United States
                   Environmental Protection
                   Agency
Air and Energy Engineering
Research Laboratory
Research Triangle Park, NC 27711
                   Research and Development
EPA/600/SR-93/181 January 1994
&EPA       Project  Summary
                   Emission  Test Report,  Field Test
                   of Carbon  Injection  for Mercury
                   Control,  Camden County
                   Municipal  Waste Combustor
                   D. M. White, W. E. Kelly, M. J. Stucky, J. L. Swift, and M. A Palazzolo
                     In 1992, the U.S. Environmental Pro-
                   tection Agency (EPA) conducted a para-
                   metric testing to evaluate the injection
                   of powdered activated carbon to con-
                   trol  volatile pollutants  in municipal
                   waste combustor (MWC) flue gas. This
                   testing was  conducted at a spray dryer
                   absorber/electrostatic preciprtator (SD/
                   ESP)-equipped MWC  in  Camden
                   County,  New Jersey. The primary test
                   objectives were to evaluate the effect
                   of carbon type, feed rate, feed method,
                   and  ESP operating temperature on
                   emissions of mercury (Hg) and chlori-
                   nated dioxins and furans (CDD/CDF),
                   and  to assess  the impact of carbon
                   injection on  the  particulate matter con-
                   trol performance of the  ESP. Second-
                   ary objectives  were to  examine the
                   impact of carbon injection on emissions
                   of other metals and volatile organic com-
                   pounds (VOCs).  This testing included
                   operation of three different carbon in-
                   jection systems and examined 16 dif-
                   ferent SD/ESP  and carbon  injection
                   system operating conditions. This test
                   was conducted as a follow-on to an EPA-
                   funded test program at a SD/fabric filter-
                   equipped MWC that focused on the
                   performance of carbon injection for con-
                   trolling Hg emissions.
                     The test results indicate  that carbon in-
                   jection upstream of a SD/ESP can achieve
                   high  levels (greater than 90%) of Hg and
                   CDD/CDF reduction. Key system operat-
                   ing parameters  are carbon feed rate,
                   carbon feed  method, and  ESP tempera-
                   ture. No detrimental impacts on ESP
                   performance were identified. The study
                   also  found that  carbon injection does
not have a significant impact on emis-
sions of the other metals sought or of
VOCs.
  This Project Summary was developed
by EPA's Air and Energy Engineering
Research Laboratory, Research Tri-
angle Park, NC, to announce key find-
ings of the research project that is fully
documented in a separate report of the
same title (see Project Report ordering
information at back),

Introduction

  In June 1987, the U.S. EPA's Office of
Air  Quality Planning and Standards
(OAQPS) announced  its intention to de-
velop new air pollution rules  for MWC
facilities. The following fall,  EPA's  Air and
Energy Engineering Research Laboratory
(AEERL) and OAQPS began a compre-
hensive field test and engineering assess-
ment program to evaluate technologies
for controlling MWC emissions. The field
test program focused on the use of a lime
spray dryer absorber and fabric filter
baghouse (SD/FF) or a lime SD/ESP sys-
tem for controlling MWC emissions. Regu-
lations for large  MWCs were proposed in
late 1989 and finalized in 1991.
  In November  1990, the Clean  Air Act
Amendment (CAAA) required EPA to add
Hg emission limits to the MWC standards.
Under the direction of EPA, Radian Cor-
poration prepared a technical memoran-
dum summarizing  the effectiveness of
various technologies in controlling Hg
emissions.  Based on U.S. field tests and
research in Europe and Canada, it was
concluded  that the control of  Hg emis-
sions in MWC SD/particulate matter (PM)
                                                                 Printed on Recycled Paper

-------
control systems depends on the  amount
of carbon in  the fly  ash.  Modern mass
burn combustors, which typically  contain
relatively low  amounts of carbon  in their
fly ash, exhibited  Hg control efficiencies
with acid gas  scrubbers ranging from 0 to
40%.  Refuse-derived fuel combustors,
which contain substantially more carbon
in their fly ash, had Hg control efficiencies
exceeding 95%. In these applications Hg
vapor does not condense but is adsorbed
on carbonaceous  particles that  can be
subsequently  collected  in PM control de-
vices.
  Research and field tests in Europe indi-
cated that powdered activated carbon can
be used to enhance control of Hg emis-
sions in SD/PM control systems.  EPA-
sponsored  tests in 1991  at the Ogden
Martin Systems of Stanislaus, Inc.  (OMSS)
MWC indicated that powdered activated
carbon  was  effective  in  controlling Hg
emissions in  mass burn MWCs with SD/
FF systems. It was found that carbon feed
rate is the primary factor affecting  Hg con-
trol. The OMSS testing  also indicated that
there are no  significant differences in Hg
control  performance  as a function of the
physical characteristics of the carbon (origi-
nal material,  particle size, pore size, and
density), the method of injection (as a dry
powder or mixed with the SD's lime slurry),
or the  location of injection (economizer
exit, SD inlet, and  into the SD). However,
it was not possible to determine how much
of the Hg is  removed by adsorption onto
carbon  particulate  in the free stream with
subsequent PM collection and how much
Hg is removed by adsorption as the flue
gas flows through the FF cake containing
captured carbon.
   Because of uncertainties regarding the
mechanisms  of Hg capture by carbon in
SD/FF  systems, it is not possible to di-
rectly translate the data collected at SD/
FF-equipped  MWCs to units equipped with
SD/ESP systems.  Available U.S. data on
SD/ESP-equipped  MWCs indicated incon-
sistent  and often poor Hg control. Data on
the  collection of  Hg by  SD/ESPs  is of
interest because  of  the number of  such
systems already operating commercially,
as well as  the potential for retrofitting ex-
isting  ESP-only  systems with  SDs as
needed for control of  acid gas  and  or-
ganic emissions.
   In  addition, very  little  data are avail-
 able from either SD/FF-  or SD/ESP-
 equipped MWCs on the effectiveness of
carbon injection for reducing emissions
 of CDD/CDF and  various VOCs.
   In  1992 EPA sponsored tests at the
 Camden County, New Jersey, MWC facil-
 ity to evaluate the  use of activated carbon
 for controlling emissions in SD/ESP sys-
tems. The Camden County and the OMSS
tests were directed by AEERL. The report
summarizes the objectives and results of
the Camden County tests.

Purpose of Tests
  The  purpose of the Camden County
tests was to evaluate the effectiveness of
powdered activated carbon for reducing
emissions of Hg, "other" metals, and trace
organic emissions from mass burn MWCs
equipped with SD/ESP systems. Specific
objectives of the tests were to evaluate:
      The relationship of carbon feed rate,
      the inherent carbon in fly ash, and
      Hg capture;
      The  effects of carbon injection on
      the control  of "other" metals, CDD/
      CDF, and VOCs;
      The  effect  of carbon injection rate
      and method (dry powder or slurried
      with lime)  on Hg  and  CDD/CDF
      control;
      The effect  of  ESP operating  tem-
      perature on Hg collection, and
      Whether there are long-term  im-
      pacts of carbon injection  on  ESP
      performance in collecting  PM and
      "other" metals.

Test Design

Description of Facility
   The Camden County MWC  is owned
and operated  by Camden County Energy
Recovery Associates, a subsidiary of Fos-
ter Wheeler Power Systems, Inc. Located
in Camden, New  Jersey,  it began operat-
ing  in 1991.  The facility  contains three
identical mass-burn waterwall combustion
units, designated as Units A,  B, and C.
Each unit is capable of burning 317 tonnes
(350 tons) per day of municipal solid waste
(MSW), and collectively they provide steam
for two 17-MW turbine generators. A gen-
eral schematic of a test unit showing car-
bon injection  and sampling locations  is
given in  Figure 1.
   The air pollution control system on each
combustor consists of a Deutsche Babcock
SD and  a Belco  five-field ESP.  The flue
gas leaves the economizer, passes down
through  a vertical circular duct, through a
 90-degree elbow, and through a horizon-
tal circular duct before entering a cyclone.
The cyclone  separates coarse PM from
the flue  gas and distributes flue gas to six
 vertical flow tubes that connect to the base
 of the SD vessel. A two-fluid nozzle lo-
 cated in the top of each flow tube  injects
 lime slurry up into  concurrently flowing
 flue gas. The lime slurry flow can be con-
 trolled by stack sulfur dioxide (SO2) con-
 centration or  it can  be set  to  provide a
 fixed lime flow rate.  Dilution water flow is
controlled by the SD's exit gas tempera-
ture. After leaving the SD, flue gas passes
through an inverted U-shaped circular duct
before entering a five-field  ESP.  During
normal operation, only four  of the  ESP
fields are in operation. Flue gas from each
ESP is ducted into a separate flue in the
stack. The  stack contains  four  circular
flues, one per operating  unit, and one for
a future unit.
  The process control systems include a
Bailey Net 90 for the boiler, a separate
control and  data  display system for the
SD/ESP,  and  two  separate continuous
emission monitoring  (CEM)  data  acquisi-
tion  systems. The CEM systems include
extractive monitors  for SO2  and oxygen
(O2) at the economizer exit  and monitors
for O2, carbon dioxide (CO2),  water (H2O),
carbon monoxide (CO), total hydrocarbons
(THCs),  methane (CH4), SO2, hydrogen
chloride (HCI), nitrogen oxides (NOX), and
opacity in the stack.

Test Matrix
  The Camden County MWC test project
encompassed three distinct testing efforts
and was  conducted in two  phases (see
Table 1).  Phase I concerned only Unit B.
These tests, defined as Phase I-B tests,
were used to select the carbon type and
carbon feed rates to be used for the Phase
II performance tests. The Phase  II  tests
included two distinct efforts. The primary
effort, conducted on Unit B (II-B tests),
investigated the effects of key carbon in-
jection system operating variables on Hg
control efficiency. The other Phase II tests,
conducted on  Unit A (II-A tests),  investi-
gated the potential long-term impacts of
extended carbon  injection on ESP perfor-
mance.
  Triplicate sampling runs were conducted
for each test condition and one test condi-
tion was completed during each test day
Plant process instruments and CEM equip-
ment were used to monitor combustor and
SD/ESP operating conditions during each
run.
   Phase I-B  Tests. During Phase I-B
tests, carbon was injected as a dry pow
der into the flue gas duct just upstream or
the SD (see Figure 1). The tests evalu
ated Hg control levels for two carbon types
and  two  carbon  feed rates. Both of the
tested carbons, Darco PC-100 and Darco
 FGD from the American Norit Company,
were used  during the OMSS  tests. The
first carbon (PC-100) was a thermally ac
tivated, bituminous-coal-based carbon with
 medium  surface  area and  high  tamped
 density.  The second carbon (FGD) was
thermally activated from lignite and had a
 lower surface area, smaller average par
 tide size, and lower tamped density than

-------
                                                                                       Legend

                                                                                       A : Inlet Sampling Location
                                                                                       B: Dry Carbon Injection Location
                                                                                       C : Slurry Carbon Injection Location
                                                                                       D : Outlet Sampling Location
      Stack
I.D. Fan       Electrostatic     Spray     Ash Conveyors
              Predpitator      Dryer
                            Absorber
Figure 1.  Schematic of the Camden County Municipal Waste Combustor.
 Table 1.    Test Matrix-Camden County MWC, Spring 1992
Phase-
Condition
I-B1
I-B2
I-B3
I-B4
I-B5
II-B6
II-B7
II-B8
II-B9
II-B10
II-B11
II-B12
II-B13
II-A1
II-A2
II-A3
II-A4
II-A5
ESP Inlet
Temperature
°C(°F)
132(270)
132(270)
132 (270)
132 (270)
132(270)
177(350)
177(350)
132 (270)
132(270)
132 (270)
132 (270)
132 (270)
132 (270)
132(270)
132 (270)
132(270)
132 (270)
132 (270)
Number of
Operating
ESP Fields
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
3
Carbon
Type
None
FGD
PC-100
PC-100
FGD
None
FGD
FGD
FGD
None
FGD
FGD
FGD
None
FGD
FGD
FGD
FGD
Carbon Feed
Method
None
Dry
Dry
Dry
Dry
None
Dry
Dry
Dry
None
Dry
Slurry
Slurry
None
Slurry
Slurry
Slurry
Slurry
Nominal
Carbon Feed Rate
kg/hr (Ib/hr)
None
4.5(10)
4.5(10)
27(60)
27(60)
None
23 (50)
11(25)
2.3(5)
None
23 (50)
23 (50)
11 (25)
None
23 (50)
23 (50)
23 (50)
23 (50)
Sample Analytes'
Hg, PM, %C
Metals, PM, %C
Hg, PM, %C
Hg, PM, %C
Hg, PM, %C
Hg, PM, %C
Metals, PM, %C
Hg, PM, %C
Hg, PM, %C
Metals, PM, %C, CDD/CDF, VOC
Metals, PM, %C, CDD/CDF, VOC
Metals, PM, %C, CDD/CDF
Metals, PM, %C
Hg, Cd, Pb, PM, %C, PSD"
Hg, Cd, Pb, PM, %C, PSD
Hg, Cd, Pb, PM, %C, PSD
Hg, Cd, Pb, PM, %C, PSD
Hg, Cd, Pb, PM, %C, PSD
• Metals: Ag, As, Ba, Be, Cd, Co, Cr, Cu, Hg, Mn, Mo, Ni, Pb, Sb, Se, 77, V
" PSD: Particle size distribution

-------
the coal-based carbon. The lower target
carbon feed rate was 4.5 kg/hr (10 Ib/hr),
which equates to a flue gas concentration
of approximately  60 mg  of  carbon per
dscm of flue gas1 and  is approximately
equal to the high carbon  feed  rate for
tests conducted at OMSS. The higher tar-
get carbon feed rate of 27 kg/hr (60 Ib/hr)
is about 360 mg/dscm and was expected
to achieve Hg removals in excess of 90%.
  During each run, simultaneous sampling
was conducted at the economizer exit and
in the stack for total PM and Hg using the
multiple metals sampling  train. The ports
at the economizer outlet  are  located ap-
proximately 2  equivalent duct diameters
from the nearest upstream flow disturbance
and 1.6 diameters from the nearest down-
stream disturbance. The  stack ports are
located near the 62-m (205-ft) elevation in
the 112-m  (366-ft) stack. Each sampling
run was 1 hour long.2 In addition, an EPA
Method 5 type  sampling  train was oper-
ated at the economizer exit to collect  a
daily composite sample of PM. The com-
posite  sample was then used  to  deter-
mine the  percent carbon in  the fly ash
caused by  incomplete combustion.
  Both carbon types indicated similar lev-
els  of  Hg  control during the I-B tests.
Thus, the cheaper Darco FGD was se-
lected as the carbon for use in the  Phase
II tests.
  Phase II-B Tests. The Phase I I-B para-
metric tests included eight test conditions
for evaluating the impact of carbon feed
rate, carbon feed method,  and flue gas
temperature on  Hg control (see Table 1).
During  each run,  simultaneous  sampling
was conducted at the economizer exit and
in the stack for total PM and Hg using the
multiple metals sampling train. During six
of the test conditions  (five from II-B and
one from I-B),  the sampling fractions col-
lected by  the  multiple metals train  were
analyzed for 16 other metals.  These met-
als were antimony (Sb), arsenic (As), barium
(Ba), beryllium (Be), cadmium (Cd), chro-
mium  (Cr),  cobalt  (Co), copper (Cu), lead
(Pb), manganese (Mn), molybdenum (Mo),
nickel (Ni), selenium (Se), silver (Ag), thal-
lium (Tl), and vanadium (V). In addition,  a
Method  5 type sampling train was oper-
ated at the economizer exit to collect  a
daily composite sample of PM for deter-
mination of percent carbon in the fly ash.
1 Based onafluegas flow rate of75,000 dscm/hr. Unless
 otherwise noted, all flue gas flow rates used in this
 paper are corrected to standard conditions [20°C (68°F),
 101.3 kPa (14.7 psia)] and all concentrations to 7% O2
 in dry gas.
2 All run durations in this paper are actual sampling times
 and  exclude times for port changes and resolving
 equipment problems.
Except for the three test conditions dis-
cussed below, each sampling run was 1
hour long.
  The testing also  included sampling for
CDD/CDF  emissions during  Conditions
B10, B11, and B12, and for VOCs during
Conditions B10 and B11. Each sampling
run during these three test conditions was
2 hours in duration.
  Phase  II-A Tests.  Phase II-A  tests
were  conducted  to evaluate potential
detrimental impacts on ESP performance
due to carbon injection over an extended
time period,  and  to assess the relation-
ship between  PM  collection efficiency
and Hg control. To satisfy these objec-
tives,  5 days  of sampling  were conducted
over a 12-day period on Unit A. Follow-
ing an initial  day of testing without car-
bon injection to  establish  baseline
performance, Darco FGD  carbon  was
added  to  the lime  slurry feed tank and
continuously pumped into  the SD.
  As shown in Table 1, the first 4 days of
sampling were conducted with four ESP
fields  in service. These tests were run on
the day prior  to the start  of carbon injec-
tion and on the first, third, and eighth days
after the start of carbon injection.  After
completion of testing on  the  eighth day,
the fourth ESP field was turned off (the
fifth field was off for all tests), thus result-
ing in  operation with only  three fields. The
fifth day of sampling was conducted after
the unit had  been  operating  with three
fields for 4 days.  This sampling schedule
was designed to  allow the ESP to reach
equilibrium operation with three fields.
These tests were conducted  to evaluate
the effects  of carbon injection  on smaller
three-field ESPs.
  During each run, simultaneous sampling
was conducted at  the economizer exit and
in the stack for total PM,  Hg,  Cd, and Pb
using  the  multiple metals sampling  train.
Also,  during  each  run,  two  eight-stage
Andersen  impactors were used to  mea-
sure the particle size distribution (PSD) of
PM in the stack gas. The two PSD trains
were run throughout each test day to col-
lect sufficient PM for quantitative  mea-
surement  of  the  weight  gain by  each
impactor stage. In addition, a Method 5
type sampling train was  operated at the
economizer exit to collect a daily com-
posite sample of PM for determination
of percent carbon in the  fly ash. The PM
and PSD data provided a  direct method of
evaluating  degradations  in  ESP  perfor-
mance that might  be associated with car-
bon injection.
 Carbon Feed Systems
  Carbon was fed to Units A and  B by
two different methods using three differ-
ent injection systems. The testing on Unit
B  included  injection of dry carbon and
addition of carbon into a slurry mix tank
installed just prior to  the SD. Carbon was
injected into Unit A by addition of carbon
to lime slurry in the feed tank.
  The dry injection system consisted of a
screw feeder  and  a  pneumatic transport
system. The carbon  injection probe con-
sisted of a 0.025-m (1-in.) pipe inserted in.
the flue gas duct upstream of the SD (see
Figure 1). The end of the probe was cut at
a 45° angle,  which  faced downstream.
Experiments conducted prior to the Phase
I tests suggested that the cyclone removed
little,  if any, of the dry injected powdered
carbon.
  Prior to the  start of the test project, the
carbon feed system  was calibrated. The
carbon feed rate was confirmed for each
test by recording the  amount of each car-
bon addition and the time between  each
pair of refillings.
  At  the end of each  testing day, the
carbon feed rate was adjusted to  the tar-
get level for the next day of testing. The
feeder was then operated overnight at this
feed rate to condition the SD/ESP prior to
the start of the next day of testing.
  The second  carbon feed system for Unit
B involved  addition of carbon to the lime
slurry in a feed tank installed near the SD
inlet.  Estimated carbon  retention  time in
the slurry with this system was about 10
minutes.  Lime slurry  was supplied to this
small feed  tank from the plant's existing
slurry system.  Carbon feed  rates  were
determined  in the  same manner as the
dry injection system,  and the carbon was
carried in the lime slurry to the SD.
  During the Phase II-A tests, carbon was
added to the plant's lime feed tank during
each  slaking cycle. The average  carbon
injection  rates were  calculated from the
amount of carbon added during each timed
slaking cycle. The lime/carbon slurry mix-
ture was  injected into the reactor with the
existing  slurry  feed through the atomiza-
tion system. The carbon retention time in
the  slurry during these tests is estimated
at 3 to 8 hours, with an average of ap-
proximately 5 hours.

Interpretation of Results

Mercury
  A summary  of key operating data and
Hg  test results is presented in Table 2

-------
Table 2. Summary of Test Conditions and Mercury Test Results
Phase-
Condition
I-B1



I-B2



I-B3



I-B4



I-B5



II-B6



II-B7



II-B8



II-B9



II-B10



I-B11



II-B12



II-B13



H-A1



Run
1
2
3
AVG
4
5
6
AVG
7
8
9
AVG
10
11
12
AVG
13
14
15
AVG
10
11
12
AVG
13
14
15R
AVG
16
17
18
AVG
19
20
21
AVG
25
26
27
AVG
28
29
30
AVG
34
35
36
AVG
37
38
39
AVG
1
2
3
AVG
Carbon Type
None



FGD



PC-100



PC-100



FGD



None



FGD



FGD



FGD



None



FGD



FGD



FGD



None



Injection
Method
None



Dry



Dry



Dry



Dry



None



Dry



Dry



Dry



None



Dry



Slurry



Slurry



None



ESP Inlet
Temperature
°C(°F)
132 (269)
131 (267)
128 (262)
130 (266)
134 (274)
130 (266)
135 (275)
133 (272)
129 (264)
133 (272)
134 (273)
132 (270)
129 (265)
143 (290)
144 (291)
139 (282)
135 (275)
136 (277)
128 (262)
133 (271)
176(348)
177(350)
176(349)
176(349)
178(352)
178(352)
173(344)
176(349)
131 (267)
128 (263)
128 (262)
129 (264)
130 (266)
130 (266)
129 (265)
130 (266)
132 (269)
130 (266)
126 (258)
129 (264)
133 (271)
134 (273)
132 (269)
133 (271)
132 (269)
132 (269)
135 (275)
133 (271)
130 (266) '
128 (263)
129 (264)
129 (264)
136 (277)
132 (270)
134 (273)
134 (273)
Carbon
Injection
Concentration
mg/dscm
0
0
0
0
73
79
78
77
89
73
88
83
477
456
418
450
430
444
450
441
0
0
0
0
313
329
324
322
173
149
190
171
30
46
43
40
0
0
0
0
357
342
387
362
324
325
336
328
183
194
200
192
0
0
0
0
Total Carbon
at Cyclone
Inlet
mg/dscm
79
79
79
79
154
160
159
158
154
138
153
148
579
558
520
552
534
548
554
546
74
101
55
77
387
429
418
411
305
276
306
295
111
141
129
127
83
98
91
91
506
504
505
505
385
368
403
385
233
265
248
249
100
86
198
128
Mercury
Concentration
at Inlet
u.g/dscm
356
1363
711
810
972
593
835
800
593
639
586
606
491
440
512
481
680
820
644
715
365
249
349
321
964
506
778
749
545
455
525
508
485
957
463
635
663
433
384
493
626
635
664
642
299
521
300
373
382
377
974
578
268
430
610
436
Mercury
Concentration
at Outlet
ng/dscm
175
210
54
146
296
63
149
169
134
29
102
88
21
14
17
17
9
13
12
12
301
177
261
246
107
22
59
63
40
23
24
29
103
170
124
132
388
279
207
291
20
16
16
17
50
77
69
65
78
81
158
106
121
290
322
244
Mercury
Removal
Efficiency
%
50.8
84.6
92.4
75.9
69.5
89.4
82.2
80.4
77.4
95.5
82.6
85.2
95.7
96.8
96.6
96.4
98.6
98.4
98.2
98.4
17.5
28.9
25.2
23.9
88.9
95.6
92.4
92.3
92.7
95.0
95.4
94.4
78.8
82.2
73.2
78.1
41.5
35.6
46.1
41.0
96.8
97.4
97.7
97.3
83.2
85.3
77.0
81.8
79.7
78.5
83.8
80.7
54.9
32.6
47.2
44.9
                                                                                                                  (continued)

-------
Table 2.  (Continued)
Phase-
Condition
II-A2



II-A3



II-A4


H-A5



Run Carbon Type
4 FGD
5
6
AVG
7 FGD
8
9
AVG
22 FGD
23
AVG
31 FGD
32
33
AVG
Injection
Method
Slurry



Slurry



Slurry


Slurry



ESP Inlet
Temperature
°C(°F)
129 (265)
129 (265)
130 (266)
129 (265)
137(278)
132 (269)
142 (288)
137(278)
141 (285)
139 (283)
140 (284)
139 (283)
139 (283)
140 (284)
139 (283)
Carbon
Injection
Concentration
mg/dscm
344
346
343
344
402
356
386
381
442
391
417
269
280
249
266
Total Carbon
at Cyclone
Inlet
mg/dscm
427
468
450
448
579
412
629
540
640
567
604
381
404
356
380
Mercury
Concentration
at Inlet
ug/dscm
302
403
1412
706
530
458
690
559
643
816
730
335
295
364
331
Mercury
Concentration
at Outlet
ug/dscm
55
78
261
131
43
108
156
102
49
90
70
40
51
52
48
Mercury
Removal
Efficiency
%
81.9
80.7
81.5
81.4
91.9
76.4
77.4
81.9
92.3
89.0
90.7
88.0
82.6
85.6
85.4
Note: Paniculate matter was not measured at the Inlet during Phase I; therefore, carbon concentrations were estimated using the average PM inlet
concentration for all Phase II-B tests. All concentrations are referenced to 7% O2 in dry gas at 20°C (68°F) and 101.3 kPa (14.7 psia). Test II-B7-15R
was conducted due to possible problems caused by interruption of carbon feed toward the end of Test 11-87-15.
The table includes data on carbon type,
injection rate and method, ESP inlet tem-
perature, total carbon concentration at the
cyclone inlet, inlet and stack Hg  concen-
trations, and Hg removal efficiency.
  Impact of Carbon Type. The influence
of carbon type was examined during Phase
I-B tests with dry injection of lignite-based
carbon (Conditions B2 and B5) and coal-
based  carbon (Conditions B3 and B4).
Conditions B2 and B3 were conducted at
a low carbon feed rate corresponding to
approximately  80 mg/dscm of flue gas.
Conditions B4 and B5 were conducted at
a high carbon feed concentration of ap-
proximately 450 mg/dscm.
  At the  low carbon feed rate, the calcu-
lated removal  efficiency was  70 to 89%
with  the  lignite-based carbon and 78 to
96% with the  coal-based  carbon. At the
high  carbon feed rate, the removal effi-
ciency was  98 to 99% with  the lignite-
based  carbon and  95 to 97% with the
coal-based carbon. While  the coal-based
carbon appeared to be marginally better
at the low feed  rate, both  carbons re-
sulted in  similar performances at  the high
injection rate. Because there was  no clear
distinction  in  the removal efficiency of
these two carbons, the remaining tests
were conducted using the  more  eco-
nomical lignite-based carbon. The simi-
larity  in  performance  of these two
carbons when injected as a dry powder
is consistent with the  results  of  the
OMSS testing.
  Impact of Carbon Injection Rate. Fig-
ures 2 and 3, respectively, present Hg
removal efficiency and stack gas Hg con-
centration as a function of carbon injec-
tion rate  for all Unit B tests with lignrte-
and coal-based  carbons.  These figures
also include all tests for Unit A and Unit B
without carbon injection. The rectangular
data points show the removal efficiencies
and stack gas concentrations measured
during individual runs conducted at an ESP
temperature  of  approximately 132°C
(270°F) and while injecting either dry lig-
nite-based carbon or no carbon. The spe-
cific test  conditions are  A1, B1, B2, B5,
B8, B9, B10,  and  B11.  Carbon  injection
concentrations for these tests ranged from
40 to 450 mg/dscm.
  These  figures show that increased car-
bon injection concentrations increase Hg
removal and decrease stack gas Hg con-
centration.  Increased injection concentra-
tions also decrease the variability in Hg
reduction and  stack gas Hg concentration
between  individual runs of the same test
condition. These tendencies were also
observed during the OMSS test program.
However, the carbon feed rates at Camden
County were significantly  higher than  at
OMSS, where the highest feed rate of dry
carbon corresponded to  an injection con-
centration of about 70 mg/dscm.10'12 (Note
that the pulse-jet-cleaned FF for the OMSS
test unit had a cleaning cycle of about 12
minutes;  thus the carbon in the filter cake
had a much longer average contact time
with "free stream" Hg than carbon  col-
lected in an ESP.)
  For a 132°C  (270°F)  ESP  inlet tem-
perature and dry carbon injection concen-
trations  above 150 mg/dscm, Hg removals
were 93% or greater and stack gas Hg
concentrations were less than 50 (ig/dscm
At higher injection rates, there were rela-
tively  small incremental increases in Hg
reduction and decreases  in stack gas Hg
concentration. At these  feed  rates, the
variability in Hg reduction between runs of
a given  test condition was 3% or less. At
carbon  feed rates of less than  150  mg/
dscm, the Hg removal efficiencies were
noticeably lower and the run-to-run vari-
ability between  individual  runs was as
much as 20% during a single  test condi
tion.
  The greatest  variation  in Hg reduction
and stack gas Hg concentration was ob-
served during tests without carbon injec-
tion, Conditions  A1, B1,  and  B10. In
particular, during  Runs 2 and 3 of Condi-
tion B1, removal efficiencies were 85 and
93%,  nearly 40% higher than  other runs
with no carbon  injection. Stack gas Hg
concentrations during Runs 2 and 3 were
210 and 54 u,g/dscm, respectively. It  was
initially  believed  that these high Hg re-
moval efficiencies reflected poor combus-
tion conditions  caused  by high  waste
moisture content (it rained heavily for sev
era! days preceding  the B1 tests) and in
the case of Run  2, high inlet Hg concen-
trations. However, similar "wet waste" con
drtions during the B10 tests did not result

-------
       700-r
    -^ 80

    ^ 70
    1
     I-
       30
        10
           0    50    100    150   200   250    300    350    400   450   500
                              Injected Carbon (mg/dscm)
                Dry Carbon @ 270F A Wet Carbon @ 270F * Dry Carbon @ 350F
Figure 2.  Dependence of mercury reduction on carbon injection rate and method at 132°C (270°F)
         and177°C(350°F).
      400
    I
      200-
       100
       50
                                                 *.-.-
50    JOO    750   200   250   300   350    400
              Injected Carbon (mg/dscm)
                                                                450   500
             | • Dry Carbon @ 270F A Wet Carbon @ 270F * Dry Carbon @ 350F
Figure 3.  Dependence of mercury concentration on carbon injection rate and method at 132°C
         (270°F) and 177°C (350°F)
in  abnormally high Hg captures. Review
of  the three previous  quarterly Hg  emis
sion tests from  Unit B shows reductions
during three-run tests of 41 to 43%, 41 to
55%, and 30 to 73%  (all based on EPA
Method  101 A). These data suggest that
Hg removals without carbon  injection at
Camden are typically  between 30 and
55%, but removals can be either higher or
lower.
   Impact of Inherent Carbon. Hg cap-
ture in SD/PM control systems is believed
to  depend on the  amount of inherent car-
bon contained in  combustor fly ash. To
quantify the amount of unburned carbon
present  in the flue gas, a composite PM
sample  was collected at  the economizer
exit during each test condition and ana-
lyzed for carbon content. The carbon lev-
els  measured  during each day  were
between 1.1 and 2.2% of the dried sample
weight. The percent carbon found in each
daily sample was then multiplied by the
measured PM loading at the economizer
exit for each run on that day. The result-
ing estimate of inherent carbon was then
added to the concentration at which acti-
vated carbon was injected to estimate the
total carbon level in  the flue gas (see
Figure  4).  Note that this approach pro-
vides only a rough estimate  of the total
entrained carbon. Specifically, this  ap-
proach provides a single estimate  of the
PM's carbon content  for each day,  and
any run-to-run  variations in  combustion
conditions that could  result in increased
carbon levels during an individual run are
not measured. Also the amount of carbon
available for Hg  absorption  at  location;
downstream of the SD's inlet cyclone is
overestimated. Visual inspection of cyclone
catches showed a substantial number of
large inherent carbon  particles in the col-
lected fly ash.
   As shown in  Figure 4, the  30-55% re-
duction  in emitted Hg at 132°C (270°F) in
the absence of  carbon injection could be
explained by the presence  of approxi-
mately 100 mg/dscm of unburned carbon
associated with the  combustor fly ash.
The high levels of Hg capture obtained
during test conditions  B11 and B5 can be
partially  explained by the high levels of
inherent carbon during these two  condi-
tions (2.2% during B11 and  1.9% during
B5). At  OMSS, the carbon content  of the
fly ash from the combustor (0.5-1.0%) was
approximately half the level  at Camden
County, and the Hg reduction without car-
bon injection was also approximately half
the average Camden level (25%).
   Impact of Carbon  Injection Method.
The relationship between the carbon in-
jection method and Hg removal and stack

-------
         700-
          90

          80

          70
          60
       QC  50-

       |  40

       I  30

          20

          10
—sir
                              200       300      400
                                Total Carbon (mg/dscm)
                                       500
                                                600
             Dry Carbon @ 270F A Wet Carbon @ 270F * Dry Carbon @ 350F
Figure 4.  Mercury reduction as a function of total carbon concentration in flue gas and carbon injection
         method at 132°C (270°F) and 177°C (350°F).
gas Hg concentrations is shown  in Fig-
ures 2 and 3, respectively. At the medium
carbon injection concentration (149 to 200
mg/dscm), Hg removal efficiencies were
92 to  95% with dry carbon injection (Con-
dition  B8) and 79 to 84% when the carbon
was injected with the lime slurry (Condi-
tion B13). For  medium carbon injection
rates,  dry injection resulted in stack gas
Hg concentrations ranging from 23 to  40
(ig/dscm, while slurry injection resulted in
stack  Hg concentrations ranging from  78
to 158 u,g/dscm.  At the carbon injection
concentrations >324 mg/dscm, Hg removal
efficiencies were 97 to 98% with dry injec-
tion (Condition B11) and  77 to 85% with
slurried carbon (Condition B12). For these
tests,  the  dry carbon  injection test stack
gas Hg concentrations ranged from 16 to
20 u,g/dscm, while the slurry carbon injec-
tion test  stack  gas  Hg  concentrations
ranged from 50 to 77 u,g/dscm.
  This observation is in  contrast to the
OMSS results,  which found that  feed
method did not have a significant impact
on Hg emissions  and Hg removal. The
cause of this difference is uncertain, but
may be due to the different carbon type
used  or the type  of PM control  device.
The carbon  used at OMSS during slurry
testing was  coal-based,  rather than  lig-
nite-based as used during slurry testing at
Camden  County.  Also,  the carbon col-
lected in the filter cake during the OMSS
test was  retained on the bags for about
12 minutes  and  thus was probably dry
                      during most of its contact time with flue
                      gas, thus effectively functioning like dry
                      carbon relative to Hg capture.
                        In contrast,  a very short period (on the
                      order of 10 seconds) was available for the
                      carbon  to  dry out  in the ESP. Carbon
                      retention time  in the slurry on Unit A was
                      estimated to be 3 to 8 hours, but only 8 to
                      10  minutes for Unit B. The  carbon feed
                      concentration during each of these condi-
                      tions  was  approximately 360 mg/dscm.
                      The Hg removal  efficiency for Units A and
                      B was very similar, with  both units  aver-
                      aging 82%. It  can be concluded that the
                      decreased Hg  adsorbency of carbon when
                      mixed with slurry occurred in less than 8
                      to 10 minutes.
                        Impact of ESP Temperature. Figure 5
                      shows the  effects of ESP inlet tempera-
                      ture and total carbon concentration on Hg
                      removal efficiency and stack gas Hg con-
                      centration.  When operating  without  car-
                      bon injection and an ESP inlet temperature
                      near  132°C (270°F) [Conditions B1  and
                      B10], Hg removals ranged from 36 to 92%
                      and stack gas Hg concentrations ranged
                      from  54 to 388 (ig/dscm. At the higher
                      ESP temperature of 177°C (350°F) [Con-
                      dition B6],  the Hg  removals  were  18 to
                      29%  and the stack gas concentrations
                      were  180 to  300 |ig/dscm. At  high total
                      carbon concentrations (360 mg/dscm) and
                      132°C (270°F) ESP temperature (Condi-
                      tion B11), Hg  removals were 97 to  98%.
                      At similar carbon feed rates, but an ESP
                      inlet temperature of 177°C (350°F) [Con-
dition B7], Hg removals were 89 to 96%
and stack gas Hg concentrations were 22
to 107 u.g/dscm. These data suggest that
the ability of carbon to  absorb Hg is di-
rectly related to flue gas temperature, but
that, even at a  relatively high ESP inlet
temperature of 177°C (350°F), activated
carbon injection  results in high Hg reduc-
tions.
  Impact of PM Control Efficiency. The
PM control  efficiency of the ESP aver-
aged  99.8%  or  more for  all test condi-
tions. The PM concentrations in the stack
ranged from 1.1  to 8.9 mg/dscm (0.0005
to 0.004 gr/dscf). These levels of PM con
trol and emission did not exhibit any ap-
parent relationship  between PM  control
and  Hg  removal efficiency for the  tests
conducted at the Camden facility.

Multlvariate Regression
Analysis of Hg Control
  A stepwise multivariate regression analy
sis was used to  assess the statistical sig-
nificance of individual process variables
and  to develop  predictive  equations  for
Hg  removal efficiency and  stack gas  Hg
concentration. These analyses identified
three statistically significant process vari-
ables influencing Hg control efficiency: car-
bon feed rate, ESP inlet temperature, and
carbon injection method. The analyses also
identified four statistically significant pro-
cess variables affecting stack gas Hg con
centration:  carbon  feed  rate, carbon
injection  method, ESP  inlet temperature
and inlet  Hg concentration.
  Figure  6 shows the predicted stack gas
Hg concentrations for the injected carbon
concentrations for  the  best regression
model based on an  ESP operating tern
perature  of  132°C (270°F) and inlet  Hg
concentrations of 200, 500, 800, and 1,100
|ig/dscm. Note that most of the reduction
in stack  Hg concentration  occurs at in
jected carbon concentrations below about
100 mg/dscm. At injected carbon concen
trations above this  level, the stack  Hg
concentration decreases, but the reduc
tion is much more  gradual. Considering
the degree of control by inherent fly ash
carbon, the variations in the inlet flue gas
Hg concentration, and the variation in re
duction efficiency of the carbon injection
process,  complying  with an Hg emission
limit of 100 u,m/dscm at the Camden f acil
ity would probably require injected carbon
concentrations in the range of 150 to 200
mg/dscm.
  The absence  of inlet Hg concentration
as  a statistically significant variable  for
predicting Hg removal efficiency is in con
trast to the  OMSS data and is believed tc
reflect the difference in control capability

-------
Mercury Reduction (%)
100
90
80
70
60
60
40 ~
30 ~
20
10 -
n
-•*!"•
•m


—
J
•
* m
*

                   100
                            200      300      400
                              Total Carbon (mg/dscm)
                        500
600
                              Dry Carbon @ 270F * Dry Carbon <§> 350F |
Figun 5. Mercury reduction as a function of total carbon concentration at 132°C (270°F) and 177°C
         (350°F).
           450
           400
                                 Inlet Mercury Concentration
                                       1100\ig/dscm
                                       800 \i.g/dscm
                                       500 \jig/dscm
                                      . 200\ig/dscm
                         100
   200         300
Injected Carbon (mg/dscm)
                                                           400
                                                                       500
Figure 6.  Regression lines for stack mercury concentration as a function of inlet mercury
         concentration and dry carbon injection rate at 132°C (270°F).
of systems equipped with a FF versus an
ESP. With a  FF,  carbon will adsorb  Hg
both while entrained  in the flue gas and
after it is collected in the filter cake. When
inlet Hg  levels vary (e.g., due to a short-
duration  spike in  Hg concentration), the
unsaturated carbon  on the filter cake is
able to adsorb additional Hg and to mod-
erate the spike at the  FF outlet. In this
situation, the efficiency of the control sys
tem (i.e., entrained carbon and filter cake)
can increase for  short periods.  During
these  periods the outlet concentration is
not strongly dependent on  inlet  concen
tration until there is "breakthrough" of the
filter cake carbon. The  ability of the filter
cake to buffer outlet  Hg spikes in inlet Hg
levels  is similar to the ability of the excess
sorbent in the filter cake to moderate fluc-
tuations  in inlet acid gas levels.  With an
ESP,  most  of the Hg  reduction  occurs
while the carbon is  entrained in  the flue
gas and  is controlled by the likelihood of
contact between carbon particles and Hg
prior to the  collection of carbon with the
fly ash on the ESP plates. Once a carbon
particle is collected on an ESP plate, the
potential  for contact with Hg  is  greatly
reduced, because of both the removal of
carbon from flue gas and the limited op-
portunity for Hg in  flue  gas to contact
carbon collected on plates of the ESP. In
this case the Hg capture is limited by the
total concentration  of  suspended  "free
stream" carbon, and the outlet Hg con
centrations for a given carbon loading are
highly  dependent on inlet concentrations.

Other Metals
  Flue gas concentrations of the 16 other
metals in addition to Hg were determined
during six test conditions (see Table  1)
Five of these test conditions were con
ducted at 132°C (270°F): no carbon injec-
tion (B10), dry carbon  injection  at a low
and a high feed rate (B2 and 611, respec
tively), and slurry injection of carbon at a
medium  and a  high feed rate  (B13 and
B12, respectively). The  sixth test condi
tion was  conducted at 177°C (350°F) with
dry carbon injection (B7).
  For  Cd,  Pb, As, Ba,  and Cu,  metals
removal  efficiencies  exceeded  99% dur
ing all test  conditions.  For Cr  and  Mn
removal  efficiencies exceeded 99% ex
cept during the high temperature run (B7)
and for Mn during the medium feed rate
carbon-in-slurry  test  condition (B13). For
Mo and  Ni,  removal efficiencies  showed
significant variability,  ranging from  a low
of 72% for Mo during the high tempera-
ture test condition up to 98%.  Removal
efficiencies for Sb, Be,  Co, and  V could
not be precisely determined because their
concentrations in  the stack  were  below

-------
their analytical detection limits. Removal
efficiencies  for Ag  and Tl could  not be
estimated because concentrations of these
metals were below their analytical detec-
tion limits at both the inlet and outlet sam-
pling  locations.  Considering the poor
recovery of matrix spikes used for analyti-
cal quality assurance, the data for Se were
unacceptable and are not reported here.
  These data indicate that the 13 detected
metals, with the possible exception of Mo,
are emitted from the combustor primarily
as PM and that emissions of these metals
are controlled predominantly by the PM
control device. There also appears to be
an effect  of ESP  temperature on the con-
trol of Cr, Mn, and Ni but, given the small
size of the data set, this relationship may
be  due to  random  chance. Injection of
activated  carbon  did not have a quantifi-
able impact on emissions of  any of the 13
detected metals,  which were generally re-
moved at high levels.

Organic Compounds
  Economizer outlet and stack gas con-
centrations  of CDD/CDF were measured
during Conditions B10  (no carbon injec-
tion),  B11 (dry carbon  at 132°C [270°F]),
and B12 (slurry carbon at 132°C [270°F]).
During Condition B10  without carbon in-
jection, the total  CDD/CDF  removal effi-
ciency across the SD/ESP was 78 to 80%.
During Condition  B11 with a  high injection
concentration of dry  carbon (360  mg/
dscm), the  removal efficiency was 95 to
98%.  During  Condition B12 with  a high
injection concentration of carbon  in slur-
ried lime (330 mg/dscm), the removal effi-
ciency was 96 to 97%. These data suggest
that,  unlike  Hg,  the CDD/CDF  removal
efficiency of dry and slurried  carbon injec-
tion was similar.
  As  shown  in Figure 7, stack gas con-
centration of CDD/CDF was  reduced from
40 to  60 ng/dscm without carbon injection
to less than  7 ng/dscm for dry  carbon
injection  and less  than 13  ng/dscm  for
slurry injection. The higher stack CDD/
CDF levels during slurry injection  of car-
bon  reflect the  higher concentration of
CDD/CDF measured at the economizer
outlet during  two of the Condition  B12
runs of approximately 375 ng/dscm, com-
pared to 130 to 220 ng/dscm for the other
seven runs. The  carbon injection concen-
tration into slurry also averaged  nearly
10% below that  for dry carbon injection.
The reduction of CDD/CDF  emissions by
carbon injection  is  consistent  with Euro-
pean field test results.
  Sampling for VOCs was conducted dur-
ing  Conditions B10 (no carbon injection)
and B11 (dry carbon injection). There ap-
CDD/CDF Concentration (ng/dscm)
ou
50
40
30
20
10
0
' '



*
1
1
1 1
No Carbon Dry Carbon Wet Carbon
(II-B10) (II-B11) (II-B12)
Figure 7.  Stack CDD/CDF concentration with and without carbon injection into flue gas at 132°C
         (270°F).
peared to  be a reduction in  the  level
of some compounds (carbon  disulfide,
benzene, chlorobenzene)  across the
SD/ESP and an  increase  in  others
(trichloro-fluoromethane,  methylene
chloride, toluene). Of significance to this
study, there was no  apparent  impact of
carbon  injection  on reduction  of any of
these compounds in the SD/ESP system.

Acid Gases
  As noted  in Description  of Facility,
above,  various gaseous  components in
the flue gas were monitored  during  each
test condition. Emissions of SO2, HCI, and
NOx were monitored using the plant  CEM
system.
  The  SCX data displayed a general in-
crease in SO2 removal with increasing car-
bon  injection rate.  However, the size of
the data set and the scatter in the data
are such that this apparent relationship
may be due to random chance. No rela-
tionship between  carbon  feed rate and
HCI or NOX emissions was apparent.
Impact of Carbon Injection on
ESP Performance
  ESP performance test results from Unit
A were  evaluated using average PM, Cd,
and  Pb removal efficiencies and the per-
cent of  total  PM less than  2 u.m during
each test condition. There was no consis-
tent  change in any of these parameters
during  the first four test conditions, indi-
cating that  carbon  injection did not alter
ESP performance.  During Condition A5,
with the fourth ESP field  out of service,
there was  no apparent change in PM re-
moval  efficiency.  However, the removal
efficiency for Cd and Pb decreased, and
the percent of emitted PM less than 2 jim
increased. These changes are consistent
with  the expected enrichment of volatile
metals onto fine paniculate and the re-
duced  ability  of the ESP  to collect fine
particulate when the fourth ESP field was
out of  service.  Stack opacity, ESP  volt-
age, and ESP current remained within nor-
mal  operating ranges during  the entire
Unit  A test period.

Conclusions
  The  collected data and results calcu-
lated for the Camden County tests led to
several conclusions:
      Hg  reductions in  excess of 90%
      were achieved by  injection of dry
      carbon at both of the ESP operat-
      ing temperatures examined (132°C
      [270°F]and 177°C [350°F]).
      The  most important process vari-
      ables affecting Hg emissions were
      carbon feed rate,  carbon injection
      method, and  ESP  operating tem-
      perature.
  •   The  amount  of unburned carbon
      present in fly ash  played  a signifi-
      cant  beneficial  role in  controlling
      Hg emissions.
      The two carbons tested (Darco FGD
      and Darco  PC-100) were similarly
      effective in controlling Hg emissions
      when injected as a dry powder. (No
      slurry tests were  conducted  with
      the coal-based PC-100.)
  •   Injecting carbon (the lignite-based
      Darco FGD) with  lime slurry  was
                                                          10

-------
less effective in reducing Hg emis-
sions  than dry injection. This con-
trasts with the results of the OMSS
tests and may be due to the perfor-
mance characteristics  of an ESP
versus a  FF or to differences in
carbon properties  (Darco PC-100
was used in the OMSS tests).
Multivariate  regression  analyses
identified three statistically signifi-
cant process variables influencing
Hg control  efficiency:  carbon feed
concentration, ESP inlet tempera-
ture, and carbon injection method.
The four significant  process vari-
ables which influence stack gas Hg
concentrations are:  carbon  feed
concentration, ESP inlet tempera-
ture, carbon feed method, and inlet
flue gas Hg concentration.
Injecting carbon  reduced  stack
emissions  of  CDD/CDF by  over
75% so that CDD/CDF removals
increased  to  95% or more. How-
ever, there was no apparent effect
of carbon injection on emissions of
VOCs.
Emissions of metals other than Hg
were primarily associated with PM,
and their control was determined
mainly by the efficiency of PM re-
moval. A possible exception to this
relationship was Mo.  Carbon injec-
tion had no apparent  benefit on the
emission control of these metals.
Carbon injection had  no discernible
impact on the ESP efficiency in con-
trolling PM.
                                                     11
                                                                &U.S. GOVERNMENT PRINTING OFFICE: 1994 - 550-0«7/80137

-------
    D. White, W. Kelly, M. Stocky, J. Swift, and M. Palazzolo are with Radian Corp.,
     Research Triangle Park, NC  27709.
    James D. Kilgore is the EPA Project Officer (see below).
    The complete report, entitled "Emission Test Report, Field Test of Carbon Injection
     for Mercury Control, Camden County Municipal Waste Combustor," (Order No.
     PB94-101540; Cost: $27.00; 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:
           Air and Energy Engineering Research Laboratory
           U.S. Environmental Protection Agency
           Research Triangle Park, NC 27711
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/SR-93/181

-------