Guide for developing and implementing a small community environmental protection plan (SCEPP)

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Publication Number TM 07-04







Table of Contents



SECTION 1 Resources Purpose Small Communities and Special Districts Mandated Requirements SECTION 2 Safe Drinking Water System Requirements Most Common Drinking Water Violations Source Water Protection Self-Assessment Questionnaire SECTION 3 Wastewater System Aquifer Protection Permits AZ-National Pollutant Discharge Elimination System (AZPDES) Permit Pretreatment Requirements Wastewater Biosolids Use and Disposal Storm Water Most Common Wastewater Violations Water and Wetlands Protection Self-Assessment Questionnaire SECTION 4 Hazardous Waste and Municipal Solid Waste Municipal Solid Waste Disposal Local Standards Operational Criteria Design Criteria Groundwater Monitoring & Corrective Action Closure & Post-Closure Care Financial Assurance Other Solid Waste Facilities Self-Assessment Questionnaire SECTION 5 Contingency Plans - RCRA Self-Assessment Questionnaire SECTION 6 Emergency Planning - EPCRA Reimbursement to Local Governments (Superfund) SECTION 7 Comprehensive Environmental Response - CERCLA SECTION 8 Underground and Aboveground Storage Tanks Self-Assessment Questionnaire For Hazardous Substance UST Only UST Financial Responsibilities Requirements Aboveground Storage Tanks Page 2 Page 3 Page 5 Page 1 Page 3 Page 17 Page 18 Page 1 Page 2 Page 3 Page 6 Page 7 Page 7 Page 8 Page 9 Page 10 Page 1 Page 3 Page 5 Page 5 Page 6 Page 6 Page 6 Page 6 Page 7 Page 9 Page 1 Page 2







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SECTION 9 Clean Air Act & Amendments Air Quality Permits Issued by ADEQ Self-Assessment Questionnaire Compliance with National Air Quality Standards Open Burn Permit Requirements Asbestos NESHAP Program and Notification Requirements What Firefighters Need To Know About Asbestos In Buildings Toxic Air Pollutants: Hazardous Air Pollutants (HAP) Publicly Owned Treatment Works SECTION 10 Toxics: Lead PCB SECTION 11 Pesticide Storage Self-Assessment Questionnaire SECTION 12 SPCC (Oil Spill) Program Arizona Used Oil Regulatory Program Self-Assessment Questionnaire SECTION 13 Pollution Prevention (P2) Self-Assessment Questionnaire SECTION 14 Mini Capital Improvements Plan for Small Communities Arizona Water Infrastructure Finance Authority (WIFA)







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Appendices



Appendix A Acronyms Appendix B: SCEPP Instructions, Examples, Template and Forms Template To Follow Appendix C: SCEPP Checklist Page 1







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Contact ADEQ's Community Liaisons for more information on the Small Communities Environmental Compliance Assistance Program.



Northwestern Arizona: (928) 779-0313 Northeastern Arizona: (928) 337-3565 Southwestern Arizona: (928) 373-9432 Southeastern Arizona: (928) 348-4040



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An Implementation Guide for a







Small Community Environmental Protection Plan



November 2007







Section 1 Page 1







SECTION 1



Resources: Small Community Environmental Prevention Plan (SCEPP) This guidance was prepared by the Arizona Department of Environmental Quality (ADEQ) under Agreements with the Environmental Council of States (ECOS) and the U.S. EPA Environmental Policy and State Innovation Grant. This guidance was financed in part by funds provided by ECOS and EPA. This guidance was developed using resources created by the Environmental Protection Agency (EPA) and other state environmental agencies and the nonprofit National Environmental Services Center at West Virginia University. We encourage you to review the following resources for detailed information on understanding and developing your community's SCEPP. Trilogy Environmental Software Trilogy was created by the Department of Agricultural and Biological Engineering of Purdue University in conjunction with the Environmental Protection Agency for Region V (MN, WI, IL, MI, IN, OH.) This EPA program offers a complete one-stop introduction to a wide range of environmental issues and decisions that affect small to medium-sized communities. It offers communities the chance to judge their own needs and preferences, and to make informed decisions on their own. Major sections cover: 1. Environmental laws and regulations 2. Self-assessment 3. Planning and comparative risk analysis 4. Financial tools and financial self-analysis 5. Case studies 6. Contact and information directory Limitations under the copyright, which allows for free reproduction and distribution of the software, can be found on the program's title page at. http://www.epa.gov/seahome/trilogy.html Sample EMS Manual The Environmental Management System (EMS) Model Manual Specific to Pennsylvania Municipal Operations was prepared for the Pennsylvania Department of Environmental Protection by Five Winds International. http://164.156.71.80/VWRQ.asp? docid=0442d740780d00000000080f0000080f&context=2&backlink=WXOD.aspx%3ffs% 3d0442d740780d00008000080200000802%26ft%3d1 EMS Implementation Guide for Small and Medium Sized Communities Voluntary Environmental Management System /ISO 14001/Publications. In December 2000, the U.S. EPA, in cooperation with NSF International, completed a revised version of this guide entitled "Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations". This revision replaces the original Guide, published in 1996. Like its predecessor, the revised Guide is intended to offer a plain English, common sense guide to organizations interested in implementing an EMS, using the basic Plan-Do-Check-Act model. The revised guide includes a number of updated examples and can be used by organizations of all sizes. We encourage you to take advantage of this easy to read guide and share it with your colleagues. In 2001 EPA made bound copies of the Guide available through its Water Resource Center. The number for the Water Resource Center is (202) 566-1735. When calling the Center, you will receive a voice message. Please respond to the message and refer to the Guide by name. You can view the complete guide online or download the guide at http://www.epa.gov/owm/iso14001/wm046200.htm#guide1







Self-Assessment Tool for Small Decision Makers West Virginia University � National Environmental Services Center at http://www.nesc.wvu.edu/netcsc/Self_Assmnt/SelfAssessment.pdf



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Purpose



The Arizona Department of Environmental Quality (ADEQ) Small Community Policy recognizes the limited financial, technical, and administrative resources available to small communities for environmental compliance. This guidance and self-assessment questionnaires are designed to promote the development and implementation of a Small Community Environmental Protection Plan (SCEPP).







Special Penalty Considerations



This self-assessment guidance is designed to be used in identifying, prioritizing, correcting, and preventing future environmental compliance problems. ADEQ will make special penalty considerations for small communities and special districts willing to work with ADEQ to achieve these goals. ADEQ will be available to assist in the development of the SCEPP necessary to achieve and maintain compliance with the focus on ADEQ's compliance assistance efforts on the comprehensive evaluations of compliance with all environmental statutes, rules and regulations that apply to a small community's or special districts' operations. Once the requirements have been met, a small community or special district will qualify for a significant reduction or waiver of penalties that might otherwise be imposed for environmental violations. This self-assessment guide is designed to be used by decision makers in small communities and special districts in identifying areas where improvements can be made in the management of environmental services and regulatory compliance. It is intended to guide decision makers in the development and implementation of a SCEPP. The self-assessment questionnaires focus on regulatory compliance, system operations, finances, administration and environmental stewardship. This self-assessment guide will address all levels of environmental services that a small community or special district may provide whether through direct service or through contracts. Questions will focus on all major areas of municipal services including drinking water, wastewater, permits and landfills. Questions will also focus on regulatory compliance relating to general operation and maintenance and the handling and disposal of hazardous wastes as well as above ground and underground storage tanks. Self-assessment questions will require simple Yes, No, Don't Know, or Not Applicable responses indicating areas where training or additional information may be needed to improve services, ensure regulatory compliance and promote continuous improvement. This guide does not cover every federal, ADEQ or local environmental requirement. Contact your ADEQ Environmental Compliance Community Liaison for information on specific federal, ADEQ or local environmental statutes, rules and regulations.







Small Community Environmental Protection Plan (SCEPP) Manual



The community or special district must develop a SCEPP Manual that includes the relevant elements listed below. ADEQ has provided a "template" in this guidance to assist in the development of the SCEPP Manual. The SCEPP must include the following: Environmental Policy A policy statement that asserts a commitment to environmental excellence; compliance with all environmental requirements; and to the use of the policy statement as a framework for planning and action.







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Operational and Maintenance Procedures Documented procedures established for all operations and activities including routine maintenance; and roles, responsibilities and authorities for regulatory compliance. Environmental Aspects Identify all operations/activities under municipal control or over which it is expected to have influence (contract vendors); determine which aspects may have a significant impact on the environment; and a procedure for semi-annual review and for revisions due to new or changed operations/activities to consider. Legal and Other Requirements Documented procedures established to ensure compliance with all environmental regulatory requirements; identification of relevant requirements, provisions by which the relevant requirements are accessed and communicated to all personnel; reviewed at least once a year; and a review of current federal, state and local legal requirements to ensure ongoing compliance. Objectives and Targets Documented environmental objectives and targets to set performance improvement goals for aspects that have significant environmental impacts; legal and other requirements, technical and financial achievability; commitments in the environmental policy; and operational requirements. Training Awareness and Competence Documented procedures established to implement training for personnel on general awareness and competency. Awareness training ensures all personnel are familiar with the environmental policy and the relevance of the SCEPP, including the potential significant environmental impacts of their work and activities. Competency training focuses on environmental procedures that are specific to personnel work activities. Appropriate training is based on a procedure that matches training requirements with personnel job descriptions and work activities. Communications Documented procedures established to include programs addressing both internal and external parties. Internal communications will ensure environmental information is disseminated to all personnel. External communications with individuals, groups, other government entities, and local businesses will provide insight into your community's environmental operational performance. Document Control and Records Documented procedures established to effectively manage SCEPP documents relating to environmental activities including compliance with records retention requirements. Document control procedures are implemented to ensure that all personnel have access to appropriate SCEPP documentation and that out-dated documents are replaced so the SCEPP remains current and up-to-date. Operational Control Documented procedures established to identify, plan and manage operations consistent with its objectives and targets. Operational control procedures direct personnel work activities and stipulate operating criteria to ensure operations and activities are carried out appropriately. Emergency Preparedness and Response Emergency preparedness and response plans that identify the potential for and the response to environmental accidents and emergency situations. An Emergency Operations Plan (EOP) includes the prevention and mitigation of environmental accidents when they do occur.



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Noncompliance and Corrective and Preventive Action Documented procedures established to conduct a management level review and investigation of noncompliance with the SCEPP. Define roles, responsibilities and investigative authority including taking action to mitigate significant environmental impacts, and initiating and completing corrective and preventive actions. Document that all changes in procedures resulting from corrective and preventive actions are implemented and recorded. Environmental Compliance Audit Documented procedures established to conduct an annual assessment of compliance with environmental rules and regulations. ADEQ will make available facility-specific inspection checklists it uses to evaluate compliance upon request. SCEPP Audit Documented procedures established to conduct an internal annual comprehensive review of adherence to the SCEPP documented in a written report to be presented to the governing body and made available to the public and to ADEQ upon request including an independent third-party audit of the SCEPP within three years of submitting the SCEPP to ADEQ. ADEQ will be available to conduct this audit upon request. Management Review Documented procedures established to ensure that the governing body will conduct an annual review all elements of the SCEPP. Management review will ensure the adequacy, effectiveness and compliance with the SCEPP as defined in the operation control procedures. Guidance documents prepared by ADEQ and/or EPA may be used for assistance in preparing a SCEPP.







Environmental Regulations � Small Communities and Special Districts



Mandated Requirements This reference guide is provided to help decision makers become familiar with requirements that may apply to your community. The level of services provided by a community will vary. This guidance is designed to address all levels of infrastructure including landfills, power plants, permits, drinking water and wastewater systems. If your community depends on county or special districts for some services, this guide will help in understanding what these entities should be doing. This review of environmental regulations will assist decision makers in responding to the Self-Assessment Questionnaires and the development of a SCEPP.







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SECTION 2



SAFE DRINKING WATER ACT (SDWA)



BACKGROUND The Safe Drinking Water Act (SDWA) was originally passed by Congress in 1974 to protect public health by regulating the nation's public drinking water supply. The law was amended in 1986 and 1996 and requires many actions to protect drinking water and its sources: rivers, lakes, reservoirs, springs, and groundwater wells. SDWA does not regulate private wells which serve fewer than 25 individuals. Originally, the SDWA focused primarily on treatment as the means of providing safe drinking water at the tap. The 1996 amendments greatly enhanced the existing law by recognizing source water protection, operator training, funding for water system improvements, and public information as important components of safe drinking water. This approach ensures the quality of drinking water by protecting it from source to tap. Does your community provide water for consumptive uses (e.g. drinking, cooking, cleaning, bathing)?















Yes







 No







 Don't Know







 Not Applicable







If you provide potable water or you do not know, review this section and answer the remaining self-assessment question numbers 1 through 50 at the end of this section. If you do not provide potable water skip to Section 3. National Primary Drinking Water Regulations U.S. EPA sets national standards for drinking water based on sound science to protect against health risks, considering available technology and costs. These National Primary Drinking Water Regulations set enforceable maximum contaminant levels (MCL) for particular contaminants in drinking water or required ways to treat water to remove contaminants. Each standard also includes requirements for water systems to test for contaminants in the water to make sure standards are achieved. EPA has delegated compliance and enforcement responsibility to ADEQ. ADEQ has adopted maximum contaminant levels established by EPA for two different categories of harmful contaminants based on the exposure required to cause health effects. Acute contaminants are those that have health effects that occur within hours or days of exposure. In other words, they can make people sick very quickly. These include microbial contaminants, nitrates and nitrites. Non-acute contaminants are those which may result in health effects over time after prolonged exposure. An Overview of Monitored Contaminants Subject to Safe Drinking Water Requirements can be found on page 3 of this section. EPA and ADEQ regulations apply to regulated Public Water Systems, namely those water providers having 15 or more service connections (hook ups) or serving 25 or more persons. Most small communities own and operate regulated public water systems and are subject to these regulations. ADEQ Compliance Assistance ADEQ offers regularly scheduled drinking water and wastewater workshops to help public water system owners and operators understand compliance requirements. Notification of these events is available on ADEQ's website. The agency's rural representatives called "Community Liaisons" are also available to assist Arizona's rural communities.



Section 2 Page 1







Drinking Water and Your Health Almost all drinking water contains some impurities, whether natural such as minerals or man made such as chlorine or other disinfectant additives. Some of these impurities, while referred to as contaminants, are often beneficial to human health in trace amounts. In Arizona, drinking water comes from two major sources: surface water such as lakes, rivers, and reservoirs, and groundwater, which is pumped from wells. Sometimes these sources are close to a community, but water can also be transported long distances by canals or pipelines. In Arizona, many communities get their drinking water from sources managed by the Salt River Project or the Central Arizona Project . These companies do not supply drinking water directly to consumers, but they provide most of the water used by public water systems in the Phoenix metropolitan area. Many others in the state's smaller and rural communities depend on local surface water and ground water sources. Because of its exposure to the environment and the potential for contamination, surface water requires both filtration and disinfection to reach drinking water quality standards. Groundwater can also become contaminated requiring filtration and disinfection to meet drinking water standards.







ADEQ Monitoring Assistance Program (MAP)



All public water systems serving less then 10,000 people are required to participate in the Monitoring Assistance Program which conducts most, but not all, of the drinking water monitoring required by the SDWA. Each system is charged a modest base fee and a small amount per service connection. These monies are deposited into a fund which is then used to hire a private contractor through the state procurement bid process to collect, transport, analyze and report results of baseline samples to the systems and ADEQ. The fee fund allows the water systems to gain economies of scale when contracting for large volumes of sampling and ensures the proper water quality monitoring is conducted. The program samples for regulated volatile organic chemicals (VOC), regulated synthetic organic chemicals (SOC), and regulated inorganic chemicals (IOC). Because of the efficiency of the program and the cost-effectiveness of the economies of scale involved, the program was expanded in recent years to include asbestos, radionuclides, nitrite, sulfate and nickel. MAP does not monitor for total coliform bacteria, lead and copper, surface water treatment rule requirements, disinfectant and disinfection byproducts (TTHMs, HAA5 and maximum residual disinfectant levels - MRDLs). Testing for these contaminants remains the responsibility of public water systems. Individual systems are also responsible for any increased monitoring that may be necessary. Nitrate Monitoring Requirements ADEQ is now monitoring nitrate levels as part of MAP for Community water systems and Nontransient Noncommunity water systems. Individual systems are responsible for any increased monitoring that may be necessary. Transient Noncommunity (TN) Water Systems Transient Noncommunity water systems are currently not required to participate in MAP. However, in the near future, ADEQ will also be phasing in responsibility for monitoring both nitrate and nitrite for TN water systems as part of MAP. Until notified by ADEQ, Transient Noncommunity public water system owners and operators remain responsible for nitrate and nitrite monitoring and reporting.







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MOST COMMON DRINKING WATER VIOLATIONS



Failure to: � Conduct required monitoring (sampling) and reporting for those contaminants not covered by MAP; (e.g. Total Coliform, Lead & Copper, Disinfectants and Disinfection Byproducts and compliance with the Surface Water Treatment Rule). � Report analytical results to ADEQ on approved laboratory forms. � Provide public notice of violations to all water customers. � Provide ADEQ with a copy and an Affidavit (notarized written statement) as proof that public notice was issued to customers. � Use certified operators of the appropriate grade level for drinking water collection treatment and distribution. � Provide Backflow prevention. � Annual backflow prevention assembly testing. � Develop and update a written Microbiological Site Sampling Plan (MSSP) for the collection of total coliform samples. � Develop and update a written Emergency Operations Plan (EOP). � Use additives, materials and equipment certified for potable water. � Obtain ADEQ approvals to construct before beginning any new construction and/or modifications to an existing public water system including a new source. � Obtain ADEQ approvals of construction prior to operation of any completed new construction and/or modification of an existing public water system including a new source. � Use Best Available Technology (BAT) to resolve ongoing maximum contaminant level (MCL) violations. � Provide an annual Consumer Confidence Report (CCR) to all water customer. � Provide a copy of the annual CCR to ADEQ.







Overview of Safe Drinking Water Requirements







Total Coliform Disinfectants Disinfection By-Products Inorganic Chemicals (IOC) Synthetic Organic Chemicals (SOC) Volatile Organic Chemicals (VOC) Surface Water Treatment







Fluorides Lead Material Ban Lead and Copper Arsenic Radionuclides (Radiochemicals) Asbestos Sulfates







Nitrate Nitrite Public Notification Consumer Confidence Reports Source Water Protection Certified Operator Construction Approvals







For more information, please contact the Safe Drinking Water Section at (602) 7712300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







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TOTAL COLIFORM RULE (TCR) � [See Table 1 for Sampling Frequency]



All regulated public water systems (PWS) must comply with the TCR, including all water systems participating in MAP. Owners and operators are responsible to comply with the TCR. MAP does not collect total coliform samples. BACKGROUND The TCR was implemented to improve public health by reducing fecal pathogens to minimal levels through control of total coliform bacteria, including fecal coliforms and Escherichia coli (E. coli). The MCL is based on the presence or absence of total coliform including testing for fecal coliforms and E. coli when sample results are positive for the presence of total coliform. ROUTINE MONTHLY Total Coliform Monitoring and Reporting Requirements Monthly total coliform monitoring and reporting requires the use of a written Microbiological Site Sampling Plan (MSSP) that is subject to review and approval by ADEQ. The number of required monthly samples is based on the total population served. [See Table 1] All total coliform samples must be representative of water throughout the distribution system according to the written MSSP. If any ROUTINE monthly sample is total coliform positive, REPEAT samples must be collected. REPEAT Total Coliform Sampling Requirements [See Table 1] Within 24 hours of learning of a total coliform positive ROUTINE sample result, the water supplier must: � � Notify ADEQ of positive results. Collect REPEAT total coliform samples as follows. 1. If a PWS collects a minimum of one routine sample per month or per quarter, at least four repeat samples for each total coliform positive routine sample found must be taken. 2. If a PWS collects more than one routine sample per month, at least three repeat samples for each total coliform positive routine sample found must be taken. a) Collect One REPEAT sample from the sample tap where the original total coliform positive sample was collected. b) Collect One REPEAT sample from a tap located within five service connections upstream of the sampling site where the total coliform positive routine sample was collected. c) Collect One REPEAT sample from a tap located within five service connections downstream of the sampling site where the total coliform positive routine sample was collected. d) If a PWS is required to take four REPEAT samples, the fourth sample may be collected from any sampling site in the distribution system. � � If any REPEAT sample is total coliform positive the PWS must collect an additional set of REPEAT samples until total coliforms are not detected in one complete set of REPEAT samples or an MCL for total coliforms is violated. ADEQ and the public must be notified of all total coliform violations..







Additional ROUTINE Total Coliform Sample Requirements A positive ROUTINE or REPEAT total coliform result requires that a minimum of five ROUTINE or FOLLOW-UP total coliform samples must be collected during the next month the system provides water to the public.



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Table 1



Population Served 5 to 1,000 1 1,001 - 2,500 2,501 - 3,300 3,301 - 4,100 4,101 - 4,900 4,901 - 5,800 5,801 - 6,700 6,701 - 7,600 7,601 - 8,500 8,501 - 12,900 12,901 - 17,200 17,201 - 21,500



1 2







Total Coliform Monitoring & Reporting Frequency



Minimum Routine Monthly Samples 1 2 3 4 5 6 7 8 9 10 15 20



2







Repeat Samples Within 24 Hours of Notification 4 3 3 3 3 3 3 3 3 3 3 3







Follow-up Samples Including Monthly Routine Sample Minimum of 5 Minimum of 5 Minimum of 5 Minimum of 5 No Additional Samples No Additional Samples No Additional Samples No Additional Samples No Additional Samples No Additional Samples No Additional Samples No Additional Samples







Includes public water systems that have at least 15 service connections, but serve fewer than 25 persons. PWS serving between 21,501 to more than 3,960, 001 per month, should contact ADEQ Drinking Water Section for the number of monthly total coliform samples required.







How is Compliance Determined? � Compliance is based on the presence or absence of total coliforms. � Compliance is determined each calendar month that water is served to the public. How is a Total Coliform MCL Triggered? Non-Acute MCL Violation 1. A PWS that collects fewer than 40 ROUTINE and REPEAT samples per month, no more than ONE sample may be total coliform positive. 2. A PWS that collects 40 or more ROUTINE and REPEAT samples per month, no more than 5% of the samples may be total coliform positive. ACUTE MCL Violation � Public Notice must be issued within 24 Hours 1. Any fecal coliform positive REPEAT sample or Escherichia coli (E. coli) positive REPEAT sample is an acute violation. 2. Any total coliform REPEAT sample following a fecal coliform positive or E. coli positive ROUTINE sample is an acute violation. Public Notice Requirements � Public Notice must be issued for all non-acute and acute total coliform MCL violations. � The type of Public Notice and how it must be issued is determined by the category of the violation. � Failure to comply with any monitoring and reporting requirement including the failure to collect required samples is a violation and Public Notice must be issued. Copies of Public Notice to ADEQ Within 10 days after the date of issuing notice of a violation to the public, a PWS must submit a representative copy to ADEQ of each type of public notice required that is distributed,



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published, posted, or made available to persons served by the public water system or to the media and an AFFIDAVIT that describes how the public notice was provided (a notarized statement).







LEAD (Pb) and COPPER (Cu) RULE



One of the most common violations is the failure to conduct Lead (Pb) and Copper (Cu) monitoring and reporting. BACKGROUND The Lead and Copper Rule was developed to protect the public health by minimizing lead and copper levels in drinking water by identifying residences or sampling locations with lead service lines, lead interior plumbing, or copper pipes with lead solder. If water is too corrosive, it can cause lead and copper to leach out of the plumbing materials and fixtures and enter the drinking water. Children are especially susceptible to high levels of lead which can cause damage to the brain, red blood cells, and kidneys. Exposure to low levels of lead can cause low IQ, hearing impairment, reduced attention span and poor classroom performance. High exposure to copper can cause stomach and intestinal distress, liver and kidney damage, and complications from Wilson's disease in genetically predisposed people. High lead levels in adults have been linked to high blood pressure. Pregnant women and their fetuses are especially vulnerable to lead exposure that can significantly harm the fetus, causing low birth weight and slowing down normal mental and physical development.







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Overview of Lead (Pb) & Copper (Cu) Monitoring & Reporting



Establishes an Action Level of 0.015 mg/L for lead (Pb) and 1.3 mg/L for copper (Cu) based on the 90th percentile level of tap water samples. An Action Alert exceedance is not a violation but can trigger other requirements including water quality parameter (WQP) monitoring, corrosion control treatment (CCT), source water monitoring and treatment, public education, and lead service line replacement. Samples must be analyzed by a laboratory using EPA approved methods. Failure to conduct lead and copper tap water sampling is a violation. ALL community water systems (CWS) and Non-transient, Non-community water systems (NTNCWS). The number of samples is based on the system size and population served [See Table 1.] A first-draw sample may be collected by the PWS or by a resident after providing instructions to the resident on proper sampling procedures. Pb and Cu samples are one liter in volume and must be collected after water has been motionless for at least 6 hours from an interior kitchen or bathroom tap. NO samples can be collected from taps with point-of-entry or point-of-use devices or from outside hose bibs. (A.A.C. R18-4-310(D)) If non-first draw samples are collected in place of first-draw samples, the sample shall be one liter in volume and shall be collected at an interior tap from which water is typically drawn for consumption. The PWS must report non-first draw samples to ADEQ and identify of all non-first-draw sample sites selected by the PWS and the length of the standing time for each substitute sample collected. (A.A.C. R18-4-310(D) (3)) The laboratory that analyzes the compliance samples will calculate the 90th percentile. However, the Drinking Water Rules do provide detailed instruction on calculating the 90th percentile. (A.A.C. R18-4-308.) ADEQ staff will also provide compliance assistance.







General Description







Who Must Sample







Taking A Sample







First Draw Sample







Non-First Draw Sample







90th Percentile Calculation







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Step 1.







Materials Survey







A PWS shall complete a materials survey of its distribution system to identify a pool of sampling sites that is sufficiently large enough to ensure that the PWS can collect the required number of tap water samples. A PWS shall identify whether any of the following construction materials are present in its distribution system when conducting a materials survey: a. Lead from piping, solder, caulking, interior lining of distribution mains, alloys and home plumbing; b. Copper from piping and alloys, service lines, and home plumbing; c. Galvanized piping, service lines, and home plumbing; d. Ferrous piping materials, such as cast iron and steel; e. Asbestos cement pipes; f. Vinyl lined asbestos cement pipe; and g. Coal tar-lined pipes and tanks. Each site from which a first-draw sample is collected shall be selected from the pool of sampling sites with the highest potential for lead and copper to leach into drinking water.







STEP 2. Targeting Sampling Sites Based on Materials Survey



Community Water System (CWS) Sample Sites - samples should be collected from Tier 1 Sites. If a sufficient number of Tier 1 sampling sites do not exist or are inaccessible, then a CWS shall collect the remaining number of tap water samples from Tier 2 sampling sites. If a sufficient number of Tier 2 sites do not exist or are inaccessible, then the remaining number of samples may collected from Tier 3 sites. 1. Single-family structures that meet any of the following requirements: contain lead pipes; contain copper pipes with lead solder that were installed after 1982; or are served by a lead service line. 2. If multiple-family residences comprise at least 20 percent of the structures served by a PWS, they may be included in the sampling pool as Tier 1 sampling sites based on the materials survey. Buildings and multiple-family residences that meet any of the following requirements: contain lead pipes; contain copper pipes with lead solder that were installed after 1982; or are served by a lead service line. Single-family structures that contain copper pipes with lead solder that were installed before 1983.







Tier 1







Tier 2







Tier 3







Nontransient Noncommunity Water System (NTNCWS or NN) Sample Sites samples should be collected from Tier 1 Sites. If a sufficient number of Tier 1 sampling sites do not exist or are inaccessible, then a NTNCWS shall collect the remaining number of tap water samples from Tier 2 sampling sites. Tier 1 Tier 2 NTNCWS Buildings that meet any of the following requirements: contain lead pipes; contain copper pipes with lead solder that were installed after 1982; or are served by lead service lines. Buildings that contain copper pipes with lead solder that were installed before 1983. A representative site is a site in which the plumbing materials used at that site would be commonly found at other sites served by the NTNCWS.







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STEP 3.



Initial







Tap Water Lead & Copper Sampling



See Table 1 for the required number of samples to be taken.







Take 2 consecutive 6 month tap water samples (January�June and JulyDecember) for lead and copper from the same sampling sites identified in the materials survey. If a water system does not exceed the action level for lead and the action level for copper in 2 consecutive 6 month monitoring periods the water system may reduce the frequency of tap water monitoring to once per year. Samples must be taken from the same initial sampling sites during the months of June, July, August or September unless ADEQ approves an alternate schedule. If the water system does not exceed the action level for lead and the action level for copper for three consecutive years of monitoring, it may further reduce the frequency of tap water monitoring for lead and copper to once every three years. No exceedance for three consecutive years includes the first year of 2 consecutive 6 month samples plus 2 annual samples. A water system that conducts reduced monitoring shall select the sampling sites from the same initial sampling sites used to collect the initial 2 consecutive tap water samples.







Annual







Triennial







Reduced Monitoring Sites







Accelerated Reduced Monitoring



A water system that demonstrates for two consecutive six-month monitoring periods that the 90th percentile tap water lead level is less than or equal to 0.005 mg/L and the 90th percentile tap water copper level is less than or equal to 0.65 mg/L may reduce the frequency of Small & Medium tap water monitoring for lead and copper to once every three years Water Systems and will not be required to take 2 annual samples. A water system that conducts reduced monitoring shall use the reduced number of sites taken from the initial tap water sampling pool and follow the sampling requirements.







TABLE 1







Number Number Of Samples Required



Number of Tap Water Sampling Sites







PWS Size







Population Served







Initial Samples Standard







Reduced







Medium







10,001 � 50,000 3,301 � 50,000







60 40 20 10 5







30 20 10 5 5







Small







501 � 3,300 101 � 500  100







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SURFACE WATER TREATMENT RULE (SWTR)



Another common violation is the failure to comply with filtration and disinfection and the monitoring and reporting requirements of the SWTR. The SWTR applies to the following PWS: � � � Use Surface Water: All water which is open to the atmosphere and subject to runoff including rivers, lakes and reservoirs. Use Groundwater that has been determined to be under the direct influence of surface water. Use both Surface Water and Groundwater.







BACKGROUND The SWTR became effective December 31, 1990. The rule seeks to prevent waterborne diseases caused by fecal coliform and E. coli bacteria and viruses such as Legionella, Giardia lamblia and Cryptosporidum. These disease causing microbes are present at varying concentrations in surface water. Surface water is particularly susceptible to microbial contamination from sewage treatment plant discharges and runoff from stormwater. These sources often contain high levels of fecal microbes that originated in livestock and septic systems. Health Effects: � Coliform Bacteria Coliform are common in the environment and are generally not harmful. However, the presence of these bacteria in drinking water is usually a result of a problem with the treatment system or the pipes which distribute water, and indicates that the water may be contaminated with germs that can cause disease. Fecal Coliform and E. coli � Fecal Coliform and E coli are bacteria whose presence indicates that the water may be contaminated with human or animal wastes. Microbes in these wastes can cause shortterm effects, such as diarrhea, cramps, nausea, headaches, or other symptoms. � Turbidity Turbidity has no health effects. However, turbidity can interfere with disinfection and provide a medium for microbial growth. Turbidity may indicate the presence of disease causing organisms. These organisms include bacteria, viruses, and parasites that can cause symptoms such as nausea, cramps, diarrhea, and associated headaches. � Cryptosporidium Cryptosporidium is a parasite that enters lakes and rivers through sewage and animal waste. It causes cryptosporidiosis, a mild gastrointestinal disease. However, the disease can be severe or fatal for people with severely weakened immune systems. EPA and the CDC have prepared advice for those with severely compromised immune systems who are concerned about Cryptosporidium. � Giardia lamblia Giardia lamblia is a parasite that enters lakes and rivers through sewage and animal waste. It causes gastrointestinal illness (e.g. diarrhea, vomiting, and cramps). PWS using Convention or Direct Filtration are encouraged to contact ADEQ Drinking Water Section at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







Section 2 Page 10







SURFACE WATER TREATMENT RULE REQUIREMENTS



SWTR: All systems using surface water and/or groundwater under the direct influence of surface water must provide: 1. Filtration and Disinfection � at least a 99% (2-log) removal of Cryptosporidium � at least a 99.9% (3-log) combined removal and inactivation of Giardia � at least a 99.9% (4-log) inactivation and removal of viruses 2. Turbidity � Turbidity has no health effects. However, turbidity can interfere with disinfection and provide a medium for microbial growth. Turbidity may indicate the presence of disease causing organisms including bacteria, viruses and parasites. � The adequacy of the filtration and disinfection process is established by measuring Turbidly (measuring the amount of particles in the treated water) and determining if the water meets EPA's performance standards 3. Continuous Disinfection � To assure adequate microbial protection in the distribution system, a PWS is also required to provide continuous disinfection of the drinking water entering the distribution system.







Section 2 Page 11







Surface Water Treatment Rules (SWTR) Summary



SWTR SWTR 1989 Surface Water Treatment Rule: Focused on reducing the risk of contamination from Giardia Lamblia and viruses. Interim Enhanced Surface Water Treatment Rule: � Broaden regulatory focus with the goal of optimizing treatment reliability and to enhance physical removal efficiencies to minimize Cryptosporidium in finished water. � Disinfection benchmark provisions to ensure continued levels of microbial protection while systems take the necessary steps to comply with Stage 1 Disinfection By-Products Rule standards. [See Disinfec] tant and Disinfection By-Products requirements below] � Applies to water systems serving more than 10,000 persons. Long-Term 1 Enhanced Surface Water Treatment Rule: � Contains provisions similar to IESWTR � Applies to water systems serving less than 10,000 persons. Long-Term 2 Enhanced Surface Water Treatment Rule: � Provide additional health protection from microbial pathogens, especially Cryptosporidium based on new scientific data. � Builds on existing surface water treatment rules by focusing on high risk systems: � Filtered systems with high source water contamination � All UNFILTERED systems � Applies to all water systems � Requires initial source water monitoring for Cryptosporidium and E. coli � Monitoring results determine if any additional treatment is required beyond IESWTR and LT1ESWTR � Disinfection profiling required for all systems � All finished water reservoirs must be covered � Applicability � Surface Water or Groundwater Under the Direct Influence of Surface Water (GUDI) � Community Water Systems (CWS) � Nontransient Noncommunity Water Systems (NN) � Transient Noncommunity Water Systems (TN) � Wholesale suppliers who provide finished water to other systems must comply based on population served of the largest system in the combined distribution system and must meet all initial source water monitoring requirements � All filtered and unfiltered systems � Do NOT have to comply with all original initial source water monitoring requirement except wholesale suppliers of finished water to other systems. � All MUST comply with: � Uncovered storage requirements � Profiling and benchmarking requirements � Sanitary Survey requirements (Inspection of the entire PWS) Please Contact ADEQ Drinking Water Section Staff: Monitoring and Reporting requirements under the SWTR is specific to the type of water filtration and disinfection technology used by a PWS. ADEQ encourages PWS to contact staff for assistance in determining the required monitoring and reporting to ensure compliance with the SWTR.







IESWTR 1998







LT1ESWTR 2002







LT2ESWTR 2006







ADEQ Compliance Assistance







Section 2 Page 12







FILTER BACKWASH RECYCLING RULE (FBRR)



In June 2001, EPA established the Filter Backwash Recycling Rule to improve public health by assessing and changing, where needed, recycle practices for improved contaminant control, particularly microbial contaminants. The FBRR requires systems that recycle to return specific recycle flows through all processes of the system's existing conventional or direct filtration system or an alternate location approved by the state. Does the FBRR rule apply to your community?















Yes







 No







 Don't Know







 Not Applicable







The FBRR applies to all PWS that use surface water or groundwater under the direct influence of surface water who use: � Conventional Filtration Conventional filtration is the most common type of filtration. It is a series of processes including coagulation, flocculation, sedimentation and filtration resulting in substantial particulate removal. Direct Filtration Direct filtration is a series of processes including coagulation and filtration, but excluding sedimentation, resulting in substantial particulate removal. Direct filtration can only be used with high-quality raw water that has low levels of turbidity and suspended solids. Recycle Spent Filter Backwash Water Spent filter backwash is a stream containing particles that are dislodged from filter media when water is forced back through a filter (backwash) to clean the filter. Recycle Thickener Supernatant Thickener supernatant is a stream containing the decant from a sedimentation basin, clarifier or other unit that is used to treat water, solids or semi-solids from the primary treatment process. Recycle Liquids from the Dewatering Process A stream containing liquids generated from a unit used to concentrate solids for disposal.







�







�







�







�







Critical Deadlines and Requirements The FBRR requirements will be phased in over time.







CONSTRUCTION APPROVALS



All regulated public water systems (PWS) including Community Water Systems (CWS), Nontransient Noncommunity Water Systems (NN) and Transient Noncommunity Water Systems (TN) must obtain ADEQ approval to construct and/or modify an existing PWS before beginning construction. This includes: adding a new source, water treatment and storage capacity as well as line extensions, blending plans or other additions, extensions and modifications. ADEQ approval of construction must be obtained prior to operation.







Section 2 Page 13







DISINFECTANT AND DISINFECTION BY- PRODUCTS RULE (DBPR)



BACKGROUND Disinfection By-Products are formed when disinfectants used in water treatment react to bromide and/or other natural organic matter (decaying vegetation) present in source water. Different disinfectants produce different types of amounts of disinfection by-products. Regulations have been established for disinfection by-products identified in drinking water including trihalomethanes and total trihalomethanes (TTHM), haloacetic acids (HAA5), bromate and chlorite. The Disinfectant and Disinfection By-Products Rule applies to ALL surface water PWS and groundwater PWS which add a chemical disinfectant to the water. � Trihalomethanes (THM) and Total Trihalomethanes (TTHM) A group of four chemicals that are formed along with disinfection by-products when chlorine or other disinfectants used to control microbial contaminants in drinking water react with naturally occurring organic and inorganic matter in water. EPA established standards in the Stage 1 Disinfectants/Disinfection By-Products Rule to regulate total trihalomethanes (TTHM) at a maximum allowable annual average of 80 parts per billion, down from the previous standard of 100 parts per billion. The new standard was effective December 2001 for large surface water PWS and December 2003 for small surface water and all groundwater systems. Haloacetic Acids (HAA5) A group of chemicals that are formed along with other disinfection by-products when chlorine or other disinfectants used to control microbial contaminants in drinking water react with naturally occurring organic and inorganic matter in water. The five regulated haloacetic acids known as HAA5 are: � Monochloroacetic Acid � Dichloroacetic Acid � Trichloroacetic Acid � Monobromoacetic Acid � Dibromoacetic Acid EPA established standards in the Stage 1 Disinfectants/Disinfection By-Products Rule to regulate haloacetic acids (HAA5) at an annual average of 60 parts per billion effective December 2001 for large surface water PWS and December 2003 for small surface water systems and all groundwater systems. � Bromate A chemical that is formed when ozone is used to disinfect drinking water and reacts with naturally occurring bromide found in source water. EPA established standards in the Stage 1 Disinfectants/Disinfection By-Products Rule to regulate bromate at an annual average of 10 parts per billion effective December 2001 for large PWS and December 2003 for small surface water systems and all groundwater systems. Chlorite A by-product formed when chlorine dioxide is used to disinfect water. EPA established standards in the Stage 1 Disinfectants/Disinfection By-Products Rule to regulate chlorite at a monthly average level of 1 part per million effective December 2001 for large surface water PWS and December 2003 for small surface water systems and all groundwater systems.







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Section 2 Page 14







HEALTH EFFECTS: Since the discovery of chlorinating byproducts in drinking water in 1974, numerous toxicological studies (studies on the health effects from exposure to high dosage contaminants usually involving animals in a lab) have been conducted. These studies have shown several disinfection byproducts to be carcinogenic in laboratory animals (including bromate, certain trihalomethanes and haloacetic acids). Some disinfection byproducts have also been shown to cause adverse reproductive or developmental effects in laboratory animals (e.g., chlorite and certain trihalomethanes and haloacetic acids). However, there is considerable uncertainty involving the results of high doses in toxicological studies of some byproducts occurring in disinfected drinking water to estimate the risk to humans from chronic exposure to low doses of these and other byproducts. Stage 1 Disinfectants and Disinfection Byproducts Rule In December 1998, EPA established the Stage 1 Disinfectants/Disinfection Byproducts Rule, which was considered the best course of action to reduce potential risks from disinfection byproducts in the near term. Stage 2 Disinfectants and Disinfection Byproducts Rule The Stage 2 DBP rule was published in the Federal Register on January 4, 2006. The Stage 2 Disinfectants and Disinfectant Byproducts Rule builds upon earlier rules that addressed disinfection byproducts to improve drinking water quality and provide additional public health protection from disinfection byproducts.







Section 2 Page 15







Disinfectant and Disinfection By-Products (DBP) Rule Summary Disinfectant



Stage 1 Disinfectant and Disinfection By-Products Rule: Updates and supersedes the 1979 regulations for total trihalomethanes. Focus is on reducing exposure to three disinfectants and many disinfection by-products. � Applies to ALL Community and Nontransient Noncommunity water systems � Established maximum residual disinfectant level goals (MRDLG) and maximum residual disinfectant levels (MRDL) for three chemicals: � Chlorine, Chloramine and Chlorine Dioxide � Established maximum contaminant level goals (MCLG) for � Total Trihalomethanes (TTHM), Haloacetic Acids (HAA5), Chlorite and Bromate � Conventional Filtration Treatment and Total Organic Carbon (TOC) � Surface water systems and groundwater systems under the direct influence of surface water and use conventional filtration treatment are required to remove a specified percentage of organic matter measured as Total Organic Carbon (TOC) that may react with disinfectants to form DBP. � Removal to be achieved through treatment technique (enhanced coagulation or enhances softening) unless an alternative removal system meets alternative criteria. � Scheduling is based on source water type and population served. � Monitoring is based on source water type, population served and the number of treatment plants. Stage 2 Disinfectant and Disinfection By-Products Rule: Intended to reduce potential cancer and reproductive and developmental health risks from DPB. � Stage 2 builds incrementally on existing DBP rules and will be phased in over the next several years. � Applies to all Community and Nontransient Noncommunity PWS that add a chemical disinfectant other than UV or delivers water that has been treated with chemical disinfectants other than UV. � Focus is on monitoring TTHM and HAA5 based on a Locational Running Annual Average (LRAA). � Takes a risk based-targeted approach to require treatment changes by ONLY those PWS that are identified as having the greatest risk. This process will be phased in over the next several years. � Step 1: A multi-year process for PWS to determine where higher levels of DBP are likely to occur in their distribution systems. These will become the PWS new monitoring sites. � Step 2: If the DPB levels at these high risk sites exceed the MCL, the system must take corrective actions. � Step 3: Corrective actions will require planning, obtaining funding and permits to construct, designing and finally construction.







Stage 1 DBP Rule 1998







Stage 2 DBP Rule March 2006







ADEQ Compliance Assistance Please Contact ADEQ Drinking Water Section Staff: Compliance under the DBP Rule involves many variables. ADEQ encourages PWS to contact staff for assistance in determining the assessment and monitoring and reporting requirements to ensure compliance with the DBP Rules.







Section 2 Page 16







CONSUMER CONFIDENCE REPORT (CCR)



Community water systems (CWS) throughout the country are required to provide an annual water quality report, know as a Consumer Confidence Report, to their customers. The CCR Report (download template) is prepared by the water system owner or operator and made available annually to water customers by July 1. The CCR provides information on your local drinking water, including the water's source, the contaminants found in the water, and how water customers can get involved in protecting drinking water. A copy of the annual CCR report must also be provided to ADEQ. The goal of the CCR is to help consumers make health-based decisions regarding their drinking water. Many municipal water systems place these reports online at the city or town website. Consumers with questions should contact their water company to request a copy of the report. For more information, please contact the Drinking Water Section at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







GRANTS AND BELOW MARKET INTEREST LOANS



See Section 14 Mini Capital Improvements for Small Communities for information on the grants and below market interest loans for water improvement projects and information about Arizona`s Water Infrastructure Finance Authority (WIFA).







SOURCE WATER PROTECTION



BACKGROUND Source water is untreated water from streams, rivers, lakes or underground aquifers which is used to supply private wells and public drinking water. Initially, the 1986 Amendments to the Safe Drinking Water Act called upon each state to develop a (ground water) 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 well fields from contamination. The 1996 Amendments to that act expanded the focus from groundwater alone to all sources and required each state to develop standards for a Source Water Assessment Program (SWAP). These assessments were to be completed for every public water system by May 2003. Arizona's Source Water Protection Program (SWPP) The SWPP is designed to protect drinking water sources from becoming contaminated in the future. ADEQ evaluated each water source used by PWS in Arizona. These evaluations assess the hydrogeology of drinking water sources to determine the quality of groundwater being drawn into wells; evaluated the watersheds supplying surface water; and surveyed land use activities occurring near drinking water sources. This information is now used to determine the degree to which a public drinking water source is protected from, or at risk of, contamination. It is used to assist local communities in implementing source water protection measures. Actions your community should be taking: ADEQ administers this program to assist PWS, local officials and utilities in developing and implementing plans to protect surface and groundwater resources by actively coordinating local pollution prevention efforts with existing state programs. ADEQ provides assistance with program development and technical resources.



Section 2 Page 17







At a minimum, each Source Water Protection Program (SWPP) must: � Delineate the source water protection area (SWPA) for each system. � Identify and inventory potential sources of contaminants within each source water protection area. � Determine the susceptibility of the PWS to contaminant sources within the source water protection area. � Notify and involve the public about threats identified. � Develop and implement management approaches to protect the water supply within source water protection areas from such contaminants. � Develop contingency planning strategies for each public water supply system to respond to source contamination or emergencies that could lead to contamination. Primary Benefits to the Community Establishing a SWPP will help to assure reliable, safe sources of drinking water and to reduce long term costs. Protecting the quality of the drinking water resource can produce significant cost savings by: � � Reducing the need to develop new drinking water sources. Reducing the costs for treatment of the drinking water supply to meet acceptable water quality standards.







The most successful source water protection programs involve public participation throughout the development of the program. ADEQ is available to provide guidance and technical assistance to the community in developing an effective program. For more information, please contact the Water Quality Division at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







Drinking Water System Self-Assessment Questionnaire



1. Does your community participate in the ADEQ drinking water Monitoring Assistance Program (MAP)?











2.







Yes







 No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know



Section 2 Page 18







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Do you know when the last regulatory inspection was conducted for your public water system?











3.







Yes







Do you know the regulatory compliance status of your water system?











4.







Yes







Has the water system received any Notices of Opportunity to Correct (NOC), Notices of Violation (NOV) or Administrative Orders in the past three years?











5.







Yes







Are plans in place to correct violations?















Yes







6.







Do you employ a licensed certified operator(s) of the proper grade and type required to operate the water system?











7.







Yes







 No







 Don't Know







 Not Applicable







Do you have written policies in place to ensure that certified operators have adequate opportunities for training and maintaining license certification? (License Renewal Hours Training)











8.







Yes







 No  No  No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know



Section 2 Page 19







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Do you know the source of the community's drinking water?











9.







Yes







Has a source water assessment been completed and made available to the public?











10.







Yes







Is a source water protection program (SWPP) been established?











11.







Yes







Have you established appropriate protection zones around wells and springs?











12.







Yes







Do you have written policies and procedures that document the regulatory requirements for water quality monitoring and reporting for the water system?











13.







Yes







Are procedures in place to ensure water managers and operators are aware of all compliance deadlines?











14.







Yes







Do you have written policies and procedures that document the regulatory requirements for the operation and maintenance of the potable water system?











15.







Yes







Do you have written policies and procedures that govern the operation and maintenance of the water system?











16.







Yes







Do you have written policies and procedures that define roles and responsibilities for the operation and maintenance of the water system?











17.







Yes







Do you have written policies and procedures that define the role of water system personnel that includes a job description, benefits, and performance standards?















Yes







18.







Can water system personnel describe their day-to-day duties and responsibilities?











19.







Yes







 No  No  No







 Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable







Do you have an inventory of the water system assets and their location and condition?











20.







Yes







Is the condition of the water system regularly assessed to determine its operational capability?











21.







Yes







Have you conducted a materials survey to determine what types of pipe materials are used in the distribution system that may cause lead and copper to leach into the drinking water?











22.







Yes







 No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Does the water system management and operator have a copy of the water system drawings of the distribution system and any treatment facility?











23.







Yes







Do you have regularly scheduled meetings to discuss water system issues and needs?











24.







Yes







Does the water system have the required written Microbiological Site Sampling Plan (MSSP)?











25.







Yes







Is the water system in compliance with the total coliform monitoring and reporting requirements?











26.







Yes







Is the water system in compliance with lead and copper monitoring and reporting requirements?











27.







Yes







Is the water system in compliance with the Consumer Confidence Reporting (CCR) requirements over the past three years?











28.







Yes







Does the water system have the required written Emergency Operations Plan (EOP)?











29.







Yes







Do you have the required backflow prevention plan?















Yes







Section 2 Page 20







30.







Have you identified each business, industry or government facility which has a cross connection to your system?











31.







Yes







 No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Is each cross connection in your system protected by a backflow prevention assembly?











32.







Yes







Is each backflow prevention assembly tested annually?











33.







Yes







Have water users complained about the taste and/or odor of the water over the past three years?











34.







Yes







Does the source have a written a wellhead protection plan (WHP)?











35.







Yes







Does the water system have a written Risk Management and Safety Policies document?











36.







Yes







Do you have a written policy and procedure to ensure the security of your water system?











37.







Yes







Does the water system have an annual budget?











38.







Yes







Are the governing board and water personnel both involved in developing the annual budget?











39.







Yes







Does the annual budget include financial resources to cover routine water quality monitoring and reporting, maintenance and the cost of repairing and/or replacement of worn out equipment or unforeseen emergencies?











40.







Yes







 No  No  No







 Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable







Do you have a Capital Improvement Plan (CIP) for the water system?











41.







Yes







Do you have a written annual financial report for the water system?















Yes







Section 2 Page 21







42.







Has the water system been certified to have adequate capacity and pressure to provide fire protection for your community?











43.







Yes







 No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Have you evaluated the capacity of your water system to accommodate future growth over the next 10 years?











44.







Yes







Do you have written plans in place to ensure the financial viability of your water system over the next 10 years?











45.







Yes







Is the water system metered?











46.







Yes







Do you have written policies and procedures for establishing and reviewing water user rates?











47.







Yes







Are water rates set at a level to ensure long-term viability of the system?











48.







Yes







Are revenues from user fees dedicated to the water system as opposed to being used as general revenue for the community?











49.







Yes







Are you currently paying back a water system improvement debt? (Loan)











50.







Yes







Do you have a written process for dealing with past due bills and delinquent water accounts?















Yes







Section 2 Page 22







SECTION 3



WASTEWATER SYSTEM & WATER QUALITY PROTECTION PERMITS



BACKGROUND The 1972 Clean Water Act (CWA) focused on identifiable sources (pointsource) of pollution of waters of the United States. Amendments to the CWA in 1977 and 1987 addressed unidentifiable sources (non-point) of pollution. General and individual permits are used to safeguard surface and groundwater quality by controlling discharges. A few examples of activities that may require a permit include: municipal/domestic wastewater treatment plants, pre-treatment treatment of wastewater, disposal of sewage sledge (biosolids), drinking water treatment plants, stormwater run-off from construction activities, stormwater discharges to drywells, industrial facilities that dispose of their waste in publicly owned treatment works (POTW - sewer system), on-site sewage disposal systems, septic tanks, direct use of reclaimed water, and mining operations. Reduced levels of funding for wastewater collection, treatment and disposal means small communities and special districts and their technical consultants must identify appropriate technology resources to substantially reduce capital project costs and operating expenses, if wastewater collection, treatment and disposal is to be affordable and effective in protecting our water supply. Does your community own or operate any of the facilities and/or are involved in any of the activities listed above that require a water quality permit?















Yes







 No







 Don't Know







 Not Applicable







If you own and operate any of the facilities or are involved in any of the activities listed above, or you do not know, review this section and answer the self-assessments questions numbers 1 through 59 at the end of this section. If you do not own or operate any of these facilities or are involved in any of the activities listed above, skip to Section 4.







SUMMARY OF WASTEWATER PERMITTING REQUIREMENTS



Aquifer Protection Permit (APP) An APP must be in place to operate a wastewater treatment plant. APP amendments are required for corrections or changes to a permit. Reclaimed Water Permit Reclaimed water permits are required for reuse of treated effluent and are normally obtained by the end user of the water. A facility's APP must specify the class of effluent generated by a facility (e.g. Class A, B or C) and associated effluent sampling requirements for the reuse activities. An APP amendment may be necessary for this purpose. AZPDES Permit An Arizona Pollutant Discharge Elimination System (AZPDES) permit is required prior to any discharge to surface water including dry washes.







Section 3 Page 1







AZPDES Stormwater Permit Coverage under a stormwater general permit must be obtained for wastewater treatment plants with design flows of one million gallons per day or more, and for any construction projects which will disturb at least one acre. 208 Water Quality Management Plan The 208 Water Quality Management Plan is a consistency review required for NEW facilities, AZDPES permits and certain modifications. Sewage Sludge (a.k.a. biosolids) Sludge or biosolids treatment storage and disposal requirements will be included in the APP or AZPDES discharge permit. Air Quality Permit Electrical generators for treatment facilities; lift stations and other purposes; which are equal to or greater than 325 horsepower need an Air Quality Permit.







General Permit Requirements



Wastewater Collection Systems & Lift Stations:* 1. Construction Authorization and Discharge Authorization � Approvals must be obtained for new collection systems and prior approval for the expansion of existing collection systems involving new construction. � ADEQ must first review the design for a new sewage collection system. � When a Construction Authorization is issued, construction may begin. � After construction is completed, a Discharge Authorization must be applied for and obtained prior to use of the new system or expanded system. * Lift Stations � Air Quality Permits � Electrical generators for treatment plants, lift stations and other purposes, which are equal to or greater than 325 horsepower need an Air Quality Permit.







2.







3. Capacity, Management, Operations and Maintenance (CMOM) General Permit � ADEQ encourages sewer providers to apply for general permit coverage to manage, operate and maintain a sewage collection system under the terms of a CMOM plan. � A CMOM will aid in preventing sanitary overflows and reduce the level of enforcement when spills and leaks occur from the collection system.







AQUIFER PROTECTION PERMIT (APP)



Arizona established Aquifer Protection Water Quality Standards (AWQS) for a variety of contaminants and the Aquifer Protection Permit (APP) program for facilities discharging chemicals that may affect groundwater or degrade water quality below AWQS standards. The key objective of the APP permitting process is to protect groundwater supplies through Best Available Demonstrated Control Technology (BADCT). An APP is required if your community owns or operates a facility that discharges a pollutant either directly to an aquifer or to the land surface or vadose zone (the area between an aquifer and the land surface) in such a manner that there is a reasonable probability that the pollution will reach the aquifer.



Section 3 Page 2







The following facilities are considered to be "discharging" and require permits, unless exempted, or the director determines that the facility will be designed, constructed and operated so there will be no migration of pollutants directly to the aquifer or the vadose zone: 1. Surface impoundments, pits, ponds and lagoons. 2. Solid waste disposal facilities, except mining overburden and wall rock that has not been subjected to mine leaching operations. 3. Injection wells. 4. Land treatment facilities. 5. Facilities adding pollutants to a salt dome, salt beds, or salt formations, drywells* or underground caves or mines. 6. Mine tailings piles and ponds. 7. Mine leaching operations. 8. Septic tank systems. 9. Underground storage facilities (if wastewater-effluent is used). 10. Point source discharges to navigable waters (including dry washes, streams and river beds). 11. Sewage or wastewater treatment plants. * All existing and proposed drywells must be registered with ADEQ. Any vadose injection wells, including drywells that receive stormwater mixed with reclaimed wastewater or groundwater, or both from manmade bodies of water associated with golf courses, parks and residential areas must be registered and a general or individual permit may be required, If your community has an APP, become familiar with the permit and its obligations including monitoring and reporting requirements.







NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) ARIZONA POLLUTANT DISCHARGE ELIMINATION SYSTEM (AZPDES)



BACKGROUND In December 2002, ADEQ was granted authority by EPA to administer the National Pollutant Discharge Elimination System program under the Clean Water Act through the Arizona Pollutant Discharge Elimination System program and the Pretreatment program covering pointsource discharges from industrial sources discharging to publicly owned treatment works (POTW) in all areas within Arizona except for Indian lands. Any facility that discharges a pollutant from a known identifiable point source to "navigable" waters is required to obtain an AZPDES permit. Pollutant is broadly defined but generally includes: � Chemical waste � Biological waste � Any constituents discharged to receiving waters Examples: � Bacteria from wastewater discharges � Sediments from construction projects � Chlorine from well development



Section 3 Page 3







� �







Groundwater redirected to a river which could include nitrates or metals Discharging to a dry wash







"Navigable" Waters Navigable Waters is a term used to describe waters of the United States. It includes not only oceans, streams, lakes, and rivers but also includes playas, wetlands, intermittent streams and ephemeral washes � that is water flows in them only in response to a storm event � otherwise these washes remain dry most of the time but are connected to other bodies of waters of the United States. Discharging to these dry washes requires a permit. Systems that have an existing NPDES permit that has not expired do not have to apply for an AZPDES permit. However, if the NPDES permit is modified, ADEQ may revise the format to reflect an AZDPES permit. When an existing NPDES permit comes up for renewal, it will be changed to an AZDPES permit. EPA has delegated ADEQ as the implementing agency and enforcement agency for NPDES permits. TYPES OF AZPDES PERMITS: Publicly Owned Treatment Works (POTW) POTW are public wastewater treatment facilities that receive wastewater, usually through a pipe system, from facilities using toxic chemicals and for publicly owned and/or any treatment works that treat domestic sewage and currently discharges, is permitted to discharge, or proposes to discharge treated wastewater to waters of the United States. (Example: Ina Road Water Pollution Control Facility, owned and operated by Pima County.) Some small communities may own or operate a publicly owned treatment works (POTW) or may be planning to develop a POTW as their community grows. Maximum achievable control technologies (MACT) standards have been established for POTW which treat wastewater received from residential, commercial and industrial sources. POTW can release air toxics in the form of volatile organic compounds in wastewater. ADEQ has developed AZPDES forms for most application types. They are very similar to the federal forms that have been in place for the NPDES program and have the same names. � POTWs and Domestic Wastewater Treatment Works Forms This form is used for publicly-owned or any other treatment works that treats domestic sewage and currently discharges, is permitted to discharge, or proposes to discharge treated wastewater to waters of the United States. � AZPDES Application Form 2A � AZPDES Application Instructions Form 2A [Also see Section 9 Toxic Air Pollutants] To determine if your existing POTW is regulated, please contact the ADEQ Water Quality Permits Section and/or the Air Quality Division at (602) 771-2300 or toll free at (800) 2345677, press 0 to speak to the receptionist who will direct your call. Facilities That Treat Sewage Sludge (Biosolids) Used for all POTW and other facilities that treat domestic wastewater and for facilities that do not treat domestic wastewater but treat or dispose of sewage sludge (biosolids). Initial Application for AZPDES Permits for Industrial and Commercial Operations that will discharge.



Section 3 Page 4







Non-domestic Wastewater Used for private and government owners of facilities that propose to discharge wastewater other than domestic wastewater (new sources and new dischargers) to waters of the United States. This includes discharges from water treatment plants, groundwater remediation efforts, mining and silvicultural operations. Renewal Application for AZPDES Permits for Industrial and Commercial Operations that will discharge Non-domestic Wastewater Used for private and government owners of facilities who currently discharge wastewater other than domestic wastewater to waters of the United States. This includes discharges from water treatment plants, groundwater remediation efforts, mining and silvicultural operations. Concentrated Animal Feeding Operations (CAFO) & Aquatic Animal Production Used for CAFO and aquatic animal production facilities that currently discharge, or propose to discharge wastewater to waters of the United States. Facilities That Do Not Discharge Process Wastewater This includes car washes, prisons, convenience stores, shopping centers, swimming pools, schools, parks, water treatment plant residues, discharges of remediated groundwater, etc. Dischargers of Stormwater Associated with Industrial Activity Used for facilities whose discharges are composed of stormwater and non-stormwater. ADEQ PERMIT COMPLIANCE ASSISTANCE ADEQ Water Permits Section issues Aquifer Protection Permits (APP), Reclaimed Water Permits and Arizona Pollutant Discharge Elimination System Permits (AZPDES) including renewal of existing NPDES permits. ADEQ staff will help you determine if your facility requires a permit or qualifies for an exemption. This section also authorizes discharges under general permits, registers drywells and certifies issuance of federal permits. Permit Assistance: 1. All general and individual permits 2. Industrial Wastewater 3. Residential Wastewater (Septic Tanks) 4. Municipal/Domestic Wastewater including Pretreatment 5. Sewage Collection Systems 6. Mines 7. Subdivisions 8. Reclaimed Water Use 9. AZPDES and renewal of NPDES 10. Stormwater 11. Biosolids 12. Operation Certification Please contact the ADEQ Water Quality Permits Section at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call. Download AZPDES Publications, Forms and Guidance







Section 3 Page 5







PRETREATMENT REQUIREMENTS



BACKGROUND "Pretreatment" refers to measures industry takes to prevent toxic pollutants from sources other than domestic wastewater from 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, permits, inspections, monitoring and enforcement. Pretreatment requirements control pollutants which are incompatible or will interfere with the treatment process, or that will pass through the treatment plant and cause problems in the receiving stream or lake. In addition, pretreatment requirements will improve opportunities to recycle and reclaim domestic and industrial wastewaters and sludge. Does the pretreatment requirement apply to my community? This rule applies only to discharges to sanitary sewer collection systems that ultimately reach a publicly owned treatment works (POTW). If the community has non-domestic users (for example, food processing plants or metal finishers) discharging pollutants that could pass through your treatment plant untreated or interfere with operations, you may have to implement a pretreatment program to satisfy AZPDES requirements. [See the NPDES and AZPDES section for more information on this topic.] Your current NPDES or AZPDES permit may contain requirements for you to regulate nondomestic discharges into your collection system. These pretreatment requirements are designed to ensure that you protect your treatment plant. Actions your community should be taking if this rule applies to your community You may be required to establish a pretreatment program. You will need to establish local ordinances and other procedures to carry out the pretreatment requirements as well as identify personnel responsible for ensuring the program is administered and enforced. If your community wants to establish a local pretreatment program, even though it may not be required to do so through an AZPDES permit, contact ADEQ Water Quality Permits Section for assistance. If you suspect a problem with the operation of your community wastewater system is caused by a non-domestic wastewater contributor, notify your treatment works operator, county sanitarian, ADEQ and the U.S. Environmental Protection Agency. Actions your community should be taking: If your wastewater treatment plant discharges to waters of the United States, the first step is to find out if you have or need an APP or AZPDES to discharge to waters of the United States (such as streams, lakes, wetlands, including dry stream beds, washes, etc.). The permit will specify effluent (liquid that comes out of a treatment plant after completion of the treatment process), limitations and monitoring requirements. Like other violations of Arizona's pollution control laws including APP and AZPDES, if your treatment works cannot meet the effluent limitations specified in the permit, you may be subject to an enforcement action. In addition, 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. Please contact the ADEQ Water Quality Permits Section at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.



Section 3 Page 6







WASTEWATER SLUDGE/BIOSOLIDS USE AND DISPOSAL



BACKGROUND Wastewater sludge or biosolids are by-products of the wastewater treatment process. Federal and state regulations ensure that sewage sludge is handled properly and is of sufficient quality either for use as a (1) soil conditioner or fertilizer, or (2) for disposal in a landfill, other surface disposal site or incinerator. For example, many small towns use biosolids as a fertilizer for parks, golf courses, etc. Monitoring, recordkeeping, and reporting are required under the biosolids regulations. Does this rule apply to your community? This rule applies if the wastewater treatment system includes any form of central wastewater treatment or mechanical plant, including a lagoon, which produces biosolids that are either periodically removed or remain on-site for more than two years. Actions your community should be taking: Be aware of restrictions covering proper use of the sewage biosolids if applied on land (both agricultural and non-agricultural); distribution for land application; and, disposal restrictions (landfills, incineration, and surface disposal). Contaminated biosolids or poor disposal practices can pose a threat to public health and the environment and are subject to enforcement action. Please contact the ADEQ Water Quality Permits Section at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







STORM WATER



BACKGROUND Stormwater runoff flows over parking lots and other areas, collects in street gutters and storm drains, and can eventually flow to water bodies with little or no treatment. Dumping used motor oil, unused paint, pesticides and other household chemicals on the ground or in the street can severely impact nearby surface water. AZPDES Stormwater Permits and Multi-Sector General Permits (MSGP) Requirements Permits are required for certain small community owned facilities including landfills, airports, equipment maintenance facilities and wastewater treatment plants with design flows of one million gallons per day or more, and for any construction project which will disturb more than one acre of land. Actions your community should be taking: Find out if the landfill, airport, power plant, construction activity, wastewater or other facilities owned or operated by your community require a permit. ADEQ staff will be able to assist you in determining which facilities need permits and how to apply for them. Develop an information and education program for community residents to increase awareness of the relationship between the stormwater and/or sewer system and local lakes, streams, rivers, estuaries, or other water bodies. You should also consider establishing local ordinances controlling the improper disposal or discharge of pollutants to the municipal stormwater drainage and/ or sewer system. Educate citizens so they can play a role in improving the quality of the streams and lakes in your area.



Section 3 Page 7







MOST COMMON WASTEWATER VIOLATIONS



Failure to: � Apply for a permit. � Read and understand permit terms and conditions which result in violations. � Obtain approval for wastewater collection extensions prior to construction and operation. � Amend permits when the system is modified or expanded. � Comply with contingency procedures following exceedance of permit limits. � Require businesses to comply with pretreatment ordinances. � Adhere to the permit compliance schedule for monitoring and reporting. � Keep the system in proper operating condition according to an operation and maintenance manual. � Notify ADEQ of facility changes, including ownership. How can small communities assure compliance with monitoring and reporting requirements? Complete and accurate monitoring results must be reported to ADEQ at a frequency specified in the permit. � ADEQ provides self-monitoring reporting forms (SMRFs) that must be used for APP reporting. � ADEQ provides discharge monitoring report (DMR) forms for each AZDPES permit. Steps owners and operators can take to avoid common permit monitoring and reporting violations: � � � � Read and understand the permit monitoring and reporting requirements. Carefully review the permit monitoring tables, including the footnotes. Keep a detailed log book of inspection and monitoring activities. Plan ahead for sampling events to ensure: 1) Analytical methods will meet permit requirements. 2) Detection limits are below permit limits. 3) Samples will be properly collected and preserved. Sample from collection points, as specified in the permit. Purge groundwater monitoring wells according to permit specifications. Track sludge (biosolids) volume, quality and disposal destinations, and submit annual report forms by February 19 of each year. Convert data to the proper units for comparison with permit limits.







� � � �







For more information, contact the ADEQ Water Quality Permits Section at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







Section 3 Page 8







WATER AND WETLANDS PROTECTION



BACKGROUND The United States has lost over half of its original wetlands. These areas provide important habitats, flood and storm protection and water quality benefits. It is extremely important to protect, restore and maintain the chemical, physical and biological integrity of our waters and wetlands to ensure that we do not lose the benefits these resources provide. Congress has recognized this and has passed a number of laws to protect U.S. waters and 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 plants (those that grow in, or are adapted to water, or that require a very wet environment). Many of these plants can be found in swamps, marshes, bogs, and other similar areas. Because of the congressional mandate to protect waters and wetlands, many activities that affect these areas could require a regulatory review before the activity begins. It is extremely important that local officials become familiar with these regulations because violation of these and related environmental protection laws can cause environmental damage and flooding of nearby areas and involve penalties, including fines, requirements to restore the area, and/or imprisonment for intentional violations. Actions your community should be taking: Many local governments may wish to assist their citizens, especially those seeking local construction permits or zoning approval, to determine whether in addition to local approval, state or federal authorization is also required.







Check before you act!



The agencies most frequently involved are: � Arizona Department of Environmental Quality � Water Quality Division � 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 before you start any activities that might affect the chemical, physical, or biological health of any U.S. waters or wetlands. Please contact the ADEQ Water Quality Permits Division at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







Section 3 Page 9







Wastewater System Self-Assessment Questionnaire



1. Do you own or operate a wastewater treatment facility?







      







Yes







 No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







2. Does your community have records of the last regulatory inspection conducted for your wastewater treatment facility? Yes







3. Is your community's wastewater treatment facility in compliance with environmental requirements? Yes







4. Has the wastewater system received any Notices of Opportunity to Correct (NOC), Notices of Violation (NOV) or Administrative Orders in the past three years? Yes







5. Are plans in place to correct violations? Yes







6. Does the pretreatment rule requirement apply to your community? Yes







7. Do you have a pretreatment program in place to prevent disruption of the treatment process? Yes







8. Are there any commercial or industrial facilities that discharge into the wastewater collection system that have the potential to negatively affect the treatment processes of your plant?







  



11.







Yes







 No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know



Section 3 Page 10







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







9. Do roof drains and/or storm drains connect to the sanitary sewer? Yes







10. Is inflow and infiltration a problem for your wastewater system? Yes







Are any homes or businesses served by onsite septic systems?











12.







Yes







Are there areas in your community with no wastewater treatment?















Yes







13.







Are there any indications that septic systems are failing either by surfacing of wastewater or pollution of groundwater?











14.







Yes







 No  No  No  No  No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know



Section 3 Page 11







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Have public health officials identified areas in your community where septic systems are failing or with no wastewater treatment?











15.







Yes







Are there conditions in your area that limit the applicability of conventional septic systems, such as high groundwater table, poor soil characteristics, or shallow bedrock?











16.







Yes







Has your community considered some form of management or required maintenance for onsite septic systems?











17.







Yes







Does your wastewater treatment discharge to navigable waters of the U.S.?











18.







Yes







Do you own or operate a drinking water treatment facility that discharges water?











19.







Yes







Does your drinking water treatment facility discharge to navigable waters of the U.S.?











20.







Yes







Do you know how and when your community's treated wastewater is disposed?











21.







Yes







Are there any natural resources that are potentially threatened by wastewater discharges such as groundwater aquifers, lakes, streams or washes?











22.







Yes







Do you have an Aquifer Protection Permit (APP)?











23.







Yes







Do you know the compliance status of your APP?











24.







Yes







Do you have a National or Arizona Pollutant Discharge Elimination System (NPDES or AZPDES) Permit?











25.







Yes







So you know the compliance status of your NPDES or AZPDES permit?















Yes







26.







Does the wastewater biosolids rule apply to your community?











27.







Yes







 No  No  No  No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Do you have difficulty disposing of sludge/biosolids from the treatment plant?











28.







Yes







Does the stormwater permit rule apply to your community facilities and activities?











29.







Yes







Do you have an inventory of the wastewater system assets and their location and condition?











30.







Yes







Have you conducted a materials survey to determine the size and types of pipe used in the collection system?











31.







Yes







Is the condition of the wastewater system regularly assessed to determine its operational capability?











33.







Yes







Do you have written policies and procedures that govern the operation and maintenance of the wastewater system?











34.







Yes







Do you have written policies and procedures that define roles and responsibilities for the operation and maintenance of the wastewater system?











35.







Yes







Do you have written policies and procedures that define the role of wastewater system personnel that includes a job description, benefits, and performance standards?











36.







Yes







Do you have written policies and procedures that document the regulatory requirements for the operation and maintenance of the wastewater system?











37.







Yes







Do you have written policies and procedures that document the regulatory requirements for wastewater permit monitoring and reporting?











38.







Yes







Can wastewater system personnel describe their day-to-day duties and responsibilities?















Yes







Section 3 Page 12







39.







Do you employ a licensed certified operator(s) of the proper grade and type required to operate the wastewater system?











40.







Yes







 No







 Don't Know







 Not Applicable







Do you have written policies in place to ensure that certified operators have adequate opportunities for training and maintaining license certification? (License Certification Renewal Hours Training)











41.







Yes







 No  No  No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know



Section 3 Page 13







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Are procedures in place to ensure wastewater managers and operators are aware of all compliance deadlines?











42.







Yes







Do you have regularly scheduled meetings to discuss wastewater system issues and needs?











43.







Yes







Does the wastewater system management and operator have a copy of the wastewater collection system and treatment facility drawings?











44.







Yes







Have you received complaints about the quality of service or about odor coming from your wastewater facility over the past three years?











45.







Yes







Do you have an Emergency Operations Plan (EOP) for the wastewater system?











46.







Yes







Do you have a written policy and procedure to ensure the security of your wastewater system?











47.







Yes







Have you evaluated the capacity of your wastewater system to accommodate future growth over the next 10 years?











48.







Yes







Do you have written plans in place to ensure the financial viability of your wastewater system over the next 10 years?











49.







Yes







Do you have written policies and procedures for establishing and reviewing wastewater rates?











50.







Yes







Are wastewater rates set at a level to ensure long-term viability of the system?















Yes







51.







Are revenues from user fees dedicated to the wastewater system as opposed to being used as general revenue for the community?











52.







Yes







 No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Are you currently paying back a wastewater system improvement debt? (Loan)











53.







Yes







Do you have a written process for dealing with past due bills and delinquent wastewater accounts?











54.







Yes







Does the wastewater system have an annual budget?











55.







Yes







Are the governing board and wastewater personnel both involved in developing the annual budget?











56.







Yes







Does the annual budget include financial resources to cover routine maintenance and the cost of repairing and/or replacement of worn out equipment or unforeseen emergencies?











57.







Yes







Do you have a Capital Improvement Plan (CIP) for the wastewater system?











58.







Yes







Do you have a written annual financial report for the wastewater system?











59.







Yes







Does your community understand the regulatory requirements for water and wetlands protection?















Yes







If you have any questions please contact ADEQ Water Quality Division at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







Section 3 Page 14







SECTION 4



HAZARDOUS WASTE and MUNICIPAL SOLID WASTE



HAZARDOUS WASTE



BACKGROUND



Many waste materials can be dangerous to human health and the environment if they are not properly treated, stored, transported, disposed of or otherwise managed. "Hazardous" wastes, as defined by the Resource Conservation and Recovery Act (RCRA), can pose fire hazards; are highly reactive; corrosive or explosive; and/or can result in exposure to toxic chemicals resulting in sickness or injury. In 1976, Congress enacted a law to make sure that hazardous waste is properly managed from the time it is created to the time it is disposed of or destroyed. This law is called the Resource Conservation and Recovery Act (RCRA), and it establishes a set of rules for dealing with hazardous and non-hazardous wastes. These rules (called RCRA requirements) define which hazardous wastes are subject to regulation. RCRA also identifies responsibilities for anyone who generates, transports, stores, treats, disposes of, or otherwise manages them. Hazardous wastes can be generated through many activities including those of governments, businesses, schools, hospitals, maintenance facilities and airports. People or operations that generate hazardous waste are called "hazardous waste generators." Households also generate hazardous waste but at this time, waste generated by individual households is not subject to RCRA waste requirements.







Categories of Hazardous Waste Generators: See Tables 1 and 2



Large Quantity Generators (LQG): A Large Quantity Generator is a facility which generates more than 1,000 kilograms per month (2,200 pounds) of any hazardous waste or more than one kilogram (2.2 pounds) of any "acute" hazardous waste. Large Quantity Generators are subject to all RCRA requirements. Small Quantity Generators (SQG): A Small Quantity Generator is a facility which generates more than 100 kilograms and less than or equal to 1000 kilograms a month of any hazardous waste. Small Quantity Generators that store hazardous waste on-site must also comply with some technical requirements, although they are not as stringent as those for LQG. Conditionally Exempt Small Quantity Generator (CESQG): Facilities that generate no more than 100 kilograms a month of any hazardous waste are conditionally exempt from RCRA regulations. Conditionally Exempt Small Quantity Generators must still (1) identify the waste to determine if it is hazardous, (2) treat or dispose of the waste in either a municipal solid waste landfill, a recycling facility or permitted hazardous waste facility, and (3) not accumulate more than 1,000 kilograms of hazardous waste on-site at any given time.







Section 4 Page 1







Table 1.



LGQ SGQ CESQG







Hazardous Waste Accumulation Limits



Kilograms (kg)



More than 1,000 More than 100 to Less than or equal to 1,000 Less than or equal to 100







Facility Size







Pounds (lb)



More than 2,200 More than 220 to Less than or equal to 2,200 Less than or equal to 220







Gallons (gal)



More than 300 More than 25 to Less than or equal to 300 Less than or equal to 25







Table 2.







Hazardous Waste Storage Limits



Kilograms (kg)



Any Quantity Less than 6,000 Less than 1,000







Facility Size



LQG







Pounds (lb) Gallons (gal)



Any Quantity Any Quantity







Storage Time Limits



Up to 90 days Up to 180 days OR 270 days if waste is transported over 200 miles No Time Limit







SQG







13,200







1,800







CESQG







Less than 220 Less than 300







Does this rule apply to your community? YES







 No







 Don't Know







 Not Applicable







Hazardous waste regulations apply to all communities. You need to know how to identify hazardous waste and how to treat or dispose of it. In addition, some types of hazardous waste may be generated by your community facility operations themselves. Because hazardous waste includes things like solvents, corrosives and materials containing heavy metals (e.g. chromium, 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 and whether it can cause explosions, fires, corrosive destruction of materials, chemical reactions, and/or can result in exposure to toxic chemicals resulting in sickness or injury. In addition to used materials which might be considered hazardous waste, you must also be careful with your management of products that you wish to discard. Leftover pesticides from grounds-keeping operations, old paint thinner, etc, must be fully evaluated before you determine what to do with it. EPA has identified several hundred chemical products which, if disposed of, would also be considered "listed hazardous waste." Trash Collection and Landfills Another area of possible concern for your community would be the operation of a trash collection system and/or a landfill. Household hazardous wastes are currently exempt from hazardous waste regulation but your landfill would be regulated under RCRA Subtitle D which describes EPA's "Municipal Solid Waste Landfill Criteria." This program is intended to ensure proper management of municipal landfills. However, the addition of commercial hazardous



Section 4 Page 2







waste materials collected and/or co-disposed with the household materials might necessitate that the entire facility be treated as a hazardous waste facility. For more information contact ADEQ Hazardous Waste Inspections and Compliance Unit at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call. Timetable Different timetables and responsibilities apply to the various activities. As long as you comply with requirements and accumulation restrictions outlined in Table 1 and 2, a storage permit is generally not required. If you accumulate waste for periods beyond those shown in Table 2, for LQG and SQG, you will have to secure a permit authorizing the treatment, storage or disposal of hazardous waste, which is a very expensive and lengthy process. Case by case extensions for accumulation times is available for Small Quantity Generators. Obtain Required EPA Identification Number (RCRA) If you determine that you are a LQG or SQG, you must obtain an EPA Identification Number from ADEQ. Actions your community should be taking: � Become familiar with the kinds of waste materials that are subject to hazardous waste regulations. � Become familiar with industrial facilities in or near your community. Understand how they are managing their hazardous waste. � Make sure you are handling hazardous materials properly and are meeting RCRA requirements. � Identify ways to reduce or recycle discarded chemicals. � Find non-toxic substitute products for hazardous waste chemicals. � Buy the right amount of chemicals you need. � Try to find someone to use the unwanted, unused chemicals rather than throwing them away. For more information contact ADEQ Hazardous Waste Inspections and Compliance Unit at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







MUNICIPAL SOLID WASTE DISPOSAL



BACKGROUND



Many communities in America are faced with a garbage disposal problem. In 2000, Americans generated an estimated 220 million tons of municipal solid waste. At the same time, fewer landfills are operating, partly because few people want to live near a landfill. To protect communities located near landfills and to make our waste disposal system work better, federal, state and local governments have adopted a new approach to waste management involving a mix of three management techniques: 1. 2. 3. Decreasing the amount of waste that must be disposed of. Increasing incentives for recycling. Improving the design and management of incinerators and landfills so they will have increased capacity and operate safely.







The challenge is to make landfills safe in order to protect our communities and our environment. The municipal solid waste disposal regulations greatly reduce the possibility that



Section 4 Page 3







landfills will become sources of pollution. These regulations describe measures that must be taken to guard against groundwater contamination and they describe the kinds of areas where landfills may not be built. Does your community own or operate a municipal solid waste (i.e. household waste) or construction and demolition debris (C&D) landfill?







  







Yes







 No  No  No







 Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable







Does your community own or operate a solid waste transfer station? Yes







Does your community own or operate a solid waste collection system? Yes







If your community does not own or operate a landfill, transfer station or solid waste collection system (garbage and trash); skip to the Self Assessment Questionnaire at the end of this section. If your community owns or operates a landfill, ADEQ regulations apply. ADEQ has an EPA-approved permitting program and is required by law to make sure landfill owners and operators meet federal and state requirements. Small Landfill Exemptions Owners and operators of new Municipal Solid Waste Landfill Facility (MSWLF) units, existing MSWLF units, and lateral expansion of existing units are generally exempt from certain landfill regulations if the following qualifications are met: � � � � The landfill receives less than 20 tons of waste per day (yearly average). The landfill shows no evidence of groundwater contamination. The landfill receives less than 25 inches of rainfall per year. There is no practicable waste management disposal alternative.







Extremely remote communities that have no ready access to other disposal sites for an extended period of time (three months of surface transportation interruptions) are likely eligible for an exemption. For more information on exemptions contact ADEQ Solid Waste Plan Review Unit at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call. Who is covered? RCRA Subtitle D regulations apply to landfills that accept household waste including garbage, trash and sanitary waste in septic tanks from "households, (single and multiple residences, hotels, motels, bunkhouses, ranger stations, campgrounds, picnic grounds and day-use recreation areas). Other requirements may apply to construction and demolition debris (C&D) landfills, surface impoundments, waste piles, land application units or units accepting only industrial nonhazardous waste. What is the timetable? Any municipal solid waste landfill unit that accepted waste after October 1993 must comply with the landfill regulations.



Section 4 Page 4







Landfill Regulations Effective October 1993: � Location restrictions. � Operating criteria. � Design criteria (new and lateral expansion only). � Closure and Post-Closure Care. Landfill Regulations Effective October 1994 to October 1996: � Groundwater monitoring and corrective action. Actions your community should be taking: If your community owns or operates a landfill or is considering developing a landfill, local officials are encouraged to contact ADEQ staff for assistance in understanding the compliance requirements. Local officials should be aware that citizens have the right to sue landfill owners and operators in court who do not comply with the federal and state regulations. The following is a brief explanation of the regulations:







LOCATION STANDARDS:



Airport Safety Because landfills attract birds that can interfere with aircraft operation, owners and operators of sites near airports must show that birds are not a danger to aircraft. This restriction applies to new, existing and laterally expanding landfills. Floodplains Landfills cannot be located in areas that are prone to flooding unless owners and operators can prove the landfill is designed to withstand flooding and prevent the waste from washing out. This restriction applies to new, existing and laterally expanding landfills. Wetlands Since wetlands are important ecological resources, new landfills and laterally expanding landfills cannot be built in wetlands unless the owner/operator can demonstrate that they meet certain requirements. Fault Areas and Seismic Zones In order to prevent damage to municipal solid waste landfills, new and laterally expanding landfills cannot be built in areas prone to earthquakes or other kinds of earth movement unless a demonstration can be made that the unit has been designed to withstand the effects of faults and seismic impact. Unstable Areas Landfills cannot be located in areas that are subject to mass movement including fissures, soilfluction, subsidence, landslides, mudslides or sinkholes, or near wetlands unless the owner/ operator can demonstrate that they meet certain requirements.







OPERATION CRITERIA:



Keeping Out Hazardous Waste EPA and Arizona have developed regulations specifically covering the disposal of hazardous wastes in special landfills. Owners and operators of municipal landfills must develop screening programs to keep these regulated hazardous wastes out of their landfills.







Section 4 Page 5







Cover Materials and Disease-Vector Control In general, each day's waste must be covered with soil to prevent the spread of diseases by rats, flies, mosquitoes and other animals that are naturally attracted to landfills. In addition, adequate daily cover controls windblown litter. Controlling Explosive Gases Methane gas, which occurs naturally in landfills, must be routinely monitored. If emission levels in the landfill are over a certain limit, the proper authorities must be notified and a plan must be developed and put in place to solve the problem. Restricting Access Owners and operators must restrict access to their landfills to prevent illegal dumping and other unauthorized intrusions. Controlling Stormwater and Protecting Surface Water To prevent pollutants from being swept into lakes, rivers or streams, landfills must be built with ditches and berms to keep stormwater from flooding their active areas and to collect and control stormwater runoff. Restricting Liquids Landfills cannot accept bulk or non-containerized liquid waste, such as waste from tank trucks and 55 gallon drums. This helps reduce both the amount of liquid leaching from the landfill and the concentrations of materials contained in the liquid. Controlling Air Emissions Landfills must be operated so they do not violate clean air laws and regulations. This includes no burning of wastes. Personnel Training Staff must be properly trained to ensure landfill operations are conducted correctly and according to the facility plan.







DESIGN CRITERIA:



Regulations require new and expanding landfills to be designed to protect groundwater by making sure that contaminant levels remain below maximum limits for safe drinking water. Groundwater Monitoring and Corrective Action Landfills must install monitoring systems to detect groundwater contamination. Sampling and analysis must be conducted based on the permit schedule. If groundwater becomes contaminated, owners/operators must clean it up to levels specified. Closure and Post-Closure Care (30 Years) When a landfill stops accepting waste, it must be closed in a way that will prevent problems later. A final cover must be designed to keep liquids away from the buried waste. After closure, the owner and operator must continue to maintain the final cover; continue groundwater monitoring to ensure that the landfill is not leaking; and perform other maintenance activities for 30 years. Financial Assurance To ensure that monies are available to correct possible environmental problems, landfill owners and operators are required to show that they have the financial means to cover expenses for site closure, post-closure maintenance, and cleanups. The regulations spell out ways to meet this requirement including, but not limited to, surety bonds, insurance and letters of credit.



Section 4 Page 6







Owners/operators of municipal solid waste landfills must obtain solid waste facility plan approval from ADEQ prior to construction and prior to implementing certain facility changes. For more information contact ADEQ Solid Waste Plan Review Unit and Solid Waste Inspections and Compliance Unit at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







OTHER SOLID WASTE FACILITIES:



NON-MUNICIPAL SOLID WASTE LANDFILLS



Does your community have any other types of non-municipal solid waste landfills such as construction and demolition (C&D) landfills, private landfills or soil treatment facilities?















Yes







 No







 Don't Know







 Not Applicable







Specific design and operational rules may apply to each of these types of land disposal facilities. These facilities are, at a minimum, subject to Aquifer Protection Permits (APP) regulations. Construction & Debris (C&D) Landfills � A solid waste facility accepting only solid waste derived from constructing, repairing or remodeling of buildings or other structures and/or demolishing buildings or other structures. Private Landfills � A solid waste facility that only accepts waste generated on-site. Soil Treatment Facilities � A facility where soil contaminated with metals and other contaminants are treated to reduce or eliminate leachability and/or total concentrations of the contaminants so the treated soils are considered inert or unregulated and the soils are reused as road base and other beneficial purposes.







SOLID WASTE TRANSFER STATIONS



Does your community own or operate any solid waste transfer station?















Yes







 No







 Don't Know







 Not Applicable







A transfer station is a site used for the handling or storing for 90 days or less of solid waste that was generated off-site for the primary purpose of transporting that solid waste. Transfer stations that have a throughput of 180 cubic yards are subject to self-certification and must submit notice to ADEQ. Transfer stations having a throughput of less than 180 cubic yards are subject to best management practices and must submit notice to ADEQ.







SOLID WASTE STORAGE FACILITIES



� � A facility at which solid waste is stored for more than 90 days are solid waste storage facilities. Solid waste facilities at which any waste is stored for 90 days or less are transfer stations (see above).



Section 4 Page 7







�







Solid waste storage facilities are subject to self-certification and must submit notice to ADEQ.







SPECIAL WASTE FACILITIES



Wastes from shredding motor vehicles and wastes containing petroleum contaminated soils (PCS) are defined as special waste. Special waste facilities are facilities where special waste is treated, recycled, sorted, stored or disposed. � Special waste facilities must obtain Special Waste Identification Numbers and are subject to annual reporting requirements.







WASTE TIRE COLLECTION FACILITIES AND SITES



Waste tires are categorized by the number of tires stored on a site. � A waste tire "facility" means a solid waste facility at which 5,000 or more waste tires are stored outdoors on any day. Waste tire facilities are subject to self-certification and must submit a notice to ADEQ. � A waste tire "collection site" means a solid waste facility at which more than 500 tires are stored outdoors on any day. Waste tire collection sites are subject to best management practices and must submit a notice to ADEQ.







OTHER WASTE TIRE SITES



Waste tire sites that store more than 100 used tires outside must comply with A.R.S. 441304.01. Storage, disposal, discard or abandonment of used motor vehicle tires; violation; classification; exception.







COMPOSTING FACILITIES



C omposting facilities must obtain file a notice with ADEQ and may be subject to plan approval. In addition, composting facilities may be subject to Aquifer Protection Permit (APP) requirements, if there is a potential for discharge of pollutants to the groundwater. Composting facilities must operate according to minimum operating standards.







BIOHAZARDOUS MEDICAL WASTE FACILITIES



Medical Waste means any solid waste that is generated in diagnosing, treating or immunizing a human being or animal or in any research relating to that diagnosis, treatment or immunization and includes discarded drugs. Biohazardous Medical Waste means medical waste that is composed of one or more of the following: 1. Cultures and stocks. 2. Human blood and blood products. 3. Human pathologic waste. 4. Medical sharps. 5. Research animal waste. Medical waste collection, transportation, treatment and disposal activities are regulated by ADEQ.







RECYCLING FACILITIES



A recycling facility is defined as a solid waste facility that is owned, operated or used for storing, treating or processing of recyclable solid waste and handles waste that has a potential for significant adverse effect on the environment. Recycling facilities are subject to best management practices and must submit notice to ADEQ.







Section 4 Page 8







For more information contact ADEQ Solid Waste Inspections and Compliance Unit or Solid Waste Plan Review Unit for facilities requiring plan approval at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







BIOSOLID (SLUDGE) PROCESSING FACILITIES



"Biosolids" are defined as sewage sludge. Biosolids facilities are facilities that process biosolids (i.e., composting facilities, etc). [Also see Section 9 Toxic Air Pollutants] Biosolid facilities must submit notice and obtain an Aquifer Protection Permit (APP) from ADEQ and must operate according to minimum standards. [See Permits: AZPDES: Other Programs Affecting AZPDES Sewage sludge and See Permits: Biosolids Sewage/Sludge] For more information contact the ADEQ Water Quality Permits Division at (602) 771-2300 or toll free at (800) 234-5677, press 0 to speak to the receptionist who will direct your call.







HAZARDOUS WASTE & MUNICIPAL SOLID WASTE SELF-ASSESSMENT QUESTIONNAIRE



Hazardous Waste



1. Do you have an EPA (RCRA) ID Number?











2.







Yes







 No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know



Section 4 Page 9







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Do you have a written Hazardous Waste Management Plan?











3.







Yes







Do you know which of your government's departments generate, store and ship hazardous waste?











4.







Yes







Do you know how your government's departments dispose of hazardous waste?











5.







Yes







Do you have written polices and procedures that document the regulatory requirements for the Resource Conservation and Recovery Act (RCRA)?











6.







Yes







Do you have written policies and procedures that govern the handling, storage and disposal of hazardous waste?











7.







Yes







Do you have written policies and procedures that define roles of hazardous waste system personnel that include a job description, benefits and performance standards?















Yes







8.







Do you have written policies and procedures to ensure that hazardous waste personnel are properly trained?











9.







Yes







 No  No  No  No  No  No  No  No  No







 Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know  Don't Know







 Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable  Not Applicable







Do you have written polices addressing the protection of health and prevention of injuries for hazardous waste personnel?











10.







Yes







Does your community have any special hazardous waste problems (illegal dumping)?











11.







Yes







Does your community have a program in place to address illegal dumping to determine if it is hazardous waste and to properly dispose of the hazardous waste?











12.







Yes







Does your community sponsor special household hazardous waste collection events?











13.







Yes







Do you have a program in place to encourage your community to reduce the amount of hazardous waste generated?











14.







Yes







Have you measured the effectiveness of your current hazardous waste reduction program?











15.







Yes







Does hazardous waste management staff have regular meetings open to the public?











16.







Yes







Does your community have a program to involve citizens in helping to provide input on hazardous waste management policies?











17.







Yes







Municipal Solid Waste



Do you own or operate a solid waste landfill?











18.







Yes







 No  No  No







 Don't Know  Don't Know  Don't Know



Section 4 Page 10







 Not Applicable  Not Applicable  Not Applicable







Do you have