907R93009
                              069308
Everything You Wanted
To Know About
Environmental
Regulations ...

       But Were Afraid To Ask
               City Hall
       A Guide For Kansas Communities
                         September, 1993
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                      Informat-'on T?v>(;onrr'e Center

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Dear Community Representative:

     In developing this document, "Everything You Wanted To Know
About Environmental Regulations But Were Afraid To Ask," we have
attempted to provide you with information that will assist you in
protecting the environmental resources of your community.

     Whereas the Environmental Protection Agency (EPA) and the
Kansas Department of Health and Environment (KDHE)  are
responsible for seeing that regulatory requirements are met,
community officials are responsible for regulatory compliance.
To assist community officials in doing their job, the EPA, KDHE
and a network of assistance providing agencies have recognized
the need to build local capacity through outreach — technical
assistance and information.  With such a partnership, we look
forward to working with you to protect the environment in, and
surrounding, your communities.


                    Sincerely,
                    William W. Rice, Acting Regional Administrator
                    Region 7 Environmental Protection Agency
                    Robert C. Harder, Secretary
                    Kansas Department of Health and Environment

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Everything You Wanted To Know About. Environmental Regulations
                    But Were Afraid To Ask

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                         Water Management Division
                         EPA Region 7
                         726 Minnesota Ave.
                         Kansas City, Kansas  66101
Attn: WPAB/WIAS

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              Everything You Wanted To Know
              About Environmental  Regulations

                      But Were Afraid To Ask

                 A Guide For Kansas Communities41
                          September, 1993

                                    * o.
                                     SAS
                              c u
     *This handbook was produced through a joint effort of the Region 7 office of
the Environmental Protection Agency (EPA) and the Kansas Department of Health
and Environment (KDHE).  The handbook is directed towards communities with
populations of 10,000 and less, and to the organizations that assist these communities.
The Kansas State Board of Agriculture (KSB A) also provided assistance in reviewing
the section on Pesticides.

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                          Preface
     This handbook was prepared for use by officials of communities with
populations of 10,000 and less, and to the organizations that assist these
communities, as a quick reference to the environmental issues  facing their
constituencies. If you are an official of a larger community, you will need, as
a minimum, to comply with the enclosed requirements. It is likely you may need
to meet additional requirements.

     This handbook provides only a summary of basic environmental infor-
mation.   It is not a definitive statement to the specific ways  in  which a
community may assure environmental compliance; it is  a quick guide to the
environmental programs that typically apply to most small communities.

     The requirements and guidance presented in this  handbook are based
on federal regulations and/or guidance in place in mid-1993.   It should be
expected that some of these requirements/guidance will change in the future.

     The handbook is organized according to key  program areas.  After
highlighting services available to you from Region 7, the handbook explores
Cross Media, Air, Land and Water programs. Cross media programs are those
that can reach across  any  of  the other program areas.  Definitions and
acronyms are provided at the end of the handbook.

     This document was initially prepared in 1990 by the Midwest Assistance
Program (MAP) under contract to  the Environmental Protection Agency,
Region  8.  It was expanded by the Region 8 Small Community Work Group
in early  1991.
                               11

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                  Table of Contents

  El 1E1  CROSS MEDIA PROGRAMS
    Pollution Prevention                                         1
    Public - Private Partnerships                                   3
    SARA Title in Emergency Planning and Community Right-to        5
           Know Act
    Asbestos                                                  7
    Indoor Radon                                              11
    Pesticides                                                 13
    Toxics - PCB's                                             15

           AIR PROGRAM
    Clean Air Act Amendments                                   16
           Refrigerant Recycling and the Prohibition on Venting        18
K=ii.i:i£:i«*
LAND PROGRAMS
    Superfund                                                20
    RCRA Hazardous Waste                                    21
    Subtitle D Municipal Solid Waste Landfill Criteria                24
    Underground Storage Tanks                                  26
    Above Ground Storage Tanks                                 30

     Q   WATER PROGRAMS
    Kansas Water Plan                                         32
    Water and Wetlands Protection                                33
    Drinking Water                                            35
           Kansas Health & Environmental Laboratory              37
           Inorganic Chemicals                                 38
           Asbestos                                          41
           Fluorides                                         43
           Lead Material Ban                                   45
           Lead and Copper                                    47
           Synthetic Organic Chemicals (Non-Volatile)              50
           Volatile Organic Chemicals                           52
           Coliform Monitoring                                 56
           Surface Water Treatment Rule                         58
           Radionuclides                                      60
           Disinfection and Disinfection By-Products                62
           Public Notification                                  64
           Underground Injection Control                         69
                         (Cont'd)
                              111

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Kansas Water Well Protection Program
Wellhead Protection
Wastewater
         State Revolving Fund Loan Program
         National Pollutant Discharge Elimination System
         Sewage Sludge Use and Disposal
         Pretreatment Requirements
         Stormwater

Bureau of District Operations
71
72

74
76
77
79
81

83
         DEFINITIONS-ACRONYMS
84
                              IV

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      EPA  REGION 7 SERVICES
      Toil-Free Access

      Residents of Iowa, Kansas, Missouri, and Nebraska can call the Environmental
 Protection Agency, Region 7 Environmental Action Line by dialing 1-800-223-0425.
 During the week,  operators can connect you  to appropriate contact persons or
 programs. After hours, and on the weekend, you will be able to leave a message.

      EPA Regional Library

      A number of services are available to residents of Region 7 from EPA's regional
library in Kansas City, Kansas. The library is available for use from 9:00 a.m. to 5:00
p.m.  Monday-Friday.  The regional library provides interlibrary loans through the
Online Computer Library Center (OCLC), or by using a standard American Library
Association (ALA) form available through your public library.

      The public can also access the library via the Online Library System (OLS), a
computer catalog of EPA's library network. An information handout about OLS and
how to use it is available from the library. To contact the library, call 1-913-551-7241.
or 1-913-551-7358.

      KDHE Library

      KDHE has a pamphlet library containing over 3,000 tides covering important
health and environmental issues.  Brochures, booklets, posters and fact sheets are
available on environmental topics such as water conservation, recycling, radon, asbes-
tos, and lead. Similar topics are covered in the audiovisual library, which contains over
2,000 titles.  Some titles are available in both video and 16 mm formats. For more
information or a copy of the 1992-1994 KDHE Audiovisual and Pamphlet Catalog.
call KDHE's Office of Government and Community Relations, Health and Environ-
ment Education Section at 1-913-296-1226.
     Speaker's Bureau
     A number of EPA employees have volunteered to be available to speak on
environmental topics. If you are interested in having someone speak to your group on
a particular environmental issue, call 1-913-551-7003.

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                                                                 D
                                                                  D
CROSS MEDIA PROGRAMS
POLLUTION  PREVENTION
EPA's Pollution Prevention approach
     The Pollution Prevention Act of 1990 establishes pollution prevention as
national policy—EPA's preferred  approach for protecting human health and the
environment  The primary goal of pollution prevention is preventing or reducing
the generation of wastes andpollutants at the source. Potential pollutants or wastes that
cannot be prevented should be recycled whenever possible. Potential pollutants that
cannot be prevented or recycled should be treated in an environmentally-safe manner.
Disposal or other release into the environment should be used only as a last resort and
should be conducted in an environmentally-safe manner. Instead of using traditional
pollution treatment and control methods to stop existing pollutants from reaching the
environment, pollution prevention aims to anticipate and avoid the generation of
pollutants in the first place.

Actions For Communities
     Pollution prevention and cleaning up the environment cannot be accomplished
by wishing, bycourt rulingsorEPA pronouncements alone. What we need is a unified
effort.   Community leaders can  develop policies that encourage environmental
awareness and provide mechanisms to help build the ethic of preventing pollution.
Small communities are in a unique position to make things happen and to win the battle
against pollution.  Local governments can encourage and stimulate the practice of
pollution prevention at all levels: by industry and manufacturing, by private and public
business (including agriculture, transportation, energy generators, hospitals and schools),
by communities and individuals.

     Here are suggestions on how community leaders can fight pollution and preserve
environmental quality, human health and natural resources:

     -Set pollution prevention  as a major goal and integrate the concept into
     governmental activities.  Publicly recognize pollution prevention as a
     priority. Practice what you preach—set an example.

     -Educate the public, as well as business and industry, about pollution
     prevention.  Create an awareness of the profitability and benefits of
     pollution prevention through greater efficiency and stewardship of natural
     resources.

     -Develop programs that provide environmental alternatives:

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  -Recycle paper, glass, plastic, aluminum, scrap metal, motor oil and yard
  wastes.

  -Use less energy. Set back thermostats; insulate; buy energy-efficient
  lighting and appliances and make creative use of daylight.

  -Use less water.  Be conservative. Use ultra-low flush toilets; install water
  meters; repair leaks; review maintenance schedules and use water
  conserving landscaping.

  -Buy energy efficient automobiles andjother fleet vehicles and keep them
  tuned. Carpool, bike, walk or use mass transit when possible.

  -Encourage sustainable agriculture.  Take advantage of natural methods of
  protection.  Apply pesticides, such as insecticides and herbicides, carefully
  if they must be used.

  -Reduce smoke, radon, asbestos and other indoor-air pollutants.

  -Control hazardous waste. Reduce toxic use; encourage product substitution
  and environmentally sound operation modifications.

  -Buy recycled or recyclable products. Seek out reusable, recyclable or
  returnable packages.  Incorporate purchase of these products into
  procurement policies and practices.

  -Reduce risks from lead. Be careful around surfaces covered with lead-based
  paint, and be cautious when children are nearby during renovation or
  rehabilitation of old buildings.  Be sure drinking water does not contain
  harmful levels of lead or other contaminants.

  -Plant trees, shrubs and indoor plants. They replenish the earth's oxygen
  supply and clean the air by removing pollution.
  Additional Information

Regional Contact:

Pollution Prevention Program:
Waste Management Division
EPA Region 7
726 Minnesota Ave.
Kansas City, KS  66101
State Contact:

Pollution Prevention Office
KDHE
Forbes Field, Building 740
Topeka,KS 66620-0001
1-913-551-7050
1-913-296-6603
                               -2-

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CROSS MEDIA PROGRAMS
PUBLIC-PRIVATE PARTNERSHIPS
                                                             n
o
D
     As a community leader, you face  the prospect of building or upgrading
facilities to meet environmental needs. You already may be feeling the squeeze of
growing environmental protection needs and expectations coupled with decreased
funding for infrastructure projects.  As the pressure grows to minimize rate shock
for facility users, local community leaders must find new ways for their communities
to hold down costs and build public support  for necessary additional expenses.
Public-private partnerships offer one solution.

     "The Self-Help Guide for Local Governments" has been written to acquaint
local officials with the concept of public-private partnerships, their benefits and the
steps a community must take to build relationships with the private sector.  This
information will be conveyed in the following sections:

Public-Private Partnerships: What and Why
     A public-private partnership  is a  contractual relationship between a public
and private partner that commits both to providing an environmental service. The
private sector can be involved in a variety of ways, from the initial design of a facility
to its daily operation and maintenance.

     Although each  arrangement is unique, most public-private  partnerships fall
into one of five categories.  These types  are contract services, turnkey facilities,
developer  financing,  privatizations and merchant facilities.  There are different
benefits associated with each of these categories.

     Communities enter into partnerships for various reasons.  These include:
access to more sophisticated technology; cost-effective design, construction and/or
operation; flexible financing; delegation of responsibility and risk; and guaranteed
cost.

Building  a Public-Private Partnership:   An  Action  Checklist
     No two communities build a partnership in exactly the same way, but all must
take roughly the same steps.  This document presents an action checklist of the steps
that will help a community make many  decisions necessary to enter into a contract
with a private firm.

     A community initiates the public-private partnership process by evaluating its
service  needs, reviewing available technology, and identifying resources that may be
able to assist in the development of  the contract.  It is also important for community
                                  -3-

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leaders to generate public support while they are evaluating financing prospects and
studying laws and regulations.

     Reviewing a potential private partner's track record is also an important part of
the process. Another option a municipality may consider is regionalizing services with
surrounding communities. Eventually, local officials must narrow partnership options,
select and conduct its procurement process and finally, develop the service agreement.

Financing, Procurement and the Service Agreement
     Three of the most difficult steps in building a public-private partnership are
financing, procurement and the service agreement.

     In choosing a financing method, a community should estimate the capital
required and identify various financing options. These financing strategies should
then be assessed against the financial condition of the municipality, the project's
costs and any risks.  The community must select the option which is most appropriate
by comparing benefits and costs.

     A local government starts to  implement its choice by initiating the procure-
ment process.  The  three types of procurement most  communities select are
advertised procurement, competitive negotiation and two-step advertising. While
advertised procurement allows the  community to dictate the terms of the solicita-
tion, competitive negotiation offers greater flexibility.  Two-step advertising is a
mixture of the other two.

     Finally, a partnership arrangement must be defined in a service agreement.
Each contract must include a number of elements.  The contract must define: the
project and performance criteria,  compensation method and timing, changing situa-
tions and risk allocations  and contract termination and step-in-rights. Insurance and
bonding should also be considered since they may affect the terms of the contract.
        Additional In formation

      Public-Private Partnership Program:
      Office of Policy and Management
      EPA Region 7
      726 Minnesota Ave.
      Kansas City, KS  66101
      1-913-551-7045
                                    -4-

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CROSS MEDIA PROGRAMS
SARA TITLE m - THE EMERGENCY
PLANNING AND COMMUNITY RIGHT-TO-KNOW
ACT
     SARA Title HI has two purposes:  to encourage and support emergency
planning for responding to chemical incidents, and to provide local governments and
the public with timely and comprehensive information about possible chemical
hazards in communities.

Does the Emergency Planning  and  Community Right-to-
Know Act Apply To My Community?
     Yes.  The chemicals in your community may pose a threat to citizens and to those
individuals  being asked to respond to emergencies involving hazardous substances.
All facilities, including government facilities, in your community storing certain
hazardous chemicals (exceeding specified quantities) must provide information to
government agencies and local communities. Also, if there is a chemical  incident
which results in the release of any one of a large number of hazardous substances,
immediate notification must be made to governmental agencies.

     The law provides stiff penalties for facilities that do not comply, and it allows
citizens to file lawsuits against companies and government agencies to force them
to obey the  law.

What Are The Requirements Under This Law?
     The law, passed in October 1986, had many requirements and deadlines. For
example, governors were required to establish State Emergency Response Commis-
sions (SERCs); facilities subject to emergency planning requirements were required to
notify their state commissions; and SERCs were required to appoint Local Emergency
Planning Committees (LEPCs). LEPCs were required to analyze hazards and develop
a local emergency plan to respond to chemical emergencies in each local district.
Additionally, the LEPC must exercise, review and update the plan annually, informing
the public of these activities.

     The LEPC  has other responsibilities besides  developing an emergency
response plan.  It receives emergency release  and hazardous chemical  inventory
information submitted by local facilities and must make this information available to
the public upon request.
                                -5-

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     Title HI requires owners and operators of facilities storing specified hazardous
substances to report to the LEPC within  60 days.  When facilities provide the
information required by the Act to local officials,  small communities can better
prepare themselves for chemical emergencies.

If the Emergency Planning and Community Right>o-Know Act
applies, what should I do?
     As a local  official, you  should insist  on complete planning and adequate
preparation for an emergency.  Review the membership list of your Local Emer-
gency Planning Committee (LEPC).  Make  sure it is fully representative of the
community and includes individuals from citizen groups, fire departments, public
institutions (hospitals, schools, state and local governments), medical facilities,
industry, business and farmers. It is important not only to participate in emergency
planning, but also to communicate with the public.

     Become familiar with the law so that you will know what tools are being made
available to the community to  better assess  and manage risks present within the
community. Identify what needs to be done at  the local level to better prepare the
response community to deal more effectively  with, and prevent, chemical emergen-
cies.
        Additional Information

      Regional Contact:

     Toxic Substances Control Section
     Air and Toxics Division
     EPA Region 7
      726 Minnesota Ave.
     Kansas City,  KS  66101
      1-913-551-7020

      SARA Title IE Hotline, 1-800-535-0202
State Contact:

Right-To-Know Program
Bureau of Air & Radiation
KDHE
Forbes Field, Bldg. 740
Topeka,KS 66620-0001
1-913-296-1690
                                   -6-

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CROSS MEDIA PROGRAMS              |D| 10
ASBESTOS
     Schools - Public and Private Nonprofit

     On October 22, 1986, the President signed the Asbestos Hazard Emergency
Response Act (AHERA) into law. The Act required EPA to develop regulations
creating a comprehensive framework for addressing asbestos hazards in schools. The
Act required EPA to construct a model accreditation program for individuals who
conduct inspections for asbestos, develop management plans and perform abatement
work.   Asbestos is  also regulated under the  authority of the National Emission
Standards for Hazardous Air Pollutants in the Clean Air Act.

     Other provisions of AHERA require all public and private elementary and
secondary schools to conduct inspections for asbestos-containing building materi-
als, develop management plans and implement response actions in a timely fashion.
Specifically, each local education agency (or LEA, which  means a public school
district or private nonprofit school) must do the following:

     -Designate and train a person to oversee asbestos-related activities in the LEA
     (designated person).

     - Inspect every school building for both friable and nonfriable asbestos
     containing building materials.

     - Prepare a management plan for managing asbestos and controlling exposure
      in each school  and submit that plan to the appropriate state agency. The plan
     should include  a time frame for implementation of recommended actions.

     - Use only properly accredited persons to conduct inspections and develop
     the asbestos management plan.  Accredited personnel must also conduct the
     required triennial reinspections.

     - Provide custodial staff and short-term  workers with information about the
     location of any asbestos-containing materials. Post warning labels as re-
     quired.

     - Survey all locations of asbestos-containing materials for damage every six
     months. Take appropriate steps  to repair or replace damaged materials.

     - Provide custodial and maintenance staff with two hours of awareness
     training and an additional 14 hours of training for employees whose duties may
     cause them to disturb asbestos. This additional training must include proper
     work practices and the use of protective equipment when disturbing asbestos
     containing materials.

     - Notify parents, teachers and other school employees about the asbestos
     inspection and the availability of the asbestos management plan for review.

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     - Utilize properly accredited individuals to design and conduct asbestos
     abatement actions that are necessary and appropriate to protect health and
     the environment. These actions or methods must be documented in the
     management plan.

     - Keep records of all asbestos-related activities in each school  plan and make
     them available for public review.

     Management plans were submitted to state agencies on or before May 9,1989,
as mandated by the provisions of AHERA. LEAs were required to begin implementa-
tion of their management plans by July 9, 1989. LEAs are required to update and
maintain management plans to reflect activities with ongoing operations and mainte-
nance, periodic surveillance, inspection, reinspection  and response action activities.

     All Buildings
     In 1971  the Administrator  of the EPA determined that asbestos presents a
significant risk to human  health  and  is therefore a hazardous air pollutant.  The
National Emission Standards Hazardous  Air Pollutants (NESHAP)  for asbestos,
promulgated under section 112 of the Clean Air Act, specifies emission control
requirements for the milling, manufacturing   and   fabricating  of asbestos;  for
demolition and renovation activities; and  for the handling and disposal of asbestos-
containing waste materials.

     The NESHAP requires that each  owner or operator of a demolition  or
renovation activity thoroughly inspect the affected facility or part of the facility for the
presence of asbestos, including Categories  I  and  H" nonfriable asbestos, before
commencement of the demolition or renovation. Private residences of four units or less
are exempt from the NESHAP.

     Under the NESHAP, all  demolitions require notification to the appropriate
regulatory agency,  including  facilities containing no asbestos.  Work practice
procedures, waste disposal  requirements, and recordkeeping provisions  apply to
those demolition  operations where the  amount of regulated  asbestos-containing
material (RACM), as defined in Section 61.141,when measured, meets or exceeds 260
linear feet on piping, 160 square feet on other facility components, or 35 cubic feet of
asbestos-containing material that has already been stripped or removed and placed in
containers, or left on the floor or ground.

     The NESHAP requires  that notification be submitted at least 10 working days
before any asbestos stripping, removal or any other activity begins that would otherwise
disturb the asbestos material.
                                    -8-

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     Under the NESHAP, renovations, including individual nonscheduled opera-
tions, require notification to the appropriate regulatory agency, as well as compliance
with work practice procedures, waste disposal  requirements and recordkeeping
provisions where the amount of RACM, when measured, meets or exceeds 260 linear
feet on piping,  160 square feet on other facility components, or 35 cubic feet of
asbestos-containing material that has already been stripped or removed and placed in
containers, or left on the floor or ground.

     The NESHAP requires at least one representative trained in the provisions of
this regulation be on site during any stripping, removal or handling of RACM.  The
AHERA contractor/supervisor course meets the NESHAP training requirements.

     The Kansas regulations governing the control  of asbestos must be at least as
stringent as the federal requirements and may be more stringent. For example, Kansas
requires notification and compliance with work practices, and waste disposal proce-
dures where more  that three square  feet or three lineal feet of friable asbestos-
containing material is to be removed. Kansas also requires that business entities who
engage in asbestos removal and encapsulation projects be licensed and that workers
who engage in these activities be trained and certified. The Kansas regulation also
establishes project evaluation fees that must accompany the notification.

     Public Employers
        Employers of public employees who  are engaged in asbestos  abatement
projects must comply with provisions of the Asbestos Abatement Projects Worker
Protection  Final Rule, designed to  protect their workers from friable asbestos-
containing materials.  Employers are required to conduct air monitoring, utilize
specified engineering controls and work practices, provide medical surveillance of
the employees  and  submit prior notification to EPA Region 7's Regional Asbestos
Coordinator.

     What Help Is Available?
     Schools  - Public and Private Nonprofit
        Under the Asbestos School Hazard Abatement Act (ASHAA) program, EPA
provides financial aid to eligible schools in the form of an interest-free loan, grant, or
a combination of both, for the purpose of abating friable asbestos-containing building
materials.

     How Do I Obtain More Information?
        Under AHERA, LEA's afford citizens the opportunity to become  familiar
with asbestos activities in their respective school districts.  The initial point of contact
to obtain information on  asbestos activities should be the LEA designee.   This
individual is most familiar with the asbestos situation in your school.  Additionally,
state AHERA designees  and local, state and national parent and teacher organizations
are excellent sources for requesting information on asbestos activities.
                                    -9-

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Additional Information

EPA Toxic Substances Control Act (TSCA) Hotline 1-202-554-1404

ASHHA Asbestos Hotline (Schools) 1-800-462-6706

"Managing Asbestos in Place, A Building Owner's Guide to Operations and
Maintenance Programs for Asbestos-Containing Materials"

"The ABC's of Asbestos in Schools"

"100 Commonly Asked Questions About the New AHERA Asbestos-in-
Schools Rule"
For The Following Information, Please Call The EPA Region 7
Office Contact.

40 CFR 61 National Emission Standard for Hazardous Air Pollutants;
Asbestos NESHAP Revision; Final Rule

"The Asbestos Informer"

"Asbestos/NESHAP Adequately Wet Guidance"
"Asbestos/NESHAP Regulated Asbestos-Containing Materials Guidance"

"Reporting and Recordkeeping Requirements for Waste Disposal"

"Common Questions on the Asbestos NESHAP"

"A Guide to the Asbestos NESHAP As Revised November 1990"
Regional Contact:

Asbestos Control Program
Air and Toxics Division
EPA Region 7
726 Minnesota Ave.
Kansas City, KS 66101
1-913-551-7020
State Contact:

Asbestos Control Program
Bureau of Air & Radiation
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-1550
                            -10-

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CROSS MEDIA PROGRAMS
INDOOR RADON

      Radon is a naturally occurring radioactive gas that comes from the natural
breakdown (radioactive decay) of uranium in soil, rock and water. Radon moves up
through the ground to the air above and into homes and other buildings through cracks
or holes in the foundation and other entry points. The home acts to trap radon gas,
especially when the home is closed, increasing indoor radon levels. Most soils contain
varying amounts of uranium and, therefore, elevated radon levels have been found in
homes, schools and buildings throughout the U.S.

      Exposure to high radon levels is dangerous. The health hazard from radon arises
from inhaling its radioactive decay products. The Surgeon General has warned that
radon is the second leading cause of lung cancer in the U.S. today. For persons who
smoke, the health risk of inhaling radon is especially high.

      EPA has established procedures for testing homes, schools and buildings. These
testing procedures are described in various radon documents that are available from
EPA and KDHE. EPA has established an action level for indoor air radon levels of
4pCi/l (picocuries per liter). Nearly one out of every 15 homes in the U.S. is estimated
to have radon levels that exceed the action level.

      In 1988 Congress enacted the Indoor Radon Abatement Act (IRAA) with the
goal of reducing indoor radon levels to radon levels found in outside air. Among
other  provisions, IRAA provided funds for state governments to establish radon
programs and to assist local governments and communities in encouraging residents
to test for radon and mitigate elevated radon levels.  IRAA also required EPA to
develop a national description of radon levels in homes and schools throughout the
country. To date, 42 states  and seven Indian Nations, in conjunction with EPA, have
conducted radon residential surveys to characterize statewide radon distributions.
Additionally, about 1,200 schools were tested in the winter of 1991.

      IRAA also required EPA to develop a program to evaluate radon mitigation
contractors and radon measurement labs. In response, EPA established four regional
radon training centers to train radon professionals. EPA also developed a national
proficiency exam to test the knowledge of radon contractors. Contractors who pass the
exam are listed on the Radon Contractor Proficiency (RCP) list. EPA also established
the Radon Measurement Proficiency  (RMP) Program.  This  program  tests and
evaluates the accuracy of firms that supply radon test devices.  Those that pass the
program are included on the RMP list.
                                  -11-

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Does The Radon Program Apply To My Community?
     Local communities, in concert with the State, play a vital role in reducing the
public health risk of radon. It is very likely that there are homes, day care centers,
schools or commercial buildings in your community that have elevated indoor air
concentrations of radon.

     Currently, most radon-related policies are non-regulatory. EPA, the State and
local governments have focused their energies toward educating the public about the
health risk of radon and encouraging voluntary testing of homes and buildings. Some
states, however, have developed radon regulations, including certification of radon
professionals and mandatory testing of all public schools.  Additionally,  model
building codes for new constructionhave been developed that may be incorporated into
the building codes of local jurisdictions.  Finally, Congressional attention has been
directed toward required radon testing during real estate transactions that involve
federal agencies, such as FHA or HUD.

     Local governments can act to protect their residents from radon in several ways:
        1. Develop radon education and outreach programs,
       2. Adopt radon-resistant building codes for new construction, such as the
               model codes,
       3. Encourage voluntary testing in local communities,
       4. Ensure that local radon contractors are RCP-listed or state-certified, and
       5. Work in conjunction with KDHE's Radiation Control Section and
               community organizations, such as the American Lung Association
               of Kansas and County Extension Offices, to elevate local
               attention to this important health risk.
Additional Information
    Regional Contact:
     Radon Program
     Air and Toxics Division
     EPA Region 7
     726 Minnesota Ave.
     Kansas City,  KS  66101
     1-913-551-7020
State Contact:
 Radiation Control Section
 Bureau of Air & Radiation
 KDHE
 Forbes Field
 Topeka, KS 66620
 1-913-296-1560
     Radon Measurement Proficiency Program
     Research Technical Information Service
     Research Triangle Institute
     Research Triangle Park, NC  27709
     1-919-541-7131
                Radon Contractor Proficiency Program
                Midwest University Radon Consortium
                1985 Buford Ave.
                St. Paul, MN  55108
                1-612- 624-8747
                                   .12-

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CROSSJUIFD1APROGRAMS
                                                                 DD
PESTICIDES
        Few chemicals have had as much impact or been the subject of as much
 controversy in recent decades as pesticides. EPA has the authority to regulate
pesticides under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
and the Federal Food, Drug and Cosmetic Act. Under FIFRA, EPA has the
authority and responsibility for  regulating pesticide registration, production, sale,
distribution, and use. No pesticide may legally be sold or used in the United States
unless it has been registered by  EPA and bears an EPA registration number.  EPA
also has the authority to suspend or cancel the registration of a pesticide.

        All pesticides must have a label. The label includes instructions for use,
storage and disposal of containers. The label, together with any literature to which
it refers, has the force of law.

        The pesticide that stays in or on farm products or processed foods is called
a residue.  EPA regulates the safety of the food supply by setting limits for pesticide
residues on food and animal feed available for sale in the United States.

        Issues currently being dealt with in the pesticide program include
agricultural workers' and pesticide handlers' safety,  applicator certification and
training, state enforcement, pesticides in groundwater and endangered species.

        To address the safety of agricultural workers and pesticide handlers,  EPA
proposed new Worker Protection Standards in 1988.  These standards were
published as final regulations on August 13,1992. These standards, which were in
response to a significant number of pesticide poisonings occurring every year,
strengthened earlier protection provisions, reduced risks of exposure and extended
coverage to additional handlers.

        Currently there are about 100  active ingredients federally registered,
which are classified as restricted use. Pesticides containing these active ingredients
can only be applied by, or under the direct supervision of, a certified applicator.
Applicators must meet certain competency requirements to use restricted pesticides.
                                   -13-

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          Efforts are under way to strengthen state training programs, particularly
with respect to groundwater protection, worker protection and endangered species
protection. EPA has prepared a Pesticides in Groundwater Strategy to address risks of
groundwater contamination by pesticide chemicals. EPA is required under the En-
dangered Species Act, to protect listed species and their habitat from the effects of
pesticides. In 1989 EPA proposed an Endangered Species Protection Program to
accomplish this.

          In most states, state pesticide regulatory agencies have assumed respon-
sibility for pesticide enforcement under agreement with EPA.  In Kansas, the State
Board of Agriculture is the agency regulating pesticide sale and use. However,
KDHE regulates the disposal of pesticide waste.
    Additional Information

    U.S. EPA, FIFRA Amendments of 1988; Schedule of Implementation.
    54 Federal Register 18078 (April 26,1989).
    Regional  Contact:

    Toxics and Pesticides Branch
    Air and Toxics Division
    EPA Region 7
    726 Minnesota Ave.
    Kansas City,  KS 66101
    1-913-551-7020
State  Contacts:

Kansas State Board of Agriculture
901 Kansas Ave.
Topeka,KS 66612
1-913-296-2263
  (For information on application and
  certification)
                                        Bureau of Waste Management
                                        KDHE
                                        Forbes Field, Bldg 740
                                        Topeka,KS 66620
                                        1-913-296-1600
                                           (For information on disposal)
                                   -14-

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CROSS MEDIA PROGRAMS
 TOXICS - PCB'S
      The EPA was required by Congress under Section 6(e) of the Toxic
 Substances Control Act (TSCA) (Public Law 94-469, October 11,1976) to
 promulgate rules for the marking, storage and disposal of Polychlorinated
 Biphenyls (PCBs).

      Virtually every municipality and utility in the U.S. is, or has been,  in
 possession of regulated PCB equipment. Manufacturers inadvertently
 con laminated  about 12% of the mineral oil filled electrical equipment in
 use prior to 1976 by using the same pumps and lines to fill their premium PCB
 equipment and their mineral oil equipment.

      Dielectric fluid less than 50 part per million (ppm) PCBs is considered "Non-
 PCB," but disposal is regulated by some states. Fluid from 50-499 ppm is "PCB
 contaminated" and is regulated. Fluid at 500 ppm or greater is considered "PCB"
 and is highly regulated.

      EPA intends to allow use of contaminated and PCB equipment for the re-
 mainder of its useful life as long as the equipment is properly monitored and
 maintained.
     Additional Information
     PCB Regulations; 40 CFR, Part 761.

     Regional Contact:

     Toxic Substances Control Section
     Air and Toxics Division
     EPA Region 7
     726 Minnesota Ave.
     Kansas City, KS 66101
     1-913-551-7020


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AIR PROGRAM
CLEAN AIR ACT AMENDMENTS

Will The Clean Air Act Amendments Apply To My Community?
     The goal of the Clean Air Act Amendments is to reduce pollution by 56 billion
pounds a year.  This reduction will generally come from cutting emissions in large
urban areas. However, there may be some impacts on small communities. Implemen-
tation of the Act will require the regulation of small businesses in order to attain and
maintain the national air quality standards and control air toxic emissions.

     To be eligible for technical and environmental compliance assistance under the
Clean Air Act Amendments, a small business stationary source must meet the
following criteria:
        a.  Owned or operated by a person employing 100 or fewer individuals;
        b.  A small business under the Small Business Act;
        c.  Not a major stationary source;
        d.  Does not emit 50 tons per year or more of any regulated pollutant; and
        e.  Emits less than 75 tons per year of all regulated pollutants.

     These small businesses frequently lack the technical expertise and  financial
resources necessary to  evaluate state regulations and determine the appropriate
mechanisms for compliance. The Act provides for the design of a program to render
technical assistance and compliance information to small businesses.
Actions Your Community Should Be Taking
     With regard to those regulations affecting small businesses, the state will
designate a Small Business Ombudsman to represent small business to the appropriate
governmental organizations. Kansas will also implement a Small Business Assistance
Program.    This program will collect  and disseminate information  on
1) determining applicable requirements under the Act and permit issuance, 2) the rights
of small businesses under the Act, 3) compliance methods and acceptable control
technologies, 4) pollution prevention and accidental release/prevention/detection
and 5) audit programs.  In the event Kansas fails to appoint an Ombudsman or
implement a Small Business Assistance Program, EPA will assume those responsibili-
ties.

     A small   community should contact its state air pollution agency and the
Regional EPA Small Community Coordinator prior to addressing significant air
pollution issues.
                                 -16-

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  Additional Information
Regional Contact:

Air Program
Air and Toxics Division
EPA Region 7
726 Minnesota Ave.
Kansas City, KS  66101
1-913-551-7020

Small Community  Coordinator:
1-913-551-7005
State Contact:
Bureau of Air and Radiation
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-1570
Small Business Assistance Program
Office of Science & Support
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-6603
Clean Air Act Amendments
Title VIE- Miscellaneous Provisions
Sec. 810. Impact on small communities
                              -17-

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AIR PROGRAM
 Refrigerant Recycling and the Prohibition
 on Venting
     Under Section 608 of the Clean Air Act, EPA published proposed regulations
 on December 10,1992, that would:

     - Require service practices that maximize recycling of ozone-depleting com-
 pounds (chlorofluorocarbons [CFCs] and hydro-chlorofluorocarbons [HCFCs])
 during the servicing and disposal of air conditioning and refrigeration equipment

     - Set certification requirements for reclaimers and for recovery and recycling
 equipment.

     - Establish safe disposal requirements to ensure removal of refrigerants from
 goods that enter the waste stream with the charge intact (e.g., motor vehicle and
 room air conditioners and home refrigerators).

     Effective July 1,1992, section 608 of the Act prohibits individuals from
 knowingly venting ozone-depleting compounds used as refrigerants into the
 atmosphere. Only three types of releases are permitted under the prohibition:

     - Minute quantities of refrigerant released hi the course of making good faith
 efforts to recapture and recycle or safely dispose of refrigerant.

     - Refrigerant emitted in the course of normal operation of air conditioning and
 refrigeration equipment such as from leaks and mechanical purging.

     - Mixtures of nitrogen and R-22 that are used as holding charges or as leak test
 gases because in these cases, the ozone-depleting compound is not used as a
 refrigerant.

 Use of Approved  Equipment
     Technicians repairing or servicing motor vehicle air conditioners must use
 either refrigerant recover/recycle or recover-only equipment approved by EPA.
 Most certified equipment will be labeled as "design-certified to SAE standards."
 A list of both types of approved equipment is available from EPA at the address at
 the end of this  section.
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Technician Training and Certification
      Technicians who repair or service motor vehicle air conditioners must be
trained and certified by an EPA-approved organization. Training programs must
cover the use of recycling equipment in compliance with the Society of Automotive
Engineers (SAE) Standard J-1989, the regulatory requirements, the importance of
refrigerant containment, and the effects of ozone depletion.  A list of approved
testing programs is available from EPA at the address at the end of this section.

Safe Disposal Requirements
      Under EPA's proposal, equipment that is typically dismantled on site before
disposal (e.g. retail food refrigeration) would have to have the refrigerant removed
and recovered in accordance with EPA's requirements for servicing. However,
equipment that typically enters the waste stream with the charge intact (e.g. motor
and room air conditioners) would be subject to special safe disposal requirements.
Under these requirements, the final person in the disposal chain would be respon-
sible for ensuring that refrigerant is recovered from equipment before the final
disposal of the equipment.

Hazardous Waste Disposal
      If refrigerants are recycled or reclaimed, they are not considered hazardous
under federal law. In addition, used oils contaminated with CFCs are not hazardous
on the condition that:
      -They are not mixed with other waste.
      -They are subjected to CFC recycling or reclamation.
      -They are not mixed with used oils from other sources.
Used oils that contain CFCs after the CFC reclamation procedure are, however,
subject to specification limits for used oil fuels if these oils are destined for burning.
Individuals with questions regarding the proper handling of these materials should
contact EPA's RCRA Hotline at 1-800-424-9346.
Additional Information:

Radiation and Indoor Air Section
Air and Toxics Division
EPA Region?
726 Minnesota Ave.
Kansas City, KS 66101
1-913-551-7020
1-800-223-0425

For information concerning regulations related to stratospheric ozone protection,
 please call:
       Stratospheric Ozone Hotline: 1- 800-296-1996
       (10am-4pm EST, M-F, except federal holidays)
                                   -19-

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    LAND PROGRAMS
    SUPERFUND PROGRAM
     As the 1970's came to a close, a series of stories gave Americans a look at the
dangers of dumping industrial and urban wastes on the land. First there was New York's
Love Canal. Hazardous waste buried for  25 years contaminated streams and soil, and
endangered the health of nearby residents, who had to be evacuated. The dioxin-tainted
land and water in Times Beach, Missouri also attracted attention.
     It became increasingly clear that there were large numbers of serious hazardous
waste problems that were falling through the cracks of existing environmental laws. The
magnitude of these emerging problems moved Congress to enact the Comprehensive
Environmental Response, Compensation and Liability Act  in 1980.  CERCLA —
commonly known as Superfund ~ was established to deal with the dangers posed by
the Nation's hazardous waste sites.
     Since the program began, hazardous waste has surfaced as a major environmental
concern in every part of the United States. It wasn't just the land that was contaminated
by past disposal practices, chemicals in the soil were spreading into the groundwater and
into streams, lakes and wetlands. Toxic vapors contaminated the air at some sites, while
improperly disposed or stored wastes threatened the health or environmental resources
of the surrounding community.
     Few realized the size of the problem until EPA began the process of site discovery
and evaluation. Thousands of potential sites existed.   Congress directed EPA to set
priorities and establish a list of sites to target. The sites on the National Priority List
(NPL), almost 1,300 in number, are the most complex and compelling cases of the
entire inventory of potential hazardous waste sites.
     Superfund responds immediately to sites posing imminent threats to human health
and the environment at both NPL sites and sites not on the NPL. The purpose is to
stabilize, prevent, or temper the effects of a release of hazardous substances, or the threat
of one, into the environment. Imminent threats might include tire fires or transportation
accidents involving the spill of hazardous chemicals.
     The ultimate goal for a site on the NPL is a permanent solution; this requires a
long-term effort.  Nearly 1,800 Superfund sites have been cleaned up, including 112
on the NPL.
     Superfund activities depend upon local citizen participation. TheEPA'sjobis to
analyze the hazards and to deploy experts, but the Agency needs citizen input. EPA
encourages citizens to get involved  in  cleanup decisions because people in the
community where a site is located will be those most directly affected by the wastes and
cleanup processes.
     Additional Information
        Superfund Program
        Waste Management Division
        EPA Region 7
        726 Minnesota Ave.
        Kansas City.KS  66101               1-913-551-7052
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LAND PROGRAMS
RCRA HAZARDOUS WASTE

     Hazardous waste is prevalent throughout all levels of commerce and industry.
Wastes are identified as hazardous if they pose a potential danger to human health and/
or the environment when not properly  treated, stored,  transported, disposed or
otherwise managed. Potential dangers include explosions, fires, corrosive destruction
of materials, chemical reactions and/or health impairing exposure to toxic chemicals.
The greater the quantity or concentration of chemicals exhibiting any of these dangers,
the greater the need to assure their proper management.

     In 1976, Congress enacted the Resource Conservation and Recovery Act
(RCRA) as the primary regulatory vehicle to assure that hazardous waste is properly
managed from the point of its generation  to its ultimate disposal or destruction, i.e.,
"from cradle to grave." RCRA establishes a very complex and comprehensive set of
requirements to define which hazardous waste is subject to regulation as well as the
responsibilities of anyone who generates, transports, stores, treats, disposes or other-
wise manages hazardous waste. At this time, waste generated by individual  house-
holds is not subject to federal RCRA requirements, even  if it exhibits some of the
dangers described above.

     There are three categories of hazardous waste generators in Kansas:

     EPA  Generator - any person who generates 1,000 kilograms (kg)
     or more of hazardous waste in a calendar month or who accumulates quantities
     greater than 1,000 kg at any time. An EPA generator also includes any person
     who generates one kilogram or more of acutely hazardous waste in a calendar
     month or who accumulates quantities greater than one kilogram of acutely
     hazardous waste at any time (A kilogram is approximately 2.2 pounds and 1,000
     kg is approximately five, 55 gallon drums of material.).

     Kansas Generator - any person who generates a minimum of 25 kg
     but less than 1,000 kg of hazardous waste in a calendar month, and who does
     not accumulate quantities greater than 1,000 kg at any time.

     Small Quantity  Generator - any person who generates less than 25 kg
     of hazardous waste in a calendar month, and who does not accumulate quantities
     greater than 1,000 kg at any time. A small quantity generator also includes any
     person who generates less than one kilogram of acutely hazardous waste in a
     calendar month,  or who does not accumulate quantities greater than one kilo-
     gram of acutely hazardous waste at any time.
                                  -21-

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Does The RCRA Program Apply To My Community?
     It is very likely that some types of hazardous waste are generated by businesses
in your community or by your municipal facility operations themselves.  Because
hazardous waste includes things like solvents, corrosives and materials containing
heavy metals like chromium, cadmium and lead,many types of small businesses such
as vehicle maintenance shops and dry cleaners may generate hazardous waste. Any
discarded material must be evaluated to determine if it has been listed by EPA as
hazardous waste or if the waste exhibits  any of the  following characteristics:
ignitablity, corrosivity, reactivity or toxicity as determined by the Toxicity Charac-
teristic Leaching Procedure (TCLP) test.

     In addition to used materials which might be considered hazardous waste,
communities must also be careful as to how products that are no longer wanted or
needed are discarded.   Discards like leftover pesticides from grounds-keeping
operations and old paint thinner must be fully evaluated before disposal decisions are
made.  EPA has identified several hundred chemical products which, if disposed of,
would also be considered "listed hazardous waste."

     Another area of possible concern for your community is the operation of a solid
waste collection system and/or a landfill. Although household wastes are exempt
from hazardous waste regulation, such wastes are regulated under a program referred
to as the "Subtitle D Municipal Solid Waste Landfill Criteria" which is intended to
insure  proper management of  all non-hazardous solid wastes.   The fact that
commercial waste materials are collected and/or co-disposed with the household
materials might trigger RCRA jurisdiction over an entire facility where hazardous
wastes are identified.

Timetable
     RCRA regulations were first published in  1980 and are constantly being
amended. If you determine that you are a generator or handler of hazardous waste,
you must notify KDHE of your activity and receive an EPA identification number.

     Different timetables  and  responsibilities apply to the different activities.
Generators may accumulate waste on-site for  up  to 90 days without triggering a
requirement to obtain a storage permit. Other storage periods may apply depending
on the amount of hazardous waste  generated in any given  month.  For more
information, contact the departments listed at the end of this section.

     Securing a permit authorizing the treatment, storage or disposal  of hazardous
waste is a very expensive and lengthy process.
                                   .22-

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       In Kansas, KDHE administers the federal RCRA hazardous waste program.
State laws and rules may differ from the federal requirements. For example, anyone
who generates over 25 kg  (about 55 pounds) of hazardous waste per month, or
accumulates over 1,000 kg of hazardous waste at any time, is required to notify
KDHE . Generators of hazardous waste also may be subject to certain fees.
        Many companies and communities look for ways to reduce the amount of
hazardous waste produced in order to reduce expense and regulatory burdens. Waste
reduction can be accomplished through better housekeeping, careful purchasing,
changes in process and a variety of other ways. Hazardous waste generators should
examine their waste streams and consider whether there might be a way to reduce what
is being generated.
      Additional Information:


       Regional Contact:

       RCRA Branch
       Waste Management Division
       EPA Region 7
       726 Minnesota Ave.
       Kansas City, KS   66101
       1-913-551-7051
State Contact:

Hazardous Waste Section
Bureau of Waste Management
KDHE
Forbes Field, Bldg 740
Topeka,KS  66620-0001
1-913-296-1600
    RCRA Regulations 40 CFR Pans 260-272

    RCRA Hotline  1-800-424-9346
                                  -23-

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LAND PROGRAMS
SUBTITLE D MUNICIPAL SOLID WASTE
LANDFILL CRITERIA
     Municipal Solid Waste is a non-hazardous waste generated at residences,
commercial and industrial establishments and institutions. Municipal solid wastes
include durable goods (appliances, furniture, etc.), nondurable goods (newspapers,
clothing, etc.), containers and packaging (boxes, bottles, etc.), food and yard wastes
and miscellaneous inorganic wastes (stones, pieces of concrete, etc.).

     The Municipal Solid Waste Landfill Criteria (MSWLFC) were published on
October 9,1991 in the Federal Register, and will go into effect October 9,1993. The
purpose of the Criteria is to set minimum national performance standards which will
protect human health and the environment. The MSWLFC set location restrictions,
operating criteria, design criteria, groundwater monitoring and corrective action
standards, closure and post closure requirements  and financial assurance require-
ments.  In Kansas, KDHE's Bureau of Waste Management regulates landfills and
implements the MSWLFC.

        Do The MSWLFC Apply To My Community?
     The MSWLFC apply to all new, existing, and lateral expansions to municipal
solid waste landfills which receive waste on or after October 9,1993. In July, 1993, the
EPA proposed to extend the effective date of this rule to April 9,1994 for all landfills
receiving less than 100 tons of solid waste per day (daily average). EPA also proposed
to extend the effective date for all small landfills (receiving less than  20 tons of
municipal solid waste daily - annual  average basis) until October 9, 1995, if the
landfills are located in areas that annually receive less than 25 inches of precipitation.
On that date, all landfill standards become applicable except the design standards. If
groundwater contamination is ever discovered at the site, the design standards also
become applicable and the owner/operator must notify KDHE of such findings.

        Action Your Community Should Be Taking
      All counties with a landfill, must be prepared to either not accept waste, or
upgrade to meet the Criteria by the applicable deadline, either October 9,1993; April
9,1994 or October 9,1995.  Those counties without a landfill should be prepared to
pay more for disposal as these deadlines are reached.  All counties should also plan and
implement solid waste management and disposal options, such as composting of tree
and yard waste, and establishing recycling programs and household hazardous waste
(HHW) collection sites.
                                  .24-

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     Solid Waste Grant Programs

        KDHE has developed three grant programs to assist counties in dealing with
municipal solid waste issues. The first is the solid waste planning grant program which
will pay up to 50% of the cost of developing a single county solid waste management
plan, and up to 90% of the cost of a regional, multi-county plan.  These plans are
mandated by state statute. Funding for the program comes from a $ 1.50/ton surcharge
on municipal solid waste disposal.

        The second program is the waste tire management grant program which is
funded with a $.50 per tire excise tax on the sale of new tires at the retail level. The
program is designed to eliminate existing problems of dumping and stockpiling waste
tires by creating a statewide effort of local  and regional public entities and private
enterprise to manage the ongoing reduction and control of waste tires. The program is
divided into base program grants and abatement (clean up) grants. Base grant monies
are allocated annually,  in part, based upon total funds available in the Waste Tire
Fund. All Kansas counties, cities or multi-county regional entities are eligible for
base program grant funds.  Abatement  funds are limited and are available on  a
competitive basis.

        The third program awards grants to local governments desiring to conduct
household hazardous waste (HHW) collection programs. The state provides up to 50%
of the cost of a local program matched by a local government or a group of local
government units using in-kind and financial support.  Grants are awarded on  a
competitive basis after  an application  and screening process. The purpose of the
program is to provide for the safe disposal of small quantities of hazardous waste in the
hands of householders and farmers; to educate the public about the dangers posed by
HHW; and, to encourage local units of governments to develop local HHW collection
programs either individually or jointly.
     Additional Information
     Regional Contact:

     Solid Waste Program
     Waste Management Division
     EPA Region 7
     726 Minnesota Ave.
     Kansas City, KS  66101
     1-913-551-7051
State Contact:

Solid Waste Section
Bureau of Waste Management
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-1600
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LAND PROGRAMS
UNDERGROUND STORAGE TANKS

     Federal regulations, which establish requirements for underground storage tanks
(UST) storing petroleum and hazardous chemicals, were developed by  EPA and
became effective December 23,1988.

     Regulated tanks include storage tanks containing petroleum or other regulated
substances in which 10 % or more of the volume, including the pipes, is below the
surface of the ground.  Following are several types of tanks which are exempt from
UST regulations:

     -Farm and residential tanks of 1,100 gallons or less
     -Single family residence heating oil storage tanks
     -Septic tanks
     -Wastewater treatment tanks (flow-through process tanks) regulated under the
      Clean Water Act
     -Tanks with a capacity of 110 gallons or less
     -Tanks above the floor of an underground area (abasement, tunnel or vault), such
      that the tank can be visually inspected on all sides.

     No company, firm or individual may install, remove, modify  or test a UST
without first obtaining a license to do so. To become a licensed UST contractor, an
application must  be submitted to KDHE with the applicable fees  and proof of
insurance. After June 1,1991, no person shall place a regulated substance (including
petroleum) in a regulated UST, unless a valid permit is openly displayed at the facility.
KDHE will issue permits to UST owners who have satisfied the regulations which
apply to their tanks.  Tank owners must register their  tanks with KDHE and pay
annual registration fees.  Placing fuel in an unpermitted UST can result in a fine.

     What Are The Leak Detection Requirements?

     Release detection for tanks is required based on the tank age, as the schedule
below indicates:
                                                     Compliance Date
     Tanks installed through 1979 or an unknown date       Dec. 23,1992
     Tanks installed during 1980 through 1988              Dec. 23,1993

     Release detection for all pressurized lines has been required since December 23,
1990. Release detection for buried lines can be accomplished by performing annual
line testing or by installing monthly line monitoring equipment. In addition to release
detection, a flow restrictor, continuous alarm or an automatic shut off must be present
which will detect a release of three gallons per hour from a pressurized line.  Release
                                  -26-

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detection for a conventional suction line is required at the same time as the tank the
line services.  If tightness testing is selected as a method of release detection for
suction lines, the test must be performed once every three years after compliance is
required.  Release detection is not required for safe suction lines, which contain
only one check valve immediately below the suction pump with the piping sloping
toward the tank.
                        Release Detection Methods
Release detection requirements can be met by a number of methods, some of which
are listed below.  Prior to the installation of release detection equipment, an
application must be submitted to and approved by KDHE.
 Annual tightness testing
Automatic tank gauging
Soil vapor monitoring method
Groundwater monitoring method
Manual tank gauging
Must be capable of detecting a release of
0.1 gallons/hr from any portion of the tank/line
that routinely contains product. If used,
required annually for tanks & pressurized lines.

Must be capable of detecting a release of
0.2 gallons/hr from any portion of the tank
which routinely contains product and must pro-
vide inventory control. This method is only
acceptable for tank testing, not lines.

Only useful at sites where soil/backfill material
are sufficiently porous, and the stored material
is volatile enough to produce a vapor level
detectable by the monitoring device. Another
method should be used if the monitoring device
will be adversely affected by moisture or back-
ground contamination.

Groundwater must intersect the tank excavation
and the backfill material must have a hydraulic
 conductivity of not less than 0.01 cm/sec.

Approved only for tanks of 1,000 gallons or
less. This method involves two consecutive
tank stickings both before and after a 36-54 hr
rest period each week.
Additional Requirements:
        Inventory control must be performed for all tanks which store or dispense
                                    -27-

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product. Inventory control must be performed every operating day for all UST
systems which store and dispense fuel.  If no fuel is dispensed from a tank on a
regular basis, the inventory must be performed and reconciled a minimum of once
a month.

      All existing tanks and metallic product lines must have corrosion protection
by December 23,1998 if they are to remain in use.  Owners may elect to upgrade
existing UST systems or replace old unprotected metal systems before the com-
pliance date. Fiberglass tanks and lines are non-corrosive materials and do not re-
quire corrosion protection.

      By December 23,1998, all tanks must be equipped with spill and overfill
protection if more than 25 gallons of product are deposited into the tank at one time.

      An environmental site assessment is required for any UST to be permanently
closed. KDHE must be notified before a UST can be removed or abandoned in
place.  If abandoned in place, the owner must hire an environmental professional
to perform the site assessment prior to abandonment.  On.ce  KDHE has
evaluated the site assessment and approved the closure, the tank may be filled with
an inert solid material such as sand.  If contamination  exceeding KDHE standards
is discovered at any closure site, remedial action will be required.

      All releases from UST systems  and associated piping must be reported to
KDHE immediately after discovery. Above ground releases of petroleum must be
reported if water or soil pollution is caused or threatened.

What Are My Financial Responsibilities?

      The deadline for owners of USTs to meet financial responsibility require-
ments was October 26,1991. The Petroleum Storage Tank Release Trust Fund was
created during the 1989 Kansas legislative session to provide pollution liability
coverage for tank owners who had no other means of meeting these federal
requirements. Coverage for third party claims for personal injury and property
damage, as  required by law, are not addressed by the Trust Fund. Third party
liability coverage, in compliance with the Kansas Storage Tank Act, can be arranged
through your current insurance  agent.  Your agent should contact the Servicing
Carrier through its representative, Woodsmall Risk Services, at 1-800-325-9154.
An average fee of $300/tank will be  required for tank owners to participate in this
program.
                                   -28-

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Additional Information:

Regional Contact:

UST Program
Waste Management Division
EPA Region 7
726 Minnesota Ave.
Kansas City, KS 66101
1-913-551-7051

 State Contact:

 UST Program
 Storage Tank Section
 Bureau of Envkonmental Remediation
 KDHE
 Forbes Field, Bldg 740
 Topeka,KS 66620-0001

    State Trust Fund:               1-913-296-0668

    New Installations/Releases                -1685

    Compliance & Federal
      Financial Responsibility                -1677

    Tightness Testing/Contractor
       Licensing                            -1598

    Ownership Charges, Registration
      Fees, Abandonment                    -1599

    Tank Closures, Leaks, Removals
      Site Assessments                      -1684
                               -29-

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   LAND PROGRAMS
  ABOVE GROUND STORAGE TANKS
      Above ground storage tanks are those in which greater than 90% of the tank
volume, including volume of the piping, is not below the surface of the ground.
Any storage tank situated in an underground area, such as a basement, cellar, drift,
shaft or tunnel is included, if the storage tank is situated upon or above the surface
of the floor (KS A 65-34,102 et seq.).  The Kansas Legislature has directed KDHE
to adopt regulations concerning above ground storage tanks (ASTs) to accomplish
the following:

      -Register all ASTs which fall under the meaning of the Storage Tank Act.  A
fee will be established and collected by KDHE as part of the registration process.

      -Establish and operate AST Trust Fund, to provide reimbursement for tank
owners who have spills or leaks from ASTs, and who expend money to remediate
contamination that results from the spills or leaks.

      -Adopt and  enforce performance standards for prevention of spills or leaks
from ASTs. These performance standards will be the same as Federal standards
when adopted.

       Although none of these regulations are in place, tank owners who are
otherwise qualified for protection under the AST Trust Fund may obtain access to
the Trust Fund by voluntarily registering their tanks with  KDHE. No fee will be
required to register until the regulations become effective.

Will The AST Regulations Apply To All Above Ground Tanks?

      No, there are several exemptions to the regulations. Tanks which will not be
regulated by KDHE include:

      -Any tanks associated with crude oil production, pipelines or refining

      -Small tanks, with capacities of less than 660 gallons

      -Noncommercial fuel tanks, such as those used for farm/ranch purposes,
      which are less than 1,100 gallons in capacity, or any tank which is used to
      store heating oil for a single family residence.
                                 -30-

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      In addition, tanks containing "regulated substances" will be regulated, but
will not be afforded protection for spill and leak cleanups under the Trust Fund.
These tanks will need to be registered, and will be required to meet prevention
measures for spill and leak protection.  Regulated substances are petroleum or any
element, compound, mixture, solution or substance defined in section 101 (14) of
CERCLA, as in effect on January 1,1989, but not if regulated as a hazardous waste
under RCRA (42 U.S.C. Sections 6921 through 6939b), as in effect on January 1,
1989 (Kansas House Bill 3153).

If the ASTs are subject to the Storage Tank Act, what must the
owner/operator do?

      - Register the tanks. Registration can be accomplished by completing the
       one-page form, "Above Ground Storage Tank System Registration,"
       available from KDHE.

      - Report spills or leaks. Kansas Law requires that spills or leaks of hazardous
       substances be reported to the State within 24 hours. Spills or leaks of
       flammable or explosive materials should also be reported to the local fire
       department.

What Other Requirements Govern ASTs?

      New or relocated tank installations must be approved in advance by the State
Fire Marshall's office and must meet requirements of the State fire code.
Additional Information:
      Above Ground Storage Tank Section
      Bureau of Environmental Remediation
      KDHE
      Forbes Field, Bldg 740
      Topeka,KS 66620-0001
      1-913-296-6242
                                  -31-

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WATER PROGRAMS
KANSAS WATER PLAN

       The Kansas Water Plan is a broad-based plan put together by the Kansas
Water Office to manage all water in the State of Kansas. This management includes
purchasing storage space in reservoirs throughout the State under a Memorandum of
Understanding (MOU) between the U.S. Department of the Army and the State of
Kansas. Water is stored for a variety of purposes, including municipal and industrial
water supply, irrigation, recreation and environmental uses.  Under the present plan,
storage of water in the state is jointly controlled by the State and the U.S. Army
Corps of Engineers.

       In addition to planning for an adequate quantity of water, the plan also
addresses the quality of water in the State. Provisions are made in five river basins
throughout the State for matching the quality of water to the use for which it is
intended.  Plans for improving water quality and assuring there is adequate water
are set forth with suggested legislative and administrative actions. Financial
requirements and  suggested time schedules are also addressed in the plan.

       The Kansas Water Plan fund has an annual revenue of approximately
$16 million. This  money comes from fees for municipal, stock watering and
industrial use.  The state imposes a fee of three cents per 1,000 gallons of water sold
at retail by a public water supply system and delivered through mains, lines or
pipes.  The same rate is charged for water appropriated for industrial use or stock
watering pursuant  to a permit granted in accordance with the Kansas Water
Appropriation Act. The State also collects $1.40 for every ton of fertilizer sold and
$100 for every pesticide registered in Kansas. Various state agencies who regulate
water use depend upon this fund for funding.
                                  -32-

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WATER PROGRAMS
WATER AND WETLANDS PROTECTION

     EPA, in partnership with state and local governments, is responsible for restoring
and maintaining the chemical, physical and biological integrity of the nation's waters.
Because of the value of wetlands as an integral part of those waters, EPA is also charged
with protecting wetland resources. The major federal  regulatory  tool for this is
Section 404 of the Clean Water Act, which is jointly administered by the U.S. Army
Corps of Engineers andEPA. Section 404 establishes a permit program to regulate the
discharge of dredged or fill material into waters of the U.S., including most wetlands.
Failure to obtain a permit or to comply with the terms of a permit can result in civil
and/or criminal penalties. The U.S. Fish and Wildlife Service has an important advisory
role in the permit review process.

     Waters of the U.S. include lakes, streams,  rivers, wetlands and coastal waters.
Wetlands are areas which are saturated or flooded for varying periods of time during
the growing season.  Because of the presence of water, there is a prevalence of aquatic
or hydrophytic vegetation, such as that found in  swamps, marshes, bogs and similar
areas.  Besides providing fish and wildlife habitat, wetlands also improve water
quality by acting as filters, offering flood protection, buffering shorelines against
erosion and providing areas for recreation.
     Additional  Information:

       Regional Contact:

       Wetlands Program
       Office of Planning and Management
       EPA Region 7
       726 Minnesota Ave.
       Kansas City, KS  66101
       1-913-551-7042
 State Contact:

Office of Science and Support
     1-913-296-5565
Bureau of Water
     1-913-296-5500
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
                                  -33-

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Additional Information

The Clean Water Act (33 U.S.C 1251 to 1387)

National Environmental Policy Act (42 U.S.C. 4321 to 4370c)

Fish and Wildlife Coordination Act (16 U.S.C. 742a to 742m)

River and Harbor Act of 1899 (33 U.S.C. 403,406,407, and 411)

The Endangered Species Act  (16 U.S.C. 1531 to 1544)

Regulations of the U.S. Army Corps of Engineers (33 C.F.R. 320-330).

Regulations of the U.S. Environmental Protection Agency
   (40 C.F.R. 230, also known as the 404 (b) (1) guidelines).

Executive Order 11990 (May 24,1977) 3 C.F.R.,  1977 Comp. pp. 121-123.

The Wetlands Protection Hotline:
  1-800-832-7828  9-5:30 (EST) M-F, excluding Federal holidays.
                               -34-

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WATER PROGRAMS
 DRINKING WATER
       The following pages describe requirements under the Safe Drinking Water
 ACL Kansas has a number of unique requirements for drinking water. For purposes
 of understanding the Federal and State requirements, please note the following
 definitions of system types:
       Public Water Supply System (PWS) - System for delivery to the public of
               piped water for human consumption that has at least 10 service
               connections (15 connections for Federal requirements) or regularly
               serves at least 25 individuals daily at least 60 days out of the year.
               This term includes any source, treatment, storage or distribution
               facilities used in connection with the system.
       Community Water Supply System (CWS)- System which has at least 10
               service connections (15 connections for Federal requirements) used
               by year-round residents or that regularly serves 25 year-round
                residents.
       Non-community Water Supply System - System which is not a community
               system.
       Non-transient, Non-community Water Supply System (NTNC)- System that
               is not a community system and that regularly serves at least 25 of
               the same persons at least six months per year.

       - All public water supplies shall be operated, maintained and supervised by
       certified personnel.  Requirements for Kansas operators are described in the
       State regulations, KAR 28-16-30 thru 36.

       - Records of all laboratory tests, chlorine residuals, turbidity  determinations,
 copies of written communication relating to sanitary surveys, or efforts to correct a
 violation of these regulations, shall be kept on file for 12 years. These records shall
 be readily  available in a convenient location for an inspection by the Secretary of
 KDHE, or an authorized representative.
       - All community systems and high-risk, non-community systems, as
 designated by KDHE, shall immediately notify the Department and  responsible local
 officials of a situation with the water service including major breakdown or serious
 loss of water service  which presents or may present an imminent and substantial
 endangerment of health.
       - All community water systems shall prepare an emergency operations plan
 to safeguard the water supply for the protection of the public if natural or manmade
 disasters occur. Emergency operations plans shall be submitted to KDHE for review
 and approval. A model copy is available from KDHE.
       - Newly constructed or repaired water mains and finished water storage
 facilities shall be flushed and disinfected before use in accordance with methods
 acceptable to KDHE.
                                   -35-

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       - All community water systems shall be operated and maintained to provide a
minimum of 20 psi pressure throughout the distribution system except under
extraordinary conditions such as unusual peak fire flow demand or major distribu-
tion system breaks.
       - All community water systems and high risk, non-community systems
designated by KDHE shall have a regular program, approved by the Department, for
the detection and elimination of cross-connections and prevention of backflow and
backsiphonage.
       - All finished water reservoirs shall be covered by a permanent material and
shall be adequately vented and screened.
       - Treatment chemicals and protective coatings exposed to water intended for
public consumption shall be used only if approved by KDHE.

 Permit Requirements For Public Water Supply Systems
        All public water supplies are required to have a permit issued by the
KDHE Secretary.  An application for a PWS permit shall be submitted for review
and approval before the use of the source of supply  and construction of
new wells, pumping stations, finished water storage or water treatment plants.
KDHE also requires plans and specifications for all new water mains. An applicant
for a permit must include a complete permit application, along with plans and
specifications.

        Additional Information:

       - The Safe Drinking Water Act.
        Kansas Enabling Legislation, KSA 65-162a et seq.

       - National Primary Drinking Water Regulations, 40 CFR Part 141.
         Kansas Regulations, KAR 28-15-11 thru 21.

       - National Secondary Drinking Water Regulations, 40 CFR Part 143.

       - The Safe Drinking Water Hotline:  1-800-426-4791  9-5:30 (EST) M-F,
              excluding Federal Holidays.

     For questions about the drinking water requirements for communities, please use
the following contacts.
     Regional  Contact:                State Contact:
     Drinking Water Program
     Water Management Division
     EPA Region 7
     726 Minnesota Ave.
     Kansas City, KS 66101
     1-913-551-7032
Public Water Supply Section
Bureau of Water
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-5514
                                  -36-

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 WATER PROGRAMS	46

 Kansas Health and Environmental Laboratory

      Each year, the Kansas Health and Environment Laboratory provides
 200,000 chemical and biological analyses to ensure the safety of 2,500 public
 water supplies in Kansas. Four specific laboratory programs are dedicated to
 detecting different hazardous substances.

      The Radiation Chemistry Laboratory analyzes water samples to detect and
 quantify radioisotopes in water. Radioisotopes are chemical elements that can
 cause adverse health effects. Uranium in geological deposits found primarily in
 western Kansas can be a problem for some water supplies.

      The Organic Chemistry Laboratory conducts analyses for the detection and
 quantification of trace levels of pesticides, herbicides and other toxic organic com-
 pounds. These analyses are particularly difficult and labor intensive because of the
 part per billion working range required by federal regulations and because there are
 at least two million different organic compounds in the environment.

      The Inorganic Chemistry Laboratory performs as many as 26 different
 analyses for detection of toxic heavy metals, plant nutrients  and other chemicals in
 samples from public drinking waters.

      The Environmental Microbiology Laboratory tests water supplies for
 coliform indicators of fecal pollution to avoid waterborne outbreaks of infectious
 diseases.
For additional information (including price lists), please contact:

      Director, Health and Environment Laboratory:       (913) 296-1620

      Radiation Chemistry Laboratory                          -1629

      Inorganic Chemistry Laboratory                          -1654

      Organic  Chemistry Laboratory                            -1647

      Environmental Microbiology Laboratory                   -165 8
                                  -37-

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WATER PROGRAMS
DRINKING WATER


INORGANIC CHEMICALS
 Inorganic Chemicals (lOCs) are elements or compounds found in water supplies and
may be natural in the geology or caused by activities of man through mining, industry
or agriculture. It is common to have trace amounts of many lOCs in water supplies.
Amounts above the Maximum Contaminant Levels (MCLs) may cause a variety of
damaging effects to the liver, kidney, nervous system, circulatory system, blood,
gastrointestinal system, bones or skin depending upon the IOC and level of exposure.
Some lOCs are more damaging to infants and pregnant women.  Because of some
special aspects of the rules for asbestos, lead and fluoride, separate pages are prepared
for them in this booklet.

Do The IOC Regulations Apply To My Community?
     Yes, prior to the 1986 Safe Drinking Water Act, there were 12 regulated lOCs.
Additional lOCs have been added with the Phase n and Phase V regulations, which are
described in the following paragraphs.

Timetable  (For Revisions To Regulations)
     New regulations called Phase n were finalized January 30,1991, and became
effective on July 30, 1992.  They added two new lOCs, asbestos and nitrite, and
changed the MCLs for four of the current lOCs. Silver was deleted as a primary MCL.
As a result of this regulation NTNC  PWSs will be required to test for lOCs, and all
PWSs (both community and non-community) will be required to test for nitrate and
nitrite at least annually.

     PWSs will continue to take IOC samples as they have in the past until January
1, 1993. A new monitoring framework was proposed for this rule to standardize
monitoring for all the new regulations.  The standardized monitoring framework
(SMF) is comprised of a nine-year cycle, called a compliance cycle, and  three-year
periods, called compliance periods. For example, a groundwater PWS would have to
test for lOCs sometime in the first compliance period (January 1,1993 - December 31,
1995).
                                -38-

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     Additional new regulations called Phase V were finalized on July 17,1992, and
added six new lOCs. These rules will become effective January 17, 1994. Public
water supply systems with 150 or more service connections are required to begin
monitoring for the Phase V contaminants in the January 1,1993 through December 31,
1995 time period.

     EPA may be expected to add an IOC to the regulated list and may change some
MCLs of lOCs as new research clarifies levels of contamination considered hazardous.
(Most lOCs are tested from the same sample, requiring no additional work and little
additional cost for the community).

     New sampling requirements for nitrates will be quarterly for surface water
supplies and annually for groundwater supplies. These frequencies may be reduced or
increased by the State based upon the levels of nitrate found.  The new sampling
requirements begin January 1,1993.  Therefore, PWSs can expect to sample at least
annually.

MCLs
     The following page lists the MCLs for lOCs.

If You Exceed Any Of The MCLs
     -Test Quarterly

     -Notify the State  and complete Public Notices as required.

     -Work with the State and/or your engineer to determine the best way to
     reduce the level of the contaminants in your water supply. Consider a variety
     of options. In addition to a new treatment process, you may need to consider
     improving your present treatment process, mix your contaminated supply
     with another supply that does not exceed the MCL or obtain a new
     source of water.

     -Request an exemption from the State to allow the community to continue
     to use the water supply while the solutions to the MCL violation are being
     explored and any needed financing is being planned.
Additional Information

     The rules for lOCs are contained in 40 CFR 141.23 and 141.62.
                                   -39-

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            Maximum Contaminant Levels for IOC's
Contaminants
  MCL (Pre-1986 and Phase
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Nitrate
Fluoride
Asbestos

Nitrite (As N)
0.05 mg/1
2 mg/1
0.005 mg/1
0.1 mg/1
refer to section on lead and copper
0.002 mg/1
0.05 mg/1
10 mg/1
4 mg/1
7 million fibers/1 (>10micrometers in
                      length)
lmg/1
Combined Nitrate & Nitrite  10 mg/1
Antimony
Beryllium
Nickel
Sulfate
Thallium
Cyanide

MCL: Phase V
Effective January 17, 1994
0.006 mg/1
0.004 mg/1
0.1 mg/1
deferred
0.002 mg/1
0.2 mg/1
                            -40-

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WATER PROGRAMS
DRINKING WATER

ASBESTOS
     Asbestos is an inorganic chemical that occurs naturally and has been used in the
manufacture of a number of products used in the  construction industry. Inhaled
asbestos fibers have been identified as causing cancer.  Asbestos fibers ingested
through drinking water are suspected as a cancer causing agent Asbestos occurs
naturally in a few water supplies and may occur by a corrosive action on asbestos
cement (AC) pipe contained in a water system.

Do The Asbestos Regulations Apply To My Community?
     Yes, if you are a community or non-transient non-community (NTNC) public
water supply, the asbestos regulations apply to you.  If  you do not have asbestos
cement (AC) pipe, your system may be designated as non-vulnerable and granted a
waiver. A PWS that is granted a waiver will not have to monitor for asbestos. If your
system does have AC pipe and your water is non-corrosive, you also may be classified
as non-vulnerable and eligible for a waiver. If a waiver is not granted, you will have
to monitor for asbestos once every nine years.

Timetable
      An MCL for usbestos was final as of January 30, 1991.  If your PWS is
vulnerable for asbestos in the water, you will have to take one sample within the first
compliance period of each compliance cycle (1993-96).

MCLs
     The MCL for asbestos is seven million fibers/liter (longer than 10 micrometers).
If your system is required to test for asbestos and it has asbestos cement pipe the sample
will be taken at the tap.  If your first test exceeds the MCL, you may wish to take a
confirmation sample.  Compliance will be based on the average of the two. If the
sample is still  over the MCL, then quarterly  testing is required.

Actions Your Community Should Be Taking
     -Cooperate with the State in terms of performing initial monitoring, applying
     for a waiver and/or performing a vulnerability assessment.
                                  -41-

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If Your Tests Indicate Levels Of Asbestos Higher Than The
MCL, You Are In Violation Of The MCL.  You Should:
     -Test quarterly.

     -Notify the State and complete Public Notices as required.

     -Work with the State and/or your engineer to determine if asbestos
     is in your source water and/or is being leached from your asbestos cement
     pipe. Plan a corrective action.

     -If asbestos is in your water source, it may be removed with coagulation/
     filtration or direct and diatomite filtration. Corrosion control is used to reduce
     leaching of fibers from asbestos cement pipe.

Other Important Considerations
     EPA proposed (in 1986) under the Toxic Substance Control Act to ban the
manufacture of many asbestos products including asbestos cement pipe. There is no
plan to call for the removal of existing pipe, but a water system may need to provide
for corrosion control if there is asbestos cement pipe in their system. More important
may be the need to plan for materials and procedures to repair existing asbestos cement
pipe in the future.

     The greatest risk related to asbestos cement pipe is to the maintenance worker
who is repairing or otherwise coming into contact with the pipe. Inhaling the dust
(fibers) from cutting the pipe is particularly hazardous. The Occupational Safety and
Health Administration (OSHA) of the Department of Labor has published rules
concerning occupational exposure to asbestos. If you work with asbestos cement pipe
in your community, contact your state Department of Labor for information on these
rules.
        Additional Information

     The rules for Asbestos are contained in 40 CFR 141.23 and 141.62.

     The rules of OSHA on Occupations Exposure to Asbestos are contained in
     29 CFR 1910 and 1926.
                                   -42-

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WATER PROGRAMS
 DRINKING WATER


 FLUORIDES
     Fluorides are compounds that contain an ionic form of the element fluorine.

     Fluorides occur naturally in many water sources and are added in the treatment
process by many public water systems.  Fluorides in amounts between 1.0 and 1.5
mg/1 have beneficial effects in reducing tooth decay. Amounts above 4.0 mg/1 may
cause bone and skeletal changes. Amounts greater than 2 mg/1 can cause discoloration
of teeth.

Does The Fluoride Regulation Apply To My Community?
     Yes, all community public water systems must test for fluoride every three
years (groundwater) or every year (surface water).

Timetable  (For Revision Of Regulations)
     Testing for fluoride was required prior to the 1986 SDWA (Safe Drinking
Water Act) Amendments.  The new regulations on fluorides continue the testing
requirement of every three years for ground water supplies and every year for surface
water supplies (Usually done with the routine testing for other regulated inorganic
chemicals -IOCs.). Waivers from fluoride monitoring as for other IOC's are possible.
A new MCL was set in the final rules published on April 2,1986 and became effective
in October 1987.

MCLs
     MCL = 4.0 mg/1 (secondary standard suggested level = 2.0 mg/1).

     If your tests show levels less than the 2.0 mg/1, your community needs to do
nothing about fluoride. Plan your next routine test in one or three years.

Actions Your Community Should Be Taking
     If your tests indicate fluoride levels between 2.0 and 4.0 mg/1, you should check
with your state agency and/or consulting engineer to see if any changes in operations
can be made to lower the fluoride level.  As this is not an MCL violation, immediate
action is not required, but planning should be undertaken to reduce levels below 2.0
mg/1.  The State may require more frequent sampling to monitor the fluoride level.
Public notice is required for levels between 2.0 and 4.0 mg/1. The mandatory text of
this notice is  given in Section 143.5 of the National Secondary Drinking  Water
Regulations.
                                 -43-

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     If Your Tests Indicate Fluoride Levels Above 4.0 mg/1, You Are In Violation
Of The MCL, And You Should:

     -Contact the State. They will assist you to form the contents of a
     public notice you are required to give your customers (See Public Notifica-
     tion section.).

     -Work with the State and/or engineer to plan for a change in your water supply
     and/or treatment system to lower the fluoride levels.

     -Continue regular testing, as suggested or required by the State to monitor
     fluoride levels while you are working on solutions.  Notify the public
     periodically, as required.

     Solutions  to fluoride MCL  violations for very small water systems usually
involve finding and using a new water source or mixing existing sources to reduce the
fluoride level. Removing fluoride through treatment can be cost prohibitive for very
small systems.
Additional Information

      The rule for fluoride is contained in 40 CFR 141.23 and 141.62.

      "Removal of Excess Fluoride in Drinking Water," "Fluoridation Engineering
      Manual," EPA, available from the Safe Drinking Water Hotline:
      1-800-426-4791.
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WATER PROGRAMS
DRINKING WATER
LEAD MATERIAL BAN
     Lead is a metal which, in the past, has been used for water supply pipe, joints in
other pipe materials and in alloy with other metals as solder in joining copper pipe and
in the manufacture of water supply fixtures. Lead has been identified as a cause of
central and peripheral nervous system damage, kidney effects and can be highly toxic
to infants and the developing fetus of pregnant women. Lead in plumbing materials may
be leached into drinking water by corrosive water.

Does The Lead Material Ban Apply To My Community?
     Yes, the use of solder containing more than 0.2% lead in the installation of new
plumbing in customers' facilities that are connected to the public water supply is
banned.  Also, pipes and pipe fittings may not contain more than 8.0% lead. The law
applies only to plumbing which distributes  drinking water and does not require the
removal of existing lead pipes or solder.

Timetable and MCLs
     On October 28, 1987, specific public notice requirements were published as a
final rule.   There is no MCL involved in the Lead Material Ban. See the section on
Lead and Copper for additional information.

Actions Your Community Should Now Be Taking
     -Inform customers involved in new construction or the replacement of
     plumbing that the lead materials ban is in effect for your water system.
     (Requiring a simple permit and inspection of new plumbing is one way some
     communities carry out this information requirement.)

     -Make information available to your customers on the actions they can take
     to reduce lead levels in the water they consume in their own home.

     -If your water supply is very corrosive, contact the State and/or
     your community's engineer  to plan for ways you can reduce the corrosive
     impact of your water on the  lead that may be contained in customers'
     plumbing.

     -If you have lead pipe or fixtures in your distribution system, consider
    replacement with non-lead materials. Leaded joints in old cast iron or other
    pipe is not believed to leach  significant amounts of lead into the water.
    Replacement is not required by the Lead Ban but may be required for systems
     that continue to exceed the lead or copper action levels under the Lead
     Copper Rule.
                                 -45-

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   Additional Information

The statute for the Lead Material Ban is contained in the Safe Drinking Water
Act, section  1417(a)(l) & (2).

"Lead and Your Drinking Water," EPA, available from the National Safe
Drinking Water Hotline: 1-800-426-4791.

"The Lead Ban: Preventing the Use of Lead in Public Water Systems and
Plumbing Used for Drinking Water," EPA. Available from the National Safe
Drinking Water Hotline at 1-800-426-4791.
                              -46-

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WATER PROGRAM
DRINKING WATER

LEAD AND COPPER
     Lead and copper are inorganic chemicals that are occasionally found in water
supplies and are frequently leached out of plumbing in water systems that have
corrosive water. Lead can cause central and peripheral nervous system damage, kidney
effects and be highly toxic to infants and in the developing fetus of pregnant women.
Copper causes taste problems  and stains porcelain and can also cause stomach and
intestinal distress.

Timetable
     Testing and MCL compliance for lead has been in effect for a number of years
prior to the 1986  SDWA Amendments for community water supplies. In June 1991,
EPA published new rules that deleted the MCL for lead but required that additional
sampling  be done at customer taps. High levels of lead and copper at the customer
taps will trigger requirements of treatment of the water supply to reduce corrosivity.
Public education should also be provided to help customers reduce their intake of lead
and copper.

Action Levels Per The New Rule:
     -The treatment technique requirements are triggered by exceedances of the
     lead action level of 0.015 mg/1 or the copper action level of 1.3 mg/1 measured
     at the 90th percentile.

     -All public water systems are required to collect one sample for lead and
     copper analysis from the following number of sites during each six month
     monitoring period.
       System Size   No. of Sampling Sites     No. of Sampling Sites
       (Population)   (Initial Base Monitoring)  (Reduced Monitoring)

       501 to 3,300           20                     10
       101 to 500             10                     5
       <100                   5                     5
     The above samples must be collected per monitoring period. For small water
systems, there are two monitoring periods per calendar year, July 1993 to December
199f and January 1994 to June 1994.
                                 -47-

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                  Compliance Deadlines
ACTION
     SYSTEM SIZE

3,300-50,000       <3,300
 Begin monitoring

Complete treatment study
(if required by State)

Recommend treatment to State
  -Study not required
  -Study required

Complete treatment installation
  -Study  not required
  -Study required

Complete follow-up monitoring
  -Study  not required
  -Study  required
   July 92

   July 95
   Jan 93
   July 95
   July 96
   Jan 98
    July 97
    Jan 99
July 93

July 96
July 94
July 96
 Jan 98
 Jan 99
 Jan 99
Jan 2000
Sample Collection Methods  And Locations
-First flush tap water samples must stand motionless for at least six hours
before the samples are collected.

-One liter of water must be drawn from the cold water kitchen or bathroom
tap.

-Systems may collect samples or enlist residents to collect samples. Residents
fill the container supplied by the water system according to directions and
leave the container for the system to pick up.

-Begin tap water monitoring program by July 1993. Tap water samples must
be collected at high risk locations:

   o homes with lead solder installed after 1982,
   o homes with lead pipes,
   o homes with lead service lines.
                               -48-

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Public Education Program Requirements:
        PWSs which exceed the lead action level must deliver a public education
program to their consumers. Please note that this program is different from the
public notification requirements discussed separately beginning on page 65.
        The rule provides specific language for use in all printed materials, public
service announcements (PSAs) and broadcast materials. This language describes
the potential health effects of excess exposure to lead and the reasons why lead in
drinking water is of particular concern.  It provides step-by-step instructions for
water testing and follow-up actions that can be taken to reduce both short-term and
long-term exposure to lead in drinking water. The rule also requires the water
system to provide tap collection for any customers who request this service. The
system, however, is not required to pay for collecting and analyzing the sample.

        The program must be delivered to your entire service area, and targeted to
high-risk segments of the population. The following are required:

        - Distribute informational notices in water utility bills, along with a special
        alert on the water bill itself, every 12 months;

        - Publish informational notices in major local newspapers, every 12
         months;

        - Deliver brochures every 12 months to specified facilities and
        organizations, including public schools and/or local school boards; city
        or county health departments; Women, Infants and  Children (WIC) and/or
        Head Start programs; public and private hospitals and clinics; family
        planning clinics and local welfare agencies; and

        - Release PSAs  every six months to at least five of the radio and television
        stations with the largest audiences that broadcast to the community served
        by the water system.

Water systems must perform these actions within 60 days from the time the lead
action level is exceeded and repeat for as long as the action level is exceeded.

        The community must also submit a letter to the State by December 31st of
each year demonstrating compliance with the public education aspects of the
regulation.

Additional Information
      The regulations for lead and copper are contained in Subpart I of 40 CFR
      Part 141.

      "Fact Sheet:  National Primary Drinking Water Regulations For Lead and
      Copper" available from EPA.
                                    -49-

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WATER PROGRAMS
DRINKING WATER
SYNTHETIC ORGANIC CHEMICALS (Non-Volatile)
      Synthetic organic chemicals (SOCs) are man-made compounds used for a
variety of industrial and agricultural purposes. For monitoring purposes, the SOCs are
divided into two groups - volatile synthetic organic chemicals (VOCs) and others which
are usually called pesticides and PCBs. This page will discuss SOCs that are not
volatile.  VOCs will be discussed on a separate page. Also see the page on disinfection
by-products. SOC effects include damage to the nervous system, kidneys and cancer
risks.
Timetable (For Revisions To Regulations)
     New regulations called Phase n were final January 30,1991. These regulations
added 13 new SOCs and revised five SOCs.  All community and non-transient non-
community PWSs will be required to test for SOCs.   Several methods are required
to test for all the SOCs, which adds tremendously to the cost.

     The Phase V regulations, which were  final on July 17, 1992, added 15 non-
volatile SOCs and three VOCs. The procedures and monitoring requirements are the
same for these contaminants as required under the Phase n rule.  Because  EPA is
required to add contaminants to the list to be  regulated on a regular schedule, SOCs
will probably be added to the list.
MCLs  (on back of page)
     These MCLs are not enforceable in very small systems until 48 months after the
final rules are published.
If Your Tests Indicate Levels Of A  SOC Higher Than The MCL
(Year Average), You Are In Violation Of The MCL. You Should:
     -Continue quarterly sampling (at times of highest vulnerability, i.e., after
     fertilizer application and a rain).

     -Notify the State and complete public  notices as required.

     -Request an exemption from the State  to allow the community to continue
     to use the water supply while the solutions to the MCL violation are being
     explored and any needed financing is being planned.

     -Work with the State and/or your engineer to determine how SOCs are
     getting into your water supply. If possible, eliminate the source of
     contamination. If you must treat your water supply to remove the SOCs, work
     with your engineer to choose the best available technology for treatment.
     Additional Information
     - The rules for SOCs are contained in 40 CFR 141.24 and 141.61.
     - "Pesticides in Drinking Water Wells," EPA.  (Agricultural Extension
        Service offices also have useful pamphlets on pesticides.)
                                 -50-

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                         Phase
Contaminant
Alachlor
Aldicarb*
Aldicarb Sulfoxide *
Aldicarb Sulfone *
Atrazine
Carbofuran
Qilordane
Dibromochloropropane (DBCP)
2,4-D
Heptachlor
Heptachlor Epoxide
Lindane
Methoxychlor
PCB's
Pentachlorophenol
Toxaphene
2,4,5-TP (SILVEX)
Acrylamide
Epichlorohydrin
        MCL
        0.002 mg/1
        0.003 mg/l
        0.004 mg/1
        0.003 mg/1
        0.003 mg/1
        0.04 mg/1
        0.002 mg/1
        0.0002 mg/1
        0.07 mg/1
        0.0004 mg/1
        0.0002 mg/1
        0.0002 mg/1
        0.04 mg/1
        0.0005 mg/1
        0.001 mg/1
        0.003 mg/1
        0.05 mg/1
Treatment Technique
Treatment Technique
These have been suspended, and will not be enforceable under
current regulations.
                Phase V (SOCs)
Endrin
Dalapon
Diquat
Endothall
Glyphosate
Di (Ethylehexyl) Adipate
2,3J,8-TCDD(Dioxin)
Hexachlorocyclopentadiene
Oxamyl (Vydate)
Simazine
PAH's [Benzo(a)pyrene]
Hexachlorobenzene
Di(ethylhexyl) Phthalate
Picloram
Dinoseb	
        0.002 mg/1
        0.2 mg/1
        0.02 mg/1
        0.1 mg/1
        0.7 mg/1
        0.4 mg/1
        3 x 10 (-8) mg/1
        0.05 mg/1
        0.2 mg/1
        0.004 mg/1
        0.0002 mg/1
        0.001 mg/1
        0.006 mg/1
        0.5 mg/1
        0.007 mg/1
                       -51-

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WATER PROGRAMS
DRINKING WATER


VOLATILE ORGANIC CHEMICALS
     Volatile Synthetic Organic Chemicals (VOCs) are man-made compounds used
for a variety of industrial and manufacturing purposes. VOCs tend to be in a gaseous
form under conditions that may occur in a water system and then separate from the
water supply. VOCs have various effects on the liver, kidneys, nervous system and
some pose a cancer risk.

Do the VOC regulations apply to my community?
    Yes, the initial Volatile Organic Chemical (VOC) rule became effective on
January 9,1989. This rule, called Phase I, set maximum contaminant levels (MCLs)
for eight VOCs and required all community and non-transient, non-community water
supply systems to monitor for, and if necessary, treat their supply to remove these
chemicals.   VOC monitoring requirements were revised on  June 30,  1991 to
synchronize them with other VOC monitoring requirements in a new set of regulations
called Phase n. This rule set MCLs for 10 additional VOCs. Other Phase JJ regulations
became effective July 30,1992. More new regulations, called Phase V, added three
new VOCs.  The Phase V rule becomes effective on January 31,1994.

    The VOC MCLs are listed below.
Phase I - Effective January 9, 1989
VOC
Benzene
Carbon Tetrachloride
1 ,2-Dichloroethane
Para-Dichlorobenzene
1 , 1 -Dichloroethylene
1,1,1 -Trichloroethane
Trichloroethylene
Vinyl Chloride
MCL (mg/1)
0.005
0.005
0.005
0.075
0.007
0.20
0.005
0.002
                               -52-

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Phase II - Effective July 30, 1992
VOC
o-Dichlorobenzene
cis- 1 ,2-Dichloroethylene
trans- 1 ,2-Dichloroethylene
1 ,2-Dichloropropane
Ethylbenzene
Monochlorobenzene
Styrene
Tetrachloroethylene
Toluene
Xylenes
MCL fmg/n
0.6
0.07
0.1
0.005
0.7
0.1
0.1
0.005
1
10
Phase V - Effective January 30, 1994*
VOC
Dichloromethane
1 ,2,4-Trichlorbenzene
1 ,2,2-Trichlorethane
*Public water supply systems
MCL fmg/n
0.005
0.07
0.005
with 150 or more


















service connections must begin monitoring in the
January 1, 1993 to December
31, 1995 time period.
Monitoring Requirements

      A major feature introduced in Phase n is its plan for synchronizing compliance
monitoring across several existing and upcoming rules. Under this Standardized
Monitoring Framework, the various monitoring frequencies for most source-related
contaminants will be coordinated within compliance periods of three years each.
Some monitoring and related system activities, such as vulnerability assessments, will
occur at intervals which may span across up to three of these three-year periods,
forming a nine-year compliance cycle.  The first compliance cycle and the initial
compliance period both begin on January 1,1993.

     Other features of Phase n monitoring requirements include:

     Sampling location - Groundwater systems must sample at entry points to the
distribution system which are representative of each well after any application of
treatment Surface water systems must sample at points within the distribution
                                   -53-

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system which are representative of each source or at entry points to the distribution
system after any application of treatment. Samples must be analyzed by a  Kansas-
certified lab.

    Initial sampling frequency - All systems must sample at a base (or minimum)
frequency which is specific for a contaminant or contaminant group. The State
may grant monitoring waivers (as discussed below) and may allow a system to
substitute suitable previous monitoring data for this initial monitoring. In the initial
compliance period, the State will determine the actual year in which a system
samples.

    Repeat sampling frequency - In general, if a system does not detect
contaminants in initial samples, then repeat sampling frequencies will be lower than
initial frequencies. Repeat monitoring requirements are generally the same for all
systems regardless of system size or water source.

   Trigger to increase monitoring - If contaminants are detected in any sample, the
system must begin quarterly sampling until the state determines that subsequent
results are "reliably and consistently" below the MQL At least two to four samples
must be taken before this determination may be  made. Detection is defined
separately for various contaminants or contaminant groups at either the MCL, 50
percent of the MCL, or at the analytical method detection limit.

   Monitoring waivers - Sampling frequencies may also be reduced or eliminated
if the system obtains a waiver based on: previous sampling results  and/or  an
assessment of the system's vulnerability to each  specific contaminant.
Additional Information

     The rules for VOCs are contained in 40 CFR 141.24 and 141.61.
                                   -54-

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      Compliance Monitoring Requirements

Contaminant
Asbestos

Nitrate
Nitrite
Inorganics
VOCs1
17 Pesticides
and o-n-n-r- bOts
Unregulated
IOCs\
SOCs

Ground wattr Surfaot water
1 Sample every 9 years
Annual 1 Quaneriy
After 1 year < 50% of MCL S WS
may reduce to an annual sample
1 Sample: If < 50% of MCL,
state discrcDon
1 Sample every Annual sample
3 years
4 Quarterly samples every 3 years
Annual after 1 year of no detects
4 Quarterly samples every 3 years
After 1 round of no detects: systems
>3300 reduce to 2 samples per year
every 3 years; systems £ 3300
reduce » 1 sample every 3 years
1 Sample
4 Consecutive quarterly sanpks

Trigger mat
Increases
Sampling
>MCL

> 50% MCL
2 50% MCL
> MCL
> 0.0005 mg/L
Method
Detection
Limit
(MDL)
N.A.
Waivers
for Base
Requirements
YES
Based on VA'

NO
NO
YES
Based on analytical
results of 3 rounds
YES
Based on VA1
YES
Based.-- V A
YES
Ba<*d on V.V
' VA - Vulnerability Assessment

2VDCs - Volatile Organic Chemicals
 ICCs - Inorganic Chemicals
 SOCs - Synthetic Organic Chemicals  (Non-Volatile)
                          -55-

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WATER PROGRAMS
 DRINKING WATER

 COLIFORM MONITORING
      Bacteria from sewage and animal wastes have presented the most frequent and
 immediate health risks to public water supplies over the years.  Coliform bacteria,
 specifically the presence of fecal and E. coli bacteria, are used as the best and most
 easily tested for indicators of potentially harmful bacteria in the water.

 Does The Coliform Monitoring Rule Apply To My Community?
      Yes, all community public water systems must submit samples for coliform
 bacteria testing on a regular monthly basis. Failure to submit samples, meet the MCL
 and report non-compliance are all violations of the rule.

 Timetable
     Your community has been required to test for coliform bacteria for many years.
 The 1986 Amendments to the Safe Drinking Water Act caused new rules to be
 published that change some of the procedures for testing, change the MCL and require
 certain public notification related to coliform monitoring. These rules were published
 in final form on June 29,1989, and became effective December 31,1990.

 MCLs
     The MCL is based on the presence or absence of total coliforms in a sample (the
 old MCL was based on an estimate of coliform density). The presence of total coliform
 bacteria indicates the possible presence of fecal and disease-causing bacteria.   A
 small water system may have no more than one coliform-positive sample per month.


     Monitoring Requirements
       You are required to submit a minimum of two routine samples per month for
 your system.  (Carefully follow procedures for sampling provided by your testing
 laboratory or the state agency.). Samples are to be from different customer taps from
 month to month. If the sample tests positive for total coliforms, you must (within 24
 hours of notification of the result) collect four repeat samples for each positive
 routine sample.   These repeat samples  must be collected within five service
 connections of the original sample with at least one being at the original location, at
 least one upstream and at least one downstream.   If total coliforms are detected in
 any repeat sample, your water system is in violation of the MCL and you must notify
 the State no later than the end of the next business day that you learned of the violation.
                                 -56-

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     If fecal colifonns or E. coli are identified in a repeat sample following a routine
total coliform positive sample (or vice versa), it becomes an acute violation and you
must notify the State the same day you receive the results. During the month following
one or more positive coliform samples, you must collect a minimum of five routine
samples. The State may choose to require more routine samples per month.

     A sanitary survey of your system is required at least every five years (usually
done by the state).  The initial survey must be completed by June 29,1994. Without
the sanitary survey, you would have to collect a minimum of five routine samples every
month.

Actions Your Community Should Be Taking
If Your System Is Not Having Total Coliform Positive Tests:

     -Continue to submit regular samples and review results.

     -Maintain a good operation and maintenance program for your water system
     including regular line flushing at fire hydrants and on dead ends.

If Your System Has A Coliform-Positive Sample Result:

     -Immediately take and process your repeat samples.

     -Carefully review your sample taking procedures to be sure you are not
     accidentally contaminating the samples.

     -Call the State and ask for help to locate any possible sources of contamination.

     -Follow the  State's direction in issuing public notices and any state
     emergency measures that may be required.
     Additional Information

     The rule for coliform monitoring is primarily contained in 40 CFR 141.21 &
     141.63, and public notice rules in 40 CFR 141.32.
                                  -57-

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WATER PROGRAMS
DRINKING WATER

SURFACE WATER TREATMENT RULE

        The Surface Water Treatment Rule (SWTR) was published in the
Federal Register on June 29,1989.  It became effective on December 31,1990.
This rule requires water treatment in lieu of water testing because it regulates
contaminants which are difficult to detect and pose acute health risks.

        Under this rule, disinfection and filtration are required for surface water
systems and for groundwater systems under the direct influence (UDI) of surface
water. These systems must install filtration if the microbiological, turbidity and
other standards in this rule are not met. All surface water systems must disinfect
and filter under Kansas requirements.

Does The Surface Water Treatment Rule Apply To My
Community?

     Yes, it applies to all Public Water Supply Systems (community and non-
community) using a surface water source (i.e. water open to the atmosphere and
subject to surface runoff) or a groundwater source under the direct influence of surface
water.

  Water Treatment Requirements

     Specific enforceable MQL standards for these microbial contaminants are not
established in this rule. Instead, treatment will be required for surface water systems.

     Criteria For Filtered Systems
        Systems which filter their water must ensure that the overall filtration and
disinfection process they use is performing effectively as demonstrated by turbidity
and disinfection criteria. These criteria are given in the table on the following page.
As with unfiltered systems, effectiveness will be demonstrated in part by the amount
of disinfectant and the length of time it is in contact with the water before reaching the
first customer.
                                 -58-

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               Filtered System Criteria
        Criterion
        Turbidity
       Disinfection
               Giardia
               Viruses
               Residual
Standard
<5 NTU at all times
<0.5NTUin95%ofall
       samples

99.9% effective
99.99% effective
0.2 mg/1 at entry	
        Systems are given time to comply with the water quality standards and
treatment requirements of this rule. Specific dates are given in the following table.

     Surface water (SW) systems
        - Filtered  systems must meet monitoring and treatment performance
requirements beginning 48 months after the rule becomes effective.

     Groimdwater Systems Under Direct Influence Of Surface
Water (GW-UDI)
        -States will determine which community water systems are under direct
influence of surface water within five years after the rule becomes effective.
System Tvp
SW-F
GW-UDI
Compliance Dates
MB Requirement
Performance and
monitoring
State must notify
system that it is UDI
Date
6/29/93
6/29/94
        Additional Information

     The rules for surface water treatment are contained in Subpart H of 40 CFR
     Part 141.

     EPA's "Guidance Manual for Compliance with the Filtration and Disinfec-
     tion Requirements for Public Water Systems Using Surface Water." Call
     the Safe Drinking Water Act Hotline: 1 -800-426-4791.
                                 -59-

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WATER PROGRAMS
DRINKING WATER

RADIONUCLIDES
      Radionuclides are radioactive particles that occur naturally in areas of uranium
and radium deposits and in waste from man made processes. Radionuclides, even in
very small concentrations, pose a cancer risk.

Does The Radionuclides Regulation Apply To My Community?
      Yes, radionuclides have been regulated since 1976 with MCLs currently set for
four types. All community public water systems must test for radionuclides at least
every four years.

Timetable (For Revision Of Regulation)
      In July 1991, proposed regulations were published that added MCLs for two
additional radionuclides, Radon and Uranium. Final new rules may be published in
late 1993. Systems will begin to monitor under the new radionuclide rules in 1996.
Until then, continue to monitor under the old rules.

MCLs
      The following are current MCLs for radionuclides and the  levels that are
proposed. The units of measure are peculiar to radioactivity and represent very small
quantities.
                             Current MCL   MCL Likely to be Adopted

   Gross Alpha Particle Activity    15 pCi/1              15 pCi/1
   Beta Particle & Photon Activity*  4 mrem/yr.           4 mrem/yr
                             ("Only if designated by the State)
   Combined Radium - 226 & 228  5 pCi/1
   Radium - 226                     -                20 pCi/1
   Radium - 228                     -                20 pCi/1
   Uranium                        -                20 ug/1
   Radon                          -                300 pCi/1
Actions Your Community Should Be Taking
     Submit samples as required for routine testing. The monitoring process requires
one sample every three months for one year (four samples in total). Compliance with
the MCL is based on an average of the four quarterly samples.  Unless test results
indicate radionuclide values above or near the MCL, the test is repeated only every four
years. Mark your calendar a few months prior to the four year time limit to remind
yourself to test
                                 -60-

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If Your Tests Indicate Levels Of Radionuclides Higher Than The
MCL, You Should:
     -Ask the State if you should resample to confirm the test results. The
     State may also require you to continue quarterly sampling until the MCL level
     is met

     -Follow the State's instructions regarding when and what type of public notice
     you need to give.

     -Request an exemption from the State to allow the community to
     continue to use the water supply while solutions to the MCL violation are
     being explored and any needed financing is being planned.

     -Start working with the State and/or engineer to consider options to eliminate
     the radionuclides from your system. In nearly all  small community water
     systems, finding a different source of water supply is the most economical
     solution to a radionuclide problem.

     -Remember that exposure to radionuclides at levels found in water is a risk
     over long term exposure. It is not an acute risk for short periods of time. Don't
     panic or start unrealistic fears. Do proceed to work out a reasonable and
     affordable solution for your drinking water supply.

        Additional Information

     The rule for radionuclides is contained in 40 CFR 141.15, 141.16, 141.26.

     "A Study of Possible Economical Ways of Removing Radium From Drinking
     Water" is available from EPA by calling the Safe Drinking Water Hotline at
     1-800-426-4791.
                                   -61-

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WATER PROGRAMS
DRINKING WATER

DISINFECTION AND DISINFECTION BY-PRODUCTS
     Disinfectants (such as chlorine) are the primary defense against diseases caused
by microbiological contaminants in public water systems. More than 90% of surface
water supply systems disinfect their water while less than half of the ground water
supplies are disinfected. Although disinfection is the single most important treatment
technique in use in public water supplies, the disinfectants themselves can react with
organic materials in water supplies. Disinfection by-products (DBFs) may be formed
which may contaminate the water with compounds that increase cancer risk.

Do The Disinfection And Disinfection By-products Regulations
Apply To My Community?
      Yes, all community and NTNC public water systems will be required to
disinfect their water, with allowance for variances if the water comes from sources
that are determined not to be at risk from microbiological contamination. Monitor-
ing for DBFs  will be  limited to  systems that are determined vulnerable to their
development.

Timetable
      Surface water supplies are now covered by final rules  on  filtration and
disinfection that were  published by EPA on June 29, 1989. These rules require
disinfection of all surface water supplies and become effective over the next three years
as determined by state schedules. Rules for general disinfection of all drinking water
supplies are expected to be proposed in June 1993 and will include MCLs for a number
of  disinfectants and disinfection by-products. At present, three disinfection by-
products (trihalomethanes) are regulated but only in community supplies of 10,000 or
greater population.

MCLs
      Proposed  MCLs have not yet been circulated. The MCL for  total
trihalomethanes is 0.1 mg/1.
                                 -62-

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Actions Your Community Should Be Taking

     Kansas requires that all drinking water supplied to the public by a water supply
system be disinfected. When chlorination is used, a sufficient amount of chlorine shall
be added to the water to maintain a measurable chlorine residual throughout the dis-
tribution system with a residual of 0.2 mg/1 of free chlorine or 1.0 mg/1 of combined
chlorine at the ends of the distribution system.  The operator shall make a daily
determination of the chlorine residual and record it in such a manner that KDHE can
determine if its requirements have been met
        Additional Information

     The authority for Disinfectants and DBFs is in Section 1412 (b) (8). of the
     SDWA.

     "Protecting Our Drinking Water From Microbes," EPA, available by calling
     the National Drinking Water Hotline 1-800-426-4791.
                                   -63-

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WATER PROGRAMS
DRINKING WATER

PUBLIC NOTIFICATION
     With the enactment of the Safe Drinking Water Act, Congress requires that
public drinking water systems notify their customers when drinking water standards
are violated. The purpose of public notification is to inform consumers of any potential
adverse health effects and to describe what steps consumers can take to minimize the
impact The notification should also educate the consumer about the needs of the
public water system to assure the delivery of safe drinking water.

Do The Public Notification Rules Apply To My Community?
      Yes, the Safe Drinking Water Act requires owners/operators of all community
public drinking water systems to notify the persons they serve if certain violations of
the National Primary Drinking Water Regulations or certain other specified events
occur.

Timetable
      Public Notification  rules are now in effect for all contaminants that your
community  is required to  monitor for.  As new contaminants are regulated and
monitoring is required in your community, you are also required to give public
notification when violations occur. This information describes the Federal Rules. The
State may add requirements for your area.

Types Of Violations Requiring Public Notification
     There  are six violations or events that require Public Notification:

     1.  Failure to comply with an applicable maximum contaminant level (MCL)

     2.  Failure to comply with a prescribed treatment technique

     3.  Failure to perform water quality monitoring (testing) as required by the
     regulations

     4.  Failure to comply with testing procedures as prescribed  by a National
     Primary Drinking Water  Regulation

     5.  Issuance of a variance or an exemption

     6.  Failure to comply with the requirements of any schedule that has been set
     under  a variance or exemption
                                 -64-

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Notification Procedures
      The method, timing and frequency of notifying the public varies based on the
"level" of the violation and the availability of the public communication media.
There are two "levels" of violation. Tier 1 violations include numbers 1,2 and 6 listed
above, namely, failure to comply with an MCL; failure to comply with a treatment
technique; failure to comply with a schedule prescribed under a variance or exemption.

     Tier 2  violations are less serious and have simpler notification  requirements.
They  include numbers 3, 4 and 5  listed above, namely, failure to comply with
monitoring requirements; failure to comply with testing procedures; operating under
a variance or exemption.

     Tier 1  violations are  subdivided into "acute" and "non-acute"  violations.
"Acute" risks are those that involve an immediate risk to human health. These are
violations specified by the state agency and presently must include violations of the
MCL for nitrate and/or nitrite, violations of the MCL for total coliforms when fecal
coliforms or E. coli are present and occurrences of a waterborne disease outbreak in
an unfiltered surface water system.

Actions Your Community Should  Take
      If you  are informed of test results that indicate you are in violation of an MCL
oryou are informed of another violation, immediately contact the State and notify them
of the violation and ask their direction in proceeding with public notification (Note: the
State  may declare a sample invalid or require a check sample before confirming a
violation and thereby ask you to delay public notification.).

Methods Of Notification
      - In communities with a daily (or weekly) newspaper of general circulation
(received by most households):

     Tierl Violations

      1.  Provide notice within 14 days of the violation through the newspaper, AND

     2.  Provide notice by direct mail or hand delivery within 45 days of the violation.
     Repeat this notice every three months as long as the violation continues, AND

     3.  For  ACUTE VIOLATIONS  ONLY - Deliver notice to the principal
     television and radio station serving  the area within 72 hours following the
     violation.
                                   -65-

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     Tier 2 Violations

     1. Provide notice within three months of the violation through the newspaper,
     AND

     2. Provide notice by mail or hand delivery within three months of the initial
     newspaper notice. Repeat this notice every three months as long as the violation
     continues.

     - In communities without a newspaper:

     Tierl Violations

     1. For ACUTE VIOLATIONS ONLY - Provide notice by hand delivery or
     by posting within 72 hours of the violation, AND

     2. For non-acute violations - Provide notice by hand delivery or by posting
     within 14 days of the violation, AND

     3. Repeat the notice by hand delivery every three months or by continuous
     posting for the duration of the violation.

     Tier 2 Violations

     Provide notice by hand delivery or by posting within three months of the
     violation.  Repeat the notice by hand delivery every three months or by
     continuous posting for  the duration of the violation.

Information That Must Be Included In The Public Notice:
     1. Must provide a clear and readily understandable explanation of the
     violation.

     2. Must include information about any potential adverse health effects.

     3. Must contain information about the population at risk.

     4. Must contain information about the steps being taken to correct the
     problem.

     5. Must contain information about the necessity of seeking alternative water
     supplies, if any.

     6. Must include any preventive measures  that should be taken until the
     violation is corrected.
                                  -66-

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      7.  Must be clear and conspicuous.

      8.  Must not contain unduly technical language.

      9.  Must not contain unduly small print.

     10.   Must not create problems that frustrate the purpose of the public
     notification.

     11.  Must include a phone number of the owner, operator or someone to
     contact at the public water system as a source of additional information.

     12.   Where appropriate, notices must be multi-lingual.


     Mandatory Health Effects Language

       EPA has established mandatory language on the health effects of contami-
nants found in drinking water. The EPA language must be included in notices by public
water systems where the system is:
       - In violation of an MCL or treatment technique,
       - Has been granted a variance or exemption,
       - Is operating under a variance or exemption,
       - Fails to comply with  a variance or exemption schedule.

     Currently promulgated mandatory health effects language is included in the
public notification regulations cited below.

     Notice To New Billing Units

       In addition to complying with the public notification requirements for Tier 1
violations, community water systems must provide notice to new billing units of any
existing Tier 1 acute and non-acute violations. A copy of the most recent public notice
must be given to all new billing units or hookups prior to or at the time service begins.
        Additional Information

     The rules for Public Notification are contained in 40 CFR 141.32.

     "General Public Notification for Public Water Systems," EPA, available by
     calling the National Safe Drinking Water Hotline at 1-800-426-4791 for a free
     copy.
                                   -67-

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WATER PROGRAMS
DRINKING WATER

Regulatory Development Schedule
     An important part of planning is knowing the specific regulations that will affect
your particular community and its public water system(s), and further, knowing when
these regulations will be in effect and enforced in your community. Following is the
most recent schedule for the development of the new federal regulations.

     Rule                                  Status        Effective

     Fluoride                                Final          10/87
     Lead Ban (SDWA 1417)                  Final          06/86
     Phase I Volatile Organics                 Final          01/89
     Public Notification                       Final          04/89
     Surface Water Treatment Rule             Final          12/90
     Total Coliform Rule                      Final          12/90
     Phase H IOCS and SOC                   Final          07/92
     Lead/Copper                            Final          12/92
     Phase V lOCs and SOCs                   Final           1/94
     Phase HI Radionuclides                    Proposed        1994
     Disinfection/Disinfection By-Products        TBP            1996
     Revised Arsenic Standard                  TBP            9/94
     Sulfate Rule                             TBP            10/93
     Phase Vffi SOCs and lOCs                 TBP            1993
     Repropose MCLs for aldicarb,              TBP            2/93
       aldicarb sulfoxide, aldicarb sulfone
     Additional List Contaminants               TBP            1997

     -  TBP means To Be Proposed
     -  IOC means Inorganic  Chemicals
     -  SOC means Synthetic  Organic Chemicals
     -  Some effective dates are phased-in by system size (see below)
     -  EPA Rules are generally effective 18 months after being finalized
                                -68-

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WATER PROGRAMS
 DRINKING WATER
 UNDERGROUND INJECTION CONTROL
      The Underground Injection Control (UIC) program is authorized by the Safe
 Drinking Water ACL The program is primarily preventative in nature and regulates
 such aspects  as siting, construction, operation, monitoring and testing of various
 types of wells used to inject fluids underground. Five classes of wells are recognized,
 including:
      Class I   - Used to inject industrial, municipal or hazardous wastes below the
 lowest underground source of drinking water (USDW).
      Class n - Used to inject fluids associated with oil and natural gas production.
      Class in - Used to inject  fluids for extraction for minerals such as salt  and
 uranium
      Class IV - Used to inject hazardous or radioactive wastes into or above a USDW.
      Class V - Wells not otherwise classified and generally used to inject non-
 hazardous fluid into or above a USDW.

      Class I, n, and ffl wells have specific requirements regarding their construction
 and operation, and have been generally accounted for.  Class IV wells are banned
 unless they are part of an authorized groundwater cleanup.  Closure is required for a
 well identified as Class IV. Class V well occurrence is not as well documented since
 this category includes any well not covered under the first four Classes.  There are
 a variety of constructions and uses for Class V wells, including deep cased wells,
 seepage pits,  cesspools and septic tanks with  lateral  (tile) fields.  (Septic tanks
 handling strictly domestic wastewater and serving fewer than 20 persons a day are
 exemptfromUICregulation.) These factors make this type of well difficult to locate.
 Many Class IV wels are mis-identified as Class V wells.

      Class IV and V wells can serve virtually any type of industrial or commercial
 facility including  automotive service stations, lawn services,  laundries and dry
 cleaners, transportation  and road facilities,  local weed control authorities, photo
 processing  labs, electroplating  companies,  printers and lithographers, chemical
 plants, electronics manufacturers, pharmaceutical plants, food processors and many
 more.

     All classes of injection wells are regulated by EPA through either primacy
 programs or direct implementation programs administered by EPA. Kansas has a
 primacy program.
                                  -69-

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Additional Information:
Regional Contact:

UIC Program
Water Management Division
EPA Region 7
726 Minnesota Ave.
Kansas City, KS 66101
1-913-551-7032
State Contact:

Industrial Programs Section
Bureau of Water
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-5560
                             -70-

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WATER PROGRAMS
 Kansas Water Well Protection Program

      The Kansas Water Well Protection Program is administered by KDHE, and
works to protect groundwater from contamination and insure the safety of human
lives. These goals are achieved through licensure of water well contractors, public
education, technical assistance and enforcement. KDHE's water well program is
assisted by local levels of government.

      In Kansas, every time a water well is constructed, reconstructed, or plugged,
a water well record (WWC5 form) must be submitted to KDHE. This record
identifies well information such as its legal location, method of construction, reason
for construction, lithology, etc.

      One aspect of the program includes licensure of water well contractors.
Individuals interested in becoming a licensed water well contractor should complete
an application form from KDHE.  Once KDHE receives the completed application
and $10 application fee, the individual is scheduled for a licensure examination.
Upon completion of the examination, the individual must pay a $100 licensure fee
plus $25 for each operating rig. Licenses expire each June 30. To keep the license
active, the fees must be paid by July 1 of each year, regardless of when the
individual was initially licensed.

      An individual does not have to be licensed in order to perform water well
construction, reconstruction or plugging on his/her own land. However, an
individual hired to perform these activities on someone else's land must be a Kansas
licensed water well contractor. In either case, WWC5 form must be completed and
submitted to KDHE within 30 days from the finished constructing, reconstructing,
or plugging date. Water well contractors are required to pay a $5 fee to construct or
reconstruct a well. No fee is required to plug an abandoned well.

      All abandoned wells are required by law to be plugged. It has been roughly
estimated that approximately 500,000 abandoned water wells are located within the
State of Kansas.  Because of this extremely high estimate, KDHE's water well
program has placed high priority on plugging abandoned water wells.

      For Further Information:
             Bureau of Water
             KDHE
             Forbes Field, Bldg 740
             Topeka,KS 66620-0001
             1-913-296-3565

                    or contact your local health department


                                 -71-

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WATER PROGRAMS
WELLHEAD PROTECTION

     The 1986 Amendments to the Safe Drinking Water Act (SDWA) call upon
each state to develop a Wellhead Protection (WHP) Program.  This legislation
established a nation-wide program to encourage states to develop systematic and
comprehensive programs within their jurisdictions to protect public water supply
(PWS) wells and wellfields from contamination.

     The statute specifies that all states will participate.  However, the EPA has no
authority to establish a WHP Program if a state chooses to forego action on its own.
There are no sanctions against states that do not participate.  States are encouraged to
participate and to exercise individual discretion in developing methods of protecting
ground water used for drinking water.

     Under SDWA,  Section 1428, each state must develop a WHP Program that
consists of several elements. At a minimum, each state's WHP Program must:

     -Specify roles and duties of state agencies, local government entities and
     public water suppliers, with respect to WHP Programs;

     -Delineate the wellhead protection area (WHPA) for each wellhead;

     -Identify sources of contaminants within each WHPA;

     -Develop management approaches to protect the  water supply within
     WHP As from such contaminants;

     -Develop contingency plans for  each public water supply system to respond
     to well or wellfield contamination;

     -Site new wells properly to maximize yield and minimize potential
     contamination;  and

     -Ensure public  participation.

Actions Your Community Should Be Taking
        The EPA has responsibility for approving WHP  programs and for
providing technical support to state and local  governments.  States shall develop
and implement WHP programs that meet the requirements of the SDWA
Amendments. Local  governments should develop WHP plans that protect their
public drinking water supply from contaminants.   An effective local program
                                 -72-

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needs participation at all levels of government and should use the state-approved
WHP program as a means to accomplish this.

      Local governments typically implement zoning decisions, develop land-use
plans, oversee building and fire codes, implement health requirements, supply water
and sewer services and enforce police powers. Each of these local powers may be used
to protect the quality of local aquifers.

      Local cities and counties are also often the innovators in developing wellhead
protection programs by applying combinations  of management techniques (e.g.,
zoning and source prohibitions) to meet unique local conditions. Localities often
protect groundwater as part of larger projects, such as developing growth manage-
ment plans or economic development efforts. In close cooperation with regional, state
and  federal agencies, local governments  can take positive steps to protect their
wellhead areas.
        Additional Information

     Regional Contact:

     Wellhead Protection Program
     Water Management Division
     EPA Region 7
     726 Minnesota Ave.
     Kansas City, KS 66101
     1-913-551-7033
State Contact:
Bureau of Water
KDHE
Forbes Field, Bldg 740
Topeka, KS  66620-0001
1-913-296-5558
                                    -73-

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  WATER PROGRAMS
  WASTEWATER

   State Revolving Fund Loan Program
       The 1987 Amendments  to the Clean Water Act authorized the Admin-
istrator of the EPA to make grants (called capitalization grants) to the states for
deposit in State Water Pollution Control Revolving Funds (SRF). Using the SRF,
states can provide loans and other types of non-grant financial assistance to
communities and intermunicipal and interstate agencies for the construction of
publicly-owned wastewater treatment facilities and for implementation
 of nonpoint source management and groundwater control programs.
      In Kansas, the SRF makes low-interest loans available to Kansas cities for
 such projects as sewage treatment plants, interceptors, inflow/infiltration
 collection/control, collector sewers and major sewer rehabilitation. Up to 10 %
 of monies must be made available to communities with populations
 less than 5,000.

       The Fund is projected to build a total asset balance of about $90 million by
 1995, which can support $12 million/year of loans ($1.2 million for communities
 of less than 5,000). SRF loans can be combined with Community Development
 Block Grants (CDBG) to finance water pollution control projects.

      To qualify for a loan, a project must submit a request to be included on the
 Priority List, have sufficiently high ranking to move to the Intended Use Plan, and
 submit a completed application including plans and specifications to the KDHE.
 A loan agreement is signed when project design and the application is complete.
 Projects must comply with federal requirements for facility planning, environ-
 mental clearances and construction contracts.

      Once a loan agreement is executed, the scope of the project and the interest
 rate are fixed for the term of the loan. The loan amount may increase or decrease
 based on actual costs within  the scope of the project.  Nearly all project costs can
 be included in the loan amount, including the costs of temporary financing and
 interest during construction,  with the exception of costs for land,  easements and
 private sewers.

      In addition to the federal funds, their must be  a minimum 20 % match in
 State funds. The match in Kansas is funded by revenue bonds issued by the
 Kansas Development Finance Authority (KDFA), a quasi-state agency. The
Fund is administered by KDHE in conjunction with the KDFA.
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Additional Information
U. S. EPA State Revolving Fund Program Implementation Regulations,
40 CFR 35.
Regional Contact:
SRF Program
Water Management Division
EPA Region 7
726 Minnesota Ave.
Kansas City, KS  66101
1-913-551-7031
 State Contact:
Municipal Programs Section
Bureau of Water
 KDHE
 Forbes Field, Bldg 740
 Topeka,KS 66620-0001
 1-913-296-5534 or-5527
                           -75-

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WATER PROGRAMS
WASTEWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION
SYSTEM (NPDES)
     Public Law 92-500 amended the Federal Water Pollution Control Act in 1972
(later amended and renamed the Clean Water Act). It established a national policy to
restore and maintain the chemical, physical and biological integrity of the nation's
waters. The EPA or the state environmental control agency has responsibility for
administering NPDES permits. In Kansas, a primacy state, KDHE administers the
NPDES  permit process. These permits are issued to  operators discharging any
pollutant (including wastewater effluent) to State/U.S. waters (such as streams, lakes,
wetlands, etc.).

     Specific terms and conditions for a NPDES permit vary from state to state, but
each primacy state must administer the program to meet minimum EPA standards. In
addition, permit requirements within a given state may also vary because of different
geological conditions, the beneficial uses of the receiving water and other factors at the
discharge site.  The State of Kansas goes beyond the  federal NPDES program,
requiring permits for all discharging wastewater treatment facilities, and those with
the potential to discharge. Discharging facilities must obtain a state and federal permit
Non-overflowing facilities are required to obtain a state permit. Permit limits are set
based upon the State's Water Quality Standards.  As the Water Quality  Standards
change, permit requirements may also change.

Actions Your Community Should Be Taking
     Maximize community awareness and education concerning wastewater collec-
tion and disposal, available solution alternatives, funding resources and procedures for
implementing the most appropriate wastewater collection and treatment facility.
Numerous technical and administrative resources are available at little or no cost to the
community.
Additional Information
     Federal Water Pollution Control Act of 1972 (33 U.S.C. 1342).

     EPA Administered Permit Programs: The National Pollutant Discharge
     Elimination System, 40 CFR 122.
       Regional Contact:
State Contact:
               NPDES Program
               Water Management Division
               EPA Region 7
               726 Minnesota Ave.
               Kansas City, KS 66101
               1-913-551-7034
       Technical Services Section
       Bureau of Water
       KDHE
       Forbes Field, Bldg 740
       Topeka,KS 66620-0001
       1-913-296-5513 Or-5525
                                 -76-

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 WATER PROGRAMS
WASTEWATER

SEWAGE SLUDGE*  USE AND DISPOSAL
     Municipal wastewater sludge is a by-product of the wastewater treatment
process. Sludge regulations ensure that sewage sludge is properly handled by disposal
or reused as a soil conditioner or fertilizer.

Do The Sewage Sludge Regulations Apply To My Community?
     Yes, the regulations apply if the wastewater treatment system includes any
form of central treatment or mechanical plant, including an overflowing or non-
overflowing  lagoon, which will need to be cleaned.  The regulations do not apply
if individual  on-site septic systems  are used.  However, the  septage from the
individual  on-site systems  must be properly handled   according  to the final
regulations.

Timetable
     The final sewage  sludge regulations (Clean Water Act, Section 503) were
published by EPA on February 19, 1993 and became effective March 22,1993. If
communities can meet the requirements of the sludge regulations without construction,
it must be  done by February  19, 1994.  However, if construction  is required,
communities will have until February 19,1995. Monitoring and record keeping must
commence by July 19,1993.

Actions Your Community Should Be Taking
     Be aware of restrictions covering proper use of the sewage sludge for land
application (agricultural  and  small  quantity local use) and proper disposal
(incineration, and surface disposal). Communities (except those with lagoons**)
should immediately  begin  testing the sludge being disposed of to determine its
quality. The communities should then evaluate which options are available based on
the  sludge in accordance with  the regulations.  If construction is required, the
community should obtain the services of a Kansas-certified professional engineer to
prepare plans and specifications, and provide them to the KDHE for construction of
the required facilities.

     These regulations are "self-implementing." In other words, they are in effect
and enforceable regardless of whether or not they are in your current wastewater
treatment facility permit.

     *The term, "Biosolids," may be used instead of "sludge" in some literature.

     **Lagoons are not required to comply with these regulations until the sludge is
removed from the lagoon.
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Additional Information

     For.infonnation about domestic sewage from private systems, contact the Local
Environmental Protection Program, KDHE, at 1-913-296-5558.

     Sewage Sludge Technical Rule, 40 CFR Part 503.
     Regional Contact:

     Sludge Program
     Water Managment Division
     EPA Region 7
     726 Minnesota Ave.
     Kansas City, KS 66101
     1-913-551-7034
State Contact:

Technical Services Section
Bureau of Water
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-5513 or-5527
                                  -78-

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WATER PROGRAMS
WASTEWATER

PRETREATMENT REQUIREMENTS
     Pretreatment refers to those measures taken to prevent pollutants, from sources
other than conventional domestic wastewater, entering the wastewater system. Pre-
treatment is the treatment of a waste before it is discharged into the sanitary sewer. A
pretreatment program includes ordinances, education, inspections, monitoring and
enforcement.

     Pretreatment requirements control pollutants which are  incompatible,  will
interfere with the treatment process or will pass-through the publicly owned treatment
works (POTW) and cause problems in the receiving stream or lake. In addition,
pretreatment requirements will improve opportunities to recycle and reclaim domestic
and industrial wastewaters and sludges.

Do The Pretreatment Requirements Apply To My Community?
      Traditionally, the smaller POTWs with individual discharges are not required
to establish local pretreatment programs.  If non-domestic users in the community
(such  as sawmills,  food processing plants, metal finishers, etc.) are discharging
pollutants that could pass through the POTW untreated or interfere with operations, the
community may have to implement a pretreatment program to satisfy the NPDES
permit requirements.

     Your current NPDES permit does contain a section on prohibited discharges and
industrial waste. These are pretreatment requirements and are designed to insure that
you protect your POTW.

If The Rule Applies To My Community, What Should I Do?
     If you are required to establish a pretreatment program, your municipality will
need to establish local ordinances implementing the pretreatment requirements and
identify a person responsible for insuring the program is administered and enforced.

     Discharge limitations are developed and enforced by POTWs to implement
prohibitions and to protect the POTW. They are site specific to ensure pretreatment
standards are in place to protect the POTW, the receiving stream and municipal sludge
quality.

     If your community wants to establish a local pretreatment program, and is not
required to through your NPDES permit, contact KDHE or EPA for assistance.
                                 -79-

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   Additional Information
Pretreatment Final Rule, 40 CFR 403.
Regional  Contact:

Pretreatment Program
Water Management Division
EPA Region 7
726 Minnesota Ave.
Kansas City, KS  66101
1-913-551-7034
State Contact:

Industrial Programs Section
Bureau of Water
KDHE
Forbes Field, Bldg 740
Topeka,KS 66620-0001
1-913-296-5552
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WATER PROGRAMS
WASTEWATER

STORM WATER
     The storm water regulations are a new part of the National Pollutant Discharge
Elimination System (NPDES). As part of the Clean Water Act amendments of 1987,
Congress acted to directly address storm water by adding Section 402(p). In response
to these changes, EPA issued a final application rule in November 1990.

     This regulation defines the initial scope of the NPDES permit program for storm
water discharges.  It  defines the terms  "storm water discharges associated with
industrial activity," and "large and medium municipal separate storm sewer systems"
and the permit application requirements for these discharges.

     At this time, the municipal side of the program requires applications only from
cities with a population of 100,000 or more, and counties having large populations in
unincorporated, urbanized areas. Phase n (sometime after October 1994) may require
communities less than  100,000 to obtain a permit and develop a storm water manage-
ment program. It is unknown at this time if there will be exemptions for very small
communities.

     Only three industrial activities  owned or operated by a municipality with a
population under 100,000 are covered by the storm water regulations ~ uncontrolled
landfills, airports and power plants.

Actions Your Community Should Be Taking
     Find out if the defined industrial operations owned or operated by the community
(i.e. landfill, airport, wastewater treatment plant and power plant) need permits. The
State or EPA contacts will be able to give assistance to determine which industrial
operations need permits and how to apply for the permits.

     Develop an information and education program for the community to increase
awareness of the relation between the storm water drain system and the local lake or
stream. Storm waterrunoff collects in street gutters and storm drains and flows directly
to streams with little or no treatment.  Citizens need to be educated so that they are
aware of the role they play in the quality of the streams and lakes. Dumping used motor
oil, unused paint, pesticides and other household chemicals on the ground or in the
street can severely impact nearby surface water.

     Communities should also consider establishing local ordinances controlling the
improper disposal or discharge of pollutants to the municipal storm water drain system.
                                  -81-

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-For the following facilities, if materials are exposed to storm water: facilities
classified under SIC codes 20,21,22,23,2434,25,265,267,27,283,31 (except
311), 34 (except 3441), 35,36,37 (except 373), 38,39, and 4221-25 (including
food; tobacco, textile; apparel; wood kitchen cabinets; furniture; paperboard
containers and boxes; converted paper/paperboard products; printing;
drugs;leather, fabricated metal products; industrial and commercial machin-
ery and computer equipment; electronic equipment; transportation equip-
ment; measuring, analyzing and controlling instruments and photographic,
medical and optical goods, and watches and clocks; miscellaneous; and
certain warehousing and storage manufacturers).
Additional Information

Regional Contact:

Stormwater Program
Water Management Division
EPA Region 7
726  Minnesota Ave.
Kansas City, KS  66101
1-913-551-7034
State Contact:

Industrial Programs Section
Bureau of Water
KDHE
Forbes Field, Bldg 740
Topeka,KS  66620-0001
1-913-296-5553
                              -82-

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    Kansas Department of Health and Environment, Bureau of District Operations

The Kansas Department of Health and Environment (KDHE) has six district offices located
across the state (indicated on the map below). These offices serve as the agency's field arm,
each staffed with environmental professionals who work to insure quality environment.

Communities  with environmental questions or concerns regarding  such topics as hazardous
waste; solid waste; petroleum storage tanks; spills; drinking water; nonpoint source pollution;
and air (open burning, incinerators, and CFCs) should contact the KDHE district office nearest
them.  All questions regarding asbestos should be directed to the Topeka Office at 913-296-
1550,  as the district offices do not handle inquiries regarding asbestos.

For further information or clarification, contact:

                        Kansas Department of Health and Environment
                        Bureau of District Operations
                        Forbes Field, Bldg.  740
                        Topeka, KS  66620-0001
                        (913) 296-0077
        Kansas Department of Health and Environment
                            District Offices
 N.W. District Office
   2301 E. 13th St.
   Hays, KS 67601
   (913) 625-5663
                        N. Central District Office
                         2501 Market PL, Ste. D
                            Salina, KS  67401
                              (913) 827-9639
                         N.E. District Office
                           800 W. 24th St.
                        Lawrence, KS  66046
                           (913) 842-4600
  S.W. District Office
  302 W. McArtor Rd.
 Dodge City, KS  67801
     (316) 225-0596
S. Central District Office
  1919 Amidon, Ste. 130
Wichita, KS  67203-2118
     (316) 838-1071
S.E. District Office
    1500 W. 7th
    P.O. Box 888
Chanute, KS 66720
   (316)  431-2390

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DEFINITIONS-ACRONYMS
     AHERA - Asbestos Hazard Emergency Response Act

     ASHAA - Asbestos School Hazard Abatement Act

     AST - Above ground storage tanks

     Bacteria - Microbiological contaminants found in drinking water
     samples are fecal coliforms and the bacterium E. coli. Their presence is
     evidence of sewage contamination.

     Biosolids - Sewage sludge, a byproduct of wastewater treatment.

     BODS - Measurement of the oxygen required for the biochemical
     degradadon of organic matter, and the oxygen used to oxidize inorganic materi
     in water (usually wastewater, effluent, or receiving water).

     CDBG - Community Development Block Grant

     CERCLA - Comprehensive Environmental Response, Compensation and
     Liability Act, also known as "Superfund"

     CFR - Code of Federal Regulations

     CWS - Community Water Supply System

     DBF - Disinfection By-product

     EPA - Environmental Protection Agency

     FIFRA - Federal Insecticide, Fungicide and Rodenticide Act

     Groundwater - Water below the land surface that feeds wells and springs.

     IOC - Inorganic Chemical

     IRAA - Indoor Radon Abatement Act

     KDHE - Kansas Department of Health and Environment, also "State"

     KDFA -Kansas Development Finance Authority

     LEA - Local Education Agency (school districts or co-operatives)
iall
                                -84-

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LEPC - Local Emergency Planning Committee, established under SARA

MCL - Maximum Contaminant Level

MSWLFC - Municipal Solid Waste Landfill Criteria

NESHAP - National Emission Standards Hazardous Air Pollutants

NPDES - National Pollution Discharge Elimination System

NPDWR - National Primary Drinking Water Regulation

NTNC - Non-transient, non-community

OSHA - Occupational Safety and Health Administration

pH - A measurement of hydrogen ion in a compound; determines whether a
compound is "acidic" or "basic."

POTW - Publicly Owned Treatment Works

Primacy State - State that has received delegated authority from EPA to
manage specific environmental programs.

PWS - Public Water Supply System

RACM - Regulated Asbestos-Containing Material

RCP - Radon Contractor Proficiency

RCRA - Resource Conservation and Recovery Act

RMP - Radon Measurement Proficiency

SARA - Superfund Amendments and Reauthorization Act

SDWA - Safe Drinking Water Act

SERC - State Emergency Response Commission, established under SARA

SIC - Standard Industrial Classification

SMCRA - Surface Mining Control and Reclamation Act

SMF - Standardized Monitoring Framework


                            -85-

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SOC - Synthetic Organic Chemical (non-volatile)




SRF - State Revolving Fund




SWTR - Surface Water Treatment Rule




TBP - To be proposed




TCLP - Toxicity Characteristic Leaching Procedure




TSCA - Toxic Substances Control Act




UIC - Underground Injection Control




USDW -Underground Source of Drinking Water




UST - Underground Storage Tank




VOC - Volatile Organic Chemical




WHP - Wellhead Protection




WHPA - Wellhead Protection Area
                          -86-

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