COMMUNITY RELATIONS PLAN

HI-PLAINS CHEMICAL COMPANY SITE

MENLO, KANSAS

APRIL 1992

30479947

Superfund A. OVERVIEW OF COMMUNITY RELATIONS PLAN

This community relations plan identifies issues of community concern regarding the Hi-Plains Chemical Company site in Menlo, Kansas, and outlines activities to be conducted during and in conjunction with a removal at the site. Generally, community concern about the site is relatively restrained, primarily because contamination at the site has been known for approximately 14 years, because pesticides are a common element in most small agricultural communities, and because no one is known to have suffered any ill effects from toxaphene or other pesticides on the site. Nonetheless, residents are concerned that they do not know the extent of the contamination, that they do not know the potential effects of exposure to the contaminants of interest, and that, generally, they haven't been kept adequately informed of developments associated with the site. Several residents indicated they had heard rumors the entire town would be bought out by the federal government because of extensive contamination, with those expressing an opinion being divided roughly equally as to whether they would favor or oppose a buy out. Whatever the knowledge level and viewpoints of individuals in the community, concern is expected to increase as EPA and its contract crews begin removing contaminated soil and other materials. Because of the limited number of residents involved and the availability in the Menlo Rexford Cooperative (Menlo Co-op), an ample, conveniently located meeting room, efforts should be undertaken to meet directly with interested parties at a public information meeting.

This community relations plan has been prepared to assist EPA in developing a community relations program tailored to the needs of the population affected by the Hi-Plains Chemical Company site. EPA conducts community relations activities to ensure that the local public has input into decisions on Superfund actions and is well-informed on the progress of its actions. These sections follow:

o Capsule Site Description

o Community Background

o Highlights of Program

o Techniques and Timing

o Attachments: List of Residents and Interested Parties and Locations for Information Repository and Public Meeting

Areas of community concern and other information in this plan are based primarily through interviews conducted February 19-20, 1992, with representatives of 14 of the 22 households in Menlo, the manager of the Menlo Co-op, and the present owner of the site. In addition, contact was made with a representative of Northwest Kansas Groundwater Management District No. 4, clerks of Thomas and Sheridan counties and other potentially interested parties. Background information also was obtained

2 from "Site Assessment: Hi-Plains Chemical Company, Menlo, Kansas," Ecology and Environment, Inc., February 6, 1992," and from material provided by the Thomas County Historical Society.

The U.S. Environmental Protection Agency (EPA) Region VII has lead responsibility for managing any removal at Hi-Plains Chemical Company; the EPA Region VII Office of Public Affairs will oversee all community relations activities at the site.

B. CAPSULE SITE DESCRIPTION

The Hi-Plains Chemical Company site covers approximately 4 acres on the northern edge of Menlo, Kansas (NW 1/4, SE 1/4 of Section 13, Township 8S, Range 13W). Menlo is on the border of Thomas and Sheridan counties, with its easternmost north-south street separating Sheridan County to the east and Thomas County to the west. Seven of its approximately 60 residents are in Sheridan County, while the remaining residents and the site are in Thomas County. The closest residence is within one block of the site.

The Hi-Plains site includes a 125- by 75-foot former grade school building that was abandoned in 1963, at which time Harlan H. Williams began using the property for his aerial crop-spraying service. Beginning in 1975, a group of interrelated companies — Hi-Plains Sprayers, Schmitt Brothers Aerial Agricultural Services Co., Hi-Plains Chemical, Inc., etc. — operated from the site. The principals in the firms were brothers Leonard J. Schmitt and Robert D. Schmitt. The pesticide applicators used a partial basement under the west end of the school building for storage and knocked out the walls in the northeast corner of the building, which allowed them access to the gymnasium in that quadrant of the school for use as an airplane hangar. An open portion of the site north of the building was used as an aircraft runway. Several empty above-ground storage tanks are located at the northwest corner of the building. An underground storage tank and dispensing pump are located east of it and a septic tank and leach field lie west of it. The abandoned pesticide facility plant is slightly less than a block west of the closest residence and is a block northwest of the Methodist Church.

High Plains Sprayer and Hi-Plains Chemical Company produced a grasshopper and cricket bait that utilized 1.2-percent toxaphene as the active ingredient. The formulation, sold as Hi-Plains Border Bait and Hopper Stopper, was registered with EPA under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Other pesticides reportedly handled on the site included 2,4-dichlorophenoxyacetic acid (2,4-D), 2-(2,4,5-trichlorophenoxy) propionic acid (2,4,5-T), Meta-Systox R (oxydemotonmethyl,) disulfoton, Ramrod (propochlor), and atrazine. Operators of the Hi-Plains Chemical site reportedly employed poor pesticide management practices, resulting in complaints as early as 1978. The Kansas Department of Health and Environment (KDHE) cited the operators for improper disposal of pesticide wastes, improper storage of pesticide stocks and waste residues and inadequate security after an

3 inspection in 1980.

EPA restricted toxaphene's use to certified pesticide applicators in November, 1982. In 1983, Hi-Plains Chemical ceased operations and abandoned the property, leaving behind stockpiles of pesticides and waste products, with toxaphene being prevalent. Toxaphene is known to cause cancer in animals and is also a suspected carcinogen in humans. Excessive exposure could cause damage to the liver, kidneys, central nervous system, and the myocardium (heart muscles). Its use subsequently was banned completely by EPA under FIFRA.

Soil-sampling efforts have shown toxaphene to be the most prevalent contaminant, though in March 1986, KDHE found atrazine as high as 250 milligrams per kilogram (mg/kg); endrin, 8.3 mg/kg; and parathion, 6.7 mg/kg. Ecology and Environment, Inc.'s (E & E's) Field Investigation Team found toxaphene as high as 3,600 mg/kg in January 1987.

Comprehensive sampling by E & E's Technical Assistance Team (TAT) in September 1991 showed toxaphene in 53 of 205 surface soil samples, at levels of 5.7 to 6,400 mg/kg. A total of 44 samples in 14 4,700-square- foot sections had toxaphene levels above the removal action limit of 15.7 mg/kg that has been proposed for the site. At depth sampling indicates that three sections, where surface contamination with toxaphene exceeds 560 mg/kg, may require excavation to a depth of about 1 foot. Plaster from walls within the building was found to contain as much as 10,000 mg/kg of toxaphene. No samples from the site failed Toxicity Characteristic Leaching Procedure tests, which determine whether contaminated materials are likely to be mobilized in water.

C. COMMUNITY BACKGROUND

1. Community Profile

Located in North Randall Township, Thomas County, Kansas, Menlo received its name in 1899, when a post office was established at a site where Zillah had existed. Zillah and Mystic, located a mile and one-quarter northwest, had merged at the site of Menlo in 1888, when a branch line of the Union Pacific Railroad reached it. By 1905, Menlo had 25 institutions. By the 1920s, it provided business for a depot, three elevators, a stockyards, a hotel, three general stores, a bank, five gas stations, a newspaper, various other shops, and a movie theater. The city had 40 residences and was noted for its windmills.

The first school was built in 1890, with a new larger frame building constructed in 1904. During a period of school consolidation in the 1920s, a large brick school building was constructed. Enrollment reached 200 elementary and 100 high school students. Menlo, like many communities around it, was a victim of the Depression in the 1930s and of a various social trends, including lessened dependence on local businesses because of the expansion of highways and the influence of

4 automobiles. The school district was lost through consolidation in 1963, and the brick building was abandoned.

Today Menlo is typical of small western Kansas towns, in that its skyline is dominated by a large grain elevator, the Menlo Rexford Cooperative Elevator. Most commerce is related to agriculture, with both dryland and irrigation techniques being applied to surrounding farmland. The nearby area is flat, becoming more rolling to the south as the south fork of the Solomon River is approached.

Residents are self-employed, own and/or work on surrounding farmland, or hold jobs in Colby, the county seat, which is located 18 miles west of the junction of U.S. 24 and K-186, an intersection located 2 miles north of Menlo. In addition to the elevator, there is a bar/cafe, and a used auto parts business. Children attend grade school in Rexford and junior high and high school in Selden, as part of a consolidated school district.

2. Chronology of Community Involvement

The Hi-Plains Chemical Company site was brought to the attention of KDHE in 1978, when a Menlo resident expressed concern that ground water pollution might occur, because the operators were mixing pesticides over an open well in the former grade school building. KDHE followed up with inspections in 1979 that included sampling of the on-site well. Initial analytical results from the well in 1979 showed low levels of pesticides, but later results the same year indicated no ground water contamination. Testing in subsequent periods, while occasionally detecting low levels of pesticides and of volatile organic compounds, has not suggested significant ground water contamination.

Residents, generally, have expressed little concern about the site, a fact that may be due, in some degree, to a certain level of comfort with pesticides used in an agricultural community. Despite not voicing fears about either the site or ground water under Menlo at least one resident has had his well water tested by Servi-Tech, an agricultural services company. The analysis, according to the resident, who lives within a block and one-half of the site, did not show any contamination.

KDHE did not conduct any public meetings in conjunction with the removal in 1986 of whole and broken pesticide sacks, contaminated debris and contaminated equipment. Contact with the residents was typically accomplished through informal conversations at the Menlo Co-op, which along, with the Menlo Pool Hall is a public gathering point in the community. KDHE's project manager for the removal said residents expressed some dissatisfaction that certain possibly salvageable equipment from Hi-Plains Chemical, such as air compressors, were not made available to the public. Those concerned about the apparent waste eventually accepted the disposal of the contaminated equipment as a sensible approach, according to the state's project manager.

5 3. Key Community Concerns

Though residents of the Hi-Plains site express neither fear nor serious concern about its presence, several rumors and some strongly held views surfaced during community interviews. Those of note, either because of their seriousness or prevalence include:

o Generally, citizens of the community accept pesticides as part of an agricultural environment and are not overly fearful of them. Several residents, however, said they had no knowledge of what class of contaminants are present at the Hi-Plains Chemical Company site, much less that toxaphene is the primary contaminant of concern.

o Although most residents do not appear to take seriously the possibility of a threat from the site, nearly everyone has heard rumors that EPA would condemn the town, rather than attempt to complete a cleanup. The genesis of those rumors may be a misconception as to how much KDHE spent during the 1986 removal. Although the KDHE project manager said the 1986 removal cost in the range of $200,000, residents believed it cost in the millions. Rumors place the cost of the pending removal at $4 million to $7 million, suggesting to those who have heard reports that it would be less expensive to buy out and relocate the property owners. Sentiment among those who had heard the buy-out rumor and expressed an opinion was roughly split, with some favoring such an approach and others opposed.

o While residents generally accept reports that indicate that the site has not resulted in ground water contamination, at least one resident was concerned enough to arrange for analysis of water from a private well. Other residents and an employee of the Northwest Kansas Groundwater Management District No. 4 (based in Colby) expressed a desire for long-term ground water monitoring around the site. The ground water management representative, in fact, offered his agency's services in collection of any necessary samples and installation of any wells or lysimeters (used to sample water from unsaturated zones). Much of the concern stems from the region's irrevocable economic ties to the Ogallala Aquifer, which lies 120 feet deep under the site. The Ogallala, the only water source available, sustains an irrigation economy and provides domestic water.

o With the exception of limited concern that the site's contaminants could reach the Ogallala Aquifer, there is virtually no concern about the site beyond Menlo and the nearby rural area. The Thomas County Clerk and a staff member of the Colby Chamber of Commerce did not immediately recall the site. Upon being prompted, the clerk said Colby's

6 residents have no concerns about the Hi-Plains site, but are very concerned about the Ace Services, Inc. site, which has affected at least one city well with chromium contamination. The Sheridan County Clerk said the county's residents have no fear of the site, though she said the county commission was pleased by reports that no materials from the site would be disposed into the Sheridan County community landfill.

o Though the toxaphene and less prevalent contaminants do not vex the residents to a great degree, there is a strongly voiced consensus that the abandoned school house on the site should be totally demolished and disposed, primarily because it is "an eyesore." Although the dilapidated building would appear to pose physical threats to anyone entering, none addressed that aspect. No one indicated knowledge of children sneaking onto the property for play or other purposes.

Although concerns seem of a general low-key nature and attitudes — except for the feeling that the school building should go — are not crystallized, the potential exists for changes in attitude with the onset of a removal. Sampling crews have encountered no difficulties when eating at the Menlo Pool Hall, the only eating establishment in town, and there is no expectation that would change during removal activities. Nonetheless, the potential exists for attitudes to change during removal for the following reasons.

o Property Values: The commencement of earth moving could disappoint some who have believed rumors that EPA would buy out the town at prices attractive in the current real estate market, rather than clean up the property. Conversely, cleanup of the site might improve property values as it removes reluctance on the part of residents to buy or upgrade existing properties.

o "Lost" Business Opportunities: Although not a resident of Menlo, one unidentified owner of construction equipment has reportedly told area residents he expected to get part of removal contracts worth millions of dollars. Although the existence of such an individual was not verified, utilization of the Emergency Response Cleanup Services (ERCS) Contractor by EPA, because of Occupational Health & Safety Administration requirements for health and safety training, has the potential to disappoint local entrepreneurs who have hoped to profit from any cleanup. The current owner of the property, according to some interviewees, has expressed an interest in selling the bricks from the school house, so that they may be recycled. He was noncommittal about his plans when interviewed during preparation of the community relations plan.

7 o Inconvenience: Removal of contaminated soil from the site will result in increased truck traffic on narrow roads in Menlo and on the surrounding roads. Large semi-trailers, because of the volume of grain produced and transported in the area, are commonplace, so trucks associated with the removal are unlikely to disrupt other drivers. Sampling crews contracted to the EPA in the past have scheduled lunch at the city's only diner at non-rush times, so as to avoid overcrowding the establishment. Dust control, which will be maintained on site to prevent migration of contaminants, could become necessary because of increased traffic, but should be minimal because streets and roads appear to be adequately sanded.

o Conducting Removal Work: Removal work, because of the necessity for crews to wear personal protective equipment (PPE), has a tendency to make those unfamiliar with cleanup operations uneasy. Observation of crews dressed in PPE has the potential to raise doubts that the removal can be conducted safely and without a threat of contaminating residents, or might suggest to residents that dangers have been understated.

D. HIGHLIGHTS

The community relations plan for the Hi-Plains Chemical Company site should be designed to allow the community a maximum opportunity to familiarize itself with the logic used and physical methods that will be employed during the removal. The program should take into account the community's need for information and its interest and willingness to be informed of the removal process.

The community relations program should include the following approaches:

1. Respond directly to Menlo's residents through an informational meeting that encourages questions and exchange of ideas. The limited population makes it possible to provide direct contact between the EPA and those with questions or concerns about the site through a public meeting.

2. Provide explanations about sampling procedures, the adopted removal action levels and any long-term monitoring that is considered. Although establishment of removal action levels and determination of confidence levels associated with cleanups are formidable topics, every effort should be made to assure residents that contaminants have been removed. This effort is necessary in light of earlier rumors that Menlo is so contaminated that the entire city should be condemned.

3. Educate area residents and local officials about the procedures, policies and requirements of the Superfund program. General misconceptions about the Superfund process, coupled with the belief of

8 some residents that KDHE should have undertaken complete cleanup of the site in 1986, make it essential that Superfund and the sources of funds and the interrelationship of EPA, state and local agencies be explained.

5. TECHNIQUES AND TIMING

The following activities are essential for a Hi-Plains Chemical Company community relations program:

1. Availability for review of the Engineering Evaluation/Cost Assessment prepared for the site. The EE/CA prepared for Hi-Plains Chemical Company site will provide background information and details that EPA will use as it considers options for cleanup at the site. These data will provide residents with a good start on understanding the cleanup process.

2. Conduct an informational meeting with residents prior to initiation of cleanup at the site. The meeting's primary goal should be to respond to questions, dispel rumors and generally to raise the community's comfort level with the removal process that will be used at the site. Additional meetings, including a formal public meeting to take testimony, could be considered. The number attending any meeting scheduled cannot be predicted, though most contacted said such a meeting would be of interest. Though concern is not high, curiosity and the acceptance of the Menlo Co-op meeting room as a social center could result in a relatively large turnout from among Menlo's residents and the 150-200 individuals who live on farms within 5 miles of the site.

3. Designation of a single contact for the site. Because a key element of any effort to dispel rumors or get out the facts is to speak with a single voice, one individual should be designated as the primary contact for those interested in the site. Although it may be someone other than the on-scene coordinator initially, the responsibility of primary contact should be the OSC's, once the OSC is on the site for removal activities.

4. Prepare fact sheets and technical summaries, as interest dictates. Because of the availability of the EE/CA and the opportunity for the 60 residents of Menlo to participate firsthand in informational meetings, it will be possible to assess periodically whether additional written information or public meetings are needed.

5. Provide news releases to local media. Prepared news releases should be provided to the local newspaper, television and radio stations. Menlo residents do not have access to cable television, receiving signals from one station in Colby and from stations in Wichita and Goodland through repeater facilities. Routine notices of meetings could be expeditiously handled by phone calls to KXXX-K.QLS radio, K.TCC-FM radio, KLBY-TV and the Colby Free Press, all in Colby, and The Hoxie Sentinel.

9 Addresses and phone numbers of media outlets are provided in Appendix A.

6. Establish and publicize official repositories. Although interest is localized, establishment of a repository in Colby is advisable, along with one in Menlo. Such a course will make it easier for county officials and residents in the county seat to have access to the administrative record, EE/CA, Community Relations Plan and other site-related documents of potential interest.

10 Attachment A

Mailing List For Hi-Plains Chemical Site Menlo, Kansas

A. Federal Elected Officials Phone

Senator Bob Dole (202) 224-6521 Room 141 Senate Hart Building Washington, D.C. 20510 or 4th Financial Center (316) 263-4956 100 N. Broadway Wichita, Kansas 67202

Senator Nancy Kassebaum (202) 224-4774 United States Senate Washington, D.C. 20510-1602 or 911 N. Main (316) 276-3423 Garden City, Kansas 67846

Congressman Pat Roberts (202) 225-2715 Room 1110 Longworth House Office Bldg. Washington, D.C. 20515 or P.0. Box 128 (913) 877-2454 105 S. Norton Norton, Kansas 67654

B. State Elected Officials

Governor Joan Finney (913) 296-3232 2nd Floor State Capitol Topeka, KS 66612

Sen. Sheila Frahm (913) 296-7356 Room 143 North State Capitol 300 SW 10th Topeka, KS 66612 or 985 S. Range (913) 462-6948 Colby 67701

11 Rep. Donald Crumbaker (Thomas County) (913) 296-7685 Room 182 West State Capitol 300 SW 10th Topeka, KS 66612 or Box 187 (913) 694-2770 Brewster, Kansas 67732-0187

Rep. Fred Gatlin (Sheridan County) (913) 296-7692 Room 181 West State Capitol 300 SW 10th Topeka, KS 66612 or 610 Main (913) 626-3780 Atwood, Kansas 67730

C. Local Officials

Charles Phillips, Mayor of Menlo (913) 855-2264 Rose Phillips, City Clerk HCR 1 Box 7 Menlo, KS 67746

Sheridan County

Fred Bixenman, Commission Chairman (913) 824-3480 RR 1 Box 31 Grainfield, KS 67737

Eugene Schwarz, Commissioner (913) 824-3434 RR 1 Box 41 Grinnell, KS 67738

Dean Thomas, Commissioner (913) 675-3895 RR2 Box 80 Hoxie, KS 67740

Doreen Kennedy, County Clerk (913) 675-3895 Box 899 Hoxie, KS 67740

Thomas County

J. H. Nickel, Commissioner (913) 462-2293 Box 453 Colby, KS 67701

12 Ernest S. Kistler, Commissioner (913) 846-7659 Rt 2 Box 470 Colby, KS 67701

John Bremenkamp (913) 462-3768 Rt 1 Box 410 Colby, KS 67701

Rosalie Seeman, County Clerk (913) 462-2561 300 N. Court Thomas County Courthouse Colby, KS 67701

D. U.S. EPA Region VII Officials

Rowena Michaels, Director (913) 551-7003 Office of Public Affairs 726 Minnesota Ave Kansas City, KS 66101

Hattie Thomas, Community Relations Coordinator (913) 551-7003 726 Minnesota Ave Kansas City, KS 66101

Carl Bailey, On-Scene Coordinator (913) 551-5015 Emergency Planning and Response Branch 25 Funston Road Kansas City, Kansas 66115

Ken Rapplean, Superfund Coordinator for Kansas (913) 551-7769 726 Minnesota Ave Kansas City, KS 66101

E. State Agencies

Paul Belt, Project Manager (913) 296-1679 Kansas Department of Health & Environment Forbes Field Topeka, KS 66620-0001

F. Property Owner

Chuck Stephen (913) 855-2315 HCR 1 Box 80 Menlo, KS 67746

13 G. Interested Party

Keith Reavis, Research Geologist (913) 462-3915 Northwest Kansas Groundwater Mangagement District No. 4 P.0. Box 905 1175 S. Range Ave. Colby, KS 67701

H. News Media

Colby Free Press (913) 462-3963 155 W 5th Colby, KS 67701

The Hoxie Sentinel (913) 675-3321 640 Main Hoxie, KS

Radio

KXXX-KQLS (913) 462-3305 1065 S. Range Colby, KS 67701

KTCC-FM 91.9 (913) 462-6762 1255 S. Range Colby, KS 67701

Television

KLBY-TV Channel 4 ABC (913) 462-8644 990 S. Range Colby, KS 67701

Box Yuna, News Director (316) 943-4221 KSNW-TV Channel 3(8 in Colby) NBC Box 333 Wichita, KS 67201

KBSL Goodland Channel 10 CBS (Repeater for) KBSH-TV CBS (913) 625-2578 2300 Hall Hays, KS 67601 Ed Zimmer, Environmental Reporter

14 Attachment B

Information Repositories

Phone Hours Menlo Rexford Co-op (913) 855-2256 Weekdays 8 a.m. to 5 p.m. HCR 1 Box M9 Saturday 8 a.m. to noon Menlo, Kansas

Pioneer Memorial Library (913) 462-7563 M-T 10 a.m. to 8 p.m. 375 West 4th Friday 10 a.m. to 5 p.m Colby, Kansas Saturday 10 a.m. to 4 p.m. Sunday 1 to 4 p.m.

U.S. EPA Region 7 (913) 551-5000 Weekdays 8 a.m. to 5 p.m. 25 Funston Road Kansas City, Kansas

Meeting Location

Menlo Rexford Co-op Seating Capacity: HCR 1 Box M9 130 at tables Menlo, Kansas

15 $5£ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 7 25 FUNSTON. ROAD KANSAS CITY, KANSAS 66115

December 4, 1992

MEMORANDUM SUBJECT: Responsiveness Summary for the Hi-Plains Chemical Company Site Removal Action, Menlo, Kansast Thomas County, Kansas; Superfund Site ID Number 6C FROM: Carl BaileyC^* OSC, Field Removal Section

THRU: George Hess Acting Chief, Field Removal Section

onald McCutcheon. Chief, Emergency Planning and Response Branch To: The Record The Administrative Record ('Record*) for the Hi-Plains Chemical Company Site Removal Action was compiled and a copy was placed at the Menlo Rexford Coop in June 1992. The Public Notice of Availability was published June 1, 1992, in the Colby Free Press (Attachment 1). In the advertisement, information was given regarding contents of the Record and the repository location. Also included was an invitation to interested persons to review the contents of the Record and submit their comments in writing to the Chief of the Emergency Planning and Response Branch by July 1, 1992, the time frame of 30-day the public comment period on the Record. A formal tracking sheet for public comments was established and maintained by an Administrative Records Coordinator (Attachment 2). At the close of the 30-day public comment period no public comments had been received in this office. Therefore, this memorandum will serve as the Responsiveness Summary on the Administrative Record File for the Hi-Plains Chemical Company Site Removal Action.

Attachments

RECYCLE AFFIDAVIT OF PUBLICATION ATTACHMENT 1 State of Kansas, Thomas County, ss:

Linda Hale, being first duly sworn, deposes and says: Thai she is ihc legal secretary of mm f THE COLBY FREE PRESS a daily ncwspajrcr printed in the state or Kansas, and published in and of general circulation in Thomas County, Kansas, with a general paid circulation on a yearly basis in Thomas County. Kansas, and that said newspaper is not a trade, religious or fraternal publication. Said newspaper is published at least 50 times a year; has been so published contin­ uously and uninterruptedly in said county and state for a period of more than five years prior to the first publication of said notice; and has been admitted at the post ;rAgpr^3;(^ office of Colby, Kansas, in said county as second class matter. iiiiav^Babflity^fpc^ psjWjc'/rwWW/ofJdo^'rnOTts^t WnyTadrhlhlstrath«ji^'rdinio>fdr.s«ioction of {£ That the attached notice is a true copy thereof and was published in the regular and entire issue of said newspaper for...... consecutive weeks, the first publica­

tion thereof being made as aforesaid on the..... 1...... day of...... (nelAa' an/l lA^AnMiiMMfthA1 mi ikJL#*1 “fS

19.with subsequent publications being made on the following dates:

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Legal Secretary

Subscribed and sworn to before me this...... /..Ct...... day of ...... CSLftfe;...... 19..?.<£.

ROTARY PUBLIC-Stitt8f BAMBI SEARLS MyAppt Exp. Nov. % 1993 Notary Public iBpb^Sah^.25^ '.''A... \9..%S My commission expires:......

ff.Hj&'ic- I Printer's fee S...... additional copies ......

t ATTACHMENT 2

TRACKING SHEET FOR PUBLIC COMMENTS ON THE ADMINISTRATIVE RECORD FOR

Hi-Plains Chemical Company Site Site Name

Menlo, Thomas County, Kansas City, County, State Public Notice publication date: June 1, 1992 Public Comment Period expiration date: July 1, 1992

mirvlfejtrative Record Coordinator Date