United States Environmental Protection Agency National Risk Management Research Laboratory Cincinnati, OH 45268 Research and Development EPA/600/SR-95/126 August 1995 vvEPA Project Summary Field Testing and Evaluation of Zerpol® Technology at Pioneer Metal Finishing Hanna J. Saqa, Daniel J. Watts, Mohammed Elsaady, and Johnny Springer The U.S. Environmental Protection Agency's Waste Reduction Innovative Technology Evaluation (WRITE) Pro- gram has an objective of evaluating technologies that have potential for waste reduction or pollution preven- tion as compared with other currently used approaches. The Zerpol1 process, as used in metal plating operations, captures all aqueous effluent from the manufacturing operations, conditions the effluent to remove any metal or cyanide that may be present, and per- mits the reuse of the conditioned water in rinsing operations. About 30% of the recovered water is fed into the plant boiler to generate distilled water for critical rinsing. The goals of this study were to confirm that the quality of the water derived from the Zerpol process is appropriate for the intended reuse, and that the process is safe, and to estimate the economics of the installa- tion and use of the process as com- pared to other alternatives. The evaluation was carried out at Pio- neer Metal Finishing in Franklinville, NJ. Field observations and sample col- lection were carried out over a 1-mo period. Based on the observations, which included determination of the content of metals and solids at selected sampling points throughout the sys- tem, it is concluded that for facilities similar to those where the evaluation was conducted, the Zerpol system pro- Mention of trade names or commercial products does not constitute endorsement or recommendation for use. vides significant advantages and is in- sensitive to fluctuations caused by acidic or basic bath dumps into the system. At Pioneer, approximately 80% of the process water is reclaimed and recirculated. Estimation of the econom- ics suggests that the incremental cost of about $120,000 for a 2000 gal/day Zerpol system results in savings in chemical usage, labor and maintenance, and waste disposal costs providing a payback period of 5.3 yr. While the sys- tem eliminates effluent discharges at the site, it does produce a metal sludge stream that facilitates metal recovery through smelting, and a high solids content stream from boiler blowdown. The system eliminates the use of chlo- rine for cyanide destruction, eliminat- ing that source of chlororganic materials emitted from the site. This Project Summary was developed by EPA's National Risk Management Research Laboratory, Cincinnati, OH, to announce key findings of the re- search project that is fully documented in a separate report of the same title (see Project Report ordering informa- tion at back). Introduction The Waste Reduction Innovative Tech- nology Evaluation (WRITE) program had an objective of identifying and evaluating technologies with potential for waste re- duction or pollution prevention as com- pared with other currently used technologies. The Zerpol process, as ap- plied to waste waters from metal finishing operations, has that potential based upon ------- claims and reports of its performance. The process involves the capture of all aque- ous effluent from the manufacturing op- eration, conditioning of this effluent to remove any metals or cyanide that may be present from rinsing procedures, and the reuse of the recovered water for rins- ing. About 30% of the recovered water is fed into a boiler to produce distilled water for critical rinsing. Boiler blowdown main- tains the salt level in the recirculated wa- ter at a level acceptable to the metal finishing process. Thus, the use of the Zerpol process has the objective of per- mitting continued recycling and reuse of water in the manufacturing process. Sys- tem water loss due to boiler blowdown and evaporation from the process tanks is made up by fresh water supply. The Zerpol process does produce at least two waste streams, a metal hydrox- ide concentrate that results from the con- ditioning of the process effluent (suitable as a resource for metal recovery by smelt- ing or similar operations) and blowdown from the boiler (a concentrated solution of soluble salts). In some instances, waste oil may accumulate at the surface of the effluent storage tanks. This oil is skimmed and disposed of as waste. A previous EPA-supported study by re- searchers at the University of Central Florida [2] evaluated the effectiveness of the Zerpol process as a waste manage- ment technique for the metal finishing in- dustry. That study concluded that there were potential applications for the pro- cess in certain segments of the metal finishing industry. However, the report raised some questions that could not be answered based on the evaluation that was carried out then. These questions included uncertainties regarding rinse wa- ter quality, boiler economics and opera- tion, product quality, and safety. The purpose of this project was to con- firm and extend the previous study of the Zerpol process to provide information about its waste reduction potential, opera- tional implications, safety issues, and eco- nomics. The evaluation was carried out at Pio- neer Metal Finishing, Inc. in Franklinville. At the time of the study the facility oper- ated one shift per day, five days per week. Pioneer Metal plates a variety of metal objects, emphasizing copper, nickel, and chromium plating operations. All parts are rack plated. All parts are cleaned, acid dipped, copper plated and nickel plated. Forty percent receive chrome. The base metals that are plated are steel, brass or zinc diecast. Components for electric equipment, automobile parts, and refrig- eration and plumbing parts make up 80% of the work load. During the field evaluation period of about one month, the shop was producing approximately 3,000ft2 of plated surface per shift. The parts varied from small screws up to items with 0.8ft2 of surface each. The plating lines and the Zerpol system are shown schematically in Fig- ures 1 and 2. The Zerpol system has been in place at the facility since 1981. This technology allows the conditioning and reuse of pro- cess water. The Zerpol technology could be useful not only for the metal finishing industry, but also for many types of water- using industrial operations. In this system, aqueous effluent is accumulated in pro- cessing tanks to allow conditioning in a batch mode. In the metal finishing appli- cation, conditioning is a step-wise pro- cess. Initially, an active oxygen compound, reported to be hydrogen peroxide [1], is added, as needed, to oxidize cyanide ions. (Although possible compositions of the active oxygen compound and the reduc- ing agent are reported in the literature, Zerpol Corporation indicates that the na- ture of these formulations is proprietary information. Therefore, during this investi- gation, no effort was made to determine their exact compositions). This step is fol- lowed by the addition of a reducing agent, reported to be sodium hydrosulfide [1], to reduce chromium, if present. Sodium hy- droxide is added for pH adjustment to induce precipitation of metals. After a 2- to 3-day settling period, the clarified water is transferred to a storage tank and used in the shop process as needed. Approximately two-thirds of the recovered water is used in the process for non-critical rinsing and about one-third is directed to the boiler. The steam gener- ated is used for heating process baths. The condensate is used in the plating process for critical rinsing and partially for boiler feed to reduce solids build up in the boiler. The net effect is the near total reuse of the effluent stream, thus attain- ing a zero discharge condition at the loca- tion. The dissolved solids in the clarified re- cycled water are kept within acceptable limits by controlling the boiler blowdown. The residual solids streams generated from the precipitation process and from the boiler blowdown are sent off site for reuse or disposal. The metal contents are re- claimed by smelting. Because effluent conditioning is done in a batch mode, one tank at a time, ad- equate tank volumes are required for col- lection of the raw wastewater and for stor- age of the clarified effluent prior to reuse. The frequency of batch conditioning at Pioneer is dependent upon production schedules; initially it averaged about once every five days or approximately five times per month. The capacity of each of the two effluent processing tanks is 25,000 gal compared to a reported design pro- cess usage rate of about 5,000 gal/day. The (clarified) water storage tank holds 50,000 gal. Over the last few years, the process flow rate has been greatly re- duced. At the time of the study, it was less than 2,000 gal/day. Due to the large holding capacities of the tanks, the Zerpol system can handle process dumps such as caustic, acid, and other cleaners without noticeable detrimen- tal effects. Some processes may need de-ionized water for the most critical rins- ing, in addition to the use of the conden- sate produced from the boiler. This condensate is controlled to have a TDS of less than 1000 mg/l. Condensates with higher dissolved solids contents are auto- matically switched over to the clarified water storage tank. Two principal concerns associated with the process relate to the successful op- eration of a boiler with an input TDS of over 5000 mg/l, and whether the produced condensate is satisfactory for critical rins- ing requirements and for acceptable prod- uct quality in the plating operation. A sufficient demand for steam will help jus- tify the energy input for the operation of the boiler. Water conservation and flow reduction are also key factors in the suc- cess of the system. System Performance Evaluation Data Several specific sets of field data were collected at the facility to measure and describe the performance of the Zerpol process and to define more closely its areas of applicability. Analysis of the col- lected data addresses the following five topics: 1) Whether the quality of the recir- culated water is appropriate to maintain the plating process effectively and effi- ciently; 2) Whether the Zerpol process yields a metal concentrate that can be used for metal recovery through smelting or other standard metal recovery technol- ogy; 3) Whether unsafe levels of hydro- gen cyanide form within the Zerpol system; 4) Whether the use of a boiler to maintain an acceptable TDS level in the recircu- lated water is a sound, practical and eco- nomically feasible alternative; 5) Whether the economics of the installation and op- eration of the Zerpol system are favor- ------- I I I to Q. .1 u. ------- 111 ?si iS^ UlQ- ra UJ ^1 1 3 ^ apiueAo ezipixo oj ZOZH ^ -j^sEw^aj oj a^/nsojp/H mnipos as n-l ie}3iu a}B}idi3ajd oj HOBN ^W^ yd tsnfPV • /^T\ V^J 1 I s. f 55 j CD *l 1 $ -8 Ul 10 Bto §>^g ^^ 8 g c "-2 Q t cu 2 5 ^"§ Ul C 3 Si R; 1 (D / t L ^ 4 «c . .§1 QJ CD r-C 0) ou_ 0^ «58> -S "c o ^- Q s § i Ul CD \ ¥• £ 5 s I to •6 .O U) to -Q I N 1 I CO u. ------- able, particularly in comparison with the costs of using other waste management options. Field Sampling and Operating Data Gathering Three types of data were gathered dur- ing six-day tests conducted over a 32-day period: 1) Composite stream samples for chemical analysis; 2) Actual flow rate mea- surements of the generated effluent, recir- culated water, steam condensate and boiler fuel gas; 3) Historical operating and maintenance data on the present Zerpol System and the system that preceded it, a system that involved precipitation of metal sludges and discharge of the treated aqueous effluent. For each test, composite samples of the process and of the Zerpol streams were taken. System flow rates, namely process effluent flow, and the pumping rates of clarified water and of the sludge were measured by capturing the flow in a container and by timing the flow with a stop watch. The boiler feed was mea- sured by an actual water meter. Samples were taken from ten sampling points and analyzed for cyanide ions, cal- cium, magnesium, copper, nickel, chro- mium, iron, zinc, cadmium, phosphorus, total solids, total suspended solids, total dissolved solids, and pH. The analytical data and volume flow measurements are used to determine mass loading entering and leaving the Zerpol system, and by difference, the amount captured by the Zerpol system. Similarly, the quality of the condensate was determined, as well as the composi- tion of the boiler blowdown. The boiler operation was monitored during five work- ing shifts. The total volume of water fed into the boiler was metered. The volume of boiler blowdown was determined by metering and by calculations. Composite samples were analyzed. Because concern was expressed in the previous study about levels of hydrogen cyanide potentially produced in the Zerpol process, air samples were taken, using OSHA standard procedures, at the first point open to the atmosphere after mixing of acid streams and cyanide ion bearing streams. These air samples were taken at the mixing tank ahead of the first holding tank, where analytical measurements of the pH and cyanide content of the water have also been made. Air samples were analyzed for hydrogen cyanide. Because Pioneer claims that the Zerpol process continues to operate well even when process baths are dumped, samples and measurements were taken before and after the occurrence of these extreme con- ditions to demonstrate whether heavier inorganic loadings interfere with the qual- ity of the recirculating water. To address the issue of potential prob- lems with foaming in the boiler that were raised in the previous report on the pro- cess, the feed water to the boiler was sampled before and after addition of the defoaming agent and evaluated according to the Standard Test Method for Foam in Aqueous Media (Bottle Test), ASTM D3601-88. It should be noted that Pioneer fre- quently reported discharge violations while the former continuous discharge treatment system was in operation from 1975 to 1981. These violations were a primary reason the previous treatment system was replaced and there have been no such incidents since the Zerpol system became operational. Since the mid-eighties, shop manage- ment has substantially reduced the total use of water from the previous 5,000 gal/ day to less than 2,000 gal/day. Waste minimization initiatives such as the reuse of dragouts, have been very effective. While the previous system required rela- tively large volumes of water for most effective operation, the Zerpol system uses substantially reduced water volumes and has encouraged and justified additional pollution prevention efforts. In 1989, the shop operation switched from two per day to one shift starting at 6:00 AM and end- ing at 2:30 P.M. The operation of the Zerpol system and the boiler were fine tuned to match the requirements of the plating process. The 25,000-gal effluent processing tank that used to hold the effluent for five work days now holds effluent for about 18-20 work days. This means that the quantity of chemicals used to precipitate the metal hydroxides in the effluent processing tanks has been greatly reduced. The boiler serves two purposes: It pro- vides 10-psig steam to heat the plating baths. The condensate is used as a source for rinsing and for boiler feed water when- ever excess condensate is available. It is also a means of controlling the level of solids in the recirculated process water. The solids are removed from the system through boiler blowdown. For this applica- Table 1. Summary of Process Streams Chemical Analyses for Metals and Solids Sample Point \ /Wafer/a Analyze CN TDS Ca Mg Cd Cr Cu Fe Ni Zn P S-2 Effluent Tank Inlet [mg/l] I d 16.63 9820 19.24 0.99 0.26 22.23 11.17 22.22 71.86 27.83 24.91 S-3 Effluent Processing Tanks [mg/l] 36.1 7820 13.94 0.57 <0.003 42.14 27.89 48.68 201 84.35 19.19 S-4 Clarified Water Tank Inlet [mg/l] 2.69 8380 22.9 0.73 <0.003 2 2.9 2.01 10.1 0.92 <4.69 S-5 Sludge Tank Inlet [mg/l] 245 8620 137 11.2 <0.235 538 445 723 3628 1434 189 Boiler Feed (S-6) Clarified Water [mg/l] 2.18 8329 16.94 0.9 <0.003 1.7 1.32 2.05 28.26 0.76 <4.86 Boiler Feed (S-6) Condensate [mg/l] 3.21 725 <8.81 <0.095 <0.008 23.36 0.24 0.47 3.73 0.16 <4.69 S-7 Boiler Blowdown [mg/l] 18.53 85146 74 1 1.25 <0.008 236 10.08 5.65 52.57 2.3 9.62 S-8 Steam Condensate Return [mg/l] 0.814 57.2 <8.09 <0.08 <0.008 0.12 0.16 0.28 <1.25 0.12 <5.98 S-9 Make Up [mg/l] <0.01 60 <8.09 0.982 <0.003 <0.046 <0.02 4.99 <1.25 0.08 <4.69 Waste Mil. In Sludge 1,000 Sq. Ft. Plated Area [lb/1 000ft2] _. — 0.058 0.0047 0.000099 0.23 0.19 0.30 1.53 0.60 — CN in air at Process Effluent Tank: 0.058 mg/rrf. CN in air at Boiler Blowdown Sump Surface: 0.101 mg/m3. ------- tion, the boiler capacity and blowdown frequency are sufficient to keep the total dissolved solids in the recirculated water at less than 10,000 ppm. Summary of the Results Table 1 shows that the average IDS of the clarified recirculated process water is about 10,000 ppm; of the steam conden- sate is about 500 ppm; of the boiler blowdown is 100,000 ppm. This table also shows that the metals concentration of the recirculated water is higher than what is allowed for discharge into a typical POTW, e.g. Ni is 10.1 ppm compared with an allowable limit of 3.98 ppm. The cyanide concentration is 2.69 ppm com- pared with the limit of 1.20 ppm. Treat- ment to levels within the allowable limit may be possible, but at much higher cost, may not be economically attractive. The observed levels are routinely maintained by Pioneer because they are economi- cally achievable and do not negatively af- fect their processes. Table 2 shows that the clarified water recirculation rate is about 1,700 gal/day. This is much lower than the initial system design rate of 5,000 gal/day. Effluent flow rate is in the range of 3.36-3.82 gpm. About 37% of the recirculated water is diverted through the boiler. Boiler blowdown averages about 0.20 gpm. The boiler generates steam to the process at an average condensate equivalent rate of 1.35 gpm. Average heat delivery to the process from the steam is about 6.55 x 105 Btu/hr. Boiler thermal efficiency based upon heat delivered to process compared to heat energy input to boiler is about 39- 40%. The daily energy cost to run the boiler is in the range of $104-127/day. Table 3 shows that the operating cost of the Zerpol system is about 1/3 that of the previous system, however; the installed cost of the Zerpol is nearly two times that of the previous system. Conclusions The Zerpol zero discharge system can be used successfully at metal finishing Table 2. Operating Data of the Zerpol Effluent Processing System Test Series Date Test Number 1 4/14/92 1 1 4/15/92 2 1 4/16/92 3 2 5/14/92 1 2 5/15/92 2 Five Day Average Clarified Water Total Flow/24 hr: Flow During Daytime to Process: (Average Flowrate) * Flow During Night to Boiler: (Average Flowrate) % of Clarified Water Passing through Boiler: Boiler Slowdowns Average Flowrate: N° Blwdns.-Minutes Ea.-Gal Ea. During Daytime: During Nighttime:0 1747.4 gal 1079.4 gal (2.57 gal/min) 668 gal (1.59 gal/min) 38% 0.28 gal/min 3/1 min/39.2gal 0/0/0 Steam from Boiler (as Condensate} 1.18 gal/min During Daytime to Process: Nighttime to Storage Tank: 1.59 gal/min Average Flowrate (24 hr.): 1.385 gal/min Average Heat in Steam Flow to the Process: 1592 gal 949.2 gal (2.26 gal/min) 642.6 gal (1.53 gal/min) 40% 0.14 gal/min 2/1min/29.4gal 0/0/0 1.26 gal/min 1705 gal 1058 gal (2.52 gal/min) 647 gal (1.54 gal/min) 38% 0.13 gal/min 2/1min/27gal 0/0/0 1.28 gal/min 6.72 *105Btu/hr 1.53 gal/min 1.54 gal/min 1.395 gal/min 1.41 gal/min 6.77 "105 Btu/hr 6.84 "105 Btu/hr 1686 gal 1096 gal (2.61 gal/min) 590 gal (1.40 gal/min) 35% 0.19 gal/min 2/1min/40gal 0/0/0 1.16 gal/min 1.40 gal/min 1.28 gal/min 6.22'105 Btu/hr 1721 gal 1088 gal (2.59 gal/min) 633 gal (1.51 gal/min) 36.8% 0.28 gal/min 3/1min/40gal 0/0/0 1.04 gal/min 1690.3 gal 1054.1 gal (2.51 gal/min) 636.1 gal (1.51 gal/min) 37.6% 0.20 gal/min 2.4/1 min/35gal 0/0/0 1.18 gal/min 1.51 gal/min 1.51 gal/min 1.275 gal/min 1.35 gal/min 6.19'105 Btu/hr 6.55 "105 Btu/hr Condensate Flow During Daytime to Process as Rinse Water: (Average Flowrate) 'Flow During Daytime to Boiler: (Average Flowrate) 549.9 gal (1.31 gal/min) 614.1 gal (1.46 gal/min) Boiler Data Type-yrin Service-Measured Eff.: 586.8 gal (1.40gal/min) 584.8 gal (1.40 gal/min) 593 gal (1.41 gal/min) 592 gal (1.41 gal/min) Columbia WL 180 - 3 yr in service - 67% to 68% 509 gal (1.21 gal/min) 566 gal (1.35 gal/min) 515 gal (1.23 gal/min) 556 gal (1.32 gal/min) 550.7 gal (1.30 gal/min) 582.6 gal (1.40 gal/min) (continued) ------- Table 2. Continued Test Series Date Test Number 4/14/92 1 4/15/92 2 4/16/92 3 2 5/14/92 1 2 5/15/92 2 Five Day Average Boiler Thermal Efficiency: 39%-41 % (Btu/hr to Process Btu/hr to Boiler) Average Energy Input 17.1 *105 to Boiler:(Btu/hr) Daily Boiler Energy $127 Costbased upon $0.53 /1O5 Btu: 38%-40% 17.7*105 $127 38%-40% 17.7*105 $127 42%-44% 14.6*105 $104.7 42%-44% 14.6*105 $104.7 40%-42% 16.3*105 $118.1 Average Effluent Flowrate During Single Tank Filling Period of 25 Days Containing 18 Workdays @ 7 Hours: 3.00 gal/min. Average Effluent Flowrate During First 3 Test Days (Excluding Bath Dumps): 3.36 gal/min. Average Effluent Flowrate During First 3 Test Days (Including Bath Dumps): 3.32 gal/min. Total Effluent Flow During Single Tank Filling Period of 25 Days Containing 18 Workdays @ 7 Hours: 22,700 gal. Clarified Water Produced During the 25-Day Period: 19,700 gal Sludge Produced During the 25-Day Period: "3,000 gal. * Boiler feed: during daytime - condensate; during nighttime - clarified water Boiler Feed Water Treatment Done Once a Day at 2 p.m. "99% Water. Water Removed after Settling. Table 3. Comparison of Installation and Operating Cost Data of the Past and Present Treatment Systems at Pioneer Equipment Previous System Individual Treatment Tanks Present Zerpol System^ Storage Tanks and Boiler Chemicals, $/yr2) Labor, Repair, Maintenance & Monitoring3) Sludge + Salts Disposal, $/yr Total Operating Costs4), $/yr Installed Costs, $ D.I. system, Installed Cost, $ Flow, gal/day Operation, day/yr Years in service Original flow, gal/day Boiler energy cost 12,300 - 15,300 35,140 not available 47,440 - 50,440 65,000 (1975) 30,000 16,000 - 40,000 250 1975- 1981 40.0006) (not included) 2,700-3,300 1,890 8,800 13,390 - 13.9905) 170,000(1981) 30,000 1,500-5,000 250 1981 to present 5,000 (not included) 1) Requires Deionized (D.I.) Water System. 2) Includes Chemicals for Boiler and D.I. Water System. 3) Based on Labor Costs of$17.5/hr Includes labor for D.I. Columns Backwash. 4) Costs of Chemicals, Operating Labor, Repair, Maintenance, and Monitoring. 5) Includes Disposal of Sludge and Salts. 6) The Previous System Could Only Function With Diluted Flow, Requiring Large Volumes of Water. shops where the treated effluent and the generated condensate can be recirculated and reused for rinsing without impairing product quality. The Zerpol system works well for the Pioneer metal finishing process which was the subject of the one- month field evalua- tion. During that period, acid and caustic baths were intentionally dumped into the system as part of the normal operation of the facility. This did not result in any no- ticeable product quality impairment. This system should perform just as well for shops with similar production and quality requirements. Because the entire effluent is captured and collected in large capacity tanks prior to recycling; 1) risk of accidental release is reduced; 2) special operating permits are not required, although local agencies should also be consulted; 3) compliance with effluent pretreatment standards is not required; 4) timing of chemical addition and processing is flexible; and 5) mainte- nance emergencies are less frequent and more easily managed than with other waste management options. Also, there seem to be no acute safety concerns. Measured levels of hydrogen cyanide at the effluent mixing tank and at the boiler blowdown sump were extremely low, well within the OSHA standards. When the required equipment for the zero discharge system is identified, its eco- nomics and pollution reduction potential should be compared with those of other systems, such as: • Zero discharge, low temperature evaporative recovery and treatment systems. • Non-chemical wastewater treatment system. • Carbon absorption. • Microfiltration, Ultrafiltration, Reverse Osmosis. • Ion Exchange. • Electrowinning by itself or in combi- nation with other treatment systems. It should be noted that while it is true that the Zerpol zero discharge system does ------- not contribute to pollution at the site, this does not mean that its recovered materi- als do not contribute pollution to the envi- ronment at the smelting facility. Identifying and quantifying this pollution could not be accomplished in this study because of the reluctance of the smelting operation to provide information, but should be consid- ered in any life-cycle analysis of this and related processes. The results of this investigation demon- strate that, at this facility, the Zerpol zero discharge system eliminates the discharge of an aqueous wastestream by allowing recycling of most of the process water. The system facilitates the removal of met- als in a form that is suitable for metal recovery. Salts from the boiler blowdown are treated as wastes in a standard water treatment facility. These positive factors represent a reduction in the volume of waste generated at the facility through a series of process modifications and have encouraged and facilitated source reduc- tion initiatives at the facility. The full report was submitted in fulfill- ment of Assistance Agreement No. CR- 816142 by New Jersey Department of Environmental Protection under the spon- sorship of the U.S. Environmental Protec- tion Agency. Hanna J. Saqa and Daniel J. Watts are with New Jersey Institute of Technol- ogy, Newark, NJ 07102; Mohammed Elsaady is with the New Jersey Department of Environmental Protection and Energy, Trenton, NJ 08625; and the EPA author, Johnny Springer (also the EPA Project Officer, see below) is with the National Risk Management Research Laboratory, Cincin- nati, OH 45268. The complete report, entitled "Field Testing and Evaluation ofZerpoP Technol- ogy at Pioneer Metal Finishing," (Order No. PB95-260238; Cost: $19.50, 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: National Risk Management Research Laboratory U. S. Environmental Protection Agency Cincinnati, OH 45268 United States Environmental Protection Agency National Risk Management Research Laboratory (G-72) Cincinnati, OH 45268 BULK RATE POSTAGE & FEES PAID EPA PERMIT No. G-35 Official Business Penalty for Private Use $300 EPA/600/SR-95/126 ------- |