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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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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(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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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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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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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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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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(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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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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(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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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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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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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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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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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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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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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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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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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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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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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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(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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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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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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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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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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. 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.
-------
-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.
-------
-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
-------
-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
-------
-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.
-------
-63-
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APPENDIX A
EPA ACTIVITIES
WITHOUT STATE PARTICIPATION
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Arkansas Valley
San Luis Valley
Weld, Morgan, Loga
All complaints
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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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