Fuel Oil Burner with
Propane/ Pilot (2.9 MMBTU/hr)
COM
AIRE
At' ri
RAM FEED &
BUSTION KILN DRIVE SOLIDS RAM
3LOWER \ HYDRAULICS FEED SYSTEN/
V f i^
/
5^^i_J ! —
•""•"•'•
VER/
9
^5fcaBH...JIL...JlL/k
kLL
q
m
KILN
l^-s,....
D./_.
TO /
CYCLONE
CONTROL
PANEL
/
BURNERS
Kiln Feed Rates
Air (SCFM)
Oxygen (SCFM)
Fuel Oil (gph)
Waste Solids (Ib/hr)
Waste Uquids (Ib/hr)
Water (gpm)
560
778
47
•»000 (by permit)
750 (by permit)
7.5
Temperature (°F)
Pressure (in w.c.)
Flue Gas Residence Time
RPM
Solids Residence Time
Heat Release (MMBTU/hr)
Operating Conditions
Normal Maximum
1450
-0.3
3.0
1.0
30
3.0
1900
-1.0
5.0
2.0
75
5.5
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U.S. EPA Mobile Incineration System Facts and Figures
SIGHT PORT
Height (ft)
O.D. (in)
1.0. (in)
Volume (ft3)
13
50
38
Description
Cyclone: Carbon Steel Casing
with Dual Refractory
Lining (3-in Insulating
Resco RS-3 plus 3-
in Resco RS-17E.
Bottom Casing
Inconel 601
Outlet
Tube:
Inconel 601
Operating
Conditions
Normal Maximum
Temperature (°F)
Pressure (in w.c.)
Flue Gas Residence Time (sec)
(includes ducts between kiln and SCC)
Solids Residence Time (sec)
Cut Point (microns)
1450
-2.0 est.
1.5
1.5
5.0
1900
-60
2.4
Secondary Combustion Chamber iSCC) and Quench
SCC Feeds Rates
Air (SCFM) 1200
Fuel Oil (gph) 41
Waste Liquids (Ib/hr) none
Temperature (°F)
Pressure (in w.c.)
Flue Gas Residence Time
Heat Release (MMBTU/hr)
COOLING "" QUENCH
SHROUD FAN ELBOW
Operating Conditions
Normal Maximum
2100 2400
-3.0 -10.0
25 2.0(min)
54 8.2
Dimensions
Trailer Length (ft) 45
SCC Length (ft) 42
SCC ID. (in) 52
SCC Volume (ft3) 531
Description
SCC:
Quench
Duct:
Burners:
Carbon Steel Shell with Forced
Draft Cooling Annulus with
Refractory Lining 6-in AP Green
Kastolite 30
Inconel 625 with internal
water spray (60 gpm)
2-Norm American Burners with
Propane Pilot (8.2 MMBTUihr Total)
Flue Gas Composition from Trial Burn:
CO,
H,O
CO
NOX
HCI
SO,
6.0% 70.3% 24.9% 577% 19 ppm 96 ppm 1.1% <300ppm
-------
U.S. EPA Mobile Incineration System Facts and Figures
Wet Electrostatic Precipitator (WEP)
TO MX SCRUBBER
- OVERFLOW
Height (ft)
Width (in)
Length (in)
Volume (ft3)
40
84
84
Collector:
Rods:
Description
Fiberglass-
reinforced plastic
(FRP) Hetron 97
with 5% Antimony
Trioxide
Conductive FRP
304 Stainless Steel
Temperature ("F)
Pressure (in w.c.)
DC voltage (KV)
DC current (ma)
AC voltage (V)
AC current (a)
Fog Water (gpm)
Wash Water (gpm)
Operating Conditions
Normal Maximum
180
-70 est.
11
60
140
25
200
-11.0
13
60
140
25
Mass Transfer (MX) Scrubber and <.D Fan
Dimensions
Trailer Length (ft) 45
Scrubber Length (ft) 8
Scrubber Height (ft) 5
Scrubber Volume (ft3) 130
Scrubber: FRP filled with plastic packing plus a 304 Stainless Steel mist
eliminator consisting of a three pass chevron unit and 5-in thick pad
I.D. Fan: 316L Stainless Steel housing with a Inconel 625 shaft and 36-in
diameter impeller and 155 HP diesel engine
Stack: 2-ft x 2-ft 304 Stainless Steel, 40-ft high
27' OVERALL
APPROX. 40' ABOVE GRADE
. STACK GAS ANALYSIS
/
t
/
C3/
LL
v-——
Tr=
t h
2 MX
r> SCRUBBER
I
\
\
/
T
\
ii
•s-
-
nn
4
P<
I.D. FAN
DRIVE
X.
1
00
CONTROL
PANEL
I.D.
FAN
MX Feed Rates
Water: (gpm) 75 Temperature ("F)
Pressure (in w.c.)
HCI Removal Efficiency (%)
Operating Conditions
Normal
175
-12
>99.9
Maximum
200
-19
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J.P. Stumbar, G.D. Gupta, R. Sawyer, A. Sherman, K.E. Hastings, J. DeHaan, G.
King and M. Szynalski are with Foster Wheeler Enviresponse,
Incorporated, Livingston, NJ 07039.
Joyce M. Perdek is the EPA Project Officer (see below).
The complete report, entitled "EPA Mobile Incineration System Modifications,
Testing and Operations - February 1986 to June 1989," (Order No. PB
90-260 4491 AS; Cost: $31.00, 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:
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Edison, NJ 08837
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No. G-35
Official Business
Penalty for Private Use $300
EPA/600/S2-90/042
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