EPA
f  908/
  1980.4
                                     COOPERATIVE AGREEMENT    '
                                     BETWEEN
                                     THE COLORADO' DEPARTMENT  OF HEALTH"
                                     AND
                                     REGION VIII
                                     OF
                                     THE  UNITED STATES
                                     ENVIRONMENTAL PROTECTION AGENCY
                                      THE CONDUCT OF ENVIRONMENTAL
                                      HEALTH PROGRAMS IN COLORADO
                                      FISCAL YEAR 1981
                                      SEPTEMBER  1980

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                            COLORADO/EPA COOPERATIVE AGREEMENT

                                         1980-1981

                                  PRINCIPAL PARTICIPANTS
Frank A. Tray!or, Jr., M.D.
Executive Director
Colorado Department of Health
        Roger L. Williams
        Regional Administrator
        U.S. Environmental Protection Agency
        Region VIII
                                   Morgan Smith
                                   Commissioner
                                   Colorado Department of Agriculture
Robert A. Arnott
Assistant Director for Health Protection
 and Environmental Programs
        Robert L. Duprey
        Director
        Air and Hazardous Materials Division
Stephen M. Kelsey
Environmental Policy and
 Planning Coordinator
Colorado Department of Health
        Duane Traylor
        Colorado Coordinator
        U.S. Environmental Protection Agency
        Region VIII
                          STATE/EPA AGREEMENT ADVISORY COMMITTEE
John A. Covert
Assistant City Manager
City of Colorado Springs
        Hester McNulty
        "208" Policy Advisory Group

Eric Eidness
Boulder, Colorado
Commission
Raymond 0. Reeb
Colorado Water Quality
 Control Commission
        Vicky Gow
        Colorado Air Quality Control
        Joe Madonna
        Soli da Waste Advisory Committee
Bryan Miller
Colorado Environmental Health
 Directors
        Blake Jordan
        Colorado Municipal League
Toni Worcester
Colorado League of Women Voters
        Dan Parker
        Colorado Association of Soil
        Conservation Districts

U.S. Environmental Protection Agency
Library, Room 2404  PM-211-A
401 M Street,  S.W.
Washington,  DC   20460

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                                           -2-
J.K. Smiths
Colorado Counties, Inc.
                                                   Jay Knudsen
                                                   Ad-Hoc Hazardous Waste Committee
Mary Taylor
Boulder, Colorado
                                                  Connie McDonough
                                                  Grand Junction, Colorado
John Nichols
Simla, Colorado
                                                  Lawrence Cerrillo
                                                  Evergreen, Colorado
Allen Jones
American Waste Works Association/
 Water Pollution Control  Association
                                                  Roland Gow
                                                  Colorado Association of Regional
                                                   Councils
Robert Farley
Colorado Association of Regional
 Councils
                                                  Paula Herzmark
                                                  Executive Director
                                                  Colorado Department of Local Affairs
                                   David  Holm
                                   Mined  Land Reclamation Board
                                   Colorado  Department of Natural Resources

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                                        TABLE OF CONTENTS'
                                                                                   Page
        Table of Contents                                                            i
        Glossary of Abbreviations                                                   iv
        PART I - INTRODUCTION                                                        1
        A.   The State/EPA Cooperative Agreement                                       1
        B.   Environmental Health Issues in Colorado                                  7
            1.    Water Pollution            ,        .   '                             7
                  (a.)  Point Source Problems
                  (b.)  Non-Point Source Problems
                  (c.)  Drinking Water Problems
            2.    Air Pollution                                                     10
                  (a.)  Colorado Springs Area
                  (b.)  Denver Region
                  (c.)  Grand Junction Area
                  (d.)  Larimer-Weld Region
                  (e.)  Pueblo Area
            3.    Hazardous  and Solid Wastes                                         12
                  (a.)  Hazardous Wastes.
                  (b.)  Solid Wastes
 /           4.    Environmental Disease Control                                      14
/
            5.    Radiation                                                          15
            6.    Environmental Emergency  Situations                                 16
            7.    Noise                                                             16
            8.    Pesticides                                                  .      17
            9.    Toxics                                                            17
        C.   Environmental Agencies in Colorado                  .,                    18
            1.    Colorado Department of Health                                      18
                  (a.)   Office of .Health Protection and  Environmental Programs  .
                  (b.)   Water Quality Control Commission and Division

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                                                     .   ,                   Page
          (c.)  Air Quality Control Commission and,Division
          (d.)  Radiation and Hazardous Wastes Control  Division
          (e.)  Disease Control and Epidemiology Division
          (f.)  Consumer Protection Division
    2.    U. S. Environmental Protection Agency - Region VIII               20
          (a.)  Air and Hazardous Materials Division
          (b.)  Water Division
          (c.)  Enforcement Division
          (d.)  Surveillance and Analysis Division
    3.    Other Agencies                                                    20
          (a,)  Colorado Department of Local Affairs
          {b.)  Colorado Department of Agriculture
          (c.)  Colorado Department of Natural Resources
          (d.)  Local Health Departments
          (e.)  Councils of Governments
PART II - THE 1980/81 COOPERATIVE AGREEMENT BETWEEN THE
          COLORADO DEPARTMENT OF HEALTH AND THE U.S.
          ENVIRONMENTAL PROTECTION AGENCY - REGION VIII
A.  Agreement, Signed by the Executive Director of the Colorado
    Department of Health and the Regional Administrator of the
    U.S. Environmental Protection Agency, Region VIII,  and                             v  T
    including the Commissioner of the Colorado Department of                           ^
    Agriculture for pesticide control activities.                           23
B.  1980/81 Environmental Programs Key Management Objectives                24
    1.  Water Quality Program                        •,                       26
    2.  Water Quality Management Planning and Policy
        Coordination                                                        33
    3.  Automotive Inspection and Maintenance                               35
    4.  Hazardous Waste Control                                             41
    5.  Environmental Epidemiology                                          44
1

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                                                                           Page
    6.  Environmental Emergency Response                                    47
    7.  Intergovernmental Environmental Issues Management                   50
    8.  Cumulative Environmental Assessment of Energy
        Development in Colorado                                             54
    9.  Environmental Data Management                                •       58
    10.  Pesticides                                                         61
C.  1980/81 Environmental Work Plans
    1.    Summary of Environmental Program Resources Subject
          to the FY 1981 State/EPA Agreement                                63
    2.    Water Quality Control                                             65
    3.    Air Quality Control                                              101
    4.    Hazardous and Solid Waste Control                                114
    5.    Environmental Epidemiology                                       119
    6.    Environmental Emergency Response                                 122
    7.    Noise Control                                        •            125
Appendix A:  EPA Activities Without State Participation
Tentative Schedule for Development of FY 1982
    State/EPA Agreement

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                                       -iv-
                            GLOSSARY OF ABBREVIATIONS
AS             Colorado Attorney General's Office
APCD           Air Pollution Control Division (Colo. Dept. of Health)
AQCC           Colorado Air Quality Control Commission
AST            Advanced secondary treatment (water quality)
AWT            Advanced waste treatment {water quality)
BAT            Best available technology
BEJ            Best engineering judgement
BMP            Best management practices
CDH            Colorado Department of Health
CO             Carbon monoxide
COG            Council of Governments {organization of local governments)
CPP            Continuous Planning Process (water quality)
CWA            Federal Clean Water Act
C&ED           Disease Control and Epidemiology Division (Colo. Dept. of Health)
DWS            Drinking water supply
EIS            Environmental Impact Statement or Emissions Inventory System (air
               quality)
EMS            Emissions monitoring system (air quality)
EPA            U.S. Environmental Protection Agency
FIFRA     "     Federal Insecticide, Fungicide and Rodenticide Act
HC             Hydrocarbon
I/M            Automotive inspection and maintenance
ISOS           Individual sewerage disposal system
MCL            Maximum contaminant level (drinking water supply)
MMS            Municipal management system (publicly-owned wastewater treatment
               facilities)
NEDS           National Emission Data System (air quality)
NESHAPS        National Emission Standards for Hazardous Air Pollutants
N02/NOX        Nitrogen dioxide/nitrogen oxides
NOV            Notice of violation
NPDES          National Pollutant Discharge Elimination System (water quality
               permits program)
03      .       Ozone
OHP            Office of Health Protection and Environmental Programs (Colo.
               Dept. of Health)
O&M            Operations and maintenance
OPR            Office of Public Relations (Colo. Dept. of Health)
OSC            On-scene coordinator (emergency response)
POTW           Publicly-owned treatment plant (wastewater)
PSI       '     Pollutant Standards Index (air quality)
PSD            Prevention of significant deterioration (air quality)
QA             Quality assurance
QNCR           Quarterly Noncompliance Report {water quality)
RCRA           Federal Resource Conservation and Recovery Act
R&HWCD         Radiation and Hazardous Wastes Control Division (Colo. Dept. of
               Health)
SIP            State Implementation Plan for Air Quality
SLAMS         -State and Local Air Monitoring System
SPCC           Spill prevention, control and containment (water quality)
TSP            Total suspended particulates (air quality)
UIC            Underground injection control (water quality/ground water)
VMT            Vehicle miles of travel
WLA            Waste load allocation (water quality)
WQCD      Water Quality Control Division (Colo. Dept. of Health)
1

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                                       PART I. - INTRODUCTION


        A.   THE STATE/EPA COOPERATIVE  AGREEMENT

        This document  is  the annual  cooperative  agreement  between  the Colorado Department
        of  Health and  Region VIII  of the  United  States  Environmental  Protection Agency for
        Fiscal  Year 1981.   The purpose of this  "State/EPA  Cooperative Agreement"  is  to
        identify those elements of Colorado's environmental  health programs  which are to
        be  supported by EPA financial  and/or, staff  resources in  a  cooperative  effort with
        the State of Colorado to attain and  maintain  a  high  level  of  environmental quality
        in  Colorado.

        Prior to FY 1980,  each of  the  Colorado's environmental programs  developed lengthy
        individual  applications for  federal  funding support.  This annual  activity was not
        coordinated among  the various  State  programs  and the EPA,  and consequently result-
        ed  in much  time-consuming  duplication of effort and  an uncertain understanding of
        the relationship  between different environmental problem areas and programs.  In
        short,  the application process was not  as useful as  it potentially could  be.  In
        recognition of this problem, the  State  and  the  EPA have  sought to  establish  an
        integrated and cooperative process whereby  the  State's environmental priorities
        are identified in  a comprehensive manner and  the relationships among them are made
        more apparent  and  understandable, thus permitting  the best all-around  use of
        available resources.

        The basic principle of the Agreement is  to  integrate the federally funded environ-
        mental  program elements into one  cohesive and coordinated  program.   This  inte-
        grated approach to environmental  problem-solving gives both the  State  and the EPA
        a management tool  to steer programs  in  a coherent  direction,  consistent with
        clearly established objectives.   It  also constitutes a joint  management process
        based upon close  working cooperation between  State and federal program managers.
        Each of the program priorities appearing in the Agreement  was mutually agreed upon
        by  the State and  the EPA,  and  the EPA and State staffs worked closely  together in
        developing  the specific work plans in this  Agreement.

•*       The federal funding programs being applied  to the  State  environmental  activities
>  ,      covered by the Agreement include: the Water  Quality Management  (106)  Program; the
'../      Safe Drinking  Water Program  (P.L. 93-523);  the  administration of Wastewater  Treat-
/       ment Works  Construction Grants (205(g)); the  Water Quality Planning  (208)  Program;
/       the Resource Conservation  and  Recovery Act  (RCRA); and the Clean Air (105)
        Program.  The  federal  funds  from  these  programs furnish  about 50 percent  of  the
        overall funding for the environmental programs  operated  by the CDH.  The  balance
        of  the State's funding for environmental programs  comes  primarily  from appropri-
        ations by the  State Legislature and  from fees paid for permits,  licenses,  etc.

        As  a management tool,  the Agreement  offers  several important  opportunities.  The
        most important is  the setting  of  overall programmatic and  budgeting  priorities.
        •The heart of the  Agreement is  the definition  of "key management  objectives"  for
        the FY  1981 environmental  programs and the  specification of detailed work plans
        for each program  area.  The  key management  objectives upon which the FY 81
        Agreement is founded reflect a commitment by  both  the State and  the  EPA to address
        key environmental  problems facing Colorado.   These management objectives  were
        identified not only on the basis  of  the  severity or  importance of  the  problem to
        be  addressed,  but  also because it was felt-by both the State  and the EPA  that
        specific, meaningful  results realistically  could be  achieved  by  the  efforts  to
        address these  items.

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                                         -2-   -                         .   "


The Agreement also provides a basis for evaluating State and EPA environmental
programs by singling out the issues of primary importance.  The intent is to
insure that the State is able to build accountability for performance and achieve-
ments into its environmental programs, and to facilitate the evaluation of program
accomplishments in light of stated objectives and priorities.  The Agreement also
allows the State to expect that the EPA similarly will work towards achieving the
priority objectives, and commits the EPA to provide a specific level of financial
support for the achievement of the State's objectives.

The tedious detail required in former grant application was too often ignored by
both State and federal program managers as soon as the ink was dry.  This
cooperative approach to securing federal support for State programs eliminates
much of the paperwork and unnecessary "bean counting."  It also streamlines the
process and contributes to a more understandable and meaningful perspective on
Colorado's environmental programs.

The overall goal of the Agreement process is to eventually achieve the complete
integretion of all EPA-funded State environmental programs, with the relationships
between problems and solutions being clearly defined.  Continued progress in this
direction is shown in this year's Agreement by the key management objectives and
work plans which address the following "integrating" issues:

    energy impacts assessment;
    intergovernmental environmental issues management;
    environmental data management;
    improve environmental epidemiology capabilities; and
    environmental emergency response.

On another dimension, integration of program activities is also supported by
introducing specific geographic foci in two broad environmental issues areas.  In
one case, the management objective concerning intergovernmental environmental
issues management, which will focus specifically on the Colorado Springs Area and
will involve the coordination of all environmental policy issues affecting that
area.  The other example is to the energy impact assessment objective.includes a
specific focus on the northwest quarter of the State and on the Arkansas River
Basin.

Finally, the significance of the Agreement as a communication link to other
agencies and the affected public should be appreciated.  The document defining the
Agreement is prepared with the general public in mind.  Bureaucratic jargon is
kept to a minimum, and the format is simple and presented largely in tables rather
than in the narrative.

The involvement of the State Policy and Regulatory Commissions^and advisory groups
in setting priorities for the Agreement is an important part of the process.   An
advisory committee has been formed to assist the Health Department in establishing
priorities and in reviewing drafts of the document.  Representatives of the Colo-
rado Water Quality Control Commission , the Colorado Air Quality Control Commis-•
sion, the 208 Policy Advisory Group, the Solid Waste Advisory Committee, public
interest groups, and local governments make up this advisory committee, and
represent a good cross-section of environmental interest groups.  This Advisory
Committee met numerous times in early and mid-1980 to assist the State and EPA
staffs in the definition of the FY 1981 key management objectives and in reviewing
overall program priorities.  The Committee was of material benefit in helping to
clarify several important environmental issues which are addressed in this
Agreement.

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        B.   ENVIRONMENTAL HEALTH.ISSUES  IN  COLORADO

        Colorado is  a State of stunning  natural  beauty  and  renowned  environmental
        quality.  It is also a state facing potentially serious  threats  to  its  public
        health and environment,  not only in the  rapidly growing  Front  Range urban
        corridor,  but in its mountain valleys, on  its rolling  plains,  and along its many
        rivers and streams.

        Air pollution,  especially in Colorado's  urban areas, presents  a  serious problem
        with no easy solutions.   Colorado's rivers and  streams,  so  important for drinking
        water, agriculture, recreation,  and wildlife, are threatened with pollution from a
        variety of sources.  And we are  just beginning  to become aware of the environ-
        mental hazards  presented by past and present  practices of disposing of  industrial
        and urban  wastes.  These and other  problems have already caused  noticeable
        deterioration in Colorado's environmental  quality,  though this deterioration  is
        not irreversible, and in fact, significant progress has  been made in improving and
        maintaining  the environmental  conditions in the State.

        1.   Water  Pollution

            Water  quality in Colorado is influenced by  natural geologic  features and  land
            and water uses.  The most common violations of  water quality standards within
            the mountainous areas of the State are due  to the  presence of metals, particu-
            larly  lead,  copper,  zinc,  iron,  cadmium,  and manganese.  Lead,  copper, and
            cadmium  pollution are most frequently  associated with relatively short stream
            segments located near inactive  or abandoned mining areas;  zinc,  iron, and
            manganese pollution  occur in most of the  major  mountain  streams.  Figure 1
            depicts  streams in Colorado  which are  experiencing problems  with metals
            pollution.

            Salinity, or the level  or total  dissolved minerals,  is of  concern in the
            Colorado River and its tributaries,  in the  Arkansas  River, and,  to  a lesser
            degree,  in  the Platte River.  Salinity seriously affects water  quality and
            water  uses  in the Arkansas River between  Lajunta and the Colorado/Kansas state
            line.  Although salinity has little  affect  on the  quality  and use of water
 4?          from the Colorado River and  its  tributaries in  Colorado  itself,  the Colorado
 3 „          portion  of  the seven-state,  two-country Colorado River Basin* is  a  source of
 '/          salts  loading for the Vest of the river system.  Salts originate from several
 -          sources,  both natural  and human  induced,  and have  a  particularly adverse
/           effect on agriculture along  "downstream"  sections  of rivers.

            Problems  with other  water quality standards in  Colorado  are  usually associated
            with wastewater discharges and  runoff  from  agricultural  activities  and urban
            areas.   Water pollution from these sources  includes  high levels  of  ammonia,
            which  affects aquatic life in the Front Range and  in the major mountain
            valleys,  and high levels  of  fecal coliform  bacteria.  Major  violations of
            fecal  coliform standards  for secondary contact recreation  (e.g.,  boating,
            fishing,  etc.)  occur in many streams,  primarily along the  Front  Range and in
            the lower P.latte and Arkansas Rivers.   High nutrient levels  (i.e.,  nitrates
            and phosphates)  occur along  the  Front  Range and lower Platte and  Arkansas
            Rivers and  endanger  the quality  of some mountain reservoirs  and  lakes.  Figure
            2 depicts streams with  ammonia  problems, Figure 3.depicts  streams with high
            fecal  coliform levels,  and Figure 4  shows streams with problems  due to high
            levels of dissolved  oxygen,  nitrates or high pH levels.

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                                         -8-


    Another problem with achieving and maintaining water quality standards is the
    need to maintain in-stream flows to meet water rights.   Examples of rivers in
    Colorado where maintenance of in-stream flows pose water quality problems are
    the Dolores, Yampa, and Saint Vrain Rivers.

    (a-)  Point Source Problems

          Discharges of treated and untreated municipal and industrial  wastewater
          have a significant influence on stream water quality.   To control  these
          causes of pollution, "point sources" such as sewage plants must have a
          discharge permit that specifies the kinds and quantities of pollutants
          that are permissible in discharged effluent.

          Major municipal wastewater facilities in Colorado are  located primarily
          within the Front Range urban corridor from Pueblo to Fort Collins.   Most
          industries located within this urban corridor pretreat their  wastewater
          before sending it to a municipal facility for final treatment and  dis-
          charge.  Water quality problems have been encountered  within  areas
          served by major municipal facilities,  even though these facilities  are
          generally among the best designed and operated within  the state.

          Minor municipal wastewater facilities are among the most common type of
          dischargers in the state.  Problems commonly encountered with these
          facilities include inadequate operational and maintenance practices -and
          overloading of treatment plant capacity.  The larger minor municipal
          facilities frequently treat non-toxic industrial  wastes, such as those
          from food processing industries or packing plants.  Such wastes can
          severly tax their treatment capabilities.

          Outside of the Denver Metropolitan Area, there are relatively few major
          industrial dischargers in Colorado.  The most common major industrial
          dischargers are those associated with mining and  milling operations,
          such as those found in Clear Creek, Gunnison, Lake and San Juan Counties.

          Minor industrial operations constitute one of the largest groups of
          point source discharge in Colorado.  Included in  this  category are  small
          treatment plants associated with seasonal resort  areas, trailer parks,
          hotels and restuarants, and numerous sand and gravel operations. Most      (
          violations of discharge permits are associated with these types of           ]
          facilities, due to seasonal overloading and inadequate or improper          \,
          operational and maintenance practices.                                      '

          Animal feedlots meeting certain criteria are also required to obtain
          discharge permits.  Permits for feedlots usually  require that there be
          no discharge from control facilities except for overflows resulting from
          unusual storm events.  Most feedlots are located  in the plains area of
          the Platte and Arkansas Valley.

    (b.)  Non-Point Source Problems

       (i.)   •-Irrigated Agriculture - The principal pollutants  associated with
               irrigated agriculture in Colorado are salinity and nitrates.   High
               nitrate levels in groundwater are associated with the use of  a
               combination of feedlot wastes and comnercial.fertilizers on
               irrigated cropland.
* The Colorado River Basin includes portions of Colorado, Arizona, California,
Nevada, New Mexico, Utah and Wyoming, as well as crossing the border between the
United States and Mexico.

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                                   -9-
 (11.)     Non-1 rri gated Agr 1 cul ture -  The principal  pollutant associated with
          dry croplands and  range! and  is  sediment.   Most  non-irrigated  crop-
          lands in  Colorado  are located on the  eastern  high  plains  and  are
          generally not associated  with serious water pollution  problems.

          Range! and,  on the  other hand, comprises  nearly  78  percent of  Colo-
          rado's  land area,  and much of that  is on  land that is  highly  erod-
          able, yielding more than  0.2 acre feet of  sediment per square mile
          per year.   Most high sediment rates in Colorado are found in  the
          Western Slope Area of the State.

(ill.)     Mining  -  Mining operations in Colorado fall into three categories:
          1)  energy fuels; 2)  metals;  and 3)  non-metals such as  sand, gravel,
          limestone,  etc. The principal  pollutants  from  these activities
          include toxic metals such as lead,  zinc,  and  cadmium which are
          soluble in low pH  (i.e.,  highly acidic),  drainage  waters, and
          suspended sediment,  which is also a source of toxic metals.

          Early mining activities in Colorado resulted  in the destruction of
          the aquatic habitat in many  mountain  streams.  Approximately  450
          miles of  degraded  streams remain today.

          The control of water pollution  from inactive  mines is  a complex
          process.   Since most inactive mines are  not truly  abandoned,  mine
          owners  must be located.  Also,  because the mines presently are not
          producing,  there are usually few, if  any,  resources available from
          the mine or its owners to pay for the clean-up  process.-  The  costs
          of  mine discharge  clean-up have been  extremely  high.   While various
          new types of relatively low-cost clean-up  techniques have been
          proposed  for inactive mines, few have been actually tested for
          effectiveness or cost under  field conditions, thus making it  un-
          certain whether they will really work.

  (iv.)    Urban Runoff - The principal pollutants  associated with urban run-
          off are suspended  sediment,  oxygen  demanding  substances,  and
          coliform bacteria.   The principal areas  experiencing urban runoff
          problems  are the major metropolitan areas  of  the state, including
          Denver, Colorado Springs, Boulder,  Greeley, Fort Collins, Loveland,
          Pueblo, and Grand  Junction.   Many smaller  mountain communities also
          cause frequent runoff problems  from both  rainfall  and  snowmelt.
       .   Reservoirs and lakes affected by such runoff  problems  include
          Dillon  Reservoir and the  "Three Lakes" areas  near  Grandby and Grand
          Lake.   Another problem is that  of reservoirs  which are experiencing
          runoff  problems due to urbanization in their  watersheds.   Reser-
          voirs experiencing such problems include Cherry Creek  and Chatfield
          in  the  Denver Area,  Vallecito Reservoir  in the  San Juan Basin, and
          the recently completed Pueblo Reservoir.   These reservoirs could
          also experience eutrophi cation  (i.e., oxygen  starvation)  and  sedi-
         ment problems caused primarily  by urban  stormwater runoff, if
          development continues without proper  controls.

          Control of water pollution from urban runoff  can be a  very expen-
          sive and uncertainly undertaking, especially  in areas  that are
          already urbanized.   Control  of  runoff pollution early  on  from areas
          that are just beginning to experience development  pressures appears
         •more promising. For example, urban drainage  plans may incorporate
          storage or other flow retention techniques to attenuate flood

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                                        -10-
               peaks.  Although not designated as pollution prevention measures,
               they do provide limited treatment capability.  In areas that are
               still underdeveloped, it is possible to use floodplain areas, low
               lying meadows, and other stream buffers to, intercept pollutantladen
               runoff waters and use the natural filtration properties of the soil
               to remove pollutants from the runoff waters before they finally
               flow into the streams.

       (v.)    Septic Systems - A host of water quality problems are associated
               with septic tank/leaching field wastewater disposal systems.  These
               include contamination of ground water with nitrates and fecal
               coliform pollution of surface waters.  A critical need is to
               develop control requirements for the proper construction and main-
               tenance of on-site disposal systems.

    (c.)  Drinking Water Problems

          The quality of drinking water supplies in Colorado, while generally
          good, faces an endemic problem with the presence of Giardia Lamb!ia in
          surface waters throughout the state.  Giardia Larnblia is a protozoan
          resistant to chemical disinfection, and causes a gastro-intestinal
          disease in humans.  Colorado suffers from several outbreaks of Giardia-
          related disease annually, principally at resort and recreation areas
          where visitors have not developed an immunity to Giardia Lamblia.  A
          secondary source of drinking water problems is the widespread presence
          of naturally-occuring radioactive elements in potable water supply
          sources.  The removal of both Giardia Lamblia and radioactive elements
          requires the installation and proper operation of sophisticated treat-
          ment facilities in addition to more "conventional" water treatment
          systems.  The removal of radioactive elements from drinking water
          supplies, in particular, requires highly sophisticated equipment and a
          high level of operational skill.

          There remain 16 communities in Colorado using surface drinking water
          supplies without the filtration needed to remove Giardia Iambiig.  As
          many as 90 water supply systems may have problems with radioa^tTve
          elements, while some 40-50 exceed drinking water standards.

2.  Air Pollution

    Five areas in Colorado are currently experiencing violations of air quality
    standards for one or more air pollutants.  The areas in which violations of
    air quality standards are exceeded are designated as "non-attainment areas."
    These are:  the Colorado Springs Area {El Paso County), the Denver Region
    (City and County of Denver, Adams, Arapahoe, Boulder, Douglas, and Jefferson
    Counties); the Grand Junction Area {City of Grand Junction and adjacent urban-
    ized areas of Mesa County); the Larimer-Weld Region (Larimer and Weld Coun-
    ties); and the Pueblo Area (City of Pueblo and adjacent urbanized areas of
    Pueblo County).

    (a.)  Colorado Springs Area

          The Colorado Springs Area has been subject to violations of the National
          Ambient Air Quality Standards for carbon monoxide (CO) and particulates
          for several years.  Suspended particulate levels in 1979 showed little
          change from previous years.  The eight-hour CO standard was violated on
          eight days at one site and six days at another monitoring location dur-
          ing 1979.  No violations of the one-hour standard were recorded.

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      The principal source of pollutant emissions in the Colorado Springs  Area
      is the use of motor vehicles.   About 50 percent of particulate emissions
      are due to dust "kicked up"  by automobiles  passing over paved highways
      and unpaved roadways.   Stationary sources accounted for only three per-
      cent of particulate emissions.  The primary source of both CO emissions
      and emissions of hydrocarbons  (HC),  which are  a primary ozone precursor,
      is also the automobile.  (NOTE:   ozone is not  emitted directly,  but  is
      formed in photochemical reactions in the atmosphere.)

      By 1982, assuming only the emissions control due to the Federal  Motor
      Vehicle Emissions Control  Program,  CO and HC emissions in the Colorado
      Springs Area are projected to  decline.  However, the decline will  not be
      enough to attain the CO standard by the end of 1982.

(b.)   Denver Region.

      The Denver Region is experiencing frequent  violations of the NAAQS for
      CO, ozone, nitrogen dioxide  (NOgK  and suspended particulate matter.
      The principal source of these  pollutants in the Denver Region is the use
      of motor vehicles.   Vehicular  sources in the Denver Region are calculat-
      ed to account for 93 percent of CO emissions,  85 percent of the HC emis-
      sions, 75 percent of particulate emissions  (including both "tailpipe"
      emissions and particulate  matter "kicked up" by vehicular travel over
      paved and unpaved roadways), and 37  percent of nitrogen oxides (NOX)
      emissions (including both  direct NO2 emissions and the NOX emissions
      which react to form NOg and  also contribute to the formation of
      ozone).  Other principal emissions sources  in  the Denver Region include
      large stationary sources (e.g.,  electrical  generating stations)  for
      NOX (50 percent) and particulates (11 percent), space heating of
      homes, offices, etc.,  for  NOX  (10 percent), and construction activity
      for particulates (13 percent).

      Based upon forecasted 1982 emissions levels, and assuming no new emis-
      sion controls beyond those already committed to, it is predicted that
      the standards for CO,  ozone, and suspended  particulates will continue to
      be violated in 1982, but that  the NOg standard will probably be met  by
      that year.  CO and ozone concentrations are projected to decrease
      between 1977 and 1982, while suspended particulate concentrations  are
      forecasted to increase.

(c.)   Grand Junction Area

      Downtown Grand Junction continues to show violations of the standards
      for total suspended particulates.  Also, violation of the new (1979)
      Airborne Lead Standard was monitored in the first quarter of 1979.   No
      violations of the eight-hour or one-hour CO standards were noted in  1979.

(d.)   Larimer-Meld Region

      During 1979, violations of the CO,  ozone, and  suspended particulate
      standards occured at several locations in Larimer and Weld Counties.
      The eight-hour CO standard was violated on  nine.days in Greeley, compar-
      ed with only four violation  days in  1978.  Fort Collins experienced
      nineteen days of violations  of the eight-hour  CO standard, mainly  during
      the period September through December, 1979.   There were no. violations
      of the one-hour CO standard  in either city. It is expected that viola-
      tions of the eight-hour CO standard will continue to be experienced  in
      both Fort Collins and Greeley  until  1982.

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                                                    -12-
                     Only  one monitoring  site  in the Larimer-Weld Region  indicated  a  viola-
                     tion  of the  suspended  participate  standard  in 1979,  that being at
                     Love!and.  The  ozone standard was  recorded  as being  violated on  one day
                     in  1979, that being  in Greeley.  No  violations of the Airborne Lead
                     Standard were recorded.

                (e.)  Pueblo Area

                     The Pueblo Area continues to suffer  from violations  of the standard for
                     suspended particulates, although all other  air quality standards are
                     being met.

                     The sources  of  particulate emissions in the Pueblo Area, activities at
                     the CF&I Steel  Corporation, vehicles on paved and unpaved roads and from
                     a variety of smaller sources.

                     In  1979, the Colorado  Air Quality  Control Commission recommended to the
                     Administrator of the EPA  that the  Pueblo Area be redesignated from
                     "non-attainment" to  "unclassifiable" with respect to attainment of the
                   .  particulate  standard.  The EPA proposed denial of this recommendation in
                     February 1980;  a final decision is expected by early October, 1980.

            3.   Hazardous and Solid Wastes
                                   *
                (a.)  Hazardous Wastes

                     Hazardous wastes include flammable,  corrosive, toxic, and infectious
                     materials.   The amount of hazardous  waste generated  in Colorado is
                     uncertain; however,  based upon a survey of  potential generators in 1979,
                     it  is estimated that some 855,000  tons of such materials are generated
                     annually throughout  the State, of  which about 10 percent may be consid-
                     ered extremely  hazardous.  Most hazardous wastes from industrial activi-
                     ties  are delivered to  Denver's Lowry Landfill disposal site, the
                     principal disposal site for such wastes in  Colorado.  The quantities of
                     hazardous wastes disposed at other disposal sites or at industrial sites
                     is  unknown.  In addition, a very small percentage of hazardous wastes
                     generated in Colorado  is  shipped out-of-state for disposal elsewhere.
                     Prior to 1980,  the disposal of hazardous wastes in Colorado typically
                     was in marginal-to-poor sites, using procedures and  technology far below
                     the state-of-the-art techniques.

                     The 1979 survey indicates that most  of the  sources of hazardous wastes
                     in  Colorado  are located along the  Front Range between Pueblo and Fort
                     Collins, with most being centered  in the Denver Metropolitan Area and
                     the Colorado Springs Area.  There  are at least 237 hazardous wastes
                     generators,  although some of these generators may be too small  to fall
                     under the regulatory requirement of  newly promulgated hazardous waste
                     regulations.  Wastes from these small generators thus potentially may be
                     shipped to solid waste sites inappropriate  for hazardous wastes
                     disposal; this  potential problem is  of special concern.

                     The principal hazardous waste-generating industries  in Colorado are:   1)
                     chemicals and allied products; 2} metal refineries and producers;
                     3)  metal products fabrication; 4)  petroleum refining and related activi-
                     ties; 5) rubber and  plastics products manufacturing; and 6) mining
.

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                                    -13-
      activities.   There are about 130 chemicals and allied products manufact-
      urers in Colorado, the majority of which are located in the Front Range
      Corridor.  Wastes from these activities may include corrosive, toxic,
      and/or flammable substances, many of which are suspected carcinogens.

      Approximately 50 metal refineries and producers are located in Colorado,
      including steel  works, foundries, smelters, etc.   The majority of these
      are located in the Denver and Pueblo Areas, the latter being especially
      notable for the large CF&I Steel Mill complex.  Such activities generate
      toxic and flammable wastes, some of which are known to be carcinogenic.
      Colorado also has about 370 metal products fabricators, including elec-
      troplating and metals coating activities.  The majority of these activi-
      ties are located in the Denver and Colorado Springs Areas.  These types
      of activities produce flammable, corrosive, and/or toxic wastes, some  of
      which are carcinogenic.

      Approximately 30 petroleum refining and related industrial operations
      are located in Colorado, including several large refineries and related
      activities in the Denver Area.  Wastes from these activities are flam-
      mable and/or toxic.  Colorado also has about 130 rubber and plastics
      products manufacturing operations, nearly all of which are located in
      the Denver Metropolitan Area.  Wastes from these industries may be
      flammable and/or toxic.

      Finally, mining activities present a major hazardous materials problem
      to Colorado.  Not only do current mining operations, of which there are
      a very Targe number in Colorado, generate hazardous and toxic wastes,
      but the tailings piles and holding ponds of long played-out or abandoned
      mines and mills  also present serious problems.  The exact number of mine
      disposal sites,  both active and inactive, is unknown, although efforts
      are underway to prepare an initial inventory of such sites.

(b.)  Solid Wastes

      In -^addition to the environmental and public health problems presented  by
      the disposal of hazardous and toxic wastes, the disposal of what is
      referred to as "solid wastes," or garbage, sewage sludge, etc., also
      presents problems.  The burial of solid wastes can present a high
      potential for chemical and bacteriological pollution of ground and
      surface water, particularly when certain geological conditions are
      present.  Observations of groundwater pollution from sanitary landfills
      have indicated that if a landfill is intermittently or continuously in
      contact with groundwater, .the groundwater can become grossly polluted
      and unfit for domestic or other uses.  However, proper site selection,
      combined with good design and operation of the sanitary landfill, can
      normally eliminate the possibility of either surface or groundwater
      pollution.  Past practices of filling in old sand and gravel pits in
      areas of shallow aquifers with municipal garbage and other refuse are
      now prohibited,  due to the high possibilities of ground water contamina-
      tion.  Another potential problem with landfills is the generation of
      explosive methane gas as the wastes decompose. .Again, good design and
      operating practices can minimize .the potential dangers of gas explosions.

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                                        -14-
          There are 201 solid waste disposal sites in Colorado, 53 of which serve
          from 5000 to 200,000 people per site.  These are classified as Class "A"
          sites, while those serving less than 5000 persons are Class "B" sites.
          About 60 percent of the Class "A""disposal sites were found to be in
          compliance with State and federal requirements at the time of their last
          inspection, while only about 36 percent of the Class "B" sites fully
          complied with these regulations.  There are problems with consistent
          compliance with design and operating standards at small solid waste
          disposal sites.  Because of this, the trend is to develop "transfer"
          facilities which serve as collection points for refuse to be transported
          to larger, centrally-located sites capable of meeting applicable
          standards.

          Increasing amounts of solid and semi-solid wastes are being removed in
          the treatment of sewage.  This residue is referred to as "sludge," and
          is usually disposed of in landfill sites.  An estimated 150 landfill
          sites are being used for the disposal of sewage sludges.  These sludges
          can create serious operational problems for landfills, including the
          generation of methane gas and the leaching of pollutants into ground-
          water supplies.

          A related problem is the disposal of industrial sludges in landfills,
          which present the same problems as sewage sludge disposal.  It is esti-
          mated that about 12 million gallons of industrial wastes are being
          disposed of annually at disposal sites throughout Colorado; much of this
          industrial sludge has not been adequately pretreated before disposal.
          Unfortunately, no complete picture exists of problems of sewage and
          industrial sludge disposal, since the disposal of such wastes is not
          currently being monitored.

          Abandoned or closed disposal sites present a potentially serious problem
          due to urban development pressures adjacent to or on these sites.  Some
          83 developments, including houses, schools, apartment complexes, shop-
          ping centers and churches, are located on or adjacent to abandoned or
          closed dumps.  The danger is that methane gas is being generated at
          these sites in what may be explosive concentrations, and that liquid
          waste materials may be leaching into and seriously polluting ground and
          surface water supplies at these locations.   Current law is inadequate to
          prevent abandoned or closed disposal sites from being developed into
          residential areas, commercial areas, schools, etc.  However, while there
          are no statutory requirements for venting,  alarm systems, or other types
          of safety controls for structures built on sites where such potential
          explosion hazards may exist, currently operating landfill sites are now
          required by the Colorado Department of Health to control methane gas
          generation.

4.  Environmental Disease Control

    Despite the tremendous array of resources invested in environmental  pollution
    control during the past decade, most of which have been oriented primarily
    toward protection of the public health, environmentally-related diseases
    remain a troubling reality.  Periodic outbreaks of water-borne diseases, the
    hazards to human health associated with the introduction of toxic substances
    into the food chain (e.g., cattle feed), and the poorly understood hazards of
    low-level radiation, are all examples of environmental disease situations
    which continue to pose real problems.

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                                        -15-


    Among the 50 States,. the environment in Colorado is relatively unique in the
    way of potential environmental disease-causing conditions that are present.
    Of particular concern are the challenges to safeguarding the public health
    from potential chemical, physical, and biological  hazards due to the large
    scale of past and present mineral resources development, and even more so with
    respect to the rapid expansion in mineral  resources developments in the
    future.  The accelerating pace of energy resources development in Colorado,
    especially uranium and oil shale, may pose potential public health threats
    about which relatively little is known.

    The National Cancer Institute estimates that some  80 percent of human cancers
    are environmentally induced.  Several" elements present in Colorado's
    environment are thought to be associated with cancer as well as other chronic
    illnesses.  For example, arsenic, lead, and selenium, which have been found  to
    be present in small amounts in some water supplies, due both to natural accur-
    ances and to mining activities,  may be related to  the development of certain
    types of cancers.  The presence of cadmium in the  air due to smelting opera-
    tions may also be linked to the development of cancers.  Radiological hazards
    in the forms of natural ly-occuring and mining-related uranium in water
    supplies, radon gas in uranium tailing piles, and  in other forms of radiation,
 .   are increasingly being linked to the unusual prevalence of cancers in exposed
    populations.  There is also growing evidence that  certain petrochemical hydro-
    carbons, such as may be present from oil refining  or oil shale processing
    activities, are linked to the development of brain tumors.

    Despite the evidence indicating linkages between environmental hazards and
    human illness, the etiologic relationships are seldom simple and often involve
    personal habits and unique occupational or other "microenvironmental" fac-
    tors.  The need for increased monitoring and investigation of possible envi-
    ronmentally-related human illness in Colorado is paramount, especially in view
    of the accelerating pace of mineral and energy resources development in the
    state.

5.  Radiation

    Radiation presents an environmental health issue of particular concern in
    Colorado.  Radioactive health hazards are far more prevalent in Colorado than
    in all but a handful of other states, due both to  naturally occuring radio-
    active uranium and radium deposits and to mining and industrial activities
    involving radioactive materials.

    Colorado has some 3000 active and inactive uranium mines and several major
    uranium processing mills.  There is also a large legacy from the past
    involving radium mining and processing in the early 1900' s.  Durango, Grand
    Junction, Rifle, Gunnison, Naturita, Slick Rock, and Maybell all  have inactive
    uranium tailings piles, a problem which has been severely compounded in Grand
    Junction by the widespread use of tailings in construction of buildings for
    homes, stores, etc., in the 1950's and 60's.  Tailings from turn-of-the-
    century radium processing facilities in Denver and Grand Junction also pose
    problems, especially since many of the early processing sites have been
    converted to other uses over the past 60 years without any clean-up of the
 •   radioactive residue.

    The possible public health dangers of low-level radioactivity from uranium and
    radium tailings have been recognized only in recent years; indeed, the very
    presence of radium tailings in Denver and  Grand Junction was all  but forgotten
    about until they were "rediscovered" in 1979.  Where old tailing  piles exist,

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                                        -16-
    and especially in cases where tailings have been used in construction or old
    sites have been converted to other uses, the problem is not one of prevention
    of possible human exposure.tq radiation, but of belatedly cleaning-up these
    significant potential sources of radiation exposure.

    Other key concerns with protection of the public from radiation in Colorado
    involve the presence of radioactive elements in water supplies due to ongoing
    uranium mining activities, such as the contamination of the North Table Moun-
    tain water supply system in the Denver Metropolitan Area with uranium from the
    effluent of the Schwartzwalder Mine in Jefferson County.  There are also
    growing concerns with the presence of radioactive elements in the Arkansas
    River and in other river basins in the state, due in large part to uranium
    mining and milling activities.  As well, the presence of naturally-occuring
    uranium in streams feeding public water supplies is of concern, since in some
    cases natural levels of in-stream radioactivity far exceed suggested drinking
    water standards.  Unfortunately, no drinking water standard currently exists
    for uranium based on radiological toxicity.

    Finally, the presence of the Fort Saint Vrain Nuclear Powerplant at Platte-
    ville, just north of the Denver Metropolitan Area, and of the Rocky Flats
    Nuclear Weapons Plant, on the northwest fringe of the Denver Metropolitan
    Area, require constant vigilance by both the plants' operators and State and
    federal regulatory agencies to minimize absolutely the possibility of acciden-
    tal releases of radioactive gases and elements into the environment.  As well,
    effective and up-to-date emergency response plans must be maintained for both
    facilities to protect the public from exposure to radiation should accidental
    radioactive releases occur from either plant.

6.  Environmental Emergency Situations

    Incidents posing significant threats to the public health and safety and to
    environmental quality occur almost daily in Colorado.  In most cases, these
    emergency incidents involve hazardous materials with toxic, flammable,
    reactive, biological or physical properties which require quick action to
    minimize and gain control over the adverse impacts of an uncontrolled
    situation.

    Environmental emergency incidents may involve pipeline breaks, truck and rail
    transportation accidents, and accidental releases of toxic or hazardous
    materials from chemical and industrial facilities.  While there have been
    significant improvements in the integrity of operations and accident preven-
    tion capabilities of hazardous materials processors and shippers in recent
    years, accidental releases into the environment must, as a practical matter,
    continue to be expected.  To contain these emergency situations, close
    cooperation between owners or operators, local governments, and State and
    federal agencies is essential to facilitate rapid response and effective
    acti on.

7.  Noise

    The noise problems within the state are becoming increasingly serious and
    complex.  The rapid growth and development along the Front Range is causing
    greater numbers of citizens to be exposed to high levels of urban noise.  In
    response, many cormwnities are becoming actively concerned with motor vehicle
    and other community noise problems.  The paramount noise problem, however, is
    probably that associated with commercial airports.  Denver's Stapleton
    International Airport is the source of particularly serious noise problems.
\

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                                                  -17-


              On the Western Slope,  energy development  is  bringing noise from construction,
              mining, fuel  transportation,  and motor vehicles  to  previously quiet rural
              areas and small  towns.   One such town, Craig,  has begun  to deal  with its boom
              town noise problems.   There are  other communities which  are just beginning  to
              feel the full impacts  increased  noise as  energy  projects are developed.

              Pristine scenic,  historic and recreation  areas will  require protection from
'-              the noise impacts of  transportation and energy development.  Also,  as people
              are increasingly exposed to excessive noise,  they will become more  insistent
              that noise in their comnunities  be quieted.   Local  governments will thus
r              likely become more aware of noise as a problem which they will need to overcome

          8.   Pesticides

              Pesticides are used for  a variety of purposes  in both the urban and rural
              environment.   The most common use is for  the control of  insect pests in
              agriculture.   However, pesticides are also used  extensively in controlling   -
              pests in forests, buildings,  yards and gardens,  and along rights-of-way.

              Pesticides benefit the agricultural community and the general public by
              increasing the quality and quantity of crops,  protecting public health, and
              helping maintain  aesthetic qualities in urban  environments.  However,
              pesticides, if misused,  may create problems  such as human poisonings and
              contamination of  livestock and human water supplies.

              While generally beneficial, the  use of pesticides frequently causes disagree-
              ments between different  interest groups.  Examples  include mosquito abatement
              programs versus agriculture/wildlife interests and  beekeepers versus insect
              control programs.  Another example involves  conflicts between farmers using
              pesticides and new homeowners who have purchased lots adjacent to agricultural
              lands.  These conflicts  are often heightened because of  the limited alterna-
              tives available to address certain types  of  pests.   For  example,  the limited
              alternatives  available to livestock producers  to control  predators  has
              resulted in many cases of illegal use of  predator poisons.

   ,       9.   Toxics

   lj,          Each environmental media program (i.e., air, water,  solid waste,  toxics) has
   '/          its own unique problems  in Colorado which involve the control of toxic
,   '           substances.  However,  control alternatives often affect  one or more of the
              other media and require  an coordinated multi-media  approach.

,f             There are many transformers and  capacitors which contain PCBs in Colorado.
              Past practices regarding PCB oil have left contamination in the soil  and
              waterways. The material  is a suspected carcinogen  and the levels of
              concentration at  which various environmental  impacts occur is unknown.

              Sprayed asbestos  material on school ceilings has been found in several Colo-
              rado schools, and many more instances will become known  upon a more complete
              sampling.  Asbestos, when inhaled, is a known  carcinogen and efforts must be
              made to locate all occurrences of sprayed asbestos  which is releasing fibers
              to the air.

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                                        -IS-


C'  ENVIRONMENTAL AGENCIES IN COLORADO

!•  Colorado.Department of Health

    The Colorado Department of Health (CDH) is the State agency charged with
    general responsibility for protection of the public health and the provision
    of health care services in Colorado.  One element of this comprehensive re-
    sponsibility is the conduct of environmental control activities in the State.

    (a.)  Office of Health Protection and Environmental Programs

          The environmental health programs administered by the Colorado Depart-
          ment of Health are organized under the Office of Health Protection and
          Environmental Programs.  This office is under the direction of an
          Assistant Director of the Department of Health, who reports to the
          Department's Executive Director.

          Within the Office of Health Protection and Environmental Programs are
          five operating divisions; these are:

               Water Quality Control Division;
               Air Pollution Control Division;
               Radiation and Hazardous Wastes Control Division;
               Disease Control and Epidemiology Division; and
               Consumer Protection Division.

          The Colorado Water Quality Control Commission and the Colorado Air
          Quality Control Commission are also administratively assigned to the
          Office of Health Protection and Environmental Programs, although both
          function as independent policy-making bodies.  In addition, a Solid
          Waste Advisory Committee, appointed by executive order of the Governor,
          is attached to the Office.

          The Office of Health Protection and Environmental Programs also includes
          a small central Planning and Management staff unit.  This unit, which is
          under the direction of the Assistant Director, is responsible for envi-
          ronmental policy planning, program development, fiscal and budgetary
          management, coordination of overall environmental planning and review
          activities, and the direction of various planning and management activi-
          ties which cut across specific program areas, (e.g., energy impact
          assessments, coordination with other State and federal agencies, etc.)
          This unit is also responsible for the State's half of the continuing
          definition, coordination, and updating of the annual State/EPA Agreement.

    (b.)  Water Quality Control Commission and Division

          The Water Quality Control Division enforces State water quality control
          statutes and the regulations of both the Water Quality Control Commis-
          sion and the Colorado Board of Health.  This Division issues discharge
          permits, conducts monitoring, and enforcement activities, assists in the
          development of wastewater treatment facilities, manages the program for
          protection of public water supplies, and provides technical assistance
          to local communities.  The Division serves in a staff capacity to the
          Water Quality Control Commission, which is an eleven-member policy and
          regulatory body, with ten members appointed by the Governor and one by
          .the Board of Health.  The Division also implements programs under the
          jurisdiction of the Board of Health; individual sewage disposal systems,
          public swimming pools, and the Wastewater Plant Operators Certification
          Board.

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                          •                         -19-


               (c.)   Air Quality Control  Commission and Division

                     The Air Pollution Control  Division has  the responsibility to act as the
                     enforcement agent for State air pollution control  statutes and the
                     regulations of the Air Quality Control  Commission,  furnish technical
                     advice  and services  for air pollution problems and  control techniques,
                     and conduct research and studies on the causes,  sources,  and control  of
                     air pollution.  The  Air Quality Control  Commission  is the State's air
                     pollution control.  Its nine members are appointed  by the Governor.

               (d.)   Radiation and Hazardous Wastes Control  Division

                     The Radiation and Hazardous Wastes Control Division administers radia-
                     tion control  activities and the management of solid and hazardous
                     wastes, pursuant to  the regulations of  the Colorado Board of Health.  In
                     the area of radiation control, it is responsible for the licensing of
                     uranium mills, processing  activities and other facilities processing  or
                     handling radioactive materials in Colorado.  The Division's radiation
                     control activities are not covered by the Agreement, since they receive
                     no EPA  financial support,  they instead  are supported by State funds and
                     other federal funds.   The  Division is also responsible for overseeing
                     the establishment and operation of solid waste disposal facilities in
                     Colorado, activities to manage hazardous wastes  in  the State.  Its
                     hazardous waste management activities are currently conducted under the
                     aegis of EPA authority, pending passage of State legislation to permit
                     development of a full  State program. Supporting the Division's solid
                     and hazardous waste  program is the Solid Waste Advisory Committee, whose
                     members are appointed by executive order of the  Governor.  The Division
                     is also responsible  for coordinating the Health  Department's environ-
                     mental  emergency response  activities, including  nuclear facilities.

               (e.)   DiseaseControl and  Epidemiology Division

                     The Disease Control  and Epidemiology Division is responsible for the
                     investigation of the cuases of human illness and the design and imple-
                     mentation of disease control  procedures.  The Division has ongoing
                     programs in the areas of tuberculosis control, zoonoses control (i.e.,
                     control of animal-borne diseases), immunization, venereal disease
    ,                 control, chronic diseases,  and epidemiology.  In recent years,  the
 -  /                 Division has begun to address environmental epidemiologic issues,
  ,.                  particularly with respect  to  human exposure to environmental radiation
^ ,(                   and toxic substances.   The Division receives its policy direction from
                     the Colorado Board of Health.

               (f.)   Consumer Protection  Division

                     The Consumer Protection Division is responsible  for the protection of
                     the public health from hazards to consumers.  This  protection is
                     provided pursuant to the regulations of  the Colorado Board of Health,
                     and involves  the inspection of public accommodations,  food manufacturers
                     and warehouses, dairy farms and plants,  food service establishments,
                     retail  food markets,  child care centers, and other  consumer product
                     safety  activities.  The Division is also involved in environmental
                     health  activities by providing technical assistance in drinking water
                     protection and insect and  vector control.

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                                        -20-
2*  U.S.  Environmental Protection Agency - Region VIII

    The EPA is a federal regulatory agency with responsibilities for establishment
    and enforcement of"environmental  control programs for air and water pollution,
    solid waste management, pesticides,  radiation, and noise.  To ensure that the
    agency is responsive to environmental problems throughout the county, regional
    offices are located in ten regions of the country.  Region VIII, with head-
    quarters in Denver, is responsible for Colorado,  North Dakota, South Dakota,
    Utah, Wyoming and Montana.

    (a.)  Air and Hazardous Materials Divison

          The Air and Hazardous Materials Division provides operational management
          and direction of programs for the control of air pollution and hazardous
          and toxic substances.  It administers the provisions of the Solid Waste
          Disposal Act of 1965, as amended by the Resource Conservation and
          Recovery Act of 1970; the Federal Insecticide, Fungicide,  and Rodenti-
          cide Act, as amended by the Federal Environmental Pesticide Control Act
          of 1972; the Noise Control  Act of 1972; pertinent radiation activities
          as they relate to Region VIII, and the Toxic Substances Control Act.

    (b.)  Water Division

          The Water Division provides operational management and direction of all
          water activities in the region.  Programs included are:  construction
          grants, water quality planning, water supply, underground injection
          control, non-point source management, water quality standards, dredge
          and fill permit reviews, and EIS reviews.

    (c.)  Enforcement Division

          The Enforcement Division provides operational management and direction
          of regional activities involved with the Permit Program and enforcement
          provisions of the Federal Water Pollution Control Act; Rivers and
          Harbors Act; Clean Air Act; Federal Insecticide, Fungicide, and
          Rodenticide Act; and any other legislation  for which enforcement respon-
          sibilities are delegated to EPA within the abatement and control
          strategies developed by the Regional Administrator.

    (d.)  Surveillance and Analysis Division

          The Surveillance and Analysis  Division is responsible for monitoring,
          laboratory services, emergency response, quality assurance, and R&D
          liaison for all program areas  in the region.

3.  Other Agencies

    In addition to the Colorado Department of Health  and the EPA, a number of
    other agencies have important environmental responsibilities.  These agencies
    include:

    (a.)  Colorado Department of Local Affairs

          The Colorado Department of Local Affairs is responsible for providing
          support to local governments in Colorado in an number of important
          areas, including housing, law  enforcement,  economic development, govern-
          mental operations, etc.  With  respect to environmental activities, the
          Department of Local Affairs is responsible  for the coordination of "208"
v

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                                                .   -21-


                      water quality management planning activities in the local  regions of the
                      State and the administration of certain  non-EPAfunded State and  federal
                      wastewater facility grant programs.   The Department's Division of Plan-
                      ning is  also responsible for demographic analyses  and forecasting,  which
                      are important in environmental  planning  activities,  and for the
                      management of Colorado's "A-95" review process.

                (&•)   Colorado Department of  Agriculture

 ,                    The Colorado Department of Agriculture is responsible for  the perform-
                      ance of  regulatory and  inspection activities relating to agriculture,
                      the control  of livestock health within the State,  the control  of pre-
                      dators and rodents, and a variety of  other activities related to
                      agriculture  and agricultural products.   Of particular significance to
                      environmental health are its responsibilities to license and control  the
                      contents,  sales,  and uses of pesticides  and to encourage and develop
                      biological controls for harmful insect and plant pests.

              .  (c.)   Colorado Department of  Natural  Resources

                      The Colorado Department of Natural Resources is  the  State's natural
                      resources "management"  agency.   The Department's responsibilities fall
                      into a number of areas, including fish and wildlife  management,  admini-
                      stration of  the State's water rights  system and  water resources
                      development,  parks and  recreation, mining and mineral land reclamation,
                      the management of State-owned lands,  and the State geological  survey.  A
                      number of these activities are  directly  related  to State environmental
                      control  responsibilities.   For  example,  the development of water re-
                      sources  and  management  of water rights are integrally related  to the
                      water quality management activities of the Colorado  Department of
                      Health,  and  the administration  of mineral land reclaimation regulations
                      requires close coordination with the  Health Department's water quality
                      control; solid waste control,  and air quality control programs.   A major
                      concern  in water quality management efforts is assuring adequate water
                      quality  fisheries and aquatic life, which again  requires close
     .                 coordination between the two departments, while  the  identification  of
     (-•                 suitable sites for disposal  of  hazardous and solid wastes  must draw  upon
     >,                 the expertise of the geological  survey.  The Department of  Natural
     '?'                 Resources also is the State's "lead agency" for  the  definition and
 i  /                 coordination of energy  resources development policy.
    (
  I             (d.)   Local  Health Departments
V                        •                                  '     .
                      Throughout much of Colorado, direct public health  services are provided
                      by local health departments. These departments  are  established  pursuant
                      to State law, and are organized on either a county level or in multi-
                      county districts.   Altogether,  there  are 13 local  health departments or
                      units in Colorado providing public health services to about one-third  of
                      Colorado's 62 counties, although at least 80 percent of the State's
                      population resides in these counties.

                      Local  health departments have important  environmental health responsi-
                      bilities.  Most apparent,  perhaps, 'are the activities of eight local
                      departments  in air pollution control,  for which  they have  contractual
                      relationships with the  State Health Department's Air Pollution Control
                      Division.  These local  air pollution  control  programs,  which cover the

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                                    -22-


      Front Range urban corridor from Fort Collins to Pueblo and the Grand
      Junction Area,  are an Important extension of the State's air quality
      control  program.   Equally important are local  health department
      activities in protecting public .drinking water supplies, controlling
      sewage septic systems,  responding to environmental  emergencies, and
      identifying and controlling environmental diseases.   Indeed, in the
      areas they serve, the local health departments function as the first
      line of  defense in environmental  health protection.

(e.)  Councils of Governments

      Colorado is organized into 13 "planning and management regions" for
      State administrative and planning purposes.  This system was established
      by executive order of the Governor in 1970, and recognizes the various
      sub-State communties-of-interest  which exist due to geographic, social
      and economic relationships.  Serving these 13  planning and management
      regions  are 16  councils of governments ("COG's")  or regional planning
      commissions, which are  made up of the local governments - counties  and
      municipalities  -  in their areas (two of the regions are served by
      several  sub-regional COG's or commissions). These  COG's and regional
      planning commissions provide very important mechanisms for intergovern-
      mental coordination and cooperation.  The larger COG's, especially  in
      the Front Range urban corridor, also serve as  regional planning bodies
      for a number of important functions, including transportation,  land use,
      economic development, social services, and environmental control.

      In the area of  environmental control, the COG's have played important
      roles in both air quality planning and water quality management planning
      activities.  Five COG's worked with the Colorado Air Quality Control
      Commission and  the Health Department's Air Pollution Control Division to
      prepare  the State Implementation  Plan (SIP) for Air Quality, and have
      continuing responsibilities for the implemention and updating of the SIP
      in their respective areas.  Ten COG's and regional  planning commissions
      played lead roles in preparing the water quality managment ("208")  plans
      for their areas,  all of which utlimately received the approval  of the
      Colorado Water  Quality  Control Commission.  The involvement of the  COG's
      in water quality management activities will continue to be an important
      aspect of their ongoing responsibilities, especially for those COG's         1
      serving  the urban Front Range corridor and major mountain recreation         ^
      areas.  Several COG's have also played important roles in regional  solid    \
      waste management  planning activities.                                        v

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                                                  -23-
          PART II  -  THE  1980/81  COOPERATIVE  AGREEMENT  BETWEEN THE  COLORADO  DEPARTMENT  OF
                    HEALTH  AND THE'U.S.  ENVIRONMENTAL  PROTECTION AGENCY  - REGION  VIII
J
This 1980-81 Cooperative Agreement Between the Colorado Department j)f Health and
Region VIII of the United States Environmental Protection Agency defines the
program of activities to be cooperatively conducted by the State and EPA during FY
1981.  Specifically, this Agreement identifies the elements of Colorado's environ-
mental health programs which will be supported by EPA grant funds, the amounts of
EPA funding support for each activity, the staff resources to be committed to each
activity by the State and the EPA, the products or outputs expected from each
activity, and estimated completion dates or key milestone dates, where appro-
priate.  In addition, this Agreement defines a set of key management objectives
which will be the primary management foci of the State and the EPA in conducting
the FY 1981 program of environmental health activities in Colorado.  The Agreement
also specifies the level of EPA staff resources committed to other environmental
health activities in Colorado which do not include direct State participation.

In addition to defining the cooperative environmental health programs of the CDH
and the EPA, the 1980-81 Agreement incorporates a limited cooperative program
betwen the Colorado Department of Agriculture and the EPA for the conduct of
pesticides control activities in Colorado.

To assure that this Agreement remains the basis for a realistic cooperative
working arrangement between the State and EPA throughout FY 1981, the Agreement
will be comprehensively reviewed on a quarterly basis during the fiscal year.
Quarterly review meetings will be held in January, April, July, and October of
1981, and will serve to assess progress and problems with the overall work
programs, and to define any revisions or amendments to the Agreement which may be
necessary.  The October review meeting will serve both to review the prior
quarter's progress and to generally review the entire FY 1981 Agreement, as well
as to initiate the FY 1982 Agreement program of activities.

Continuing coordination and joint management of the overall program of cooperative
activities are important to the success of this Agreement, and will  be the shared
responsibility of the Office of Health Protection and Environmental  Programs of
the Colorado Department of Health, and of the EPA-Region VIII Air and Hazardous
Materials Division.  The Director of the Air and Hazardous Materials Division will
designate a permanent Colorado Coordinator to provide day-to-day coordination with
the State for the FY 1981 Agreement.  For the cooperative activities of the EPA
and the Colorado Department of Agriculture in the area of pesticides control,
ongoing coordination will be the responsibility of the Office of the Commissioner
of the Colorado Department of Agriculture and the EPA-Region VIII Air and
Hazardous Materials Division.

In addition to the set of key management objectives and the program of activities
specified in this Agreement, the Colorado Department of Health and the EPA-Region
VIII will work with the Colorado Department of Local Affairs during FY 1981 to
define how the Department of Local Affairs' important water quality planning
("208") and public waste water facilities construction grants programs can be
better incorporated into the overall coordination and management mechanism of the
FY 1982 State/EPA Cooperative Agreement.

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                                      -23-A-


This Agreement may be amended at any time, pursuant to applicable regulations  or
laws.  Amendments shall be made by supplemental  agreements executed in writing by
the parties to this Agreement, as may be reauired in order to carry out the
provisions or intentions of this Agreement or for any other purpose in furtherance
of this Agreement.
     Frank A. Tray lor, Or., M.D.  Q            Date
     Executive Director
     Colorado Department of Health
           L. wm.iams r                         Date
        rional JCdministrator
      egion VIII
     U.S. Environmental  Protection Agencv

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                                        -24-
                             KEY MANAGEMENT OBJECTIVES
Key Management Objective Number 1:   Mater .Quality Program

    Complete key water quality program initiatives which were begun in FY 80,
    these being:

    (A.)  Establishment of the new system of stream classifications and water
          quality standards for all "state waters" in Colorado.

    (B.)  Improvement of the NPDES permitting and enforcement system.

    (C.)  Assumption of the "205(g)u construction grants management program, with
          particular emphasis to be given to:

          1)   Ongoing delegation of the program;

          2)   Review and revision of the construction grants priority list for
               municipal wastewater facilities;  and

          3)   Improving the operations and maintenance (O&M) capabilities and.
               performance of municipal wastewater facilities.


Key Management Objective Number 2:   Mater Quality Management Planning  and Policy
Coordination:

    Develop formal recognition of the plans produced by the "208"  water quality
    planning process and integrate the technical provisions of those plans into
    the ongoing decision-making process of the Water Quality Control Division  and
    Commission related to grants, discharge permits, and site applications.
Key Management Objective Number 3:   Automotive Inspection and Maintenance

    Implement the automotive emissions control inspection and maintenance program
    (I/M), established by the Colorado Legislature for the nine-county Front Range
    urban corridor.

Key Management Objective Number 4:   Hazardous Waste Control

    Establish an interim program of hazardous waste control  activities, including
    technical cooperation with EPA to assist with designation of hazardous waste
    facilities under the provisions of Subtitle "C" of RCRA,  and the provision of
    support to the legislature to develop authorizing legislation for State
    control of hazardous wastes.
V
Key Management'Objective Number 5:   Environmental  Epidemiology

    Establish an ongoing environmental  epidemiology capability within the
    Department of Health to provide the expertise  necessary to address human
    health problems associated with environmental  control  activities and pollution
    incidents.

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                                        -25-
Key Management Objective Number 6:  Environmental Emergency Response

    Improve, strengthen and intergrate the capabilities of CDH, EPA, and local
    governments to respond to environmental incidents and emergen- cies, both
    through direct action and by providing assistance and advice to "on-the-scene"
    agencies.
Key Management Objective Number 7:
Management
Intergovernmental Environmental Issues
    Develop a pilot intergovernmental environmental policy coordination and issues
    management process which will define the inter-related roles of State, federal
    and local agencies and establish a mechanism for the management and resolution
    of major environmental issues, and for involving local communities in the
    definition of environmental policies and program priorities.
Key Management Objective Number 8:
Development in Colorado
Cumulative Environmental Assessment of Energy
    Begin a continuing comprehensive assessment of the aggreggate and cumulative
    environmental effects and implications of energy development in Colorado.


Key Management Objecitve Number 9:  Environmental Data Management

    Initiate a comprehensive review and assessment of the environmental data
    collection, processing, and management system of the CDH to determine actual
    data needs and how a useful, efficient, and manageable environmental data
    system should be established within the Department of Health.
Key Management Objective Number 10:   Pesticides

    Maintain an ongoing Federal pesticide program in Colorado responsive to the
    needs of the people in the State, as circumstances dictate and resources
    permit.

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                                        -26-
                         Key Management Objective Number 1
                               WATER QUALITY PROGRAM
   I.      Key Management Objective:   Complete key water quality program
          initiatives which  were begun in  FY  80,  these being:

    (A.)   Establishment of the new system  of  stream classifications  and water
          quality standards  for all  "state waters" in  Colorado.

    (B.)   Improvement of the NPDES permitting and enforcement  system.

    (C.)   Assumption of the  "205(g)"  construction grants management  program,  with
          particular emphasis to be given  to:

          1)    Ongoing delegation of the program;

          2)    Review and revision of the  construction grants  priority  list for
               municipal wastewater facilities;  and

          3)    Improving the operations and maintenance (O&M)  capabilities and
               performance of municipal wastewater facilities.

  I-A.    "Establishment of  New System of  Stream Classifications and Water Quality
          Standards ..."
 II-A.     Rationale;   The Federal  Water Quality Control Act  requires  all  surface
          waters be classified according to present  and potential  uses  and  numer-
          ical  limits for pollutant constituents to  be set to  protect those uses.
          The State is to establish such a water quality  classification system  and
          to review and update those classifications every three years  as needed.
          The Colorado Water Quality Control  Act has assigned  this responsibility
          to the Colorado Water Quality Control Commission.

          The Commission originally established stream classifications  in 1973.
          Those classifications were limited to a combination  of cold and warm
          water fisheries and partial  and whole body contact recreation.  In 1975,
          the Commission initiated the development of a more comprehensive  system
          of use classifications and numerical  limits associated with a much
          broader range of uses.

III-A.     Approach;  The Commission pursued a two-part approach to updating the
          stream classifications and water quality standards.  The first  estab-
          lished a system of several different  use classifications and  associated
          numerican criteria for all pertinent  pollutant  parameters.

          After four years of staff work, hearings,  legal challenges, and consi-
          derable internal deliberation, the Commission finally adopted the
          overall system in July 1979.  This  part of the  revision  process proved
          to be considerably more complex and controversial  than was  originally
          seen.                                   ..,-••

          In August 1979, the Commission initiated the second  part of the process
          by applying the new stream classification  system to  individual  streams.
          The Commission held lengthy hearings  for the South Platte and Republican
          River basins in July.  Hearings for waters in various regions of  the
          State have been scheduled through April, 1981,  with  the  complete  set  of
          new classifications to be adopted by August, 1981.

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                                       -27-


         The issues associated with this effort include:

         (a.) Maintaining scheduled progress in view of the legal,  procedural,
              and techncial obstacles.

         {b.) Providing adequate staff  support.

         (c.) Defining permit discharge limits during the interim period until
              the streams are finally reel ass ified.

         The Commission and the WQCD have faced many problems in maintaining a
         rapid schedule for the reclassification effort.  Many uncertainties and
         external factors exist.  Municipal, industrial, and to some extent,
         agriculture interests are very concerned with the implications of the
         reclassifications.  As a result, the hearings have evolved into a highly
         legalistic  set of proceedings, with inherent delays and taxing demands
         on the staff and. the Commission.

         In recognition of the difficulties of the stream reclassification pro-
         cess and the need to expedite  it,  the Commission is proceeding first
         with those  substate areas that are in most  need of reclassification.
         During the  period until the reclassification is accomplished,  discharge
         permits will continue to be processed according to the prevailing stream
         classifications on receiving waters.  The Division will also continue  to
         use the numerical limits contained in the July, 1979 stream classifica-
         tion document as a guide in establishing the numerical  limits  for
         individual  permits.

IV-A.    Key Activities:  During FY 1981, the key activities will be:

         A.   Completion of stream classifications for the:

                  Arkansas River Basin

                  Lower Colorado and Gunnison River Basins

              .   San Juan, Dolores and Rio Grande  River Basins.

         B.   Prepare complete set of revised stream classifications and
              associated standards;  finalize and submit to EPA.

         C.   EPA review and approval of submissions.

 V-A.    Responsibilities:  The State,  acting through the Water  Quality Control
         Commission  and Division,  is responsible for the conduct of the activi-
         ties leading to the adoption of stream classifications  and standards
         statewide.   The Division  is responsible for developing  proposed
         classifications and numerical  limitations for individual streams.   It
         primarily relies on available  water quality monitoring  data and inform-
         ation developed by the Division and other sources,  and  on  local  input.
         The subsequent hearing conducted by the Commission addresses the Divi-
         sion's proposal.   Ultimately,  the  Commission adopts a set  of standards
         and classifications for the area in question.   Upon transmission to EPA,
         that agency must act on the State's submission within 90 days.

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                                        -28-
 VI-A.    Resources;   Division support has consisted primarily of two Water Qual-
          ityEngineers ™ho have been working about 70 percent of their time on
          stream classifications.  The Division's mobile laboratory has provided
          field data to the process.   The Division will  add another engineer on
          nearly a full-time basis for FY 1981.   If necessary, EPA may be asked to
          assist by detailing one or  two technical people to the State.
VII-A.    Anticipated Progress and Milestones;

          .  Conduct hearings for the Arkansas  River Basin.

          .  Publish recommended stream classifications and
             standards for the Lower Colorado and Gunnison
             River Basins.

          .  Conduct hearings for the Lower Colorado and
             Gunnison River Basins.

          .  Publish recommended stream classifications and
             standards of the San Juan, Dolores and Rio Grande
             River Basins.

          .  Conduct hearings for the San Juan, Dolores and
             Rio Grande River Basins.

          .  Prepare overall revised stream classifications
             document and submit to EPA.
 I-B.

 II-B.
III-B.
             EPA action on State submittal.
                                                         December 1980



                                                         December 1980


                                                         February 1981



                                                         March 1981


                                                         May 1981


                                                         August 1981

                                                         October 1981
"Improvement of theNPDES Permittingand Enforcement System."

Rationale;  The State's NPDES program needs considerable attention.  It
has been beset with difficult morale and management problems and has
been improperly understood as the foundation of an effective water qual-
ity control program.  Compounding this, the program staff faces even
more complex projects and additional federal program requirements., all
to be supported by a gradually declining resource base.  Pretreatment
and the municipal management system are two relatively new program
requirements that must be faced.  As a result, an ever expanding backlog
of permits has occurred.  That backlog currently stands at nearly 300
permits, or about 25 percent of the total number of NPDES permits in
Colorado.

Enforcement of permits is essential to maintaining the credibility of
the water quality control program.  However, the resources devoted to
enforcement activities have been insufficient to maintain an efficient
enforcement program.  Recent improvements have occured due to hard work
by the staff, improved support from the Attorney General's Office, and
improved dedication by the Commission towards enforcement issues.

Approach;  Improved levels of resources and management activities are
keys to more effective water quality permitting .and enforcement activi-
ties.  The resource problems of the NPDES program have been alleviated
somewhat in the short time that the State Legislature has made a "one-
time" appropriation of $94,000 for the NPDES program in the State FY
1981.  Although these funds cannot be used to enlarge the ongoing staff,

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                                       -29-


         they can be used to hire staff services on a temporary.basis.   The Divi-
         sion has asked- for an increase in permit fees to offset the costs of
         administering the permit program.  Although this will  be a point of
         emphasis for the upcoming legislative sessions,  success is difficult to
         predict.  The Division has asked EPA for the use of "205{g)w funds to
         expand the enforcement program staff and offset  the loss of "106"
         funds.  In addition, the Division will  be examining resources  supported
         by other ongoing grant support to see if some additional resources can
         be directed to permits and enforcement.  The combination of these
         sources should expand the resources devoted to permits and enforcement.

         In addition to addressing resource needs, management options for the
         permits program are being evaluated.  These options will likely lead to
         increased paraprofessional and administrative capabilities together with
         the establishment of a management system for processing more permits.
         The development of program policies will be part of that system.

         An overall strategy for both the permits and enforcement programs will
         be developed during the year - the permits strategy for reducing the
         backlog and the enforcement strategy for taking  action against violators
         in an effective and efficient way.  These strategies will be developed
         as soon as additional resources are available Both strategies will need
         close managerial attention from both WQCD and EPA management staffs.

         With respect to the municipal management system, the Division  has made
         an initial inventory of the municipalities that  are faced with regula-
         tory problems associated with Section 301(i) of  the Federal  Clean Water
         Act.  The need will be to develop improved consistency in actions by the
         permits and enforcement programs to meet the June 30,  1983,  deadline for
         compliance with water quality standards and to bring about increased
         financial support through the construction grants program.   During FY
         1981, the Division will develop a process to tie together these program
         activities and for taking specific actions against present and potential
         violators.

IV-B.    Key Activities;  During FY 1981, the key activities will be:

         A.   Development and implementation of an improved internal  management
              structure for processing NPDES permits.

         B.   Development of a management strategy for reducing and ultimately
              eliminating the backlog of permits.

         C.   Development of a strategy for a consistent, equitable,  and
              aggressive enforcement approach.

         0.   Development and implementation of a municipal management  process
              for relating permits, enforcement actions and grant support
              involving public wastewater treatment facilities.

 V-B.   . Responsibilities;  With the delegation of the NPDES program to Colorado,
         the primary responsibility for this key program  is with the WQCD.  The
         Division will work with EPA in defining improved permitting  and report-
         ing procedures.  The Division will expect program and  financial support
         from EPA, such as directing available 205{g) funds to  enforcement
         efforts and obtaining information on successful  NPDES  programs in other
         states.

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                                        -30-


 VI-B.    Resources;   The WQCD will  devote 4.4 FTE to the achievement of these
          activities,  in" addition to the technical staff directly responsible for
          day-to-day permitting and  enforcement activities.

VII-B.    Anticipated Progress and Milestones;

               Develop and implement a managment
               structure for processing permits.           October 1980

               Develop a management  strategy for
               reducing the permits  backlog.                October 1980

               Develop a management  strategy for
               enforcement.                                February 1981

               Develop and implement a municipal
               management system program.                   December 1980
  I-C.    "Assumption of the 205(g)  construction grants  management program with
          particular emphasis to be  given to;

    1)    The ongoing, delegation of  the program;

    2)    Review and revision of the construction grants priority list for
          municipal  wastewater facilities;  ajid

    3)    Improving  the operations and maintenance (O&M) capabilities  and
          performance of municipal wastewater  facilities."

 II-C.    Rationale:  The construction grants  management program is in a transi-
          tional  period.  Roles and  responsibilities  are changing.   Construction
          grants are currently taking an undue amount of time to process,  espe-
          cially considering the presence of overloaded  and overflowing existing
          facilities.  The priority  system for the program  needs a major review,
          particularly to meet the enforceable needs  of  the Federal Clean  Water
          Act.   And  many existing facilities are frequently not operating  to their
          potential  capabilities and efficiencies.

          The delegation of the construction grants program to the State is
          reasonably close to the schedule defined in the joint agreement  between
          the WQCD and EPA.  The Division is securing the necessary staff  re-
          sources to accomplish this work.  During FY 1981, the delegation agree-
          ment needs to be reviewed  and revised as necessary to reflect both
          administrative changes and the issues discussed in this Agreement.' In
          conjunction with this, the Division  and EPA need  to review the overall
          grants process to determine ways in  which the  grants process can be
          expedited  to provide more  timely grant assistance, consistent with
          projects that are urgently needed.

          The priority system also needs to be comprehensively re-examined to
          better direct the limited  funds to those projects needed to  meet the
          regulatory requirements of the Federal Act.  The  current system  was
          established in 1976.   Conditions  have changed  and new issues and needs
          face Colorado municipalities.

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                                        -31-
in-c.
 iv-c.
Improved O&M of municipal facilities has been a chronic problem through-
out the State,'particularly for relatively small facilities.  Many
factors contribute to this.  The Division has a variety of efforts
underway for trying to meet this problem.  They include an active
operators training program, communications with design engineers, direct
technical support to many municipalities, and an enforcement program to
help bring about compliance.  However, a more aggressive overall
strategy to improving municipal operations need to be defined, and
ongoing O&M efforts need to be examined for possible changes in light of
that strategy.

Approach;  The Division and EPA will work together to define measures
for expediting grant assistance.  Several projects have been delayed for
inordinate amounts of time because of issues raised during the project
review stages, particularly as related to environmental reviews.
Procedures need to be developed to address such problems during the
early stages of facility planning so that such costly delays are avoided.

The construction grants priority system also will receive considerable
attention.  The issues are difficult, particularly those related to
growth, but the need is particularly evident since federal support will
likely fall considerably short of meeting the overall needs of the
State.  The WQCD will-conduct meetings at different locations throughout
the State to discuss wastewater facility needs and issues and to provide
information on how the priority list should be revised.  Eventually, the
priority list system will need to dovetail reasonably close with grant
support available from the State and Farmers Home Administration grant
programs.

Efforts to improve O&M will be defined by the O&M strategy.  It is
anticipated that much of the ongoing work will continue, but salaries of
municipal plant operators are traditionally low, and will likely stay
that way unless external pressures bring about change.  The Division may
need to work with the Colorado Municipal League and the Colorado
Association of Special Districts to bring about greater recognition of
this problem.
Key Activities;
include:
The key activities to be undertaken during FY 1981 will
          A.   Review of the grants process to provide more timely grant support;

          B.   A review and revision,  as necessary,  of the construction grants
               priority system.   This  effort needs to address many issues,  such as
               the relative importance of existing versus future capacity needs,
               treatment plant needs versus interceptor sewers,  capacity needs
               versus additional  levels of treatment, and municipalities subject
               to regulatory actions versus those not faced with such actions; and

          C. -Develop an overall strategy for enhancing municipal O&M that
               addresses technical  support, effective training,  enforcement
               actions, the concept of a utility management programj  and operation
               certification.

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                                       -32-


  V-C.    Responsibilities^  Because of the transition in responsibilities for the
         construction grants management program and the magnitude of the problems
         and issues involved with it,  the WQCD and EPA will, need to jointly
         address this management objective.  The Division will  take the lead on
         many of the activities, but EPA involvement, assistance, and cooperation
         is particularly important in  evaluating-the grants management process,
         assisting in developing the O&M strategy, and providing staff support on
         the priority system.  Any ultimate change in the priority system must,
         however, be made by the Commission, which must provide clear policy
         direction to the Division in  the assessment of possible revisions to the
         priority system.

 VI-C.    Resources:  The Water Quality Control Division has established a Con-
         struction Grants Section which encompasses an interdisciplinary tech-
         nical staff.  The level of staff support committed to  the Construction
         Grants Management Program is  in accordance with the terms of the
         "205(g}" delegation agreement with EPA.  During FY 1981, a total of 18
         FTE will be committed to the  construction grants management activity,
         which will bring the program  to full staff strength necessary for full
         State assumption and operation of the program.  In addition, the EPA
         will commit another 6.7 FTE to this activity, and will provide the State
      .   with $558,700 in financial support.

VII-C.    Anticipated Progressand Milestones:

              Review of the grants management process                     January
              1981
              to provide more timely grant support.

              Develop an improved O&M  strategy for                        February
              1981
              municipal facilities.

              Develop revised construction grants                         July
              1981
              priority system.

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                                       -33-


                        Key Management Objective Number 2
            HATER QUALITY MANAGEMENT PLANNING AND POLICY COORDINATION


  I.     Key Management Objectlve:   Develop formal  recognition of the plans pro-
         duced by the "208"  water quality planning  process  and integrate the
         technical  provisions of those plans into the ongoing decision-making
         process of the Water Quality Control  Division and  Commission related to
         grants, discharge permits,  and site applications.

 II.     Rationale;   The 208 plans  the for substate regions of Colorado have been
         reviewed and approved (with conditions  as  necessary), as policy docu-
         ments by the Water Quality Control Commission.  Those plans contain
         generalized information for decision-making at  both the local  and State
         level.  In some instances,  however, the detail  necessary for site speci-
         fic decisions are lacking.   A more serious problem, however, has been
         that the Division and Commission have not  been  routinely following these
         plans, particularly with respect to site approvals and discharge per-
         mits.  Also, it has always  been a federal  requirement that construction
         grants and NPDES actions be consistent  with the adopted and certified
         208 plans.

         Because of the increasing  complexities  associated  with the location,
         timing, and capacities of  wastewater  facilities, particularly in growth
         areas, a serious need exists for the  development and maintenance of
         these plans in much of the  State.  Investments  have been made in the
         development of 208  plans, which provide the only logical ongoing and
         continuing process  for defining facility needs.. The need is to update
         and improve these plans, and assure their  use in State decision-making
         and action.

III.     Approach;   The WQCD has begun to work with the  State 208 Coordinating
         Unit (Colorado Department  of Local Affairs) in  developing a proposed
         policy for consideration by the Commission which will explicitly estab-
         lish the 208 plans  as the  basis for ongoing Division/Commission
         decision-making.  This policy will need to define  what information is
         needed, the process to formalize plans, and the lead time needed before
         the policy becomes  effective.

         A significant problem exists.   Ongoing  federal  funding is no longer
         available  for continued work in developing the  facilities portion of 208
         plans.  Any efforts to keep those plans up-to-date will  impose costs on
         local governments.   However, it is hoped that the  realization of the
         benefits to local  governments will overcome this problem and that local
         funding for maintaining, updating and improving "208" plans will  be
         forthcoming.

 IV.     Key Activities;  The key activities to  be  undertaken during FY 1981  will
         consist of drafting of a proposed policy,  review of that policy by the
         Commission, public  input and review of  the policy  culminating in a
         public hearing, and adoption of the policy by Jthe  Commission and its
         implementation by the Division.

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                                        -34-
   V.
  VI.
 VII.
Responsibilities;  Responsibility for this activity will involve a
cooperative effort between the Division, Commission, and the 208 Exec-
utive Committee.  EPA endorsement will also be needed because of their
approval role.  Once a'policy is adopted, the responsibility will be
with local governments to collectively provide the necessary detail to
update and improve the "208" plans to ensure their usefulness in state
decision-making and action.

Resources;  The resources to be devoted to this activity will be, at a
minimum, 0.2 FTE from the WQCD and 0.1 FTE from the 208 Coordinating
Unit, plus the necessary attention of the Water Quality Control
Commission.
Anticipated Progress and Milestones;

     Submission of proposed policy to
     the Commission.

     Public hearing on the proposed
     policy.

     Adoption of the policy.

     Effective date of policy.
                                                           October 1980


                                                           November 1980

                                                           December 1980

                                                           July 1981
VIII.
Comments;  The development of a policy for using "208" plans as a basis
for State action is far reaching and affects many interests.  It re-
flects the need for cooperative State/local decision-making on water
quality actions by the State.  But it is difficult to anticipate its
full ramifications or the response it will receive.  If it is very
controversial, it may require a greater amount of time and effort to
follow through with a specific action by the Commission.  In that
regard, the schedule may need to be modified.

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                                                    -35-
                                     Key Management Objective Number 3
                                   AUTOMOTIVE  INSPECTION AND MAINTENANCE
               I.     Key Management Objective;   Implement the automotive emissions  control
                      inspection and maintenance program {I/M},  established by the Colorado
                      Legislature for the nine-county Front Range urban corridor.

              II.     Rationale;  The State recently has enacted legislation requiring an
                      inspection and maintenance program which requires 1968 and newer light-
                     •duty vehicles to be inspected for tailpipe emissions.

                      The largest single source  of carbon monoxide and hydrocarbon emissions
                      into the atmosphere is exhaust from motor  vehicles.  In the Denver Area,
                      for example, over 90 percent of the CO and 85 percent of the HC emis-
                      sions are "tailpipe" emissions.  The need  is to significantly  reduce
                      these emissions, especially of CO, to bring the Denver Region,  Colorado
                      Springs Area, and Larimer-Weld Region nonattainment areas into compli-
                      ance with the National Ambient Air Quality Standards by the end of
                      1987.  The most efficient  single means of  accomplishing this objective
                      is to insure that automobiles are operating efficiently, thus  minimizing
                      emissions due to inefficient engine operation,  and that exhaust emission
                      control systems are properly operative.  The mechanism for this is the
                      regular inspection of motor vehicles to  assure their compliance with
                      vehicular emission standards, with mandatory maintenance or repairs for
                      those vehicles failing to  meet the standards.  The I/M program estab-
                      lished by the Colorado Legislature in 1980 (Senate Bill 52)  is expected
                      to result in a 15-20 percent reduction in  CO emissions by 1987, thus
                      helping achieve the CO standard which would otherwise likely be
                      unachievable by that year.

             III.     Approach;x

                      A.   Only light-duty vehicles in Adams,  Arapahoe, Boulder, Denver,
                           Douglas, El Paso, Jefferson, Larimer, and Weld Counties will  be
                           required to participate in the emissions inspection program.   The
                           vehicle may be inspected any time within the six months just  prior
                           to the State safety inspection.

                      B.   On or after July 1, 1981, no 1968 or  later model used vehicle which
                           is registered in the  program area shall be registered in  the  nine-
                           county program area by a new owner, and no 1968 or later  model used
                           vehicle shall be registered for the first time in the program area,
                           unless such vehicle has emission control certification  or an  emis-
                           sions exemption.  A new owner of a  vehicle required to  obtain emis-
                           sions control certification may require the prior owner to provide
                           this certification at the time of sale.  If a motor vehicle is
                           being registered for  the first time in the program area,  the  owner
                           shall obtain the certification and  submit it with the application
                           for registration.

                      C.   From July 1, 1980, to December 31,  1981, motor vehicles of model
                           years 1968 through 1981, owned by the State or a political sub-
                           division, shall be inspected once and emissions control certifica-
                           tion obtained.
_

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                              -36-
D.
E.



F.




G.



H.


I.
             From July 1, 1981, to December 31,  1981,  all  motor vehicles of the
             model years 1981 or later may be voluntarily  inspected and emis-
             sions control certification obtained,  which shall  be valid for one
             year.

             On or after July 1, 1981, all United States Government motor
             vehicles, model years 1968 and later,  shall be inspected once each
             year and emissions control certification  obtained.

             On or after January 1, 1982,  all motor vehicles, model years 1968
             and later, shall  be inspected once  each year, not  earlier than six
             months prior to the month the annual safety inspection is due,  and
             emissions control certification obtained.

             New motor vehicles shall  be issued  emissions  compliance certifica-
             tion without inspection to expire twelve  (12) months after initial
             vehicle registration.
             The cost of the inspection is  not to  be  greater than $10.00.
             fee must be posted in the Inspection  Station.
This
             Vehicles failing the inspection will  be required  to  have  idle
             speed,  idle mixture, and ignition timing set  to manufacturer's
             specifications for a maximum adjustment fee of  $15.00.  Beginning
             July 1,  1982,  all  1981 and newer light-duty vehicles failing the
             inspection after the adjustments are  made will  be required  to
             receive repairs to a maximum of $100.00.  In  addition,  all  vehicles
             will  be inspected  to determine if any emission  control  equipment
             has been disabled, removed,  or rendered inoperable.   If such
             tampering is found,  the equipment must be restored to its original
             condition.

IV.      Key Activities and  Responsibilities:  During FY 1981 the  key activities
        will be the  Development of Rules  and Regulations:

             Part A— General Provisions;

             This part, currently under study, will contain  significant
             definitions of terms, abbreviations,  and exempt vehicles.

             Part B  - Vehicle Emissions Inspection Station

             "Part B" of the recommended  regulations covers  the administrative
             and procedural requirements  for licensing of  approved emissions
             inspection stations.  The major elements of Part  B are:

             (a.)  Procedures for license  applications.

             (b.)  Official  inspection and readjustment stations may  also be
                  official  "safety" inspection stations.

             (c.)  Eligibility requirements for licensing of  "Official  Inspection
                  and Readjustment Stations."

             (d.)  All inspection mechanic licenses issued  will  remain  in effect
                  unless revoked.

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                         -37-


(e.) Rules for operation of a licensed inspection station.

(f.) Requirements for "inspection and adjustment station" licenses.

Part C - Emissions Inspectors/Mechanics

"Part C" of the recommended regulations covers the requirements for
licensing of emissions inspectors/mechanics and the procedures for
performing the emissions inspection.

Part D - Emission Inspection Certificates

"Part D" applies to the purchase, issuance and use of emissions
Inspection certificates.  All emissions inspections certificates
are purchased from the Colorado Department of Revenue.

(a.) Emissions inspection certificates may include the following:

       (i.)    certificate of emissions compliance, issued to those
               vehicles which pass the exhaust emissions standards;

      (ii.)    certificate of emissions adjustments, issued to
               those vehicles which fail  the exhaust emissions
               standards, and have adjustment or repairs according
               to the regulations; and

     (iii.)    certificates of emissions  exemption, issued to those
               vehicles which qualify for exemption under the .
               regulations of the Colorado Air Quality Control
               Commission.

(b.) Procedures for Issuance of Certificates of Emissions are:

       (i.)    to be issued when a vehicle fails either or both the
               hydrocarbon (HC) and/or carbon monoxide (CO) emis-
               sion standards, and has been adjusted or repaired
               according to the Commission's regulations and still
               does not comply to State emission standards;

      (ii.)    the certificate is good for ten days, during which
               adjustment or repairs can  be made to the failing
               vehicle;

     {iii.)    an inspection rejection report may accompany the
               rejected vehicle; and

      (iv.)    having failed the reinspection, a suggested
               voluntary repair procedure will be issued to the
               vehicle owner.

Part £ - Emissions Inspection Procedures

"Part E" describes the general requirements, procedures, and
instructions for conducting the emissions inspection.

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                         -38-
Part F - Exempt Vehicles

"Part F" deals with the qualifications, definitions, and procedures
for the authorization to issue a certificate of emissions exemp-
tion.  The following classes of vehicles are exempt:'

(a.) authorized emergency vehicles as defined by State Law;

(b.) all vehicles which exceed 8500 pounds gross vehicle weight;

(c.) all vehicles which are propelled by other fuels other than
     gasoline or gasohol; and

(d.) all other vehicles exempt by Colorado Air Quality Control
     Commission regulations.

Part G - Emission Inspector/Mechanic Certification

"Part G" sets forth the requirements, qualifications,  and demon-
strated abilities necessary for prospective inspectors/mechanics to
qualify for a certificate of qualification.  These qualifications
include:

(a.) successful completion of approved emissions inspection and
     repair training courses;

(b.) demonstrated mechanical ability in conducting an emissions
     inspection and attainment in the skill and use of emissions
     inspection equipment;

(c.) affidavits evidencing that the prospective inspector has
     attained and possesses the necessary skills to properly
     perform as a qualified inspection inspector; and

(d.) successful passing of qualification tests approved by the
     Colorado Air Quality Control Commission for emissions
     inspection inspectors/mechanics.

Part H - Exhaust Gas Measurement Device Approval

"Part H" applies to requirements for evaluation and certification
of analyzers used as exhaust gas samplers in licensed official
emissions inspection stations.  Approved analyzers will need to be
capable of providing exhaust gas measurements of hydrocarbons {HC}
and carbon monoxide (CO) within the minimum criteria as established
by the Commission under performance standards for HC/CO measurement
instruments.

Part I - Exhaust Emissions Inspection Standards

"Part I" sets forth the exhaust emission standards which must be
complied with to qualify for an emissions inspection certificate,
compliance, or adjustment.

Inspection standards are specified for 1968 and newer model year
motor vehicles and are indicated in percent by volume for carbon
monoxide and in parts per million for hydrocarbons.

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                                       -39-
 VI,
VII-,
     Part J - State Administered Referee System

     "Part J" identifies administrative and operational procedures for
     the State referee system.  The State referee system may be operated
     for the following purposes:

     (a.) for vehicle owners to present their vehicles for purposes of
          contesting the grounds for repeated exhaust emissions failures;

     (b.)'to conduct emissions inspections, analysis and diagnostic
          investigations into the cause or causes for emissions failures;

     (c.) to recommend corrective actions as a result of the
          investigations; and

Responsibilities;.  The responsibility for addressing this management
objective will be shared by the Colorado Department of Health, the Air
Quality Control Commission, and the Colorado Department-of Revenue.  The
Department of Health will have overall responsibility of developing and
implementing the inspection and maintenance program, technical material,
and the motor public information program.  The Air Quality Control Com-
mission will adopt rules and regulations.  The Department of Revenue is
responsible for issuing licenses, administration, and enforcement.
Major responsibilities for each area are detailed in Senate Bill 52.

Resources:  The following resources will be committed to the meeting of
their management objectives:

                                         Department of Revenue
  Department of Health

    Cash funds: $591,635
Federal funds:  $200.000
Total funds:$791,635

Anticipated Progress and Milestones:

   ,  Mechanic Training Contracts,
     Community Colleges.

     Rules and Regulations.

     Public Hearings - Rules and Regulations.

     Standards — 1968-1981 Model Motor
     Vehicles.

     Public Information Program Starts.

     Mechanic Training Classes Start.
                                                         $278,248
                                                            -0-
                                                         $278,248
                                                          October 1980

                                                          August  1980

                                                          November 1980


                                                          December 1980

                                                          October 1980

                                                          February 1981
              High Altitude Adjustment Handbook
              Prepared..
                                                 January 1981

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                         -40-
Technical Centers Established:
                         Denver             January 1981
                         Fort Collins       April  1981
                         Colorado Springs*   May 1981

State Personnel Training Starts.             March  1981

Home Mechanic Training Starts.               June 1981

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                                       -41-
                        Key Management Objective Number 4
                             HAZARDOUS WASTE CONTROL
  I.     Key Management Objective:   Establish an interim program of hazardous
         waste control  activities,  including technical  cooperation with EPA to
         assist with designation of hazardous waste facilities under the provi-
         sions of Subtitle "C" of Resource Conservation and Recovery Act (RCRA),
         and the provision of support to the Colorado Legislature to develop
         authorizing legislation for State control  of hazardous wastes.

 II.     Rationale;  The issuance of regulations in May, 1980 by EPA for the
         control of hazardous wastes has set the stage and the timing require-
         ments for States to decide what their efforts will be and to develop and
         implement programs to carry out these efforts.  The intent of RCRA and
         EPA policy in  implementing that Act is that the states conduct programs
         to control hazardous waste in lieu of an EPA program.  Current
         legislative authority in Colorado to do so is inadequate, and past
         attempts to secure authorization have been delayed.   The major focus of
         the 1980-81 work on hazardous waste recognizes this situation.

III.     Approach:  The major State efforts will be twofold:   1) pursuit of
         necessary legislative authority for State authorization by working with
         an interim study committee and with the 1981 Session of the General
         Assembly; and  2) in the absence of legislation, to carry out major work
         tasks for implementing hazardous waste control under a cooperative
         agreement with EPA.  The EPA will provide oversight and will  conduct
         compliance monitoring enforcement actions, the issuance of permits,  and
         other activities for which the State has inadequate authority.

         These developmental and implemental actions are expected to accomplish
         the major substance of the management objective and to provide the even-
         tual basis for smooth takeover of a full hazardous waste control  program
         in Colorado.  This approach is appropriate since it is anticipated that
         the necessary  legislation  will be passed in the 1981 or 1982 Legisla-
         ture, and it thus is appropriate for the State to conduct as much of the
         program as it  can on an interim basis so that it will have as many of
         the elements of the program in place as possible when full  authorization
         is eventually  received from the Legislature and the EPA.  This approach
         will best serve the people of Colorado and accomplish the goals of RCRA
         in controlling hazardous wastes.

 IV.     Key Activities:   See the work plan for the Interim Hazardous Waste
         Control Program.

  V. '     Responsibilities;   The State will be responsible for the conduct of the
         major technical  tasks outlined in the cooperative agreement to bring
         about hazardous waste control  in Colorado and do the developmental  work
         for legislative authorization; EPA will conduct compliance monitoring,
         enforcement actions, and issuance of any new permits, and will also
        .provide oversight of the State efforts to assure that these are
         consistent with the provisions of RCRA.

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                                       -42-
 VI,
VII,
Resources:  Conduct of this Interim program will involve 9.4 FTE in the
Radiation and Hazardous Waste Control Division, supported by $234,000 in
federal funds.  Approximately $102,000 of grant funds are being used to
conduct the federal program.  There may be increased calls for
involvement of local Health Departments in the beginning stages of the
RCRA program, because of uncertainty about materials that can be
disposed in locally-control- led solid waste sites, but these will
probably require management within current resources.
Anticipated Progress and Milestones;

     Initiate cooperative agreement.

     Establish management system for review
     of facilities with Interim Status and
     work on Notification System.

     First oversight report to EPA.

     General Assembly begins consideration
     of legislation.
       •

     Assist General Assembly in developing
     legislation.
                                                          October 1980



                                                          November 1980

                                                          December 1980


                                                          January 1981


                                                          February-May 1981

                                                          May 1981
     Second oversight report to EPA.

          review of all notifiers;

          non-notifiers located and integrated into system; and

          investigative survey of State efforts under the Federal  Solid
          Waste Act pertaining to the one off-site disposal facility
          expected to receive an "interim status" permit under RCRA.
              P'assage of Legislative Authorization.

              Initiate development of application
              for EPA authorization to State.
                                                 May 1981.
                                                 October 1981

                                                 July 1981

                                                 October 1981
              Provide oversight report to EPA.

              Annual oversight report to EPA.

                   legislative authorization progress;

                   proposed schedule for EPA authorization to State;

                   investigative review of TSD  facilities, recommend  actions,  new
                   facility permits; and
                   future work plan.

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                                        -43-
VIII.     Comments;  In the event the legislative efforts do not succeed in pro-
          ducing sufficient authorization for State assumption of the hazardous
          waste program, a decision must be made by both EPA and the State on
          whether to continue or modify the cooperative agreement according to
          expected success in FY 1981-82.  If passage of legislation occurs,  work
          in the last quarter of FY 1980-81 will focus on those tasks necessary
          for receipt of EPA authorization.

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                                       -44-
                        Key Management Objective Number 5
                            ENVIRONMENTAL EPIDEMOILOGY
  I*      Key Management Objective:   Establish an ongoing environmental  epidemi-
         ology capability within the Department of Health to provide the
         expertise necessary to address human health problems associated with
         environmental  control  activities  and pollution incidents.

 II.      Rationale:   The "bottom line"  for environmental  pollution  control  acti-
         vities is the protection of the public health.   Unfortunately,  this
         seems often to be overlooked in both national  and State environmental
         pollution control programs, perhaps  due both to the success in  minimiz-
         ing many of the more serious types of environmental diseases,  and
         because much of the focus  of pollution control  efforts has been on
         engineering-oriented solutions to minimizing waste streams.  In any
         case, it is fair to say that protection of the public health as the
         principal context for  environmental  pollution control  activities has not
         been given  the emphasis it needs.

         The need to reemphasize the health protection aspect of environmental
         control programs is especially paramount in Colorado,  with the  many
         unique health-related  problems present in this  State.   The Colorado
         Department  of Health limited environmental  disease control and  epidemi-
         ology capabilities for a number of years in its  Disease Control and
         Epidemiology Division.   Unfortunately, this capability has been main-
         tained on a "shoestring" basis, often by directing resources away  from
         other epiderniologic activities.  This arrangement is no longer  accept-
         able, both  because of  the  need to address environmental  health  issues  on
         a sustained, continuing basis, and because of the increasing difficul-
         ties in drawing upon other, non-environmental  epidemiologic resources
         for environmental-related  activities when those resources  are facing
         increased demands.  The requirement  is to establish an ongoing  environ-
         mental epidemiology program, with its own committed resources,  to  serve
         the various environmental  pollution  control programs of the Colorado
         Department  of Health.
Ill,
 IV.
Approach:  The Colorado Department of Health Disease Control and
Epidemiology Division and the EPA Toxic Substances Branch will work
together to expand the existing, but limited, environmental epidemiology
capabilities of the State.  The focus during FY 1981 will be to improve
abilities to detect and respond to environmental disease incidents in
Colorado, and to bring medical, epidemiologic, and toxicologic capabil-
ities to bear on such incidents to determine whether biological effects
have occurred, to provide necessary medical care, and to determine the
etiology of the observed bioeffects.

Key Activities;  During FY 1981, the key environmental epidemiology
%*
:ti
         activities  win  be:
         (a.)  Upgrade existing  surveillance for  environmental  health  complaints
              and reports  routinely received from  county health  departments,
              State and federal agencies,  physicians,  and the  general public.

         (b.)  Develop and  implement protocols for  handling surveillance reports.

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                                      -45-
 V.
(c.) Expand capabilities for preparing epidemiologic study designs, for
     conducting biomedical and toxicologic appraisals, for data process-
     ing, analysis and interpretation, and for conducting literature and
     data base searches.

(d.) Expand capabilities to support the Colorado Department of Health
     Air Pollution Control, Water Quality Control, and Radiation and
     Hazardous Wastes Control Divisions in recognizing and responding to
     the human health effects of biological, chemical, and physical
     agents.

Responsibilities;  The responsibility for addressing this management
objective will be shared jointly by the CDH Disease Control and
Epidemiology Division and the EPA-Region VIII Toxic Substances Branch.
The Disease Control and Epidemiology Division will have overall "lead"
responsibility for this activity.  Follows is a list of activities which
must be performed in an environmental epidemiologic program, with an
identification of the relative roles of the Colorado Department of
Health and EPA.
               Activity
  Epidemiologic and Study Design.
  Toxicology.
  Medical Workups.
  Literature and Data Base Searches.
  Survey Federal Programs for Additional
    Resources  to Address Specific  Problems
    (e.g. R&D, grants, access level-of-effort
    contracts, other federal  agencies, like
    experiences in other states).
  Field Work (sampling,  records capture,
    interviewing).
  Data Base Construction.
  Computer support for data analysis.
  Data and sample analysis.
                                              Responsibility

                                                CDH          EPA
                                               Lead
                                               Assist
                                               Lead
                                               Assist
Assist
 Lead

 Lead
                                                Lead
                                                Lead
                                               Assist
                                                Lead
Assist
Assist
 Lead
Assist
VI.     Resources;   The following resources  will  be committed  to meeting this
        management  objective:

        Agency:   Colorado Department of Health-Disease Control  and  Epidemiology
                 Division
                  Chief,  Environmental  Epidemiology Section
                  Medical Consultant,  Env.  Epi.  Section
                  Division Director
                                                             0.5 FTE
                                                             0.5 FTE
                                                             0.3 FTE
                                                     TOTAL
                                                             1.3 FTE

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                                       -46-
         Agency;   EPA r Region VIII-Toxic Substances Branch

                   Epidemiologist
                   Toxicologist
                   Environmental Protection Specialists
                                                      TOTAL
0.2 FTE
0.2 FTE
0.3 FTE

0.7 FTE
2.0 FTE
VII.     Anticipated Progress and Milestones;   See 1980-81 Environmental  Work
         Plan.  It is not possible to provide more detail  at this time because of
         the embryonic nature of program.

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                                       -47-


                        Key Management Objective Number 6
                       -  ENVIRONMENTAL EMERGENCY  RESPONSE


  I.      Key Management Objective;   Improve,  strengthen and  Intergrate the capa-
         bilities of the  CDH,  EPA,  and local  governments to  respond  to
         environmental  Incidents  and emergencies,  both  through direct action  and
         by providing assistance  and advice to "on-the-scene"  agencies.

 II.      Rationale;   Regardless of  the level  of regulatory control and planning
         to prevent  accidental  "emergency-level"  incidents which  threaten  the
         public health.and environmental  quality,  such  incidents  will  occur.
         Accordingly, the capabilities to cope with  the various types of environ-
         mental emergencies must  be developed and maintained.   A  comprehensive
         environmental  emergency  response capability must  be based upon the inte-
         grated efforts of a  number of different  agencies  and  entities, including
         the local  "on-the-scene" agency  first responding  to an incident,  the
         CDH, the EPA,  and other  State, local, and federal agencies  and private
         resources.   Further,  this  environmental  emergency response  capability
         must be consistent with  and integrated into the overall  Colorado
         Emergency Response Plan.

         Recent years have seen an  increase in the potential for  serious
         environmental  accidents  involving hazardous materials, such as poly-
         chlorinated biphenyls  (PCBs), heavy  metals  (e.g., mercury,  cadmium,
         etc.), polyvinylchlorides  (PVCs), and radioactive materials,  due  to  the
         increasing  use of such materials in  manufacturing processes.   Coincident
         with the increasing  dangers presented by such  materials  there has been a
         growing awareness of  these dangers and of the  specific types of emer-
         gency threats  these materials may pose.   It has come  to  be  recognized
         that, along with the  traditional environmental emergencies  posed  by   •
         floods, storms,  and other  natural phenomena, new  categories of environ-
         mental emergencies can occur due to  accidents  involving  toxic or
         hazardous materials used in or generated by modern  industry.

III.      Approach;   In  the past,  the environmental emergency response efforts of
         the Colorado Department  of Health were managed by the specific divisions
         in whose general  area of purview an  incident appeared to fall  (e.g., an
         oil spill threatening  water quality  was  the sole  responsibility of the
         Health Department's  and  Water Quality Control  Division).  Under this
         arrangement, a coordinated approach  to responding to  major  emergency
         situations  was difficult to achieve.

         In FY 1981, responses  to major emergency incidents  will  be  addressed by
         designated  coordinators, who will direct the respective  environmental
         emergency response efforts of the CDH and of the  EPA  and serve as
         coordinators with other  cooperating  agencies.   This will facilitate
      •   optimal use of the full  range of emergency  response capabilities  of  the
        . two agencies.  Responses to minor incidents will  generally  continue  to
         be handled  by  the appopriate operating divisions.

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                                      -48-


        Partlcular emphasis will be given to the State's program to respond to
        emergency incidents involving hazardous or toxic materials which pose
        threats to environmental health in Colorado.  This program provides
        technical assistance to police, fire, and emergency crews involved in
        the control  of emergency situations as they occur; the collection and
        analysis of contaminants; clean-up of emergency sites and disposal of
        the hazardous materials causing the emergency; the ongoing review and
        evaluation of emergency response capabilities and specific emergency
        response situations; and the provision of training for emergency
        response crews.

IV.     Key Activities;   Emergency response activities to be conducted during FY
        1981 will include:

        (a.) Establishment  of the CDH emergency response coordinator system.

        (b.) Direction of and participation in emergency response and emergency
             impact mitigation efforts.

        (c.) Conduct of  emergency impact mitigation monitoring.

        (d.) Spill  prevention and mitigation.

        (e.) Emergency response contigency planning.

        (f.) Training and technical  assistance to State,  federal,  and local
             agencies.

        Detailed definitions of FY 1981 emergency response work  program activi-
        ties is provided in the Environmental Emergency Response Work Plan.

 V.     Responsibi1ities:   Depending on the specific emergency situation,  re-
        sponsibility for an emergency response effort can be assigned either to
        a specific  Health Department and EPA operating division  for  relatively
        "routine" emergency incidents or,  in the case of major emergencies,  be
        under the direction of an assigned coordinator who will  oversee all
        emergency response  efforts.   In most cases,  the CDH will  have the  lead
        responsibility for  directing responses to environmental  emergency  inci-
        dents in Colorado,  with assistance to be provided by the EPA.   The EPA
        Emergency Planning  and Response Branch will  have primary responsibility
        for directing EPA emergency response efforts.

        Response efforts directed toward emergency incidents involving  hazardous
        materials and situations involving radiation are the day-to-day operat-
        ing responsibility  of the Health Department's  Radiation  and  Hazardous
        Wastes Control Division.   The Water Quality Control  Division has primary
        operating responsibility in situations involving  spills  into waterways
        and for spill prevention efforts.   Coordination of EPA emergency
        response efforts is the responsibility of the Emergency  Planning and
        Response Branch  of  the EPA-Region  VIII Surveillance and  Analysis Divi-
        sion.   Contingency  planning and training activities will  be  coordinated
        by the Health Department's Radiation and Hazardous Wastes  Control
        Division and  the EPA Emergency Planning and  Response Branch.

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                                       -49-


 VI.     Resources:  The resources committed to ongoing environmental emergency
         response coordination, contingency planning and training during FY 1981
         will, as a minimum, be 1.0 FTE by the CDH and 1.7 FTE by the EPA.
         Resources actually committed to emergency response efforts will be
         significantly greater, with the specific efforts to be determined by the
         requirements of particular environmental emergency situations.  The
         ongoing operating programs of the State and EPA will provide the actual
         staff and material resources needed for actual "on-scene" emergency
         response efforts.

         Specific identification of the staff resources to be committed to on-
         going emergency response activities; and of the EPA funds committed to
         these activities, is provided by the Environmental Emergency Response
         Work Plan.

VII.     Anticipated Progress and Milestones;  During FY 1981, it is anticipated
         that some 40 significant environmental emergency incidents will occur,
         based upon past trends.  In addition, it is anticipated that there will
         be some 250 minor incidents, requests for technical assistance, spill
         clean-ups, etc.  These situations will -likely be spread fairly evenly
         throughout the year, with ,the exception of truck transportation
         incidents, which are more frequent during the winter months.

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                                       -50-
                        Key Management Objective Number 7
                 INTERGOVERNMENTAL ENVIRONMENTAL ISSUES MANAGEMENT
  I.     Key Management Objective;  Develop a pilot intergovernmental  environ-
         mental policy coordination and issues management process which will
         define the inter-related roles of State,  federal and local agencies and
         establish a mechanism for the management  and resolution of major envi-
         ronmental issues,  and for involving local communities in the definition
         of environmental policies and program priorities.

 II.     Rationale;  Colorado is facing increasingly complex environmental  health
         problems and policy issues.   Solutions are rarely simple, and must
         typically cut across lines of governmental responsibility.  Unfortunat-
         ely, the development of intergovernmental mechanisms has not kept  pace
         with the growing complexity and inter-re!atedness of environmental
         issues.  There is  a profound need to better define the roles  and respon-
         sibilities of each unit and level of government involved in or affected
         by environmental decision-making, and to  assure adequate channels  to
         effectively manage intergovernmental environmental  issues. Too often,
         needless intergovernmental conflict occurs because of simple  problems
         with communications.  Broad environmental issues,  specific technical
         problems, legal  procedures,  operating activities,  economic concerns, and
         political relationships all  are points around which intergovernmental
         conflict can occur, and which need an improved mechanism for  inter-
         governmental conrnunications, coordination and management of environ-
         mental issues.

III.     Approach;  During  FY 1980-81, a pilot intergovernmental  communications,
         coordination and issues management process will be developed.  This
         pilot process will focus on the Colorado  Springs Area.

         The Colorado Springs Area has been selected because of  a number of
         favorable factors.  It is an important urban area and yet has only a few
         local governments, the most significant being the City  of Colorado
         Springs and El Paso County.   It presents  the full  array of environmental
         health problems and opportunities found in Colorado,  from air pollution
         to hazardous wastes.  The City of Colorado Springs has  already organized
         an internal environmental planning and issues management process of
         considerable sophistication, and is thus  in a good position to begin
         cooperative work with the State and federal agencies.  The City is some-
         what unique in that it is the provider of all  utility services to  the
         area, including water supply, sewerage, and electricity, thus providing
         a central focal  point for many water quality and air quality  issues.
         The El Paso County Health Department has  one of the more sophisticated
        ' local environmental health programs in Colorado, and is  already affil-
         iated with the CDH.  The Pikes Peak Area  Council of Governments, which
         serves the Colorado Springs  Area, has a comprehensive work program and
         long experience in the areas of water quality and air quality planning,
         as well as assisting in general  intergovernmental  coordination.  And,
         most importantly,  the key governmental entities in the  Colorado Springs
         area are enthusiastic about participating in the effort  to develop a
         mechanism to improve intergovernmental coordination,  communications,  and
         issues management.

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                                      -51-

                                                                                 r
        The focus for efforts during  FY  1980-81  will  be:   1)  to identify and
        develop a mutual  sensitivity  to  general  environmental  health  concerns  of
        the Colorado Springs Area,  local  governments,  CDH,  and the  EPA;  2)  to
        develop a prototype mechanisms for intergovernmental  environmental
        policy coordination and  issues management  in  the  Colorado Springs Area;
        and 3) to define  mutual  objectives and  issues  to  be initially addressed
        in this prototype process.

        The initial  step  will  be to establish an Intergovernmental  Environmental
        Coordination Working Group.  The Working Group will consist of FNE
        members:   a  representative  of the Mayor  and City  Manager of the City of
        Colorado Springs; a representative of the  El  Paso County Board of County
        Commissioners;  a  senior  staff representative  of the Pikes Peak Area
        Council of Governments;  a senior staff  representative of the  Office of
        Health Protection and Environmental  Programs  of the CDH; Colorado
        Department of Health;  and. the EPA-Region VIII  Colorado Coordinator.  The
        Working Group will  be chaired by the City  of  Colorado Springs, and  will
        meet at least once a month  during FY 1980-81.  The purpose  of the
        Working Group will  be to establish,  main-  tain and assess the
        intergovernmental policy coordination and  issues  management process.   To
        do this,  the Working Group  members will  need  to have  a comprehensive
        knowledge of all  environmental programs  and activi- ties in their
        respective agencies, and an understanding  of  key  inter- governmental
        environmental, issues.  To assist in the  management and resolution of
        these issues, part of the Working Groups'  responsibilities  may include
        the preparation of joint "issue  papers"  which  examine issues  of mutual
        concern and  identify and assess  the respective perceptions  and positions
        of each institutional  level taking part  in this process.

        While the Working Group  will  provide day-to-day coordination  and manage-
        ment of this prototype intergovernmental issues management  process,  it
        will  not necessarily be  expected to  be responsible for directly resolv-
        ing specific issues.  Key policy issues  will  be referred to the Mayor
        and/or City  Manager of Colorado  Springs, the  Executive Director of  the
        CDH,  and the EPA-Region  VIII  Regional Administrator.   These top policy-
        makers and managers will meet together  as  needed  to exchange  views  and
        resolve major issues.  Appropriate technical  or legal  staff from each  of
        the participating institutional  levels will also  be brought into the
        process of jointly addressing specific  technical  or legal issues of
        intergovernmental concern.  The  specific mechanisms for involving the
        policy-makers and technical and  legal staff will  be developed during FY
        1980-81.

IV.     Key Activities;   Tasks to be  undertaken  during FY 1980-81 will  include:

        (a.)  Formation of the Intergovernmental  Environmental  Coordination
             Working Group.

        (b.)  Identification of general environmental  policy issues  of concern  to
             each participant in the  process, including points of common
             interest and actual or potential conflict.

        (c.)  Definition of objectives and issues to be addressed during
             FY 1980-81.  .

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                                      -52-
        (d.) Development of a specific prototype environmental policy
             coordination and issues management process for the Colorado Springs
             Area.
        (e.) Assessment of the progress and success in establishing an
             intergovernmental policy coordination and issues management process.
 V.     Responsibilities;  The responsibility for addressing the management
        objective will be shared jointly by the COM, EPA-Region VIII,  and the
        City of Colorado Springs.  The City of Colorado Springs will be respons-
        ible for chairing the Intergovernmental Environmental Coordination
        Working Group.  Members of this Working Group will  be a representative
        of the Mayor and City Manager of the City of Colorado Springs, a senior
        staff member of the Office of Health Protection and Environmental
        Programs of the CDH, and the EPA-Region VIII Colorado Coordinator.
VI.     Resources:  The following resources, as a minimum,  will be committed to
        meeting this management objective:
           Government or Agency
        City of Colorado Springs
           Assistant City Manager for Intergovernmental
             Relations
           Other
        El  Paso County
        Pikes Peak Area Council  of Governments
        Colorado Department of Health
           Office of Health Protection & Environ-
             mental Programs
           Other
FJJE


0.15
0.20
0.35

0.15


0.10
0.15
0.25
        EPA-Region VIII
           Colorado Coordinator
           Other
0.10
0.10
0.20
                                 TOTAL
TU5TJ  FTE

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                                       -53-
VII.
Specific funding is not identified for this project, since it is primar-
ily a coordinative and management activity.  Specific technical  or legal
staff resources devoted to this project will be covered by the related
work plan budget elements.

Anticipated Progress and Milestones;
         .  Working Group established.
                                                         October 1980
         .   Definition of objectives and issues to
            be addressed during FY 1980-81.
                                                         November 1980
            Development of prototype intergovernmental
            policy coordination and issues management
            process.
            Definition of joint work program for
            remainder of FY 1980-81.
         .   Initial  assessment of prototype
            intergovernmental  process.
                                                         January 1981



                                                         January 1981



                                                         July 1981
.   Definition of joint work plan for
   continuation of prototype intergovern-
   mental process in FY 1981-82.
                                                                  September 1981

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                                       -54-


                        Key Management Objective Number 8
                  CUMULATIVE ENVIRONMENTAL ASSESSMENT OF ENERGY
                  •  . •••••V:  DEVELOPMENT IN COLORADO


  I.     Key Management Objective;   Begin  a continuing comprehensive assessment
         of the aggreggate and  cumulative  environmental  effects and implications
         of energy development  in Colorado.

 II.     Rationale;   Colorado is experiencing accelerating,  large-scale develop-
         ment of energy resources and facilities,  especially in the northwestern
         corner of the state.   Coal, oil,  gas,  oil  shale,  and uranium resources
         are abundant, and either are already being actively exploited or are on
         the threshold of large-scale development.

         The large-scale of energy development in  Colorado requires the Colorado
         Department  of Health and the EPA-Region VIII  to develop the capabilities
         to identify and assess the cumulative environmental effects of many
         individual  energy projects and facilities. While the environmental
         effects of  any single  activity by itself  can  be assessed with relatively
         good accuracy,  no effective means  is available at this time to assess
         the cumulative and aggregate environmental effects  of a number of major
         projects which are relatively adjacent to each other.  This is a serious
         deficiency, since a large portion  of both current and proposed energy
         projects in Colorado are located within relatively  limited areas, re-
         sulting in  significant environmental interactions and aggregate effects.

         A dramatic  example of  this characteristic of  proximity is the concentra-
         tion of virtually all  of Colorado's oil shale deposits in only two
         adjacent counties, which overlap with the three adjacent counties com-
         prising Colorado's principal coal  resources area.   Within this same
         four-county area (Garfield, Moffat, Rio Blanco,  and Routt Counties) are
         a major oil and gas field, and five major coal-fired power stations.
         This area falls entirely into the  Colorado River  drainage and the Yampa
         and White Rivers sub-basins, a fact with  significant air quality and
         water quality implications.  Also  within  this area  are located three
         sensitive environmental areas:  a  major national  monument and two
         national forest wilderness areas.   Similar, though  less dramatic, energy
         concentrations exist elsewhere in  Colorado.

III.     Approach;  The focus of efforts during FY 1980-81 will be 1)  to develop
         a substantial awareness of the issue of cumulative  and aggregate envi-
         ronmental impacts of large-scale  energy development; 2)   to identify
         cumulative  assessment  needs with respect  to air quality, water quality,
         and other environmental issues; and 3) to begin to  develop the necessary
         analytical  techniques  to conduct useful assessments of cumulative and
         aggregate environmental impacts associated with energy projects.

         The initial step will  be to establish an  Interagency Energy Impact
         Assessment  Working Group,  consisting of key staff of the Colorado
         Department  of Health and EPA-Region VIII,  and also  with representation
         from other  key State and federal  agencies such as the Colorado Depart-
         ment of Natural Resources, the U.S. Department of Energy, and the U.S.
         Department  of the Interior.  The Working  Group will be chaired by the
         CDH.  The purpose of the Working Group will be to identify major energy
         projects and issues of significant environmental  concern, to define
         assessment  questions and research  needs,  and  to marshal! the limited
         resources available during FY 80-81 among  the participating agencies, to

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                                      -55-


        address in an integrated and unified way the key environmental  impact
        issues associated with energy developments.   The Working Group  will  also
        be expected to develop an on-going environmental  assessment program  for
        energy development activities in Colorado,  and secure commitments of
        resources necessary to support this on-going assessment program.

        Particular attention will be given to the following areas during  1980-81:

        (A.)  Cumulative air quality and water quality impacts of energy develop-
             ments in the Garfield-Moffat-Rio Blanco-Routt Counties area.

        (B.)  Cumulative effects of uranium mining and milling activities  on
             water quality in the Arkansas River Basin,  with emphasis on  levels
             of radioactive elements in the Arkansas River.

        (C.)  Definition of a continuing program of  environmental assessment
             activities for 1981-82 and subsequent  years, including identifying
             and securing commitments for necessary staff and monetary  resources.

IV.     Key Activities;  Tasks to be undertaken during FY 1980-81 will  include:

        (A.)  Formation of the Interagency Energy Impact Assessment Working
             Group, and definition of the specific  charter, responsibilities,
             and objectives of the Working Group.

        (B.)  Definition of a "consensus" level, or  alternative levels,  of likely
             energy development in Colorado, to assure that further work  is
             based upon common assumption.

        (C.)  Definition of the information, data, and research needs which must
             be addressed to help the CDH and EPA-Region VIII make key  regula-
             tory and policy decisions.

             (i.) Identify those questions for which answers already exist,
                  albeit in forms which may require further analysis.

             (2.) Identify those questions for which answers are lacking, and
                  define a time-frame for developing these answers and  related
                  data.

             (3.) Development of a mechanism for gathering or developing  needed
                  information and data, developing  necessary analytical tools,
                  conducting necessary analyses and assessments, and updating
                  existing information.

             (4.) Preparation of a specific interagency work plan and budget for
                  energy impact assessment activities during FY 1981-82.

 V.     Responsibilities;  The responsibility for addressing this management
        objectives will be shared jointly by the CDH and the EPA-Region VIII.
        The CDH will be responsible for chairing the Interagency Energy Impact
        Assessment Working Group.  Commitments for  active staff participation in
        the Working Group will be sought from the Colorado Department of  Natural
        Resources, the U.S. Department of Energy, and the U.S. Department of the
        Interior.  Responsibility for this management objective is assigned  to
        the Office of Health Protection and Environmental Programs at the CDH,
        and to the Energy Policy Coordination Office at EPA-Region-VIII.

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                                       -56-
 VI.     Resources;  The following resources, as a minimum, will be committed to
         meeting this management objective:
            Government or Agency                              FTE
         Colorado Department of Health
            Office of Health Protection &
              Environmental Programs                          .30
            Air Pollution Control  Division                    .25
            Water Quality Control  Division                    .25
            Radiation & Hazardous  Wastes Control
              Division                                        .20
                                       . -                      1.0
         EPA-Region VIII
            Energy Policy Coordination Office                 .30
                                                           *
            Air & Hazardous Materials Division                .30
            Water Division                                    .20
            Surveillance & Analysis Division                  .20
                                                              1.0

                                       TOTAL        "          2~HT FTE
   Specific funding cannot be identified at this time,  although a specific budget
   and work plan will be developed during 1980-81 for  activities during 1981-82
   and subsequent years.
VII.     Anticipated Progress and  Milestones:

         .  CDH and EPA establish  Working Group,
            secure committed participation by Colo.
            DNR, U.S. DOE, and DOI, and other key
            organizations.                             November 1980
         .  Identify and summarize energy-related
            environmental research activities.         December 1980
         .  Define levels of anticipated energy
            development in Colorado.                   January 1981

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                                        -57-


          .  Define initial set of questions and data
             and research needs.                        March 1981


          .  Commence assessment of energy-related
             environmental impacts in northwestern
             Colorado.                                  April 1981


          .  Commence assessment of radioactivity
             in the Arkansas River                      April 1981
         f

          .  Develop commitments for funding and
             support of cumulative energy impact
             assessment activities.                     June 1981


          .  Develop"work plan for FY 1981-82.           July 1981

VIII.     Comments;  While considerable concern has been voiced during the past
          several years about the environmental consequences of rapid and large-
          scale energy development in Colorado, little concrete action has been
          taken to identify and assess those consequences,  or to define possible
          means of mitigating them.  At the federal level,  all  acknowledge the
          seriousness of the issue, but have yet to develop any concerted approach
          to addressing energy-related environmental issues.  At the State and
          local level, attention has tended to  focus more on the economic and
          social implications of large-scale energy development rather than on
          environmental effects and control requirements.  The clear need exists
          to develop an integrated and cohesive mechanism to address energy-relat-
          ed environmental issues, and to secure the continuing commitment of
          resources to this effort.

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                                       -58-
                        Key Management Objective Number 9
                          ENVIRONMENTAL DATA MANAGEMENT
  I.      Key Management Objective;   Initiate a comprehensive review and assess-
         ment of the environmental  data collection,  processing,  and management
         system of the CDH to determine actual  data  needs  and how an useful,
         efficient, and manageable  environmental  data system should be establish-
         ed within the Department of Health.

 II.      Rationale;  The CDH collects a wide array and large volume of environ-
         mental  data. Data collection,  processing, analysis, and management
         activities constitute a significant portion of the work programs  of  the
         Health Department's environmental  divisions,  and  absorb a large share of
         the staff and monetary resources  devoted to these divisions.   Growing
         concern is being directed  to the  Health  Department's environmental data
         activities by technical  staff, program managers,  members of policy
         commissions, and other key decision and  policy-makers.

         Questions are increasingly being  asked about the  data system.  Why are
         we collecting the data that we are?  Are these data right for our
         needs?  What are the purposes  of  the data that are being collected?
         Would other data better serve  these purposes?  Are these proposes appro-
         priate or useful?  Are the data being collected of real use to State and
         federal environmental decision-making?  Can the various types of  data
         being collected be consolidated,  so that fewer types of data are  neces-
         sary?  Is the level of resources  committed  to data activities appro-
         priate in light of other needs and the-value of these data?  In short,
         is the overall environmental data system effective and efficient  in
         meeting environmental data needs,  or are significant improvements
         necessary?

         Answers to these questions are not readily  available at this  time.
         Lacking positive answers,  however, it should not  be assumed that-the
         ultimate answers will indicate that major changes or improvements are
         necessary.  Nor should it  be confidently assumed  that the environmental
         data system is as efficient as it  should be.

         The growing concerns about the Department of Health's environmental  data
         system, and the lack of clear  assurance  about its efficiency and  util-
         ity, requires that the overall environmental  data collection, processing
         and management system be thoroughly assessed to determine whether it is
         adequately meeting the array of environmental data needs of the State's
         environmental regulatory and planning program, including the need for
         economic efficiency.

III.      Approach;  The focus of data system assessment efforts during FY  1980-
         81 will be:  1) to identify and specify  the concerns and issues of
         environmental data collectors, processors,  managers, analysts, and users
         with respect to the overall operations of the Department of Health's
         environmental data systems; 2) to identify  and define the specific needs
         for and uses of data by the Department of Health's environmental  pro-
         grams; and 3) to begin an  assessment of  the overall performance of the
         environment data system in meeting varied data needs in an efficient and
         effective way.

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                                      -59-


        The initial step will be to establish an Environmental  Data System
        Assessment Working Group from among key staff of the Colorado Department
        of Health, and with participation by staff of EPA-Region VIII.  The
        purpose of the Working Group will be to address general and specific
        concerns with the functioning of the Health Department's environmental
        data system.

        The Working Group will be chaired by the Office of Health Protection and
        Environmental Programs, and will include representation from the Air
        Pollution Control, Water Quality Control, Radiation and Hazardous Wastes
        Control, and Disease Control and Epidemiology Divisions, as well as the
        Data Processing Section and Laboratory Division.  Also  included will be
        representation from the Colorado Air Quality Control Commission and
        Colorado Water Quality Control  Commission, to the extent they wish to
        participate.   EPA participation on the Working Group will be coordinated
        by the Data Analysis Branch of  the EPA-Region VIII Surveillance and
        Analysis Division.

IV.     Key Activities:  Tasks to be undertaken during FY 1980-81 will include:

        (a.) Formation of the Environmental Data System Assessment Working Group.

        (b.) Definition of criteria for an efficient and effective environmental
             data system; and

        (c.) Definition of specific problems, issues, and concerns with the
             Department of Health's environmental data system.

        (d.) Begin assessment of the overall  performance of the environmental
             data system.

 V.     Responsibilities;  The Office of Health Protection and  Environmental
        Programs will have the principal responsibility for addressing this
        management objective, and will  chair the Environmental  Data System
        Assessment Working Group.  EPA-Region VIII participation in the Working
        Group will be coordinated by the Data Analysis Branch of the Surveill-
        ance and Analysis Division.

VI.     Resources;  The following resources,  as a minimum, will be committed to
        meeting this management objective during FY 1980-81:

           AGENCY                                            FTE

        Colorado Department of Health

           Office of  Health Protection  &
             Environmental Programs                         .05

           Air Pollution Control Division                   .15

           Water Quality Control Division            , --   .15

           Radiation & Hazardous Wastes Control
             Division                                       .15

           Disease Control & Epidemiology
             Control  Division                               .05

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                                      -60-
            Data Processing Section
            Laboratory Division

         EPA-Region VIII
            Data Analysis  Branch
            Air & Hazardous Materials Division
            Other
      .10
      .05
      .70

      .10
      .30
      .20
      .60
                                       TOTAL
      O~FTE
   Funding for this activity will  be covered by the data-related work plan
   activities specified for each of the major program areas in the 1980-81
   State/EPA Agreement.  No specific funding will  be identified for this activity
   during FY 1980-81.
VII.     Anticipated Progress and Milestones:
            Establishment of Working Group.
            Definition of specific environmental
            data needs and uses.
            Initial  definition of criteria for an
             efficient environmental  data system.
            Commence assessment of CDH environmental
            data system.
            Develop work plan for continuing
            environmental data system assessment
            activities during FY 1981-82. '
October 1980

January 1981

February 1981

April 1981

July 1981

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                                       -61-


                        Key Management Objective Number 10
                       •            PESTICIDES


  I.      Key Management Objective;   Maintain an ongoing Federal  pesticide.program
         in Colorado responsive to  the needs of the people in the State,  as
         circumstances dictate and  resources permit.

 II.      Rationale:   In June,  1980  the Colorado State Legislature directed the
         Colorado State University  Cooperative Extension Service to  no longer
         cooperate with EPA in providing  training for pesticide  applicator certi-
         fication.  This action will  require EPA to continue to  administer the
         pesticide certification and enforcement program in Colorado during  FY
         1981.   In addition to monitoring available training causes, as in the
         past,  the Regional Office  is developing a self-study training program
         which  will  be available to private applicators for certification in FY
         1981.

III.      Approach;  During FY  1981  EPA will provide self-study manuals, etc.,  for
         approximately 11,000  private applicators whose initial  certification
         expires. A continuing small number of private applicators  will  need
         initial  certification.  In addition,  training and certification, which
         includes monthly testing of commercial applicators, will absorb much of
         the Region's pesticides resources.

         The Regional Office will continue to  increase its enforcement activities
         in the State by more  pesticide use investigations.  Field offices estab-
         lished in Grand Junction and Fort Collins will provide  a closer relation
         with the agricultural community as well as quicker response time to
         investigate pesticide problems.   Another office is under consideration
         for Pueblo  while the  establishment of a summer office in the San Luis
         Valley is being contemplated.  Special emphasis will be given to re-
         certification of private applicators  and the strengthening  of the
         pesticides  enforcement program.

 IV.      Key Activities;

         (a.) Administer Federal certification and training program  in Colorado.
             Regional Office  will  provide services and perform  duties in lieu of
             state  agencies.

         (b.) Investigate complaints of herbicide drift damage throughout the
             State.  Concentrated  efforts will be focused in the San Luis and
             Arkansas Valleys, as  well  as Logan, Morgan,  and Weld Counties.

         (c.) Investigate possible  pesticide misuse and accidents within the
             State.

         (d.) Enforce violations of the amended FIFRA.

         (e.) Monitor Section  18 exemptions, 24(c) registrations and experimental
             use permits.

         (f.) The Colorado DOA and  EPA will continue to work towards establishing
             a cooperative work agreement to  more effectively implement the
             pesticides program in Colorado.

-------
                                       -62-
  V.     Responsibilities:  The Toxic Substances Branch,  Air and Hazardous
         Materials Division, and the General  Enforcement Branch, Enforcement
         Division of EPA-Region VIII will  have the responsibility for administer-
         ing the Federal Pesticide Program in Colorado.
 VI.     Resources;  The following personnel  resources will be devoted to this
         program:
              Certification            5.0
              Enforcement              8.5
VII.     Anticipated Progress and Milestones:
         See Environmental  Work Plans.

-------
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        APPENDIX A
      EPA ACTIVITIES
WITHOUT STATE PARTICIPATION

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               Tentative  Schedule  for Development  of  FY  1982
                            State/EPA Agreement
Review of FY 1981 Agreement to help establish
 direction for FY 1982.-
Develop list of consolidate FY 1982 Key
 Management Objectives.
Define detailed schedule for development
 of FY 1982 Agreement.
EPA sends out FY 1982 guidance.
Develop initial draft list of FY 1982 Key
 Management Objectives.
EPA provides State with Initial estimate of
 FY 1982  funding levels for each grant program.
First draft of FY 1982 work plans prepared.
FY 1982 Key Management Objectives finalized.
November 1980

December 1980

January 1981
February 1981

March 1981

April 1981
May 1981
May 1981
     ;j.G. Environmental Protection
     Lthroov. «oom 240*  FM-211-A
     401 M Street, S.W.
     Washington.. DC   20460

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