United States Environmental Protection Agency National Risk Management Research Laboratory Research Triangle Park NC 27711 Research and Development EPA/600/SR-95/167 February 1996 4>EPA Project Summary Evaluation of the High Volume Collection System (HVCS) for Quantifying Fugitive Organic Vapor Leaks EricS. Ringler Fugitive volatile organic compound emissions associated with gas and/or petroleum processing facilities have historically been difficult and expen- sive to measure accurately. A measure- ments technique has recently been developed that offers the potential for providing an easy-to-use and cost-ef- fective means to directly measure or- ganic vapor leaks. The method, called the High Volume Collection System (HVCS), uses a high volume sampling device and a portable flame ionization detector (FID) for field analysis. The HVCS can obtain direct measurements of mass emission rates without the need for tenting and bagging. This study of HVCS method performance in- cluded both field and laboratory test- ing. Laboratory evaluation of HVCS results closely matched EPA method results with a difference in total mea- sured emissions of only about 3%. In one field test, the HVCS matched the EPA estimate of total facility emissions within about 4%. In the other field test, the HVCS measured approximately 18% more emissions than the EPA method. However, the bias was present only early in the test. Later in the test, after efforts were made to identify and cor- rect its source, HVCS bias was essen- tially zero. With some physical and procedural enhancements, the HVCS may be offered to EPA for approval as an acceptable alternative to the EPA protocol bagging method with gas chro- matographic analysis. This Project Summary was developed by EPA's National Risk Assessment Research Laboratory, Research Triangle Park, NC, to announce key findings of the research project that is fully docu- mented in a separate report of the same title (see Project Report ordering infor- mation at back). Introduction Fugitive emissions of methane and other organic vapors from leaking pipelines, valves, flanges, and seals associated with natural gas, petroleum, and chemical pro- duction and processing facilities are an important source of methane and other organic emissions to the atmosphere. Such emissions have historically been difficult and expensive to measure accurately. EPA Reference Method 21, "Determination of Volatile Organic Compound Leaks," de- scribes instruments and procedures that can be used to locate and assess the magnitude of such leaks. However, Method 21 does not provide a direct measure of the mass emission rate. According to the current EPA protocol, the mass emission rate is arrived at by associating plant/ component specific information and instru- ment screening values (per Method 21) with published EPA emission factors or correlation equations. These emission fac- tors and correlations were developed over the last 15 years, based on field studies at petroleum refineries, gas plants, and Synthetic Organic Chemical Manufactur- ing Industry plants. In these studies, screening measurements based on Method 21 were associated with direct measurements of mass emissions ob- tained by isolating leaking components and measuring the pollutant concentration in a ------- known flow of carrier gas (i.e., tenting and bagging the leak). A measurements technique has recently been developed as a result of work spon- sored by the Gas Research Institute. The method, known as the High Volume Col- lection System (HVCS), uses a high vol- ume sampling device in front of a portable flame ionization detector (FID) (Foxboro OVA Model 108 portable FID). The HVCS uses a battery-powered pump to draw air across a leaking component at rates be- tween 10 and 500 standard cubic feet per hour (scfh1). Flows are metered using three calibrated rotameters (100-1000, 10-50, and 2-20 scfh). The FID is used to mea- sure the hydrocarbon concentration in the collected air. Hydrocarbon mass emission rates are determined from the measured airflow rates and hydrocarbon content in the flow. The success of the method de- pends on capturing all of the leaking gas from a component in the flow entering the sample inlet. The inlet is constructed to enhance this capture (the inlet is shaped like the mouthpiece of a snorkel). Diffuse leaks from larger components (such as a large flange) are captured by wrapping the component in polyethylene wrap so that the air flow passes over the entire leaking surface. A flexible spring coil (toy slinky) is used to prevent the wrapping from obstructing the leak or inhibiting the airflow across the component. The HVCS was designed to obtain di- rect measurements of mass emission rates without the need for tenting and bagging and offers the potential for providing an easy-to-use and cost effective means to measure organic vapor leaks from gas, oil, and chemical industry sources. The HVCS has the potential to provide accu- rate and cost effective emissions data com- pared to the current EPA protocol methods. It provides a direct measurement of emis- sions at the source and is simple and inexpensive to operate. These capabilities also provide the means to effectively evalu- ate alternative inspection and maintenance programs and select the program that pro- vides maximum control and minimum cost. Project Objectives and Scope The purpose of this study was to com- plete a detailed evaluation of HVCS method performance over the wide range of leak sizes, component types, and oper- ating conditions characteristic of natural gas production in the U.S. The focus of this evaluation is direct comparisons of HVCS results versus controlled leak rates 1 scfh = 0.0283 std m3/sec. (laboratory) and EPA protocol "tent and bag" method results (field). Consideration is also given to the broader issue of whether the HVCS can be used to accu- rately determine total emissions from a facility. The report presents results from each of these points of view. The study included both field and labo- ratory testing. The field testing assessed the accuracy of the HVCS method relative to an EPA protocol emissions measure- ments method. The goal was to challenge HVCS performance over the range of leak rates, component types and sizes, and operating conditions characteristic of U.S. natural gas production. A major focus of the study was to develop performance criteria for field use of the HVCS method. This included identifying strengths and weaknesses of the prototype HVCS sys- tem, making recommendations for im- provement, identifying conditions under which best and worst HVCS performance is achieved, and recommending proce- dures for obtaining optimum results. The laboratory testing was conducted to es- tablish the accuracy and precision of the EPA protocol (bagging) and HVCS meth- ods compared to controlled leak rates. This testing provided necessary support to the field test results by examining the performance of both methods under con- trolled conditions. In the laboratory, many of the sources of uncertainty associated with field testing were eliminated; the most important source is that the true leak rate in the field is unknown. A detailed Quality Assurance Project Plan (QAPJP) was prepared, reviewed, and approved, prior to beginning any actual testing. This plan served as a guide throughout the field testing and final data analysis. Summary of Testing and Results Laboratory testing was completed be- fore the field testing and consisted of EPA method and HVCS measurements on 134 constructed leaks (75 HVCS and 59 EPA) representing a range of leak rates and component types typical of natural gas production. The EPA protocol vacuum method was selected for the study based on results of preliminary testing with both EPA protocol methods. Field testing was conducted at two gas production fields: one in South Texas and one in West Texas. A total of 135 paired EPA and HVCS quantifications were obtained in the field studies (56 in South Texas and 79 in West Texas). The field sites were selected to represent "typical" facilities where one would expect to find leaking components. This profile required an average facility age of 15 or more years, moderate oper- ating pressures (< 1000 psi2), low hydro- gen sulfide levels, and no active leak detection and repair program. The sites had to contain a sufficient number of wells, compressor stations, and other installa- tions located in a small enough area to permit cost effective screening and quan- tification. Leaks were identified with soap solution, and selected leaks were quanti- fied by both the EPA and HVCS methods. Gas composition was determined in the field by gas chromatography (GC) for each bag sample. Laboratory Test Results The EPA and HVCS methods were both evaluated in laboratory studies. Since the EPA method, like any measurement, is subject to imprecision and bias, quantifi- cation of these data quality indicators was essential before the EPA method could reliably be used in the field as a measure of HVCS performance. Only limited con- trolled testing of EPA protocol method per- formance has been conducted previously, and this did not include treatment of er- rors associated with the total sampling system, including the "bag" or component enclosure. The laboratory tests conducted for this study were devised to represent "real world" components and leak types so that overall errors (including total sampling er- rors) are represented. Actual pipeline com- ponents were assembled in such a manner that induced leak rates could be carefully controlled and accurately metered against a primary flow standard. Components tested included a 2 in.3 gate valve, a 4 in. threaded coupling, a 6 in. pipe flange, and a 1/2 in. pump shaft. These represent component types and sizes that are typi- cally encountered at natural gas produc- tion and processing facilities. Details of the laboratory test bench setup and test matrix are given in the QAPJP. Laboratory test procedures were identical to the field test procedures. Leak rates induced in the laboratory study span 4 orders of magni- tude and are representative of the range of leaks likely to be encountered at actual gas and oil production facilities. Induced leak rates ranged from 0.02 to 20 stan- dard liters per minute (slpm) (.04 to 40 Ib/ day as methane4). Laboratory test results are summarized in Table 1. Percentage differences are 2 1 psi = 6.89 kPa. 3 1 in. = 2.54 cm. 4 1 slpm = 2lb/day(thisconvertsthemetricstandard liter per minute leak rate to the nonmetric pounds per day mass equivalent of the principal gas, methane). ------- Table 1. Laboratory Results Summary Method Bias EPA Method Bias vs. Induced HVCS Bias HVCS Relative Bias HVCS "True" Bias Mean (MVU)a -7.4% -8.3% 0.3% -7.1% Lower 95% Limit -9.7% -12.0% -9.0% -15.7% Upper 95 % Limit -5.0% -4.3% 8.5% 0.5% No. 55 32/55b 9/22b 9/22b Difference in Total Emissions EPA Method vs. Induced HVCS Method vs. Induced EPA vs. HVCS Leak (slpm) 96.1 175.1 25.1 (EPA) Result (slpm) 90.4 164.5 24.4 (HVCS) Diff(%) -5.9 -6.1 -2.8 No. 55 55 22 * MVU = Minimum variance unbiased. b Summary results are calculated using only data that are unaffected by a bias caused by the position of the FID probe in the HVCS exhaust., This bias was discovered during the laboratory study, and measures were taken to prevent the bias from occurring during the field study. used as the measure of bias in four cases: (1) EPA results versus known leak rates, (2) HVCS results versus known leak rates, (3) HVCS versus EPA results (HVCS rela- tive bias), and (4) HVCS versus bias cor- rected EPA results (HVCS "True" bias). The EPA bias correction is -7.4%, as de- termined in these studies. HVCS "true" bias is a useful measure of field perfor- mance, since it compares the HVCS re- sults to an estimate of actual emissions (as estimated from the EPA method re- sults), rather than relative to another mea- surement (the EPA method). Results are summarized in terms of a minimum variance unbiased estimator of the mean, lower 95%, and upper 95% confidence interval limits. These summary statistics were selected based on the natu- ral log-normal distribution of the percent- age difference used to measure bias. In the laboratory study, the HVCS and EPA methods gave very similar results (relative bias is 0.3%). Both methods showed a moderate negative bias (7 to 8%) compared to the known leak rates. For the EPA method, the negative bias is probably due to incomplete mixing in the bag, so that outside air is taken up prefer- entially to the leaking gas. For the HVCS method, the negative bias is probably due to incomplete leak capture, or failure of the HVCS system to fully capture the leak- ing gas in the slipstream of air pulled in around the component. In the laboratory study, the components were not fully en- closed during HVCS sampling. In the field study, however, components were thor- oughly wrapped in polyethylene film dur- ing HVCS sampling. This appeared to improve leak capture. To assess the ability of the HVCS to quantify total facility emissions, total emis- sions from all leaking components in the laboratory test results may be viewed as total facility emissions. The total induced leak rate from all components tested by the HVCS method was 175.1 slpm (84.6 Ib/day). The total leak rate measured by the HVCS method was 164.5 slpm (79.5 Ib/day), for an overall difference of -6.1%. The total induced leak rate from all com- ponents tested by both the HVCS and EPA methods was 26.1 slpm (54.0 Ib/ day). The total leak rate measured by the EPA method was 25.1 slpm (52.0 Ib/day), and the total leak rate measured by the HVCS method was 24.4 slpm (50.5 Ib/ day). The overall difference between the EPA and HVCS methods was -2.5%. The total induced leak rate from all compo- nents tested by the EPA method was 96.1 slpm (198.9 Ib/day). The total leak rate measured by the EPA method was 90.4 slpm (187.1 Ib/day), for an overall differ- ence of -5.9%. Field Test Results To locate leaks for the study, over 21,000 components were screened at two gas production facilities located in sepa- rate areas (South Texas, and West Texas). Table 2 summarizes the number and type of components screened and leaks found at each location. Table 3 summarizes the field study re- sults using summary statistics as described for the laboratory study. At the South Texas site, measured leak rates ranged from less than 0.01 to more than 9 slpm as measured by the EPA method. Some larger leaks were not mea- surable by the EPA method. The HVCS method measured leak rates up to 13 slpm. The average leak rate was about 1.2 slpm, with a median of 0.25 slpm. Total measured emissions (EPA method) were about 70 slpm, or about 140 Ib/day, representing most of the leaks in two of three gas fields served by the facility. There appears to be a positive bias in the South Texas field data compared to the labora- tory results; however, a statistical com- parison ("t" test) gives a probability that the means are different by about only 65 to 75%. That is, given the variability in the data, the means cannot be distinguished with a very high level of statistical signifi- cance. In terms of an inventory, the rela- tive bias overstates the difference between the two methods. Overall measured emis- sions (final validated data only) are 58.2 slpm (about 120 Ib/day) for the HVCS method and 55.8 slpm (about 115 Ib/day) for the EPA method, an overall difference of only 4%. The reason for the overstate- ment is that small differences in measure- ments of small leaks often yield large percentage differences. The negative bias observed in the laboratory studies was probably eliminated by the additional "wrapping" of components that was rou- tinely performed in the field. At the West Texas site, measured leak rates ranged from less than 0.01 to more than 20 slpm. The average leak rate was about 1.2 slpm, with a median of 0.7 slpm. Total measured emissions (EPA method) amounted to about 130 slpm (about 260 Ib/day). Most of the measurements were obtained in a gas processing plant (51/ 79); the remainder were collected at well heads and in a propane storage area. There is a very significant positive HVCS bias in the overall West Texas results. The probability that the mean bias is the same as in the laboratory studies is very small (0.4%). The probability that the mean bias is the same as in the South Texas data is also small (0.9%). For the vali- dated data, the HVCS method measured a total of 93.9 slpm (194 Ib/day), while the EPA method came up with only 79.2 slpm (164 Ib/day). This difference in total emis- sions is significant (18.6%) but not far outside acceptable limits for field emis- ------- Table 2. Component Screening and Leak Identification South Texas West Texas Component Flanges Threaded Connectors Tube Connectors Valves Open-End Lines Miscellaneous Screened 889 3733 931 1785 216 74 Leaks 0 12 3 25 8 11 Screened 1401 8010 982 2901 55 94 Leaks 1 11 0 79 0 7 Total 7628 59 13443 98 sions measurements. It is notable that the bias occurred only early in the study. Be- fore September 26, the difference in total emissions was 47.1%, and after this date the difference was essentially zero (-1.5%). This is significant, as some operational and procedural changes were made in the field after September 26 in an attempt to improve results. The bias in the West Texas results was immediately noted in the field. The field crew conducted numerous quality control and operational checks to determine the source of the bias. The HVCS and bag sampling apparatus were carefully leak- checked, and additional flow calibrations were performed. The OVA was calibrated before and after each HVCS quantifica- tion, using the same methane standards used to calibrate the GC. Controlled leak tests and other special tests were also conducted in an attempt to isolate the source of the bias. After efforts early in the study failed to eliminate the bias, a concentrated effort was made on September 26 to isolate and eliminate the bias, if possible. This included controlled leak tests, equipment checks and cleaning, and minor changes in operating procedures. A hypothesis that the apparent positive HVCS bias may have actually been due to a negative bias caused by dilution in the EPA sampling apparatus was also investigated. Unfortu- nately, this effort failed to identify and explain the exact source of the bias; how- ever, after this date, the bias was no longer present in the results. Two additional possibilities that could explain the apparent HVCS bias were iden- tified: (1) high background hydrocarbon levels and (2) analytical bias of the OVA versus the GC. Background hydrocarbon concentrations can produce a positive HVCS bias since the background concen- tration is multiplied by the higher HVCS flow rate to obtain the emission rate (i.e., the HVCS result is more strongly influ- enced by background levels than the EPA vacuum method, even though both use the air surrounding the leaking compo- nent as dilution gas). Note, however, that observed background hydrocarbon con- centrations were, in most cases, not suffi- ciently high to have produced the observed HVCS bias. Although both the GC and the OVA use FID, an analytical bias could result from differences in instrument de- sign that make the OVA response sensi- tive to sample contaminants, sample gas composition, and possibly environmental effects such as pressure. The possibility that an analytical bias was present was suggested by field efforts to identify the source of the bias. In addition to the possible effect of op- erational changes that were implemented after September 26 (the pump was cleaned and an extension tube was added to the EPA apparatus), the improvement in HVCS results after September 26 may be re- lated to a combination of two other fac- tors. First, as part of efforts to determine and eliminate the source of the bias, mea- suring in areas with high background lev- els was avoided after that date. Earlier in the study, most of the measurements were obtained from dense clusters of leaking components where there were potentially high background levels. At the South Texas site, background levels were mini- mal (samples were obtained in remote, open areas and wind speeds were very high). Second, the average leak rate after September 26 ( 1.8 slpm) is larger than the average leak rate before that date (1.2 slpm). This would reduce an HVCS bias related to background hydrocarbon since such a bias is less significant for larger leaks. After the field studies, additional labora- tory studies were conducted to confirm the field tests that suggested an analytical bias and to identify the source of the bias. For these tests, five gas samples were obtained in pressurized stainless steel sample canisters from the West Texas plant. The samples were collected pro- gressively through the gas processing stages and represent the areas in the gas plant where leaks were quantified. In ad- dition, the same OVA used in the study was obtained for comparative tests with the GC. The laboratory testing was de- signed to compare the response of the OVA and the GC under more controlled conditions, to identify a contaminant in the gas samples, and/or to identify an uniden- tified compound that could have produced the observed bias. No evidence was found in the labora- tory tests to confirm a positive analytical bias of the OVA versus the GC. In addi- tion, no contaminants or excess com- pounds were identified that could have produced such an analytical bias. The only identified factors that were not investigated in these tests are environmental; e.g., the difference in atmospheric pressure due to the high altitude of the West Texas site (about 3500 ft5 above mean sea level compared to near sea level elevations for the laboratory and South Texas studies). While the OVA response is known to be sensitive to sample inlet pressure, this should not effect the results since the OVA was calibrated at the pressure at which it was used. Conclusions As demonstrated in the laboratory study and by the South Texas results, the HVCS is capable of accurately quantifying fugi- tive leaks over a wide range of leak sizes, and component types and sizes. On the other hand, the West Texas results re- vealed an important limitation of the sys- tem. Laboratory evaluation of HVCS per- formance was very favorable. The HVCS results closely matched EPA method results with a difference in total measured emissions of only about 3%. The HVCS also repro- duced a wide range of known leak rates with an average bias of-8.3%. The negative bias is probably due to incomplete leak capture. In the laboratory tests, HVCS leak cap- ture depended solely on the ability ' 1 ft = 0.3 m. ------- Table 3. Method Bias Field Study Results Summary Mean (MVU)' Lower 95% Limit Upper 95% Limit No. South Texas HVCS Relative Bias 15.2% South Texas HVCS "True" Bias 6.6% West Texas HVCS Relative Bias - 44.5% Overall -3.6% 34.3% 29.8% 20.2% 56.7% 48 66 West Texas HVCS "True" Bias - Overall West Texas HVCS Relative Bias - On or Before September 26 West Texas HVCS "True" Bias - On or Before September 26 West Texas HVCS Relative Bias - After September 26 West Texas HVCS "True" Bias - After September 26 33.8% 67.0% 54.7% 5.7% 0.0% 24.4% 56.5% 44.9% -0.4% -7.3% 45.1% 84.8% 71.1% 18.6% 9.8% 66 40 40 26 26 Difference in Total Emissions South Texas West Texas - Overall West Texas - On or EPA (slpm) 55.8 79.2 32.7 HVCS (slpm) 58.2 93.9 48.1 Diff. (%) +4.3 + 18.6 +47.1 No. 48 66 40 Before September 26 West Texas - After September 26 46.5 45.8 -1.5 26 MVU = Minimum variance unbiased. of the HVCS to capture all of the leaking gas in the slipstream of di- lution air entering the HVCS inlet. No enclosures were constructed to shield components and direct gas into the HVCS inlet. The HVCS also performed very well in the South Texas field study. The HVCS matched the EPA estimate of total facility emissions within about 4%, similar performance to that obtained in the laboratory stud- ies. In the field, enclosures were constructed to shield components from wind and assist in directing leaking gas into the HVCS inlet. Early in the West Texas study, an apparent positive bias was ob- served in the HVCS results. On and before September 26 (about midway of the study), the HVCS measured 47.1% more total emis- sions than the EPA method. After this date, no appreciable bias was observed. After the entire study, the HVCS measured 18.6% more emis- sions from the facility than the EPA method. The source of the early study bias is unclear; however, re- sults suggest that some operational problems may have been overcome as a result of efforts undertaken in the field. Other factors that may have contributed to the changed results include (1) efforts that were made to avoid sampling in areas with potentially high background concentrations that could cause a positive bias in the HVCS results and (2) the fact that average leak rates were higher later in the study, which would lessen the effect of background interference on the HVCS quantifications. Overall, these results are within accept- able limits for field emissions measure- ments. With some physical and procedural enhancements, the HVCS should offer an acceptable alternative to the EPA protocol bagging method with GC analysis. Special precautions must be taken to obtain accurate HVCS quantifi- cations where there may be el- evated background concentrations, such as in confined areas, or where there are dense clusters of leaking components or very large leaks. The simplest approach is to attempt to quantify background levels with the OVA and apply an appropriate correction to the results. This must be done very carefully since back- ground levels in such areas have been observed to range widely in small areas and change very rap- idly. An alternative method for de- termining the background level has been suggested that, in some in- stances, could provide a useable correction, even when background levels cannot be practically mea- sured. The limitation of this method is that one must be certain that changes in HVCS outlet concentra- tion are due solely to changes in HVCS flow; i.e., total leak capture must be attained at all HVCS flows. Improved HVCS flow capacity, con- trol, and metering are needed to enhance leak capture and provide greater reliability and ease of use in the field. With the current rota- meter set-up, the capacity could be doubled by simply increasing pump capacity. Power requirements would also be increased, but the unit could still be battery-operated (a 12-V pump could reach near 1000 scfh). Much larger flows would require more power, decreasing portability, and the metering system would also have to be modified substantially to handle the higher flows. Increased flow capacity would also increase the size of leaks that could be quan- tified without the need for a dilution probe, or other alternative to ex- tend the range of the portable hy- drocarbon monitor. Enhanced leak capture might also make it possible to measure leaks from larger com- ponents without the need for auxil- iary bagging. This could decrease the time required for each mea- surement. Increased range and enhanced sta- bility of the portable hydrocarbon monitoring device used with the HVCS are also needed. The por- table hydrocarbon monitor used with the HVCS needs greater range and reliability than the Foxboro OVA Model 108 that is currently used. The OVA's upper range is at 10,000 ppm, or 1%. This can be extended to perhaps 15,000 ppm using the ------- direct voltage output from the OVA; however, precision rapidly deterio- rates at this upper end. In the field, Foxboro's dilution probe was used to extend the quantification range, with generally good results; how- ever, the use of the dilution probe adds a degree of complexity. The OVA is also very sensitive to sam- pling conditions, contaminants, bat- tery levels, and other factors. The OVA requires frequent calibration, which adds significantly to the ex- pense and level of uncertainty as- sociated with its use in quantitative applications. The OVA is very sen- sitive to sample gas composition since the detector is exposed to the entire sample stream at once and uses sample stream air as com- bustion air for the FID. The OVA exhibits varying responses to dif- ferent hydrocarbons, and some- times radical responses to "contaminants" (water, dust, and gases—e.g., excess hydrogen— that affect the response of the FID). Some research is needed to iden- tify and test alternative analyzers with greater range and stability than the OVA. This might include infra- red devices and electrochemical sensors. In addition, there has been some preliminary develop- ment of a catalytic combustor that would determine hydrocarbon con- centration by stoichiometry, using measurements of oxygen and car- bon dioxide at the entrance to and exit from the combustor. The HVCS may have a very significant role to play in applications where rapid, cost effective, on-site leak quantifications are important. With the HVCS, a single operator can quantify approximately 30 leaks per day. With the EPA bag- ging method, approximately 10 leaks can be sampled per day with additional time and expense re- quired for GC analysis. The HVCS could be very useful in evaluating the effectiveness of dif- ferent inspection and maintenance programs, and determining the most cost effective approach for main- taining emissions below a given level. The HVCS would also be useful for emissions inventory and compliance testing activities related to federal and state air permit requirements. In addition, the HVCS may be valu- able in evaluating the performance of optical-sensing-based techniques for determining fugitive emission rates under real world conditions. Such methods are currently under development at EPA and may soon be tested under actual site condi- tions. For these tests, there will be a need to independently determine leak rates from multiple fugitive sources as a basis for evaluating the performance of the optical-sens- ing-based methods. ------- Eric S. Ringler is with Southern Research Institute, Chapel Hill, NC 27514. Charles C. Masser is the EPA Project Officer (see below). The complete report, entitled "Evaluation of the High Volume Collection System (HVCS) for Quantifying Fugitive Organic Vapor Leaks ," (Order No. PB96- 136395; 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 National Risk Management Research Laboratory U.S. Environmental Protection Agency Research Triangle Park, NC 27711 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-95/167 ------- |