United States
               Environmental Protection
               Agency	
Risk Reduction
Engineering Laboratory
Cincinnati OH 45268
               Research and Development
EPA/600/S-92/024  Sept. 1992
EPA       Project Summary
                Construction,  Monitoring,  and
                Performance  of  Two  Soil  Liners
                Ivan G. Krapac, Keros Cartwright, Bruce R. Hensel, Beverly L Herzog, Timothy
                H. Larson, Samuel V. Panno, James B. Risatti, Wen-June Su, and Kenneth R.
                Rehfeldt
                  A prototype soil liner and a field-
                scale soil liner were constructed to test
                whether compacted soil barrier systems
                could be built to meet the standard set
                by the U.S. Environmental Protection
                Agency (EPA) for saturated hydraulic
                conductivity (< 1 x 10'7 cm/s). In situ
                ponded infiltration rates into the proto-
                type liner were measured with the use
                of two large, (5-m diameter) sealed
                double-ring infiltrometers. The satu-
                rated hydraulic conductivity of the liner
                was estimated from the infiltration data
                to be no more than 3.6 x 10-" cm/s.
                Fluorescein and rhodamine WT  dyes
                were allowed to infiltrate the prototype
                liner for 46 days. Dye patterns observed
                during excavation of the prototype liner
                indicated that lateral flow occurred be-
                tween lifts and along the interface be-
                tween soil clods. Although the proto-
                type liner met the EPA requirement for
                hydraulic conductivity, the dye flow
                paths indicated a need for better bond-
                ing between  lifts and for reduced soil
                clod sizes to eliminate preferential flow
                paths in the liner.
                  The field-scale liner (7.3 x 14.6 x 0.9
                m) consisted of 6 compacted lifts each
                15-cm thick.  Full-scale equipment was
                used for compaction. This liner was
                compacted at an average moisture con-
                tent of 11.5%, 1.5% wetter than the op-
                timum moisture content as determined
                by the Standard Proctor test. The mean
                dry density of the liner was 1.84 g/cm3,
                93% of the maximum Standard Proctor
                density.
                  Based on 1 yr of measurements of
                water infiltration into the liner, estimates
                of saturated hydraulic conductivities
                were 3.3 x 10* by large-ring infiltrom-
 eters, 5.3 x 10-8 by small-ring infiltrom-
 eters, and 6.7 x 10"8 cm/s by a water
 balance analysis. Measurements of soil
 tension using pressure transducer ten-
 siometers indicated that the wetting
 front had reached a depth greater than
 20 cm.

   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 documented in a separate
 report of the same title (see Project
 Report ordering  information at the
 back).


 Introduction
   In 1985, the Illinois State  Geological
 Survey began a multi-year study to evalu-
 ate the procedures used in constructing
 and testing soil  liners at waste-contain-
 ment facilities. To fulfill the study objec-
 tives, the movement of water and solutes
 through two test liners was monitored. The
 project  was divided into three phases.
 Phase 1, which began in 1985, included
 (1) an  evaluation of the properties that
 make a soil suitable for constructing a
 liner and (2) the selection and character-
 ization of  a soil for use in this project.
 Phase 2, which began in 1986, included
 the construction of a prototype soil liner to
 test construction practices and to deter-
 mine if  a hydraulic conductivity less than
 1 x 10'7 cm/s could be measured in situ
 using the soil selected. Phase 3, begun in
 1987, included the construction and long-
 term monitoring of a field-scale soil liner.
 This extensively instrumented liner contin-
 ues to be monitored.

           n?3) Printed on Recycled Paper

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 Procedures

 Soil Selection Criteria
   Qualitative  selection criteria were es-
 tablished to compare the construction char-
 acteristics of three glacial tills (the Snider,
 Plat, and Batestpwn  Members of  the
 Wedron Formation).  Representative
 samples of the tills were collected from
 five locations  in Illinois. Numerical criteria
 were assigned to hydraulic conductivity,
 Atterberg limits, particle-size distribution,
 natural moisture content, and the dry bulk
 density. One  potential material failed the
 hydraulic conductivity criterion. Other prop-
 erties tested  (dispersivity,  clay  mineral-
 ogy, specific gravity, cation exchange ca-
 pacity)  were  not significantly different in
 the three tills to serve as selection criteria.
 Because of the similarity of their proper-
 ties, the final selection  of  a material to
 construct the liner was  based  on eco-
 nomic factors  related to the cost of obtain-
 ing  and transporting  the soil. The
 Batestown Till, an illitic glacial till with  a
 (oam texture, was the material selected to
 construct the soil liners.

 Prototype Liner
   A small, 3-  x 9- x 0.9-m prototype liner
 was built in six lifts. Each lift was con-
 structed by spreading a 23-cm thick layer
 of foose soil and compacting it to 15 cm.
 The loose soil contained some clods and
 stones up to 15 cm in diameter, although
 an effort was  made to remove any clods
 and stones larger than 10 cm in diameter.
 A padfoot compactor with feet 10 cm long,
 capable of delivering 222.4 KN  (50,000
 tb) of force in the vibratory mode, was
 used to compact  the soil. Lift  surfaces
 were scarified  after compaction to improve
 lift bonding. The liner was compacted at
 an average moisture content of 11.7%,
 and a dry density of 2.02 g/cm3.
  The experimental  configuration of the
 prototype liner consisted of two,  large-
 diameter, sealed, double-ring infiltrometers,
 with inner rings 1.5-m  in diameter. The
 Infiltrometers measured in situ infiltration
 rates that were subsequently used to esti-
 mate the hydraulic conductivity of the liner.
 Soil-water  monitoring  instruments  were
 also tested in the liner. Monitoring devices
 included tens'tometers and gypsum blocks
to measure  soil-water tension and  pres-
sure-vacuum lysimeters to collect soil-wa-
ter samples for solute concentration analy-
sis. Horizontal  and vertical installation tech-
niques for the monitoring devices  were
compared to determine which method was
more reliable.  Horizontally installed  moni-
toring devices  were positioned during con-
struction of the liner. A tensiometer and a
 gypsum block were placed on the surface
 of compacted; lifts 1, 3, and 5, which cor-
 responded to, depths  of 75, 45, and  15
 cm, respectively.  In  addition, lysimeters
 were placed o'n the tops of lifts 4 (a 30-cm
 depth) and 5. The wires and  PVC tubing
 connected to these devices were laid
 across  the top  of the compacted  lift in
 shallow  trenches  cut into  the compactor
 foot pattern and covered with loose soil
 before compaction of the  next lift.  Verti-
 cally installed  monitoring  devices  were
 positioned between  the inner and  outer
 rings of the infiltrometer after the liner was
 constructed. Additional, vertically installed
 instruments were  placed near each hori-
 zontal instrument.  For vertical instruments,
 holes slightly larger  in diameter than the
 instruments were cored to the tops of lay-
 ers 1, 3, 4, and 5  and the holes backfilled
 with a bentonite slurry after installation of
 the instrument.
   Dyes were added to the water in one of
 the infiltrometers to reveal preferential flow
 paths in the liner caused by endemic soil
 properties and compaction processes. The
 dyes were also used to reveal preferential
 flow paths around monitoring  devices re-
 sulting from the installation methods.


 Field-Scale Liner
   The field-scale  soil liner was  built  to
 assess  the a|real  variability  of  a liner's
 hydraulic properties, to determine the tran-
 sit time of water and tracers through the
 liner, and to address the feasibility of con-
 structing a liner  with the EPA's hydraulic
 conductivity specifications. Before con-
 struction of the liner, the clod size of the
 Batestown till was reduced to  less than 5
 cm in diameter and rocks larger than 5 cm
 in diameter were removed. Water was then
 added to the soil so that the soil moisture
 content would; meet the design specifica-
 tion of 1% to 2% wetter than the optimum
 moisture content as determined by  Stan-
 dard  Proctor itests.  The  soil was  then
 stored and thp soil moisture  content  al-
 lowed to equilibrate for 3 wk.
   A static padfoot compactor, with a rated
 operating weight of 20,370 kg,  compacted
 the six  lifts of the 7.3- x  14.6-  x 0.9-m
 liner; each foot was 20 cm long. The soil
 for each lift was spread, tilled, and then
 compacted to a thickness of 15 cm. The
 surface of each lift was scarified to facili-
 tate bonding between lifts.  The liner was
 compacted at.an average  moisture con-
tent of 11.5%; 1.5% wetter than the opti-
 mum moisture content as determined by
the Standard Proctor test. The mean dry
 density of the liner was 1.84 g/cm3, 93%
of the maximum Standard Proctor density.
   The  liner  is enclosed  in a  shelter to
 allow year-round monitoring and to pre-
 vent the liner from freezing. A 31 -cm-deep
 pond, contained above the liner, was filled
 in 1988. An underdrain system  consisting
 of geomembrane and gravel was built be-
 neath  the liner to collect any  water dis-
 charging from the  liner. The underdrain
 system was  built so that the amount of
 discharge from each quadrant of the liner
 can be collected and measured.  In addi-
 tion to the underdrain system, pan lysim-
 eters were installed beneath the liner in
 the  center of each  quadrant as  another
 method  of measuring liner effluent. Four
 large-ring (1.5-m diameter) and 32 small-
 ring (0.3-m diameter) infiltrometers moni-
 tor infiltration rates at various locations on
 the liner surface. The infiltration rates are
 used to estimate the spatial variability of
 the liner's hydraulic conductivity and pos-
 sible scale effects of measurement. In ad-
 dition,  a different tracer  (bromide, o-tri-
 fluoromethyl benzoic acid, m-trifluoromethyl
 benzole acid or pentafluorobenzoic acid)
 was added  to  each of the  large-ring
 infiltrometers. We  use tensiometers in-
 stalled  in 12 nests with 6 instruments in
 each nest (1 tensiometer in each lift of the
 liner) to monitor changes in the moisture
 and soil-water tension  in the  liner. Soil
 water samples are collected with the use
 of pressure-vacuum lysimeters  located in
 10 nests of 6 lysimeters. Evaporation pans
 are  used to  measure evaporation  rates
 from the pond above the liner surface so
 that a  water  balance for the liner can be
 determined.
  Two models, SOILINER and CHEMFLO,
 were used to estimate the time required
 for water and tracers to break through the
 field-scale soil liner. The  ability of these
 models to predict transit times through the
 liner was evaluated by comparing model
 predictions to field measurements. To es-
 timate  saturated hydraulic conductivity of
 the liner, the conductivity value required
 by each model to produce  a flux value
 equal to that  measured in the  liner was
 determined.
  The  numerical codes  of  both  models
 use  Richards equation to predict  one-di-
 mensional flow  and  transport of  a
 nonreactive tracer  through  unsaturated
 soils. Input requirements for both models
 include  (1) a  mathematical approximation
 of a soil-moisture-characteristic  curve,  (2)
 a mathematical relationship  between hy-
draulic conductivity and soil moisture con-
tent, (3) values for saturated hydraulic con-
ductivity  and  moisture content,  (4) upper
 and  lower boundary conditions, and  (5)
 initial moisture conditions.  In  addition,
CHEMFLO allows input of chemical trans-

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port parameters such as dispersivity and
diffusion.
  SOILINER can simulate flow and trans-
port in a  layered  soil system; however,
this code does not incorporate adsorption,
degradation, dispersion,  or  diffusion into
its particle tracking algorithm. Instead,  it
tracks the movement of a particle of tracer
through the system by advection only. In
essence,  it tracks the  point where  the
relative   concentration  (C/C0)  of  a
nonadsorbed,  nondegraded, nondiffused
tracer is 0.50.
  CHEMFLO simulates flow and transport
for  one soil layer. The effects of  disper-
sion, diffusion, and degradation on trans-
port may  be incorporated  in this  model.
CHEMFLO  computes the concentration
profile  of the tracer in the soil at  regular
intervals.
  Three simple  analytical solutions were
also used to predict water  and solute
movement through the soil liner. The three
methods are a simple, transit-time equa-
tion; a  modified,  transit-time equation; and
the Green-Ampt wetting-front  model. The
input parameters required for each equa-
tion include saturated hydraulic conductiv-
ity,  porosity, initial  soil moisture content,
and depth of the wetting front.

Results and  Discussion

Prototype Liner
  The  infiltration of water and dyes  into
the prototype liner was measured. An av-
erage  steady-flux  of 1.5  x 10-7 cm/s was
achieved  2 to  3 wk after the infiltration
experiment began. The saturated hydrau-
lic conductivity of the liner was estimated
from the  infiltration data to  be no more
than 3.6 x 10'8 cm/s, which met the EPA
hydraulic conductivity requirement for soil
liners.  Transit time for the wetting  front to
reach  the liner bottom was calculated to
be  about 3 yr.
  Water  containing fluorescein  and
rhodamine WT dyes was allowed to infil-
trate into  the prototype liner for 46 days.
Dye patterns observed during excavation
of the liner indicated that flow occurred
between lifts and  along the  interface of
soil clods. Although the liner met the EPA
conductivity requirement, the dye flow
paths indicated that preferential flow paths
existed in  the prototype liner suggesting
the need  for better bonding between lifts
and smaller soil clod sizes to  eliminate
these  paths.  These observations  sug-
gested that soil processing before liner
construction and rigid adherence  to con-
struction QA/QC requirements are neces-
sary if soil liners are to perform according
to design specifications.
  Dye observed in the seals of the verti-
cally installed instruments showed no evi-
dence of preferential flow; this suggests
that the technique used  to install the in-
struments was adequate for at least short-
term monitoring. Dye movement at lift in-
terfaces was, however, enhanced by pref-
erential flow paths around horizontally in-
stalled instruments. Also many of the hori-
zontal instruments were damaged and ren-
dered  inoperable during construction  of
the liner. We concluded, therefore, that
installing instruments vertically through  a
liner after its construction is the most reli-
able method of monitoring a soil liner.
Field-Scale Liner
  Only data collected during the first year
of monitoring  the field-scale liner are re-
ported here. Monitoring  of the liner will,
however, continue until water breakthrough
occurs at the base of the liner. Analysis of
the first year  of monitoring  has provided
the following information.
  Infiltration properties:
  • Average infiltration fluxes were 7.9 x
    10-" cm/s, 5.0 x 10'9 cm/s, and 1.0 x
    10'7 cm/s for the  small-ring  infil-
    trometers, large-ring infiltrometers, and
    pond water balance, respectively.
  • Flux data measured by the large-ring
    and small-ring  infiltrometers formed
    two statistically distinct  populations.
    The small-ring infiltrometer fluxes cal-
    culated  from  cumulative  infiltration
    curves formed a log normal distribu-
    tion; the large-ring infiltrometer fluxes
    consisted of four widely-scattered data
    points.
  • Gedstatistical analysis (Kriging) of the
    small-ring infiltrometer  fluxes 'esti-
    mated a mean infiltration flux for the
    entire liner of  7.1 x 10'8 cm/s. Kriged
    estimates of infiltration fluxes for each
    quadrant of the liner ranged from 6.7
    x 10-8to7.1 x 10-8cm/s.
  • An isotropic  exponential variogram
    was found to  best model'the spatial
    relationship of the small-ring infiltrom-
    eter fluxes. Flux data were spatially
    uncorrelated  at measurement dis-
    tances greater than 1.3 m. This analy-
    sis, and the small variances exhibited
    by  the flux data, suggested the liner
    was homogeneous with respect to in-
    filtration fluxes.
  • Hydraulic gradients  in the field-scale
    liner have fluctuated between 1.1 and
    1.7. When steady state conditions are
    achieved in  the  liner, the gradient
    should be approximately 1.3.
  Saturated hydraulic conductivity:
  •  Hydraulic conductivities calculated us-
    ing Darcy's law were 5.3 x 10'8 cm/s,
    3.3 x 10'9 cm/s, and 6.7 x 10'8 cm/s
    for the small-ring infiltrometer, large-
    ring infiltrometer, and liner water-bal-
    ance data sets, respectively.
  •  Hydraulic conductivities calculated us-
    ing the Green-Ampt infiltration  model
    were 3.8 x 10'8 cm/s, 2.4 x 10'9 cm/s,
    and 4.7 x  10'8 cm/s for the small-ring
    infiltrometer,  large-ring  infiltrometer,
    and liner water-balance data sets, re-
    spectively.
  •  All saturated  hydraulic conductivities,
    regardless of the method of calcula-
    tion or  data set used, were below the
    EPA maximum  of 1.0  x  10"7 cm/s.
    The consistency and reproducibility
    of these data among the four quad-
    rants  of  the  liner indicate  that the
    regulatory requirement for the  satu-
    rated  hydraulic conductivity was
    achievable.
  Predictive methods (modeling):
  •  The numerical code of SOILINER was
    used to calculate the relationship be-
    tween flux and hydraulic conductivity.
    When observed flux was inserted into
    the model, a  corresponding hydraulic
    conductivity  of 5.1 x 10'8 cm/s was
    obtained.  This value is similar to the
    hydraulic  conductivity value  of 5.3 x
    10'8 cm/s (calculated by using Darcy's
    law) and 3.8 x 10'8 cm/s (calculated
    by using the  Green-Ampt) based on
    the small-ring infiltrometer data set.
  •  Transit times  were calculated by three
    analytical  methods provided  in the
    EPA Technical Resource Document
    on  liner design, construction, and
    evaluation.1 The results estimate the
    earliest time  at which water will exit
    the bottom of the field-scale liner. The
    simple transit-time equation, which as-
    sumes steady-state saturated  condi-
    tions,  predicted the transit time to be
    5.5 yr. The modified transit-time equa-
    tion, which adds suction at the base
    of the  liner to the simple transit-time
    equation, predicted water break-
    through to be 3.7 yr. The Green-Ampt
    model  predicted a transit time of 1.3
    yr. All these  predictions assumed ef-
1 U.S. Environmental Protection Agency, I988a, De-
 sign, construction, and evaluation of clay liners for
 waste management facilities: Risk Reduction Engi-
 neering Laboratory, Cincinnati, OH, EPA/530/SW-86/
 007F, 502p.

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     fectiva porosity equals total porosity
     and ignored dispersion and diffusion.
   •  SOILINER predicted chemical break-
     through at 12.6 yr. The model does
     not  consider the effects of effective
     porosity, dispersion, diffusion, attenu-
     ation, and reaction. Therefore, mean-
     ingful  contaminant transport  results
     were  difficult to  calculate  with
     SOILINER.
   •  CHEMFLO predicted breakthrough of
     the tracers between 2.5 and 4.6 yr.
   Other findings:
   •  Tension/head data in the  liner ap-
     peared to be affected by atmospheric
     pressure and temperature fluctuations.
     Even after correcting  for barometric
     pressure variation, we observed a cy-
     clic  pattern of pressure head: pres-
     sure head is greatest in the summer
     and lowest in the winter. An increas-
     ing time  lag with  depth in the  liner
     indicated that the  cyclic rise and fall
     of pressure head was at  least par-
     tially caused  by changing  tempera-
     tures In the liner.
   •  The effects of temperature and atmo-
     spheric pressure on the tension  data
     made exact measurements  of a wet-
     ting-front depth impossible. The ap-
     parent  reaction of head values to
     changes  in temperature suggested
     that the liner was saturated to a depth
     greater than 20 cm, tension-saturated
     to a depth of a  least 70  cm,  and
     unsaturated at its base.
   •  Tracer data suggested that no prefer-
     ential,  lateral flow paths exist in the
     field-scale liner, either because  they
     were eliminated during liner construc-
     tion  or were not intersected by the
     sampling devices.


Conclusions and
Recommendations
   Standard engineering geology practices
are adequate for sampling and  selecting
borrow materials for use in construction of
soil liners. The measured properties of the
soil used to construct the field-scale  liner
deviated from initial predictions (based on
field sampling) by less than 10%; densi-
ties were slightly less than estimated; and
plasticity indexes were slightly higher than
estimated by the  material selection pro-
cess.
   Soil properties must be strictly specified
and quality control  rigidly maintained to
ensure that a soil liner will be constructed
to  perform  according to design criteria.
Specifications for an acceptable soil must
include not only a  maximum  laboratory
conductivity or in situ hydraulic conductiv-
ity, or both, but should also  include mois-
ture content at time  of compaction, maxi-
mum clod size, and minimum density and
plasticity requirements.
   Soil moisture should be 1% to 3% wet-
ter than the optimum value determined by
a Standard Proctor  test. Liner  materials
should be processed before liner construc-
tion to ensure a  uniform moisture content,
a clod size less than 5 cm in diameter,  no
stones greater than 5 cm in  diameter and
as few smaller stones as practical.
   Construction equipment must be large
enough to fully compact the entire thick-
ness of each lift, and compactor feet must
be at least  as  long as the compacted
thickness of each  lift, preferably as  long
as the loose lift  plus the thickness of the
loose material resulting from  scarifying the
surface of the previously compacted lift.
Compaction 'should continue on each  lift
until a prescribed minimum density is mea-
sured  at a  reasonable number of loca-
tions before proceeding to the next lift.
   Transport rates through the liner can  be
affected by the physical state of the liner.
In our experiment, tensiometer results sug-
gested that air  is entrapped throughout
the field-scale liner. The presence  of this
entrapped air can  significantly affect wa-
ter movement through the liner. When two
fluids such  as air  and water occupy the
pores of the :soil, the effective permeabil-
ity of the soil to each is decreased. Effec-
tive permeability to one fluid may be zero
if  no interconnected  pores  contain  that
fluid. Thus, the permeability to air may be
zero, not allowing  the air to escape, yet
reducing the effective permeability to wa-
ter. This condition can exist until  the air is
totally  dissolved. This phenomenon  can
result in reduced water-transport  rates. In-
creased transport rates  could, however,
result if the air is trapped in small isolated
pores and water occupies the large pores.
In this case, the reduction in effective per-
meability to water will be insignificant, but
the reduction  in effective porosity will in-
crease  transport rates. The liner will not
reach "true" steady state until all entrapped
air is dissolved. The effect of these  phe-
nomena on the performance of a soil liner
needs to be evaluated.
   Liners with  low hydraulic conductivities
can contain preferential pathways through
which fluid flow  is concentrated.  The pro-
totype liner had an estimated hydraulic
conductivity of 3.6 x 10~8 cm/s, yet showed
significant preferential paths; dyes  pen-
etrated  30 cm into the liner during the 50-
day  test, suggesting that breakthrough
could have occurred at the bottom of the
liner in  less than 6 mo.  The  main path-
ways were horizontal along lift interfaces.
Infrequent fine fractures or other pathways
can  carry  significant  amounts of  fluid
through  a liner; the occurrence  of these
pathways can be reduced only  by strict
design,  construction,  and quality control
standards.
   Questions  regarding methodologies to
collect in situ  infiltration data have arisen
from this research. Differences have been
noted in infiltration fluxes,  as measured
by different types of infiltrometers. Pertur-
bations   in  measurements of infiltration
rates and soil tensions have been corre-
lated with barometric pressure fluctuations,
or temperature  changes in  the  liner, or
both. Continued  monitoring of the  liner
and further laboratory and field research
may explain these observations.
   Land  burial of wastes is  a commonly
used  waste management strategy.  Soil
liners are and will continue to be an  inte-
gral part of many waste management pro-
grams. When  properly applied, designed,
and constructed, soil liners can effectively
contain contaminants so that human health
and the  environment are  protected.
  The full report was submitted  in fulfill-
ment of Cooperative Agreement  No.
CR812650 by  the Illinois State Geological
Survey under the sponsorship of  the U.S.
Environmental Protection  Agency.
                                                                                     •U.S. Government Printing Office: 1992— 648-080/60057

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Ivan G. Krapac, Kerns Cartwright, Bruce R. Hensel, Beverly L Herzog Timothy H.
  Larson, Samuel V. Panno, James B. Risatti, and Wen-June Su are with the Illinois
  Stata Geological Survey, Champaign, IL 61820. Kenneth R. Rehfeldtis with the
  Illinois State Water Survey, Champaign, IL 61820.
Michael Roulleris the EPA Project Officer (see below).
The complete report, entitled "Construction, Monitoring, and Performance of Two
  SoU Liners," will be available from:
        (Order No, EG-141; Cost: $4.00, subject to change)
        Illinois State Geological Survey
        615 E. Peabody Drive
        Champaign, IL 61821
        or
        (Order No. PB92-124049; Cost: $26.00, subject to change)
        National Technical Information Service
        5285 Port Royal Road
        Springfield, VA 22161
        Telephone: 703-487-4650
The EPA Project Off leer can be contacted at:
        Risk Reduction Engineering Laboratory
        U.S. Environmental Protection Agency
        Cincinnati, OH 45268
    United States
    Environmental Protection Agency
    Center for Environmental Research Information
    Cincinnati, OH 45268

    Official Business
    Penalty for Private Use
    $300
      BULK RATE
POSTAGE & FEES PAID
         EPA
   PERMIT No. G-35
    EPA/600/S-92/024

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