Everything You  Wanted
To  Know About
Environmental
Regulations .  . .

      But Were Afraid To Ask
   A Guide For Very Small Communities

-------
This handbook was developed by the Region VIII Small Community
Work Group.  The agencies and organizations represented on the
work group include:
     Colorado Department of Local Affairs
     Colorado Counties, Inc.
     Council of Energy Resource Tribes
     EPA, Region VIII
     Midwest Assistance Program
     Montana Department of Commerce
     National City and County Journal
     North Dakota Department of Health
     North Dakota League of Cities
     Northern Montana College
     Rural Community Assistance Corporation
     South Dakota Department of Environment & Natural Resources
     South Dakota Municipal League
     Utah  Department of Environmental Quality
     Wyoming Association of Municipalities
     Wyoming Department of Environmental Quality
                    SEPTEMBER  1991

-------
                          Preface
     This handbook was prepared with the very small local units of govern-
ment (communities) in mind. For the purpose of this handbook, a very small
community is defined as a local unit of government with a population of 1,000
or less. It was prepared for use by the officials of such communities as a quick
reference to the environmental issues facing their constituencies. If you are
a community which exceeds this definition you will need, as a minimum, to
comply with  the enclosed requirements. It  is likely you may need to meet
additional reauirements.

     Information presented in the handbook is meant only as a summary of
basic environmental requirements and/or agency guidance criteria. It is not
intended to serve as a definitive statement  to the specific ways  in which a
community may assure environmental compliance, but as a quick guide to the
environmental programs that typically apply to most very small communities.
The handbook does not provide a complete overview of all federal and state
environmental requirements. As an example, EPA's Superfund Program is
not discussed in this handbook since the majority of very small communities
do not have superfund issues.

     The requirements and guidance presented in this handbook are based
on federal regulations and/or guidance in place in mid-1991. These require-
ments  are implemented by a federal agency, usually the Environmental
Protection Agency. It should be expected that some of these requirements/
guidance will change in the future. In addition, States and Indian Tribes are
required to adopt rules at least as stringent as these federal rules.  States and
Tribes may adopt rules that are somewhat different in some cases, e.g.,
frequency of sampling or required date of implementation. Be sure to ask for
and read the rules from the appropriate state or tribal agency.

     This document  was initially prepared in late 1990 by the Midwest
Assistance Program,  Inc. under contract to EPA Region VIII.  It was
expanded by EPA Region VIII in early 1991. The purpose of the expansion
was to include the EPA non-regulatory programs that typically apply to very
small local units of government.
                                11

-------
             Table of Contents
n
         CROSS MEDIA PROGRAMS          1-10
   Pollution Prevention
   Public - Private Partnerships
   SARA Title III Emergency Planning and Community Right-to
         Know Act
   Asbestos
   Indoor Radon
                                              II
      AIR PROGRAM
Clean Air Act Amendments
         LAND PROGRAMS
                                           12-18
   RCRA Hazardous Waste
   Subtitle D Municipal Solid Waste Landfill Criteria
   Underground Storage Tanks


    O WATER PROGRAMS
   Water and Wetlands Protection
   Drinking Water
   Wellhead Protection
   Wastewater
                                           19-73
o
S"
*+•
O
1
^
ra
=1

y
=:
;=

5

^
Sjjj«
^^





^
LJ
         DEFINITIONS-ACRONYMS
                                           74-75
         RESOURCE MATRIX
                                           76-82
                          in

-------
CROSS /VIED/A PROGRAMS
01
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 and pollutants at the source.  Pollution that cannot be
prevented should be recycled whenever possible. Pollution that cannot be pre-
vented 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
     Rulings by courts, pronouncements by EPA, or wishing alone cannot clean up
the environment or keep it from becoming more polluted. What we need is an
attitude change. Community leaders can develop policies that encourage environ-
mental 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 genera-
tors, hospitals and schools), by  communities and individuals.

     Here are suggestions of  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 utilization of natural
     resources.

-------
-Develop programs that provide environmental alternatives:

   -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, use water conserving
   landscaping.

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

   -Sustainable agriculture. Take advantage of natural methods of protec-
   tion.  Apply pesticides such as insecticides and herbicides carefully if they
   must be used.

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

   -Hazardous waste. Reduce toxic use, encourage product substitution and
   operation modification to environmentally sound practices.  Recycle used
   motor oil.

   -Buy recycled or recyclable products. Seek out reusable, recyclable or
   returnable packages.

   -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 dean the air by removing pollution.
  Additional Information

EPA, Region VIII, Pollution Prevention Office:
Don Patton, 303/293-1456.
Sharon Childs, 303/293-1471.

-------
CROSS MEDIA PROGRAMS
                                                            n
PUBLIC-PRIVATE PARTNERSHIPS
                                                                O
     As a community leader, you face the prospect of building or upgrading
facilities to meet environmental needs. You already maybe 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 Parternships: 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 these
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

-------
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
situations and risk allocations; and contract termination and step-in-rights.  Insur-
ance and bonding should also be considered since they may affect the terms of the
contract.
        Additional Information

     EPA, Region VIII, Pollution Prevention Office:
     Don Patton, 303/293-1456.

-------
CROSS MEDIA PROGRAMS
Q
Q
                                                              D
SARA TITLE III -THE EMERGENCY
PLANNING AND COMMUNITY RIGHT-TO-
KNOW ACT
     SARA Title III has two purposes:  to encourage and support emergency
planning for responding to chemical accidents, 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, includinggovernment facilities, in your community storing
certain hazardous chemicals (excluding specified quantities) must provide informa-
tion to government agencies and local communities. Also, if there is a chemical
accident, and if the accident 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
associated with its passage. For example, governors were required to establish State
Emergency Response Commissions (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.

-------
     Title III requires owners and operators of facilities storing specified hazard-
ous substances to report to the LEPC within 60 days. As a result, the law allows
small communities to identify what needs to be done at the local level to better deal
with chemical emergencies.

If the Emergency Planning and  Community Right-to-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
Emergency 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,
industry and  business fields, and farmers. It is important not only to participate in
emergency planning but to also communicate with the public.

     Become familiar with the law so that you will know what tools are beingmade
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 more effectively deal with and prevent chemical emergen-
cies.
        Additional Information
     EPA, Region VIII, Emergency Response Branch, 303/293-1723.

     SARA Title ffl Hotline, 1-800/535-0202.
   (See the listing for the State Emergency Response Commissions in the Resource Section)

-------
CROSS MEDIA PROGRAMS
ASBESTOS
                                                             m\m
     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.

     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 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 andcontrolling 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.

     - 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 todisturb 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.

     - 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 the plan and make them
     available for public review.

     - Inform employees and building occupants or their legal guardians annually
     regarding the management plan availability and related ongoing activities
     pertaining to implementation.

     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
implementation of their management plans by July 9,1989. LEAs are required to
update and maintain management plans to reflect activities with ongoing operations
and  maintenance, periodic surveillance, inspection, reinspection,  and response
action  activities.

What help is available?
     EPA has established several programs to assist schools in  assessing and
managing their asbestos related problems.  Through  its Headquarters office in
Washington, D.C. and the Regional office, the Agency provides direct technical
assistance to help school officials, school employees and parents better understand
asbestos  issues.  EPA provides funds to assist  States in developing asbestos
programs, and to help schools comply with federal asbestos regulations.

     Under the Asbestos School Hazard Abatement Act (ASHAA) program, EPA
provides  financial aid to schools in the form of an interest-free loan, grant, or a
combination of both.

How  do I obtain more information?
     Under AHERA, LEAs 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 organi-
zations are excellent sources for requesting information on asbestos activities.

        Additional Information

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

     ASHAA Asbestos Hotline (Schools) -1-800/462-6706.

     EPA has an asbestos ombudsman to help citizens with asbestos-in-schools
     issues, questions, and complaints. Call 1-800/462-6706.

     Call 202/554-1404 to obtain the following documents: "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."

-------
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 hi homes, schools and buildings throughout the U.S.

     Exposure to high radon levels is dangerous. The health hazard from radon
arises from inhaling of 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 elevated radon levels is especially high.

     The EPA has established an action level for indoor air radon levels of
4 pci/1 (picocuries per liter). Nearly one out of every 15 homes in the U.S. are
estimated to have radon levels that exceed the action level. The EPA has established
a testing procedure for testing homes, schools and buildings. This procedure is
described in the "Citizen's Guide to Radon."

     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, IRRA provided funds for state governments to establish radon
programs and to assist local governments and communities in encouragingresidents
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, 40 states and seven Indian Nations in conjunction with the EPA
have conducted radon residential surveys to characterize statewide radon distribu-
tions. Additionally, about 1,200 schools were tested in the winter of 1991. Results
of the National School Radon Survey should be available in June, 1992,

     IRAA also required the EPA to  develop a program to evaluate radon
mitigation contractors and  radon  measurement labs.  In  response,  the EPA
established four regional  radon training centers to train radon professionals. The
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. As of February, 1991, about 1,200 contractors were included
on the RCP list.
                                   -Q-

-------
Does the radon program apply to my community?
     Local communities, in concert with state governments, 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, 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, by the
end of 1991, model building codes for new construction will be 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: first, through developing radon education and outreach programs; second,
through adopting radon-resistant building codes for new construction, such as the
model codes currently proposed by the EPA;  third, by encouraging voluntary testing
in local communities; fourth, by ensuring that local radon contractors are RCP-
listed; finally, by working in conjunction with the state radon office and community
organizations such as, the American Lung Association, to elevate local attention to
this important health risk.

Actions your community should  be taking
     -Become familiar with the health risks associated with radon, as well as the
     ways radon enters homes, schools and buildings.

     -Identify ways to educate the community about radon and to encourage
     voluntary testing.

     -Contact your state radon office.  Request  their assistance in providing you
     with public information about radon, including citizen guides to radon,
     current lists of radon contractors and measurement firms, and the status of
     state regulatory programs.
        Additional Information

     The EPA has established a toll-free number for radon - 1-800/SOS
     RADON. Many states also have toll-free numbers to answer questions
     regarding radon.

-------
AIR PROGRAM
                                                           I  III
CLEAN AIR ACT AMENDMENTS
Will the Clean Air Act Amendments apply to my
community?
     Most provisions will not affect very small communities. However, there may
be instances when impacts may occur. There may arise situations when air toxics
are being emitted by a facility in excess of the MCL's (Maximum Contaminant
Levels). Also, on occasion, ski communities may have wood burning or particulate
problems that will need to be dealt with.

Actions your community should be taking
     Prior to initiating significant involvement to address air pollution issues which
may arise, small communities should contact their state air pollution agency and the
Regional EPA Small Community Coordinator for guidance. The Air Program is
aware of the economic impact which the Clean Air Act Amendments may have on
small communities. Therefore, before taking any regulatory action which may affect
small communities, Regional Offices  of EPA will contact EPA Headquarters and
determine the possible impacts of the action.
       Additional Information

     Clean Air Act Amendments:
     TITLE VIII- MISCELLANEOUS PROVISIONS.
     Sec. 810. Impact on small communities.
     Before implementing a provision of this Act, the Administrator of the
     Environmental Protection Agency shall consult with the Small Communities
     Coordinator of the Environmental Protection Agency to determine the
     impact of such provision on small communities, including the estimated cost
     of compliance with such provision.

     Region VIII Small Community Coordinator:
     Charles Gomez, 303/294-1108.

-------
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 what hazardous waste is subject to
regulation as well as the responsibilities of anyone who generates, transports, stores,
treats, disposes or otherwise manages hazardous  waste.  At this time, waste
generated by individual households, many of which may still exhibit some of the
dangers described above, are not subject to federal RCRA requirements.

     Currently, there are three categories of hazardous waste generators under the
RCRA program requirements:

     -Full Generator - Facilities that generate more than 1,000 kilograms per
     month of any hazardous waste or more than one kilogram of any "acute"
     hazardous waste. A kilogram is approximately 2.2 pounds and 1,000
     kilograms is approximately five, 55 gallon drums of material.

     -Small Quantity Generator - Facilities that generate less than 1,000 kilo-
     grams per month of hazardous waste but more than 100 kilograms per
     month (approximately one half 55 gallon drum). Small quantity generators
     are given additional lime to comply with new regulations and for on-site
     storage of their waste.

     -Conditionally Exempt Generator - Facilities that generate less than 100
     kilograms a month of any hazardous waste are conditionally exempt from
     the RCRA regulations. These facilities may generally dispose of their waste
     in accordance with State "solid waste" requirements such as those
     described under the Subtitle D program (Municipal Solid Waste Landfill
     Criteria).

-------
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 chrome, cadmium, and lead, vehicle maintenance shops often
generate hazardous waste that may be subject to RCRA requirements.  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 Toxic Character-
istic Leaching Procedure (TCLP) test.

     In addition to used materials which might be considered hazardous waste, you
must also be careful with your management of products that no longer are wanted
or needed, and you now wish to discard. Leftover pesticides from grounds keeping
operations, old paint thinner, etc. must be fully evaluated before you determine what
you are going to do with the waste. 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 would be the operation
of a trash collection system and/or a landfill. Normally, because household wastes
are currently exempt from RCRA regulation, municipal landfills are regulated
under a program referred to as the "Subtitle D Municipal Solid Waste Landfill
Criteria" which is intended to insure proper management of the municipal landfill.
However, the addition of commercial waste materials collected and/or co-disposed
with the household  materials might trigger RCRA jurisdiction over the  entire
facility.

Timetable
     RCRA regulations were first published in 1980 and are constantly amended
to add new wastes subject to the program. Once you determine that you are a
handler of hazardous waste (i.e., either generating, storing, transporting, etc.), you
must notify EPA and/or the State Hazardous Waste Office of your activity and
receive an EPA RCRA 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. Small quantity generators have up to 180
days.

     Securing a permit authorizing the treatment, storage, or disposal of hazardous
waste is a very expensive and lengthy process.
                                   -13-

-------
Actions your community should be taking
     -Become familiar with the kinds of waste materials that are subject to
     RCRA regulation.

     -Identify ways to reduce or recycle chemicals that are generating waste.
     Find non-toxic substitute products for hazardous chemicals,

     -Buy the right amount of chemicals you need, not more. Try to find
     someone to use unwanted, unused chemicals rather than throwing them
     away.

     -Become familiar with the industrial facilities served by your community.
     Understand how they are managing their dangerous and hazardous waste.
       Additional Information

     The  RCRA regulations are published at 40 CFR (Code of Federal
Register) Part 260 through Part 272.  Part 261 defines what materials are
hazardous waste and therefore subject to the RCRA requirements. (See the
listing for the Solid and Hazardous Waste Program Directors in the Resource
section.)

     Many States have been approved by EPA to apply and enforce the federal
RCRA hazardous waste requirements. You may wish to contact your State
Environmental Agency to get more information on how your State offices are
involved.

     EPA has also established a toll free RCRA Hotline to answer questions
regarding the applicability or interpretation of the RCRA regulations. The
RCRA Hotline number is 1-800/424-9346.

-------
LAND  PROGRAMS
SUBTITLE D MUNICIPAL SOLID WASTE
LANDFILL CRITERIA


     Municipal Solid Waste is a non-hazardous waste generated at residences,
commercial establishments, and institutions.

     The Subtitle D Municipal Solid Waste Landfill Criteria proposed rule sets
general facility standards, groundwater monitoring requirements, closure and post
closure standards, and performance and operating requirements.

Does the rule apply to my community?
      The rule applies only if your community owns or operates a landfill. The rule
at this time is proposed. It will be effective 18 months after promulgation.

Timetable
      Final regulations have been postponed several times, but are expected to be
published during 1991.

Actions your community should be taking
     -Be alert to the publishing of final regulations. Expect changes in the
     regulations from August 1988.

     -Be prepared to either not accept waste or upgrade to meet criteria.

     -Develop community education and recycling programs.

     -Plan and prepare solid waste management and disposal options.
       Additional Information

     40 CFR Part 258, Proposed regulations under RCRA Subtitle D Part 258,
     Criteria for Municipal Solid Waste Landfills.

     RCRA Hotline -1-800/424-9346.

     Technical guidance will be available after promulgation.

-------
LAND PROGRAMS
UNDERGROUND STORAGE TANKS

     What is an Underground Storage Tank?  An Underground Storage Tank
(UST) is any tank, including underground piping connected to the tank, that has at
least 10 percent of its volume underground.

Does the UST regulation apply to my community?
     Yes, if an UST is storing either petroleum or certain hazardous chemicals and
it fits the UST definitions. Most communities have USTs covered by these
regulations.

Does the UST regulation apply to all underground storage
tanks?
     No, some exclusions are:

     -Farm or residential tanks holding 1,100 gallons or less of motor fuel
     used for noncommercial purposes

     -Tanks storing heating oil which is used on site

     -Emergency spill or overfill containment UST system

     -Septic tanks and systems for collecting storm or wastewater

     -Wastewater treatment tanks regulated under the Clean Water Act

     -Tanks whose capacity is 110 gallons or less

     -Storage tanks on or above the floor of an underground area, such as a
     basement, tunnel or vault

     -Field constructed tanks

If the UST regulation does apply, what must the owner do?
     -Equip the UST with devices that prevent spill and overfills by Decem-
     ber 1998.

     -Protect the tank and piping from corrosion or structural failure by
     upgrading it by December 1998.
                                -16-

-------
     -Equip the tank and piping with leak detection within the following
     specified time frames:
        Tank and Piping Age:           Leak Detection is Required By:
        25 years or older                         December 1989
        20 - 25 years old                          December 1990
        15 - 19 years old                          December 1991
        11 -14 years old                          December 1992
        5-9 years old                           December 1993
     -Verify that the stored contents are compatible with the tank's interior
     walls.

     -Be financially responsible for the cost of cleaning up a leak or compen
     sating other people for bodily injury and property damage caused by the
     leaking UST.

I own tanks to which regulations apply, but I'm not using
them, what should I do?
     Follow closure requirements for tanks temporarily or permanently closed.
(Note: Tanks not used for 3 to 12 months can be temporarily closed.) Beyond 12
months, for permanent  closure, the tank will have to be emptied and cleaned,
possibly removed. The State Agency will help you decide how best to close the UST
so that it meets all local  and state requirements.

If a leak or spill should occur, what must be done?
     -Contact the fire department to ensure that it does not pose a hazard to
     human health and  safety.

     -Tell the State Agency within 24 hours; the regulatory authority will decide
     if you must take further action.

     -Assume financial  responsibility for taking corrective measures and
     compensating individuals who are harmed by leaks or spills from USTs that
     store petroleum products.

     -If closure is necessary, notify the State Agency as soon as possible
     before you close your UST.

-------
What are the reporting requirements?
      You need to check with your State Agency about the particular reporting
requirements in your area. You may only need to report to the State Agency at the
beginning and end of the UST system's operating life.
        Additional Information

     "Musts for USTs: A Summary of the New Regulation for Underground
     Storage Tank Systems," U.S. EPA, Office of Underground Storage Tanks,
     Jury 1990.

     RCRA/Superfund Hotline 1-800/424-9346.

     Local Fire Marshall.

     Your State Agency will also be able to provide additional information.

        (See the listing for the State UST Program offices in the Resource section)
                                  -18-

-------
WATER PROGRAMS
WATER AND WETLANDS PROTECTION


     The National Environmental Policy Act of 1969 and Federal Water Pollution
Control Act of 1972 (later amended and renamed the Clean Water Act) expanded
the definition of waters of the United States to include wetlands and mandated every
federal agency to assess the environmental impact of any proposed federal actions.
Protection of U.S. waters and wetlands involves several federal agencies (primarily
the U.S. Army Corps of Engineers, U.S. Environmental Protection Agency, U.S.
Fish and Wildlife Service, and Soil Conservation Service) plus many State Agencies
(usually State Departments of Environmental Quality, Health, Conservation,
Transportation, Agriculture and others). The function of these legislative acts, and
subsequent regulations are to  restore and maintain the chemical, physical and
biological integrity of the U.S. waters including wetlands.

     U.  S. waters include lakes, streams, rivers,  wetlands and coastal waters.
Wetlands include saturated or flooded areas where there is a prevalence of aquatic
or hydrophytic vegetation, such as in swamps, marshes, bogs and other similar areas.
Protecting these U.S. waters and wetlands means virtually any type of activity which
affects or may potentially affect them could require a regulatory review prior to the
activity commencing. Violation of these and related environmental protection laws
can involve stiff penalties, including fines, requirements to restore the area and/or
imprisonment.

Actions your community should be taking

      Check before you act

     The three agencies most frequently involved are:

        - U.S. Department of Defense, Army Corps of Engineers

        - U.S. Department of Interior, Fish and Wildlife Service

        - U.S. Environmental Protection Agency

     Contact each of these agencies prior to commencing activities which might
affect the chemical, physical or biological integrity of any U.S. waters or wetlands.

-------
   Additionallnformation

The Clean Water Act of 1977 (33 U.S.C. 1251-1376).

The National Environmental Policy Act of 1969 (42 U.S.C. 4321).

Fish and Wildlife Coordination Act of 1934, amended 1946,1958,1977 (16
U.S.C. 661-667e).

River and Harbor Act of 1899, Section 10 Hazardous Waste.

Marine Protection, Research and Sanctuaries Act of 1972, as amended (33
U.S.C. 1431).

The Coastal Zone Management Act of 1972 (16 U.S.C. 1451).

The Endangered Species Act of 1973 (16 U.S.C. 1531).

U.S. Army Corps of Engineer Regulations (33 CFR 320-330).

U.S. Environmental Protection Agency (40 CFR 230, also known as the
404(b)(l) guidelines).

Executive Order 11990, May 25,1977, pages 26961-26965.

The Wetlands Protection Hotline operates Monday through Friday, exclud-
ing Federal holidays, from 9:00 a.m. to 5:30 p.m. (EST). The Hotline number
is 1-800/832-7828.

   (See In* listing for the Federal Wetlands contacts in the Resource section)

                             •
                             -20-

-------
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, at present there are 13  regulated lOCs (including fluoride lead, and
copper).

     All community public water supply systems must monitor for regulated lOCs
in their water  supply.  Sampling for lOCs is required every three years  for
groundwater supplies and every year for surface water supplies under present rules.

Timetable (for revisions to regulations)
     New regulations called Phase II were finalized January 30,1991, which added
two new lOCs, asbestos and nitrate, and changed the MCLs for four of the current
lOCs. Silver is now a secondary MCL. As a result of this regulation non-transient
non-community (NTNC) Public Water Supplies (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 3-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 - January
1,1996). This regulation allows PWSs to get waivers for monitoring. A waiver either
eliminates or reduces monitoring. A PWS with a waiver for lOCs means that they
would need to sample once each compliance cycle or once every nine years
beginning January 1,1993. It is the PWSs responsibility to ask the state for a waiver
prior to January, 1993.  It is the State's responsibility to grant the waiver.

-------
     Additional new regulations called Phase V were proposed on July 25,1990,
and add six new lOCs.  These rules will be final in March, 1992. A PWS would be
allowed to apply for a waiver after three monitoring rounds if the new lOCs were
not detected. Again  a waiver for lOCs would reduce sampling to once every nine
years.

     EPA may be expected to add an occasional IOC to the regulated list f r om time
to time and may change some MCLs of lOCs as new research clarifies levek 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/nitrites 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/nitrite found. The
new sampling requirements begin January 1,1993. EPA does not allow waivers for
nitrates. Therefore,  PWSs can expect to sample at least annually.

MCLs
     A separate page follows to list current and proposed MCLs for lOCs.

Actions your community should  be taking
     -Continue sampling yearly or every three years for currently regulated lOCs.

     -Make sure newly regulated lOCs are tested for as the new MCLs become
     effective.

     -Apply for a waiver for lOCs before December 31,1992.

If you exceed any of the MCLs
     -Take additional three check samples. The State will then use the average
     of these four tests to see if you exceed the MCL. The current exception is
     nitrate where only one check sample is required.

     -Notify the State Agency and complete Public Notices as required.

     -Work with the State Agency and/or your engineer to determine the best
     way to reduce the level of the contaminate 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.
                                  -22-

-------
-Request an exemption from the State Agency 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.

-Contact resource agencies listed in the back of this booklet for help in
planning and finding finances for your system improvements.
   Additional Information

The rules for lOCs are contained in 40 CFR 141.11,141.23,141.62.

State rules concerning lOCs are contained in	
   (The blank line is provided for you to insert where your State's rules are contained.)

Your State Agency can provide some additional information on any of the
individual lOCs.

National Safe Drinking Water Act Hotline -1-800/426-4791.

EPA, Region VIII Drinking Water Branch -1-800/759-4372,
Ext. 1413.

See separate pages of this booklet for information on Asbestos, Fluoride,
Lead and Copper.

   (See the listing for the State Drinking Water contacts in the Resource section)

-------
          Maximum Contaminant Levels for IOC's
Contaminants
MCL: Current
Arsenic                 0.05 mg/l
Barium                 1 mg/l
Cadmium                0.010 mg/l
Chromium               0.05 mg/l
Lead                    0.05 mg/l
Mercury                 0.002 mg/l
Selenium                0.01 mg/l
Silver                   0.05 mg/l
Nitrate                  10 mg/l
Fluoride                 4 mg/l
Asbestos
Nitrite (As N)
Combined Nitrate & Nitrite
MCL: Proposed
May 1989
                  5 mg/l
                  0.005 mg/l
                  0.1 mg/l

                  0.002 mg/l
                  0.05 mg/l
                  Dropping MCL
                  10 mg/l

                  7 million fibers/1
                  lmg/1
                  10 mg/l
                 MCL: Proposed July 1990
Antimony
Beryllium
Nickel
Sulfate
Thallium
Cyanide
    0.01/0.005 mg/l
    0.001 mg/l
    0.1 mg/l
    400/500 mg/l
    0.002/0.001 mg/l
    0.2 mg/l

-------
 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 Digested
 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 your State Agency has a
 waiver program, a  vulnerability assessment may be performed on your system. If
 you do not have asbestos likely to occur in your water source and do not have
 asbestos cement pipe, your  system may be designated as non-vulnerable and be
 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 asbestos was finalized 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 (1993-19%).

 MCLs
     The MCL for asbestos is 7 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 system has asbestos in the source water only
 then test at the source. If your first test exceeds the MCL, take a repeat 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.

-------
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 Agency and complete Public Notices as required.

      -Work with the State Agency 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.

      -Contact resource agencies listed in the back of this booklet for help in
      working out financial needs.

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 maybe 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 1413 (b) (1).

      State rules concerning Asbestos are contained in	.
     (The blank line is provided for you to insert where your State's rules are contained.)

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

     Your State Agency may be able to provide additional fact sheets on Asbestos.
     EPA Region VIII Drinking Water Branch 1-800/759-4372, Ext. 1413.
        (See the listing for the State Drinking Water contacts in the Resource section)

-------
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 parts per million (mg/1) have beneficial effects in reducing tooth decay.
Amounts above 4.0  parts per million 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 fluorine every three
years (ground water) 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.) 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 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. Some of the options listed below may be necessary.  The State Agency
may require more frequent sampling to monitor the fluoride level. Public notice,
with mandatory health effects language, is required for levels between 2.0 and 4.0
mg/1.

-------
      If your tests indicate Fluoride levels above 4.0 mg/1, you are in violation of
the MCL, and you should:

      -Immediately submit three check samples to confirm the initial test results.

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

      -Seek help through other resource agencies (listed in the back of this
      booklet) for help in finding financial resources if needed to make water system
      changes.

      -Continue regular testing, as suggested or required by the state agency 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 is usually cost prohibitive
for very small systems.
        Additional Information

     The rule for fluoride is contained in 40CFR 141.11,141.23,141.62.

     State rules concerning fluoride are contained in	
     (The blank line is provided for you to insert where your State's rules are contained.)

     "Removal of Excess Fluoride in Drinking Water," "Fluoridation Engineering
     Manual," EPA, available from the Safe Drinking Water Hotline:
     1-800/426-4791.

     Your local dentist or state dental association will have information available
     on the beneficial effects of correct amounts of fluoride in your drinking water.

     EPA Region VIII Drinking Water Branch -1-800/759-4372, Ext. 1413.


        (See the listing for the Stale Drinking Water contacts in the Resource section)

-------
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 the 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.  The law applies only to plumbing which distributes drinking water and
does not require the removal of existing lead pipes or solder. Check with your state
for additional  information.

Timetable
     On October 28,1987, specific public notice requirements were published as
a final rule. Contact your state or U.S. EPA for additional information.

MCLs
     There is no MCL involved in the Lead Material Ban. See the section on Lead
and Copper for additional information.

Actions your community should have completed
     -Complete a plumbing materials inventory in cooperation with your State
     Agency.

     -Complete a set of tests (under the instructions of your State Agency) to
     identify the corrosion related factors in your water supply.

     -Publish a notice about the lead ban and the information on corrosiveness
     for the information of your customers. (This was to have been completed by
     June 19,1988. In some  states,  a state-wide notice was published.)

-------
      -Consider adopting an ordinance or rule prohibiting the use of lead
      materials in any new plumbing that is connected to your water system. In some
      cases, a statewide plumbing code has met this requirement. If your commu-
      nity has adopted one of the national plumbing codes, (or are part of a
      jurisdiction that has adopted a code), these codes have all been amended to
      include the lead materials ban.

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 your State Agency 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 considered 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.
        Additional Information

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

     State rules concerning the Lead Materials Ban are contained in	.
     (The blank line is provided for you to insert where your State's rules are contained.)

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

     EPA Region VIII Drinking Water Branch -1-800/759-4532, Ext. 1431.

-------
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.

Does the Lead and Copper Rule apply to my community?
     Current rules require all community public water supplies to test for lead every
three years (ground water) or one year (surface water) along with several other
inorganic chemicals. The new rules will include copper in the same testing frequency
as lead.

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 will ultimately delete the MCL for lead but require
additional sampling to 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.

-------
         Regulatory Schedule for Small Systems (< 3,300 people)
   Date
        Activities (system activities denoted by *)
May 1991


November 1992

July 1993

January 1994


January 1995


January 19%

July 1996


January 1997

January 1998


January 1999
July 1999

January 2000


July 2000
National Primary Drinking Water Regulations
(NPDWRs) for lead and copper promulgated

Treatment technique requirements take effect

* Begin tap water monitoring

*Recommend optimal corrosion control treatment
by State1

State requires system to conduct corrosion control
studies2

State designates optimal corrosion control treatment3

'Complete corrosion control studies and
recommend treatment to State2

State designates optimal corrosion control treatment2

*Complete installation of corrosion control
treatment3

*Complete installation of corrosion control
treatment2

*Complete follow-up monitoring and submit
results to State3'4

State designates water quality parameters3

""Complete follow-up monitoring and submit
results to State2'4

State designates water quality parameters2
 Assumes system exceeds lead or copper action level during first monitoring period.
•^SmaH systems required to conduct comparative treatment studies.
3Small systems which State specifies optimal treatment without studies.
^Systems that continue to exceed action level begin 15-year lead service line replacement
program.

-------
MCLs
      Currently, if your test indicates lead levels above the current MCL, you
should:
     -Have three check samples tested to confirm test results.

     -Provide public notice of the MCL violation. Contact your state for specific
     requirements.

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
     in 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
    I	
     The above samples must be collected per monitoring period. One monitoring
period is equivalent to six months. There are two monitoring periods per calendar
year, January to June and July to December.

Sample collection methods
     -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.

-------
Actions your community should be taking
      -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.

      -Work with your State Agency and/or engineer to consider changes to your
      system to reduce lead levels to acceptable levels. This may include finding a
      new water source with lower lead levels of treating the present supply.
      Treatment technologies used for lead removal include: Ion Exchange,
      Reverse Osmosis, Lime Softening, Direct Filtration, and Coagulation/Filtra-
      tion. Both capital and operation and maintenance costs vary greatly for these
      different technologies.

      -Start planning now for ways to reduce the corrosivity of your water. If you
      have a corrosive water supply (as determined by tests done in the last 2 or 3
      years) and if lead and copper materials were identified in your system
      materials inventory recently completed, contact your State Agency for addi-
      tional sources of assistance.
        Additional Information

     The rule for lead and copper MCLs and treatment are contained on 40 CFR
     Part 1412 (1).

     State rules concerning lead and copper are contained in	.
     (The blank line is provided for you to insert where your State's rules are contained.)

     EPA, Region VIII Drinking Water Branch -1-800/759-4372, Ext. 1413.

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

     "Summary - Proposed Regulations For Lead In Drinking Water - Require-
     ments For Water Systems Serving Fewer Than 500 People," available from
     EPA.

        (See the listing for the State Drinking Water contacts in the Resource section)

-------
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.

Do the SOC regulations apply to my community?
     The six currently regulated pesticides only apply to surface water systems. The
trihalomethane MCL's only apply to PWS > 10,000 population. At present, there
are six regulated SOCs plus the disinfection by-products called trihalomethanes.

Timetable (for revisions to regulations)
     New regulations called Phase II were finalized January 30, 1991.  These
regulations added 13 new SOCs and revised five SOCs. All community and NTNC
PWSs will be required to test for SOCs. For a PWS that is vulnerable to SOCs,
quarterly sampling is required beginning in 1993, the first compliance period (1993-
19%) in the first compliance cycle (1993-2001).  If there are no detects of SOCs
repeat sampling is: two quarterly samples beginning hi the second compliance
period (19%) for PWSs greater than 3,300 people,  or one quarterly sample also
beginning in the second compliance period for PWSs with less than 3,300 people.

     It is the PWSs responsibility toperform the vulnerability assessment for SOCs.
The vulnerability assessment is mailed to the State with a request for a waiver. If
a waiver is granted by the State no monitoring is required for that compliance period.
The PWS must be granted a waiver before the year testing is required.  Every
compliance period thereafter, the PWS must update the vulnerability assessment
and be granted a waiver. To test for all the SOCs several methods are required,
which adds tremendously to  the cost.  The PWS should perform the vulnerability
assessment and secure the waiver prior to the year monitoring is required to avoid
a significant cost to the system.

     On July 25,1990, additional proposed regulations called Phase V add 15 non-
volatile SOCs and three VOCs. These rules will be finalized in March 1992.  The
same procedures and monitoring requirement will be used as with the May 1989
proposed rules. Because EPA is required to add new contaminants to the list to be

-------
regulated on a regular schedule, SOCs will probably be added to the list. The PWS
will want to perform a vulnerability assessment on these new SOCs and request a
waiver to eliminate monitoring.

MCLs
     A separate page is included to list current and proposed MCLs for SOCs.
Proposed MCLs will not be enforceable in very small systems until 48 months after
the final rules are published.

Actions your community should be taking
     -Complete any sampling for currently regulated SOCs as required, if your
     system uses surface water.

     -Cooperate with your State Agency to determine vulnerability of your water
     supply to SOC contamination. If it is determined that you are non-vulnerable
     (SOCs are not around to get in your supply) you will not have to sample for
     SOCs.

     -If your system is vulnerable, cooperate with your State Agency to get the
     first round of samples taken. Some states are doing this for very small systems.
     If SOCs are not  detected, you will not  have to sample until  the second
     compliance period (19%-1999).

Once the new SOC regulations are final, if your tests
indicate levels of a SOC higher than the MCL (averaged
over the  year), 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 Agency and complete public notices as required.

     -Request an exemption from the State Agency 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 Agency 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.  Filtering

-------
through granular activated carbon is suggested for most SOCs. Packed tower
aeration and polymer addition practices are used for some.

-Contact resource agencies listed in the back of this booklet for help in
working out financial needs.

-Changing water sources may be the most economical solution in situations
where available.
   Additional Information

The rules for SOCs are contained in 40 CFR 141.11,141.23,141.62.

State rules concerning SOCs are contained in	.
(The blank line is provided for you to insert where your State's rules are contained.)

"Pesticides in Drinking Water Wells," EPA. (Agricultural Extension Service
offices also have useful pamphlets on pesticides.)

National Safe Drinking Water Act Hotline, 1-800/426-4791.

EPA, Region VIII Drinking Water Branch -  1-800/759-4372, Ext. 1413.


   (See the listing for the State Drinking Water contacts in the Resource section)
                               -37-

-------
             MCLs for Synthetic Organic Chemicals  (SOC's)
Contaminant

Alachlor
Aldricarb
Aldicarb Sulfoxide
Aldicarb Sulfone
Atrizine
Carbofuran
Chlordane
2,4-D
Heptachlor
Heptachlor Epoxide
Lindane
Methoxychlor
PCB's
Pentachlorophenol
Toxaphene
2,4,5-TP (SILVEX)
Acrylamide
Epichlorohydrin
MCL: Proposed April 1989

       0.002 mg/1
       0.01 mg/1
       0.01 mg/I
       0.04 mg/1
       0.003 mg/1
       0.04 mg/1
       0.002 mg/1
       0.07 mg/1
       0.0004 mg/1
       0.0002 mg/1
       0.0002 mg/1
       0.4 mg/1
       0.0005 mg/1
       0.2 mg/1
       0.005 mg/1
       0.05 mg/1
Treatment Technique
Treatment Technique
MCL: Current
0.1 mg/1
0.004 mg/1
0.1 mg/1
0.005 mg/1
0.01 mg/1
                       MCL: Proposed July 1990
Endrin
Dalapon
Diquat
Endothali
Glyphosate
Di (Ethylehexyl) Adipate
23,7,8-TCDD(Dioxin)
Hexachlorocyclopentadiene
Oxyamly (Vydate)
Simazine
PAH's [Benzo(a)pyrene]
Hexachlorobenzene
Di(ethylhexyl) Phythalate
Pichloram
Dinoseb
       0.002 mg/1
       0.2 mg/1
       0.02 mg/1
       0.1 mg/1
       0.7 mg/1
       0.5 mg/1
       5x108 mg/1
       0.05 mg/1
       0.2 mg/1
       0.001 mg/1
       0.0002 mg/1
       0.001 mg/1
       0.004 mg/1
       0.5 mg/1
       0.007 mg/1
0.002 mg/1
                                -38-

-------
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, at present, there are eight regulated VOCs. These regulations became
final in July 1987, and require very small water systems to begin monitoring by
January 1,1991. Initial monitoring  is done by one sample every three months for
one year. States can reduce this to one sample for groundwater systems which are
not vulnerable.

     All community and NTNC public water systems must monitor for regulated
VOCs in their water supply. If VOCs are not detected, your system must monitor
again beginning in 1993. If VOCs are detected, monitoring must be done quarterly.

Timetable (for revisions of regulations)
      New regulations called Phase II proposed on May 22,1989 add 10 VOCs.
These rules are final as of January 30, 1991 and will require quarterly monitoring
beginning in January 1993. More new regulations proposed on July 25,1990 will add
three more VOCs.  Monitoring for these are proposed to begin by January 1,1996.

     If a system is non-vulnerable  a system may be granted a waiver which will
reduce monitoring. If you have a groundwater source, a waiver will reduce sampling
to once every six years.  If you have a surface water source, and you are non-
vulnerable, testing is done at state discretion. A PWS vulnerable to VOCs must test
annually beginning in 1994, after the four quarterly samples in 1993. The state may
grandfather or use the data taken previously and apply it to the critical monitoring.
This grandfathering of data will allow the replacement of the four quarterly samples
due in 1993 for one sample.

     Because EPA is required to add new contaminants to the list to be regulated
on a regular schedule, some VOCs may be added to the list from year to year. Little
change should occur to the very small system because all VOCs are tested from the
same sample and with little additional cost.

-------
MCLs
      A separate page is included to list current and proposed MCLs for VOCs.

Actions your community  should be taking
     -Complete any sampling for the first round of four quarterly samples for
     currently regulated VOCs as required. (In some states the State Agency is
     helping small systems with VOC sampling.)

     -Test for VOCs again beginning January 1,1993.  Grandfather old data.

     -Let your customers know through a newsletter or poster when you find that
     your water is free of VOC contaminates (and other contaminates that you
     don't have to worry about as well).

     -Apply for a waiver to reduce monitoring, before December 31,1992.

     EPA's revised drinking water regulations have been published in phases.
Phase I set monitoring requirements and MCLs for eight VOCs and required one-
time monitoring for up to 51 other "unregulated"  VOCs (listed in three lists).
Phase I became effective for small PWSs (< 3,300 population) in January  1991.
Phase II has now set MCLs and routine monitoring requirements for 12 of the 51
"unregulateds"  and these requirements go into effect in July 1992.

     All PWSs must comply with all the monitoring requirements and MCLs, The
only exception is for PWSs serving fewer than 150 service connections. Instead of
collecting samples for the "unregulateds" monitoring, PWSs serving fewer than
150 connections may simply send a letter to the State regulatory agency stating that
the system is available for sampling. The catch here is the overlap of  12 VOCs
between Phase I and Phase II.

     If a PWS serving fewer than 150 connections performs the monitoring of the
Phase I unregulateds, then the data for the 12 that become regulated in Phase II
can be "grandfathered" in for compliance with the MCLs.  If not, then the PWS
will have to monitor  the 12 VOCs quarterly for four  quarters when Phase II
becomes effective. (Doing one round of Phase I "unregulateds" in 1991 will save
having to do four analyses after July 1992.)

     In summary, regardless of State policy, all PWSs should test for lists one and
three of the unregulated contaminants to save money in monitoring costs in the
future. Testing list 1 will cover the future Phase II requirement testing; testing list
three will cover the future Phase V requirements.
                                  -40-

-------
If your tests indicate levels of a VOC higher than the MCL
(average over the year), you  are in violation of the MCL.
You should:
     -Continue quarterly sampling (at times of highest vulnerability).

     -Notify the State Agency and complete Public Notices as required.

     -Request an exemption from the State Agency 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 Agency and/or your engineer to determine how VOCs
     are getting into your water supply.  If possible, eliminate the source of
     contamination.

     -If you must treat your water supply to remove the VOC, work with your
     engineer to choose the best available technology for treatment. Filtering
     through Granular Activated Carbon and Packed Tower Aeration are com-
     mon treatments for most VOC removal.

     -Contact resource agencies listed in the  back of this booklet for help in
     working out financial needs.

     -Consider changing the source of your water supply as one option. This may
     be the most economical solution when available.
        Additional Information

     The rules for VOC are contained in 40 CFR 141.11,141.23,141.62.

     State rules concerning VOCs are contained in	.
     (The blank line is provided for you to insert where your State's rules are contained).

     Your State Agency will be able to provide additional fact sheets on VOCs,

     National Safe Drinking Water Act Hotline, 1-800/426-4791.

     EPA, Region VIII Drinking Water Branch - 1-800/759-4372, Ext 1413.


        (See the listing for the State Drinking Water contacts in the Resource section)
                                   -41-

-------
I.  Phase I        	

A. Regulated Volatile Organic
Chemicals Currently in Effect
   Contaminant

Trichloroethylene (TCE)
Carbon Tetrachloride
Vinyl Chloride
1,2Dichloroethane
Benzene
Para-dichlorobenzene
1,1-Dichlorehtylene
1,1,1 Trichloroethane
MCL: Final

0.005 mg/l
0.005 mg/l
0.002 mg/l
0.005 mg/l
0.005 mg/l
0.075 mg/l
0.007 mg/l
0.20 mg/l
B.  Unregulated Contaminants

List I: Monitoring Required For All
Systems
        Bromobenzene
        Bromodichloromethane
        Bromoform
        Bromomethane
        Chlorobenzene
        Chlorodibromoraethane
        Chloroethane
        o-Chlorotoluene
        p-Chlorotoluen
        Dibropmomethane
        m-Dichlorobenzene
        o-Dichlorobenzene
        trans-l,2-Dichloroethylene
        cis-l,2-Dichloroethylene
        Dichloromethane
        1,1 -Dichloroet hane
        1,1-Dichloropropane
        1,2-Dichloropropane
        1,3-Dichloropropane
        1,3-Dichloropropene
        2,2-Dichloropropane
        Ethylbenzene
Styrene
1,1,2-Trichloroethane
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
1,2,3-Trichloropropane
Toluene
p-Xylene
o-Xylene
m-Xylene
                List 2:  Monitoring Required for
                Vulnerable Systems

                Ethylene dibromide (EDB)
                l,2-Dibromo-3-Chloropropane
                (DBCP)

                List 3:  Monitoring Required at
                the State's Discretion

                     Bromochloromethane
                     n-Butylbenzene
                     Dichlorodiflouromethane
                     Fluorotrichloromethane
                     Hexachlorobutadiene
                     Isopropylbenzene
                     p-Isopropyltoluene
                     Napthanlene
                     n-Propylbenzene
                     sec-Butylbenzene
                     tert-Butylbenzene
                     1,2,3-Trichlorobenzene
                     1,2,4-Trichlorobenzene*
                     1,2,4-Trimethylbenzene
                     1,3,5-Trimethylbenzene

                *To be regulated in Phase V

-------
II.  Phase II
    Regulated VOCs Effective July
               1992
Contaminant
cis-l,2-Dichloroethlene
1,2-Dichloropropane
Ethylbenzene
Monochlorobenzene
0-Dichlorobenzene
Styrene
Tetrachloroethylene
Toluene
trans-l,2-Dichloroethylene 0.1 mg/1
Xylenes (total)           10 mg/1
MCL: Final
  0.07 mg/1
  0.005 mg/1
  0.7 mg/1
  0.1 mg/1
  0.6 mg/1
  0.1 mg/1
  0.005 mg/1
  1.0 mg/1
III. Phase V

            Regulated VOCs

                       MCL; Final
Dichloromethane
(Melhylene Chloride)    0.005 mg/1
1,1,2-Trichloroethane    0.005 mg/1
1,2,4-Trichlorobenzene   0.009 mg/1
 Monitoring begins January 1,19%.
 For additional information, contact
 your State office.

-------
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 andE. coli bacteria, are used as the best
and most easily tested for indicator of potentially harmful bacteria in the water.

Does the Coliform Monitoring rule apply to my
community?
      Yes, all community rjublic 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. All community PWSs have had to do  other testing.  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 notifica-
tion related to coliform monitoring. These rules were published in final form on
June 29,1989, and became effective December 31,1990. Most states have already
implemented them.

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).  A very small water
system may have no more than one coliform-positive sample per month.

Monitoring Requirements
     You are required to submit one routine sample 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. 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 Agency no later than the end of the next
business day that you learned of the violation.

-------
     If fecal coliforms or E. colt are identified in a sample in a month that the water
system violates the MCL, it becomes an acute violation and you must notify the State
Agency the same day you receive the results. The month following a violation of the
total coliform MCL you must collect five routine samples.  The State Agency may
choose to require more than one routine sample per month.

     A sanitary survey of your system is required at least every five years (usually
done by the State Agency). The initial survey must be completed by June 29,1994.
Without the sanitary survey, you would have to collect 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 your State Agency and ask for help to locate any possible sources of
     contamination.

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

     -Correct any problems causing contamination immediately. Contact one of
     the resource agencies listed in the back of this booklet if you need technical
     support or help in financing.
        Additional Information

-------
   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.

State rules concerning coliform monitoring are contained in	.
(The blank line is provided for you to insert where your State's rules are contained.)

EPA and your State Agency have several information sheets and pamphlets
on sampling and testing for coliform bacteria. Contact your State Agency for
more information.

You may also contact the National Safe Drinking Water Act Hotline at
1-800-426-4791.

EPA Region VIII Drinking Water Branch -1-800/759-4372, Ext. 1413.
   (See the listing for the State Drinking Water contacts in the Resource section)
                               -46-

-------
WATER  PROGRAMS
6
DRINKING WATER

SURFACE WATER TREATMENT RULE

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.

Timetable
     Compliance timetables under the Surface Water Treatment Rule are as
follows:

     A.  State Regulations
     1. State regulations necessary to implement the rule must be in place by
     December 30,1990.

     2. States must adopt by December 30,1990, procedures for determining
     whether a groundwater source is under the direct influence of surface water.

     B.  Surface water systems currently using filtration and disinfection
     1. The existing interim turbidity standard (1 ntu) continues in effect until
     June 29,1993.

     2. New Filtration criteria, disinfection criteria, and monitoring and report-
     ing requirements must be met beginning June 29,1993.

     C.  Surface water systems currently using disinfection only
     1. The existing interim turbidity standard (1 ntu) continues in effect until
     December 30,1991 (except as noted in the following item 5).

     2. PWSs are required to begin recording new monitoring and repotting
     requirements for unfiltered systems starting December 30,1990.  PWSs
     must  meet these new monitoring and reporting requirements starting
     January 1,1992.
                                 -47-

-------
      3. States must determine before December 30,1991, which systems are
      required to filter.

      4. If filtration is required, it must be installed before June 29,1993 or 18
      months after it fails to meet the avoidance criteria.

      5. If the state determines before December 30,1991, that an unfiltered
      system must filter, the system must comply with the existing interim
      turbidity standard until June 29,1993, or until filtration is installed, which-
      ever is later.

      D. Surface water systems currently using no treatment
      Disinfection must be installed, and the compliance deadlines under the
      preceding section C must be met.

      E. Systems using a groundwater source
      For each system using a groundwater source, the state must determine
      whether that source is under the direct influence of surface water according
      to the following deadlines:

        Community water systems - June 29,1994
        Non-community water systems - June 29,1999

      If a PWS is deemed groundwater under the influence (GWUI) of surface
      water it must begin sampling for the avoidance criteria within 6 months.  The
      PWS must begin meeting the avoidance criteria 18 months after the deter-
      mination. Failure to meet the avoidance criteria after 18 months may result
      in that PWS having to install filters. (Note: In some States, if a PWS is deemed
      GWUI they must install filters.) Check with your State as to their policy in
      using the avoidance criteria to avoid installing filtration.

Actions your community should be  taking
      -Public Water Supply must be operated by personnel that meet qualifications
      specified by the State or EPA. The water purveyor is required to monitor the
      water system, by sampling and testing the water, for compliance to the MCLs
      listed for the public water system category (community, non-community, etc).

      -Treatment must remove or inactivate at least 99.9% of Giardia lamblia cysts
      and 99.99% of viruses; all systems must disinfect, and might be required to
      filter if certain water quality and site-specific criteria are not met; criteria must
      be met for determining if treatment (turbidity removal, disinfection) is
      adequate for filtered systems.

-------
-Systems using surf ace water must send in reports to the State documenting
compliance with treatment and monitoring requirements.

-The EPA must be informed, as well as water users through public notifica-
tion, of any violations.
  Additional Information

The rules for surface water treatment are contained in 40 CFR 141.71(b).

State rules concerning surface water treatment are contained in	.
(The blank line is provided for you to insert where your State's rules are contained.)

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.

EPA, Region VIII Drinking Water Branch -1-800/759-4372, Ext. 1413.

November issue of .Opflow, AWWA newsletter to operators.

Contact your State Drinking Water Agency for additional information
about requirements  for certain reporting requirements.

   (See the listing for the State Drinking Water contacts in Resource section)

-------
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 nuclear reactive
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 every
four years.

Timetable (for revision of regulation)
      Proposed regulations were published in June 1991 that will add MCLs for two
additional radionuclides (Radon and Uranium). The Radon level will be set low
because it is easily removed by aeration and may raise the MCL for Radium 226 &
228. Final new rules may be published in late 1993. Systems will begin to monitor
under the newradionuclide 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 Proposed
   Gross Alpha Particle Activity    15 pCi/1
   Beta Particle & Photon Activity  4 mrem/yr.
   Combined Radium - 226 & 228  5 pCi/1
   Radium - 226
   Radium - 228
   Uranium
   Radon
15pCi/l
4 mrem/yr

20pCi/l
20pCi/l
20ug/l
300pCi/l
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). 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.

-------
      Compliance with the MCL is based on an average of the four quarterly
samples.

If your tests indicate levels of radionuclides higher than the
MCL, you should:
     -Ask the State Agency 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 your State Agency's instructions regarding when and what type of
     public notice you need to give.

     -Request an exemption from the State Agency 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 your State Agency and/or engineer to consider options
     to eliminate the radionuclides from your system. In nearly all very small
     community water systems, finding a different source of water supply is the
     most economical solution to a radionuclide problem.  Radon can be removed
     with aeration or granular activated charcoal. Any treatment may produce
     radioactive wastes that will be difficult to dispose of.

     -Agencies listed in the Resource section of this booklet may be able to help
     you in working with the State Agency, arranging for financing, and including
     your community in solving your violation 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 to your drinking water supply.

       Additional Information

     The rule for radionuclides is contained in 40 CFR 141.11,141.23,141.62.

     State rules concerning radionuclides are contained in	.
     (The blank line is provided for you to insert where your State's rules are contained.)


     "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.

     EPA, Region VIII Drinking Water Branch - 1-800/759-4372, Ext. 1431.


     EPA's "Radon in Drinking Water" pamphlet.

       (See the listing for the State Drinking Water contacts in Resource section)
                                   -51-

-------
WATER PROG/MAIS
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 to form disinfection
by-products (DBFs) which may prove to 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 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 August 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.

Actions your community should be taking
     -If your water supply is surface water, contact your State Agency to determine
     your schedule for compliance with the filtration and disinfection rules.

     -If your water supply is ground water and you are now adding a disinfectant,
     start regular disinfectant residual tests (weekly or monthly) at some consumer
     taps to determine how much disinfection is available at the "end-of-the-line"

-------
in your system. This will help you plan for modifications in your disinfection
to meet any new standards that are required.

-If your water supply is groundwater and you are not adding a disinfectant
now, the following steps may help in your planning:

   o Check your coliform bacteria tests over the past three or four years.  A
   history with some coliform positive tests are likely to require you to
   disinfect.

   o If you have no coliform positive tests, keep it that way by following a
   proper sampling procedure and through good maintenance and operation
   of your water supply and distribution systems.  You may be able to ask for
   an exemption to the new disinfection rule.

   o Look at and price different equipment for disinfection.  For most very
   small systems, chlorination provided through gas, liquid solutions or
   granular compounds are the methods used. Costs vary and may not be out
   of reach for your community. Your State Agency, engineer or an equip-
   ment supply firm can help you with this information.

   o Visit neighboring communities that are disinfecting and see how they
   do it and what it costs.

   o Start public information/education efforts to help your customers
   understand the reasons and advantages of protecting your water supply
   from contamination through disinfection: Resource agencies listed in the
   back of this booklet may be able to help you with this.

   Additional Information

The rules for Disinfectants and DBFs are in 40 CFR 1412 (b) (8).

State rules concerning Disinfectants and DBFs are contained in	.
(The blank line is provided for you to insert where your State's rules are contained.)

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

Your State Agency has materials available, which describe the proper
installation and use of disinfection equipment in small systems.

EPA, Region VIII Drinking Water Branch -1-800/759-4372, Ext. 1413.

   (See the listing for the State Drinking Water contacts in Resource section)
                              -53-

-------
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. It 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 (or 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.  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.
Your 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

-------
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
or you are informed of another violation, immediately contact your State Agency
and notify them of the violation and ask their direction in proceeding with public
notification. (Note: the State Agency may declare a sample invalid or requireacheck
sample before confirming a violation and thereby ask you to delay public notifica-
tion.)

Methods  of Notification
     Communities with a daily (or weekly) newspaper of general circulation
(received by most households) in the community:

     Her 1 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.
                                   -55-

-------
     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
     notice. Repeat this notice every three months as long as the violation
     continues.

Methods of Notification
     Communities without a newspaper:

     Her 1 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.

     Her 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.
                                  -56-

-------
 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.
  Additional Information

The rules for Public Notification are contained in 40 CFR 141,142, and 143.

State rules concerning Public Notification are contained in	.
(The blank line is provided for you to insert where your State's rules are contained.)

"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. The chart on the following page is taken from this manual.

EPA Region VIII Drinking Water Branch -1-800/759-4372, Ext 1413.
   (See the listing for the State Drinking Water contacts in Resource section)
                               -57-

-------
      Checklist of Public Notification Requirements for
                   Community Water Systems

     Part A:  Determine your notification requirements for each violation by
circling all that apply.  Read footnotes carefully.
                Public Notification Requirements
            «**•
                                           *»*•

                                        14    49
  ICftl

  1.MMX

  *.
                       TV wrf H^rin *•
VM

Vw
        V**
  TKftl

  I

  2.


  3.
 Foolnoces
 llf no newspaper of general circulation is available, posting or hand delivery is required as
 specified in...
 2May be waived in accordance with ...
 3Less frequent notice (but no less than annual) lo be required as in ...
                                   •58-

-------
    Part B: Check each item below that appears in the notice you have prepared.
When  all appropriate items have been checked, your notice should meet the
requirements established for General Public Notification.
                         Notice Contents

   The notice provides a clear and readily understandable
    explanation of the:

     - violation;

     - potential adverse health effects (mandatory health effects language);

     - population;

     - steps the system is taking to correct the violation;

     - necessity of seeking alternative water supplies (if any); and

     - preventive measures the consumer should take until the violation is
     corrected.

    The notice:

     - is clear and conspicuous in design;

     - contains non-technical language;

     - uses print that is easily read;

     - content creates no problems that would frustrate the purpose of public
     notification;

     .- contains the telephone number of the owner, operator, or designee of the
     public water system as a source of additional information; and

     - contains multi-lingual information, where appropriate.
                                   -59-

-------
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 regulations.

     Rule                                  Status         Effective

     Fluoride                               Final          10/87
     Lead Ban (SDWA1417)                  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 II lOCs and SOC                  Final          07/92
     Lead/Copper                           Final          01/92
     Phase V lOCs and SOCs                 Proposed      1993
     Phase III Radionuclides                  Proposed      1994
     Disinfection/Disinfection By-Products      TBP          19%
     Additional List Contaminants              TBP          1997

     - All dates after 1992 are estimated
     - 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

An Example of a Special  Schedule for Small Systems
     Not all  systems are required to comply with all the regulations upon the
effective date. Some of the requirements are "phased" in over time depending on
the size of the system, e.g., the monitoring requirements for VOCs and unregulated
contaminants. The following chart displays the actual schedule that smaller systems
must follow, unless otherwise informed by the state.
                                -60-

-------
Number of persons served

  Over 10,000
  3300 to 10,000
  Less than 3,300
Monitoring to begin by

January 1,1988
January 1,1989
January 1,1991
For additional information call EPA Region VIII Drinking Water Branch
1-800/759-4372, Ext. 1413.
                             -61-

-------
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
     WHPAs 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 Wellhead Protection Program requires the participation of all levels of
government. The Federal Government is responsible for approving State Wellhead
Protection Programs  and  for providing  technical  support to State and local
governments. States must develop and implement Wellhead Protection Programs
that meet the requirements of the SDWA Amendments.  While the responsibilities

-------
of local governments depend upon the particular requirements of their State's
Wellhead Protection Program, localities are often in the best position to implement
measures to ensure that wellhead areas are properly protected from contamina-
tion.

     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
maybe 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

     Ground Water Protection Document Request Hotline: 1-202/382-7779.


       (See the feting tor the Wellhead Protection contacts in the Resource section)
                                   -63-

-------
WATER  PROGRAMS
WASTEWATER

NATIONAL POLLUTANT DISCHARGE ELIMINATION
SYSTEM (NPDES)
     Public Law92-500 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 U.S. EPA or the state environmental control agency has responsibility
for administering NPDES permits. These permits are issued to operators discharg-
ing any pollutant (including wastewater effluent) to State/U.S. waters (such as
streams, lakes, wetlands, etc.)  If, however, the operator can effectively establish a
non-point discharge of domestic wastewater effluent, requirements and responsi-
bility for NPDES may be minimized.

     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.

Actions your community should be  taking
     Maximize community awareness and education concerning wastewater col-
lection and disposal, available solution alternatives, funding resources and proce-
dures 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. Your State Agency may be able to provide additional
information.

     Historically, state and  federal wastewater regulations  have  encouraged
metropolitan ideas to be used as a design guide for rural community systems. This
has significantly advanced industry technology, but according to the 1978 Control-
ler General Report to Congress, millions (billions by  1990) of state and federal
dollars have been spent unnecessarily in rural America.  Thus, Congress imple-
mented phase-out funding for the EPA Wastewater Construction Grant Program,
beginning October 1,1990.

     Reduced levels of funding for wastewater collection and disposal means rural
communities and their technical consultants must identify appropriate technology
resources to substantially reduce capital project cost and operating expense if
wastewater collection and  disposal is  to be affordable and  effective in rural
America.

-------
    Fortunately, these technology resources are available, but not all technical
consultants, regulatory authorities and funding agencies have made the necessary
transition to facilitate full use of these options. Thus, it is crucial in the decade of
the 90*s to better educate all participants if the most appropriate and affordable
wastewater collection and disposal facility is tobe installed in your  particular
community. Knowledge and cooperative efforts from all parties are essential for
rural America to have successful wastewater collection and disposal in the decade
of the 90s.
       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.

     Small Wastewater Systems - Alternative Systems for Small Communities and
     Rural Areas, EPA National Small Flows Clearinghouse, 1-800/624-8301.
     "T*»,
 'It's Your Choice - A Guidebook for Local Officials on Small Community
Wastewater Management Options," EPA National Small Flows Clearing-
house, 1-800/624-8301.

"Self-Help Handbook," Jane Schautz, Rensselaerville, NY 12142,
518/797-3783.

"Community Managed Septic Systems - A Viable Alternative to Sewage
Treatment Plants," Controller General Report to the Congress of the United
States, CED 78-168, 11/3/78.

"Design Manual - Constructed Wetlands and Aquatic Plant Systems for
Municipal Wastewater Treatment," Center for Environmental Research
Information, Cincinnati, OH 45268, EPA/625/1-88/022.

   (See Ihe listing for the State Water Quality contacts in the Resource section)
                                   -65-

-------
WATER PROGRAMS
WASTEWATER

SECONDARY TREATMENT OF MUNICIPAL
WASTEWATER
     Secondary treatment is the minimum treatment requirement for most Publicly
Owned Treatment Works (POTW). The secondary treatment, among other things,
requires that effluent concentration of five-day biochemical oxygen  demand
(BOD5) and total suspended solids not exceed 30 mg/1 as a 30-day
average. Some States allow higher total suspended solids limits if certain conditions
are met. In general, at a minimum the treatment process must be a stabilization pond.

Does the secondary treatment regulation apply to my
community?
     Yes, all treatment facilities that discharge to waters of the U.S. must comply.
Beneficial uses of the receiving waters may necessitate higher quality effluent be
discharged or possibly require no point discharge.

Actions your community should  be taking
      If a wastewater treatment plant discharges to waters of the State/United
States (such as streams, lakes, wetlands, etc.), it is required to have a National
Pollutant Discharge Elimination System (NPDES) permit. States may have slightly
different names for  their permit programs.  The permit will specify effluent
limitations and monitoring requirements.

     If the POTW cannot meet the effluent limitations specified in the permit, it may
be necessary to upgrade the treatment facility, review operational improvements,
and/or improve the sewer collection system to correct excess  inflow/infiltration
problems.

     If you suspect a problem, notify the organization you feel appropriate, starting
with the POTW itself, community officials, county sanitarians, or state officials
responsible for water quality and/or wastewater discharge permits.

       Additional Information

     U.S. EPA Secondary Treatment regulations, 40 CFR 133.

     "Needs Survey Report to Congress," EPA, February 1987.

     "Overview of Selected EPA Regulations and Guidance Affecting POTW
     Management," EPA, September, 1989.

       (See the listing for the State Water Quality contacts in the Resource section)

-------
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 handled properly and is
of sufficient quality for use as a soil conditioner, fertilizer, or other intended use.

Do the sewage sludge  regulations apply to my community?
    Yes, if the wastewater treatment system  includes any form of central
treatment or mechanical plant, including a lagoon, which will need to be cleaned.

    No, if the wastewater treatment mechanism is by individual on-site septic
systems; however, these do produce septage which must be properly disposed. See
local and state regulations and proposed sludge rules.

Timetable
    Proposed rules were Public Noticed February 6,1989 and will be located in
40 CFR 503. Many sections of the proposed regulation are undergoing changes,
and the effective date of the regulation is expected to be early 1992. If you can meet
the requirements of the sludge regulations without construction you must do this
within 12 months of the final regulation. However, if construction is required you
will have 24 months from the effective date of the regulation.

Actions your community  should be taking
    Be  aware of restrictions covering proper use of the sewage sludge land
application (both agricultural and non-agricultural) or distribution and marking,
and proper disposal (landfilling, incineration, and surface disposal). Contaminated
sludge or poor disposal practices can pose a threat to public health and the
environment.

    Monitoring will be required and specified in the NPDES permit.
                                -67-

-------
  Additional Information

State Sludge Management Program Regulations are contained in 40 CFR
501. Proposed Federal Regulations for sewage sludge are contained in 40
CFR 503.

EPA's Policy Promoting The Beneficial Use Of Sewage Sludge and The New
Proposed Technical Sludge Regulations, June 1989.

"Environmental Regulations and Technologies-Control of Pathogens in
Municipal Wastewater Sludge," September 1989.

"Suggested Guidelines for the Disposal of Drinking Water Treatment
Wastes Containing Naturally Occurring Radionudides," U.S. Environmen-
tal Protection Agency, Office of Drinking Water, July 1990.

"Guide to Soil Suitability and Site Selection for Beneficial Use of Sewage
Sludge," Manual 8, Oregon State University Extension Services/U.S. EPA
(Less  than five copies are FREE of charge.)

Information may be obtained by contacting the county sanitarian, or your
State Agency responsible for water quality.
   (See the listing for the State Water Quality contacts in the Resource section)

-------
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. Pretreatment is the treatment of a waste before it is discharged into the
sanitary sewer. A pretreatment program includes ordinances, education, inspec-
tions, monitoring, and enforcement.

    Pretreatment requirements, in other words, control pollutants which are
incompatible or will interfere with the treatment process or pass-through the
POTW and cause problems in the receiving stream or lake. In addition, pretreat-
ment 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 re-
quired to establish local pretreatment programs. Very small communities have
few, if any, non-domestic users.

    If the community has non-domestic users (such as sawmills, food processing
plants, metal finishers,  etc.) 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 National Pollutant Discharge
Elimination System (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
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 pretreat-
ment standards  are in place to protect the POTW, the receiving stream and
municipal sludge quality.
                                 -69-

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

     If you suspect a problem, notify your POTW operator, community official,
county sanitarian, department of state government responsible for wastewater
discharge permits or the Environmental Protection Agency. All states have such
departments.
        Additional Information

     Pretreatment Final Rule, 40 CFR 403.

     Your State Agency or EPA will be able to provide additional details.

     (See the listing for the EPA State Pretreatment contacts in the Resource section)

-------
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 II (sometime after October 1992) may
require communities less than 100,000 to obtain a permit and develop a storm water
management program. It is unknown at this time if there will be exemptions for very
small communities.

     The industrial side of the program requires specific "industrial type" facilities
(see attached page on storm water associated with industrial activity) to apply for
and obtain a permit regardless of the size or ownership (private or government) of
the operation.

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, construction activity
and possibly others) 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 runoff water collects in street gutters and storm drains
 and flows directly to streams with little or no treatment. Educate the citizens that
 they play a role 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.

     Classes of facilities that discharge storm  water associated with industrial
activity.

     -Facilities subject to National effluent limitation guidelines;

     -Facilities classified as Standard Industrial Classification (SIC) Codes 24
     (except 2434), 26 (except 265 and 267), 28,29,30,311,32,33 3441, and 373
     (including lumber; paper; chemical; petroleum; rubber; leather tanning and
     finishing; stone, clay, glass, and concrete; metal; enameled iron and metal
     sanitary ware; and ship/boat manufacturers);

     •Facilities classified as SIC codes 10 through 14 including active and inactive
     mining and oil and gas operations with contaminated storm water discharges,
     except for areas of coal mining operations which have been reclaimed and the
     performance bond has been released by the appropriate Surface Mining
     Control and Reclamation Act (SMCRA) authority, or non-coal mining
     operations which have been released from applicable State or Federal
     reclamation requirements after 30 days after publication of the final regula-
     tion;

     -Hazardous waste treatment, storage, or disposal facilities;

     -Landfills, land application sites, and open dumps that receive industrial
     wastes;

     -Recycling facilities including metal scrap yards, battery reclaimers, salvage
     yards, and automobile junkyard (classified as SIC codes 5015 and 5093 only);

     -Steam electric power generating facilities (including coal handling sites);

     -Transportation facilities classified as SIC Codes 40,41,42, 44, and 45
     (including vehicle maintenance, equipment cleaning, and airport deicing
     areas);

     -Treatment works treating domestic sewage or any other sewage sludge or
     wastewater treatment device or system, used in the storage, treatment,
     recycling, and reclamation of sewage (including land used for the disposal of
     sludge located within the confines of the facility) with a design flow of 1.0 mgd
     (million gallons per day) or more;

-------
-Construction activity (except for disturbances of less than five acres of total
land area which are not part of a larger common plan of development or sale);
and

-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).
                               -73-

-------
DEFINITIONS-ACRONYMS
     AHERA - Asbestos Hazard Emergency Response Act

     ASHAA - Asbestos School Hazard Abatement Act
     Bacteria - Microbiological contaminants frequently found in drinking water
     samples are fecal coliforms and the bacterium E. coll. Their presence is
     evidence of sewage contamination.

     CERCLA - Comprehensive Environmental Response, Compensation and
     Liability Act

     CFR - Code of Federal Regulations

     DBF - Disinfection By-product

     EPA - Environmental Protection Agency

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

     GWUI - Ground Water Under the Influence (of surface water)

     IOC - Inorganic Chemical

     IRAA - Indoor Radon Abatement Act

     LEA - Local Education Agency

     LEPC - Local Emergency Planning Committee, established under SARA

     MCL - Maximum Contaminant Level

     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

Public Water System - (25 or more persons or 15 or more service connections)

RCRA - Resource Conservation and Recovery Act

RCP - Radon Contractor Proficiency

SARA - Superfund Amendments and Reauthorization Act

SDWA - Safe Drinking Water Act

SMCRA - Surface Mining Control and Reclamation Act

SERC - State Emergency Response Commission, established under SARA

SMF - Standardized Monitoring Framework

SOC - Synthetic Organic Chemical (non-volatile)

State  Agency - When used in this handbook, "State Agency" or "State,"
means that department of the State Government designated by the Governor
and approved by EPA to administer the rules discussed in this handbook.
State agencies with addresses and phone numbers for each state in Region
Vffl are listed at the end of this handbook.

Surface Water - Water that is open to the atmosphere and subject to surface
runoff.

TCLP - Toxicity Characteristic Leaching Procedure

TSCA - Toxic Substances Control Act

UST- Underground Storage Tank

VOC - Volatile Organic Chemical

WHP - Wellhead Protection

WHPA-WellheadProtectionArea
                             -75-

-------
RESOURCE MATRIX
            Pollution
 SUI»       Prevention

 Colorado    Don Patton
            U.S.  EPA
            999 l»h Street, Suite 500
            Denver, CO 80242
            3*3/293-145*

            Sharon Chlldi
            U-S.  EPA
            309/293-1471
Public-Private
Partnership*

Don Patton
U.S. EPA
999 18th Street, Suite 5*0
Denver, CO 80202
303/293-1456
Emergency
Response

Department of Health
Wiwte Management Division
4210 E. llth Ave
Denver, CO 80220
303/331-4858

U.S. EPA
303/2S3-17Z3
 Montana
 No. Dakota
 So. Dakota
 Utah
            Don Patton
            U.S. EPA
            303/2*3-1456

            Sharon Child*
            C.S. EPA
            303/2*3-1471
            Dan Patlon
            U.S. EPA
            303/2*3-1456

            Sharon Child*
            U.S. EPA
            303/2*3-1471
            Don Patlon
            U.S. EPA
            303/2*3-1456

            Sharon Child*
            U.S. EPA
            303/293-1471
            Don Patton
            U.S. EPA
            303/2*3-145*

            Sharon Child*
            U.S. EPA
            303/2*3-1471
Don Patton
U.S. EPA
303/2*3-1450
Don Patton
U.S. EPA
303/2*3-1456
Don Patton
U.S. EPA
303/293-1454
Department of H<0lth and
Environmental Science*
      ill Bulldlne Room A206
Don Fatten
U.S. EPA
303/2*3-1456
406/4M 3*48

U.S. EPA
303/2*3-1723

Dlvtalon of Emergency Menu
State Emergency Oper. Center
P.O. BOB 5511
Bttmark, ND SBSOi-SSll
7011224-2111

U.S. EPA
303/2*3-1723

Department of Environment
* Natural Resource*
Joe Fo» Building
523 E. Capllol Ave.
Pierre. SD 57501-3181
•BS/T73-31S1

U.S. EPA
303/2SJ-1723

Departmont of Envlronmentsd Quality
Dtvbton of Environmental
Management
P O Box 1*690
Salt Lake Oty, UT Ml 14-4820
Ml/538-033

U.S. EPA
308/1*3-1723
            Don Patton
            U.S. EPA
            303/2*3-145*

            Sharon Child*
            U.S. EPA
            303/2*3-1471
Don Patton
U.S. EPA,
303/2*3-1456
WY Office of Emergency Mgmt
P.O. Box 170*
Cheyenne,  WY 82003
307A77-7566

U.S.  EPA
303/2*3-1723
 HoUlne
                                                                               1-800A35-02A2

-------
RESOURCE MATRIX
       Ah-
                                         Asbestos
                                                                             Radon
       Phlrtcb Rebbeck
       VS. EPA
       99» 18th Street, Suite 500
       Denver, CO  80202
       303/293-1758
       Patricia Reisbeck
       U.S. EPA
       303/2*3-1758
V.S. EPA (8AT-TS)
999 18th Street, Suite 500
Denver, CO  80202
303/293-1442

Steve Fine
Air Pollution Control Dlvttion
Department of Health
4210 Ea»l Illh Avenue
Denver, CO 80220
3*3/331-8592

Jack Bendbton
Denver Department of Health
and Hoiipllali RM-333
605 Bannock Street
Denver, CO 802
-------
RESOURCE  MATRIX
 Slate

 Colorado
 Hazardou*
 Waale

 Para Harlcy
 Solid Warte and Incident
 Management Section
 Department of Health
 4210 East Jlth Awe
 Denver, CO 80220
 303/331'I830

 KeBy Robcrtj
 Recycling Coordinator
 OfTtce of Energy Cocuervatlon
 1*75 Broadway, Suite 1300
 Denver. CO M2*2-4oI3
 303/620-C92
            r*ll PoweM
            Solid & Hazardou*
            Wad* Bureau
            Department of Health *
            Environmental Science*
            CoMwetl Buildlnt
            Helena, MT 5K20
            406/444-1430
 No. Dakota
            Neil Knatterud
            Dtv. ofWacteMfmt
            Department of Health *
            ConMttdatod Laboratorte*
            1200 MhtMuri Ave
            Btemarck, ND 585024530
            701/721-51*4
I'nderground
Sloragf Tank*

CO State L'ST Coordlnalor
Department of Health
Ha*.  Mat. A Wane Mgmt.
Undereround Tank Pracnun
•CIO  Eait llth Ave
Denver, CO 80220
5M3/3M-487S
                                  MT Slate 1ST Coordinator
                                  I'ST Prefram
                                  Department *T Health A
                                  Envtronmentat Sdencw
                                  Canwdl BulMlne, Room 8201
                                  HeTena. MT5M3B
                                  40*V444nS«70
                                  ND Slate I'ST Coordinator
                                  Department of Health *
                                  CocualMated Laboratorta
                                  DrvMen of Want Management
                                  UOO  MlMMirl Avenue
                                  BUmarek, ND SRSOZ-5520
                                  70I/ZZ1-51M
 Wetland
 ProttclkMi

 John Brink/Enforcement
 U.S. EPA
 999 IMh Street, Suite 500
 Denver, CO 80202
 303/2W-1547

 Sara Fowler
 Permit Review, 230.80
 US. EPA
 303/299-1575

 Vern Hetblg
 Permft Review, 230.80
 Enforcement
 U.S. EPA
 303/2*3-1585

 Brad Miller
 Enforcement, Policy
 U.S. EPA
 303/293-1583

 Paul Mclver
 Public Outreach
 U.S. EPA
 3«3/2»-IS52

 Sieve Potu/Permft Review,
 Enrorcement
 Montana Operationi Office
 Fed. Slate Bid* Drawer 19996
 Ml South Park
 Helena, MT 5M20-002«
 406/444-Sttt

 John Brink
 303/2*3-1547

 John Peten
 Permit Review, 230.80, Enfaonvt
 U.S.  EPA
 303/2»-157»

 Paul  Mclver
 303/2*3-1552

John Brink
303/2*3-1547

John Peter*
303/2*3-157«

Paul Mclver
303/2*3-1552
 So. Dakota  Terry Kdler
 Utah
            Dhr of Envfr Refutation
            Department of Environment *
            Natural !
            31» S. Coteau
            Oo 500 E. Cap)!*!
            Pierre, SD 57501-31M
            0*5/773-3153
Ru»ty Lundberf
Ptannlng * Pr«fram Dtvetopment
Section
Dlvtoton of Solid * Has. Wtute
Department of Environmental Quatfrr
288 North 14*0 Weal
Salt Lake City, IT 84114-4820
Ml/5384170
                                  SD State UST Coordinator
                                  Offlce of Water Quality
                                  Department of Environment A
                                  Natural Resource.
                                  Joe Fat* Building
                                  52) E. Capital
                                  Pierre, SD 57501-3181
                                  005/773-3351
                                              IT Slate UST Coordlnalor
                                              Dtvteton of Solid « HM. Wa»te
                                              Department of Environmental Quality
                                              28?North 14*30 WeM
                                              Satl Lake City, IT 84114
                                              801/S38-47S2
                                 John Brink
                                 303/2«-W47

                                 Bob Malrley
                                 Permit Review, 230.80,
                                 Enforcement
                                 U.S. EPA
                                 303/2*3-1582

                                 Paul Mclver
                                 303/2*3-1552

                                 John Brink
                                 303/2*3-1547

                                 Paul Mclver
                                 3«3/2*3-1552

                                 Bob Malrley
                                 303/2*3-1582
                                                    -78-

-------
RESOURCE MATRIX
    Drinking
    Water

    Department of Health
    4210 East llth Avenue
    Denver, CO  80220
    303/331-4545

    U.S. EPA
    l-8Mr7SM372, Ext. 1413
U.S. EPA
Groundwater Branch (8WM-GW)
999 IKlh Street, Suite 500
Denver, CO 80202-2405
903/294-1162

U.S. EPA
Washington, 0.C.
202/382-7077
Water
Quality

Department at Health
Water Quality Control Dlv.
4210 East llth Avenue
Denver, CO 80220
303/331-4534
     Water Quality Bureau
     Department of Health &
     Environmental Science*
     Cornell Building, Rm A206
     Helena, MTS9IS20
     U.S. EFA
     I4IV7SM3T2, ExL 1413
U.S. EPA
303/294-1162

U.S. EPA
Washington, D.C.
Water Quality Bureau
Department of Health &
Environmental Science*
Cogswell Building
Capitol Station, Room A206
Helena, MT 59620
406/444-2406
    DftWon rf Water Supply *
    FWIutton Centroi
    Stale Department of Health
    ConMlldated Laboratories
    1200 Mbwurl Avenue
    Blwnarck, ND S8S02-5520
    7tl/231-S210
    VS. EPA
                 Ext. 1413
    OfTk* of Drlnklnf Water
    Department «T Environment Jk
    Natural RMMircct
    Jw F«M BtilMInc
    523 East Capitol
    Pierre, SO
U.S. EPA
3*3/294-1162

U.S. EPA
Washington, D.C.
2027382^077
U.S. EPA
303/294-1162

U.S. EPA
Wathlngton, D.C.
202^82-7077
EnvlronmentaJ Health Stctkwi
Slat* Department of Health &
Cwuolldaled Laboratorle*
1200 MlMourl Ave, Rm 102
Bismarck, >T> 58502-5520
701/221-5210
Department at Environment It
Natural Resource*
Joe FOM Building
S23 East Capitol
Pierre, 9D 77501-3181
MS/773-3151
    U.S. EPA
    1^0V759-4372,  ExL 1413
    Sail Lake City County
    Health Department
    (10 South 200 East
    Salt Lake City, UT Mill
    W1/S34-4S4I
    V.S. EPA
    l-WO/759-4372,  Ext. 1413
U.S. EPA
3*3/2*4-1162

U.S. EPA
Washington, D.C.
202/382-7077
Department of Environmental QuaMy
Division oT Water Quality
288 North 1460 West
Salt Lake City, UT 84114-4870
801/538-6146

-------
RESOURCE  MATRIX
State

Wyoming
           Hazardou*
           Wa*tt

           David A. Flnfey
           SolU Watte Program
           Dcpt of EnviranmcntaJ Quality
           Htndifer Building, 4th Flow-
           is Wen 2Slh Str«4
                 , WY 8SM2
Undcrfround
Sloragf Tank*

WY Stale LST CMrdlnafair
Dept oT Envtronmcntal Quality
Water Quality DivHton
Hendtlcr BulWIng, «h Ftoor
122 Wett 2SUi Slrtrt
Chcyenae. WY 82MC
3«7/7T7-7WS
Wrtland
Protertlon

John Brink
3W3/2W-1S47

BobMalrley
                                                                 Vern HHblg
                                                                 3O/2*9-15te

                                                                 Paul Mclvw
  HMllM
                                          -HO-

-------
RESOURCE MATRIX
  Drinkhtf
  Water

  tVotrtoeiit *T Environmental

  *5er Quality DrvWoB
  Kenchler ButMtnf, 4th floor
  Łt Wcrt 2Stb Street
  Cheyenne. WY CMZ
  WW77T-7781

  U^. EPA
  1-«*V7SM372, Ext 1413
Prol«cHon

U.S. EPA
3*3/294-11C

U.S. EPA
WariilncUm, D.C.
2C/383-7t77
Wa««r
Quality

Department of Environmental
Quality
Water Quality DtvUfam
Hcnchler Building, 4th FToor
122 W«t 2Sth Street
Cheyenne, WY 8BMZ
3«7/777-7t72
                             1-2K2/382-7T79
                                                         1-800/634-8J01
                                        -81-

-------
RESOURCE  MATRIX
   Slate

   Colorado
   Montana
   No. Dakota
   So. Dakota
   Utah
   Wyoming
Sludge

Phil H«f«nui
Department of Health
4210 East nth Avenue
Denver, CO  80220
303/331-4544
Scatl Anderson
Water Quality Bureau
Department of Health &
Environmental Science*
Cornell Building. Room KM
Helena, MT 596:4-5520
406/444-2406
Sheila McOnathan
Diction of Wain- Quality
State Department of Health A
Consolidated Laboralork*
1200 MbMMtH Avenu*
Bismarck, ND 5850B-5S20
701/221-5210
Wltliam Geyer
Division of Waler Resource
Management
Department of Environment
Natural Resource*
Joe FOM Building
SO Ea*t Capltoi
Pierre. SD 57501-3181
405/773-3351
Paul Krauth
Department of Environmental
Quality
Division of Water Quality
288 North 1440 We*!
Salt Lake City. LT 841U-«7»
M1/SW4I4*
Pretrattment

Department of Health
4210 E«*l llth Avenue
Denver, CO MZ3»
349031-4590

U.S. EPA
WaW Management DlvUon
IndiMtrlal Prematmenl
9*9 18th Street, Suite SM
Denver, CO 80242-2405
1-8M/7S9-4372
U.S. EPA
Iitdutlrtal Pretreatnwnt
U.S. EPA
Industrial Pretnatment
1-WO/7SM372
U.S. EPA
Industrial Pretreatment
John Wapwr (permlU)
E.J- Fannlnc (tcchnotogy)
Department ef Environmental
Quality
Water Quality Dtvtf ton
Herachler Building. 4th Floor
Cheyenne, WYCM2
3«7/777-7B82 (P)
M7/777-TD74 (T)
                                                 Department of Environmental Quality
                                                 Division of Water Quality
                                                 288 North 1460 We*t
                                                 Salt Lake City, IT 84114-487«
                                                 801/538*144
                                                 U.S. EPA
                                                 IndutfrtaJ Pretrealmenl
                                                 14MHSM972
U.S. EPA
Induitrtel Pretreatnient
 Storm Water

 Vern Berry
 U.S. EPA
 99* 18th Street, Suite 500
 Denver, CO 88202-2405
 330/293-1240

 Patricia Nebon
 Department of Hearth
 Water Quality Control Division
 4210 Eatt llth Avenue
 Denver, CO 80220
 903/331-4590

 Vern Berry
 U.S. EPA
 303/29M240

 Fred Shewman
 Water Quality Bureau
 Department of Health *
 Environmental Science*
 Cogswell building
 Helena, MT 59620
 406/444-2404

 Vern Berry
 U.S. EPA
 303/295-1240

 Shelta McClenathan
 Division of Water Quality
 Slate Department of Health it
 ConsolldatMl Laboratork*
 1200 Mluourl Ave
 P.O. Box 5520
 BUmarck. ND 58502-5520
 701/221-5210

 Vern Berry
 U.S. EPA
 330/293-1240

 Glenn Pterltz
 Dtvlikm of Environmental
 Regulations
 Department of Environment It
 Natural  Rewurce*
 Joe FOM Building
 523 Ewt Capitol
 Pierre, SD57S01-3181
Vern Berry
U.S. EPA
303/293-1240

Paul Krauth (Municipal)
Harry Campbell (Industrial)
Department of Environmental
Quality
Division of Water Quality
288 North 1460 Wat
Salt Lake City, IT 84114-4870
801/538-4144

Vern Berry
t'.S. EPA
330/293-1260

John Wagner
Department of Environmental
Quality
Water Quality Division
Herschier Building, 4th Floor
122 We*l 2Slh Street
Cheyenne. WY 82002
307^777*7082
   Hotline
                                                                                    703/734-3124

-------