EVALUATION  OF
   THE  COLORADO  WATER
       SUPPLY  PROGRAM
ENVIRONMENTAL  PROTECTION AGENCY  REGION VIII  DENVER. COLORADO

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         EVALUATION
           OF THE
COLORADO WATER SUPPLY PROGRAM
     WATER SUPPLY SECTION
   CONTROL TECHNOLOGY  BRANCH
        WATER DIVISION
ENVIRONMENTAL PROTECTION AGENCY
          REGION VIII

         NOVEMBER, 1974

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                       TABLE OF CONTENTS

                                                           Page

SUMMARY	1

RECOMMENDATIONS	12

INTRODUCTION 	  19

PLAN OF STUDY	21

  Purposes of Evaluation 	  21
  Definitions	21
  Evaluation Criteria	22

STUDY FINDINGS	25

  Water Supplies in Colorado	25
  Community Water Supplies  	  25
       Bacteriological  Quality 	  27
       Chemical Quality	29
       Facilities Appraisal	29
       Fluoridation	31
  Small Public Water Supplies	34
  Individual Water Supplies	35
  Water Supply Program	35
       Legal Authority	36
       Regulations	38
       Organization	39
       Responsibilities	41
       Policy	43
       Budget and Staffing	44
       Engineering and Surveillance of Public Water
       Supplies	48
       Training	52
       Local Health Departments	53
       Laboratory Support -  Bacteriological	56
       Laboratory Support -  Chemical  	  57
       Other Agencies	58
       Data Management .	-.  .  61
       Public Health Risk	61

PROGRAM NEEDS	66

  Legal Authority	66
  Regulations	68
  Policy	71
  Surveillance of Public Water Supplies	71
  Staffing Requirements for  Engineering Surveillance ...  74
  Budget Requirements for Engineering Surveillance ....  78
  Organization 	  79
  Laboratory Support-Bacteriological  	  80
  Laboratory Support-Chemical	83

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                       TABLE OF CONTENTS
                                                        Page
      Data Management	    84
      Summary of Water Supply Program Costs	    84
REFERENCES CITED 	    87
ACKNOWLEDGEMENTS 	    88
APPENDICIES
     Appendix A - 1962 U.S.P.H.S.  Drinking Water
                  Standards	    89
     Appendix B - Summary - Community Water Supplies
                  in Colorado	    93
     Appendix C - Community Water Supplies Failing
                  Bacteriological  Standards in 1972. .    96
     Appendix D - Colorado Water Supply Legislation. .    97
     Appendix E - Colorado Water Supply Regulations. .   108
     Appendix F - Colorado Water Supply Policy ....   112
     Appendix G - Budget and Manpower Comparisons.  . .   122
     Appendix H - Bacteriological Laboratory Survey. .   123
     Appendix I - Incidence of Waterborne Diseases  . .   142
     Appendix J - Estimated Resources - Chemical
                  Laboratory Support	143

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                          LIST OF FIGURES

Figure                                                          Page
  1      Colorado Department of Health	    40
  2      Districts of the Public Health Engineers 	    42
  3      Budget Comparisons of Environmental  Programs 	    46
  4      Staffing Comparisons Between Environmental  Programs  .    47
  5      Counties Served by Organized Local  Health Departments.    54

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                          LIST OF TABLES

Table                                                          Page
  1     Water Supplies in Colorado	    26
  2     Community Water Supplies Failing Bacteriological
        Standards in 1972	    28
  3     Community Water Supplies Not Meeting Drinking Water
        Standards for Chemical Quality	    30
  4     Facilities Appraisal of Community Water Supplies.  .  .    32
  5     Colorado Department of Health Guidelines for the
        Surveillance of Public Water Supplies 	    45
  6     Bacteriological Testing Requirements	    81
  7     Water Supply Program Budgets	    86

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SUMMARY

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                              SUMMARY

     Ninety percent of Colorado's 2.4 million citizens  are served by
an estimated 704 community water supplies.   The remainder obtain  their
drinking water from small  public or individual  systems.   The small
public systems at restaurants, motels, recreational  areas and trailer
parks also serve many of the 8.4 million people who  travel in Colorado
each year.
     In view of the importance of safe and  adequate  quantities of
drinking water, Mr. William N. Gahr, Director of the Engineering  and
Sanitation Division of the Colorado Department of Health, requested
the Environmental Protection Agency to evaluate and  determine the
effectiveness of Colorado's water supply program.
     An extensive review of the records pertaining to public water
supplies maintained by the Colorado Department of Health was conducted.
Since only 394 of the community water supplies (all  those serving over
100 people) were under routine surveillance as of January 1973, the
information presented primarily concerns these systems.   Bacteriological
and chemical qualities of the supplies were judged on the basis of the
1962 U.S. Public Health Service Drinking Water Standards.  In addition,
the adequacy of the water supply program was evaluated in regard  to
its legislative authority, regulations, policies, surveillance activities,
laboratory support, manpower  and budget.

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               Evaluation of Community Water Supplies

Bacteriological Water Quality
     Bacteriological testing is essential  to determine if drinking  water
is safe.  Since the isolation of pathogenic (disease-producing)  organisms
is complex and time-consuming, coliform bacteria are used as  indicators
of the sanitary quality of water.   These bacteria are normal  inhabitants
of the intestines in warm-blooded animals; therefore are present in
their fecal discharges.  The Drinking Water Standards recognizes the
coliform group as a reliable indicator of the bacteriological  quality
of drinking water.   The presence of coliform organisms in drinking  water
suggests either inadequate treatment or contamination of the water
after treatment.   Failure to meet the bacteriological quality  standards
indicates that drinking water is a  potential  carrier of infectious
disease.  This is a serious health  hazard and calls  for immediate
corrective action.
     Of the 394 community water supplies:
     1.  102 (26%)  failed to meet bacteriological quality standards
         for one or more months during 1972.   These  systems were serving
         about 12 percent of the State's population  with potentially
         contaminated water.
     2.  249 (63%)  did not submit the required number of samples for two
         or more  months during 1972.

Chemical Water Quality
     Drinking water should not contain substances which are toxic or
cause adverse health effects in man.  Ma.ny harmful elements do occur

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naturally in the earth; therefore can  be present in  any  water  supply.
The Drinking Water Standards has  established mandatory  chemical  standards
for such substances.   If the mandatory limits are not met,  additional
treatment should be provided or the supply should be rejected.
     1.   33 (8%) of the 394 community  water supplies failed to
         meet at least one of the mandatory limits.   These  systems
         serve about 25,000 people with water that could cause adverse
         health effects.
     Good quality drinking water should not contain  substances  which
adversely affect its appearance,  odor, taste or cause undue discomfort
to man.   The Drinking Water Standards  has set recommended chemical
limits to assure that drinking water contains no substance  in  concen-
trations which would make it undesirable.  When the  recommended
standards can't be met, consideration  should be given to selecting
a more suitable source of water supply.
     1.   78 (20%) of the 394 community water supplies failed to meet
         at least one of the recommended limits.  These systems serve
         approximately 143,000 people  with aesthetically inferior water.
Facilities
     Water supplies include everything needed for the collection, treat-
ment, storage, and distribution of drinking water from  the  source to  the
consumer's tap.  Whether the facilities include an elaborate treatment
plant or just a chlorinator, they must be able to produce adequate
quantities of safe drinking water and prevent contamination from
entering the system at any point.  Any condition, device, or practice

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in the water supply system and its operation,  which  allows water  of
questionable quality to be delivered to the consumer,  constitutes  a
health hazard.
     Of the 394 community water supplies at the  end  of 1972:
     1.  105 (27%}, serving over 187,000 people, had inadequate
         treatment.   The majority of these systems were not even
         providing  disinfection of their water,  resulting in  no
         margin of  safety against disease transmission by water.
     2.  62 (16%),  serving about 285,000 people, had sanitary
         defects within their systems.   The ability  of these
         supplies to produce safe water at all times is  questionable.
     3.  The systems serving less than  1,000 people  have the  most
         deficiencies.   For example, of the 105  supplies having
         inadequate treatment, 84 percent served 100-1,000 people.

Fluoridation
     Many years of  medical and dental  research have  shown fluoridation
to be a safe and beneficial practice.   Approximately 80 percent of
Colorado's population is  served water containing  a dentally signi-
ficant amount of fluoride.  Thirty-five water  supplies adjust the
fluoride content of the water to obtain the recommended opitmum level.
In order for the maximum benefits to be realized, the  fluoridation
equipment must be well  operated and maintained.
     Surveillance of these systems is  the responsibility of the Colorado
Department of Health.  Nevertheless, inadequate  attention is  being
given to the surveillance program as indicated by the  following:

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     1.   Not enough emphasis is  placed on proper operation  and  mainten-
         ance of the fluoridation equipment during the engineering
         inspections.   As a result many communities are not maintaining
         the fluoride  concentration at the level  at which it is most
         beneficial.  Therefore, in many cases the communities  are
         not receiving the benefits that properly managed fluoridation
         can achieve.

     2.   Check samples to determine the fluoride concentration  in the
         water are required only every three months.

     3.   The operators are not required to maintain or submit operating
         records on the amount of chemical used or the fluoride
         concentrations.

     4.   The fluoridation records at the Colorado Department of Health
         are inadequate and not carefully maintained.

                     Small Public Water Supplies
     The Colorado Department of Health estimates that there are 900
water supplies located at small  residential areas, trailer courts,
campgrounds, motels, and recreational areas which serve a major
portion of the 8.4 million people who travel in the state each  year.
Many of these supplies receive little or no surveillance.  During
1972, four waterborne outbreaks were associated with supplies serving
the traveling public in Colorado which illustrates that such systems
can pose significant health problems.

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     Although no field studies were conducted during this evaluation,
studies completed in other states by the Environmental Protection Agency
revealed that the small public systems are, in most cases, in worse
condition than the community supplies and have the most difficulty
meeting the quality standards.

               Evaluation of the Water Supply Program

     Drinking water quality and the conditions of water supply facilities
are related directly to the adequacy of the water supply program at
the State level.  To determine if Colorado's water supply program was
capable of fulfilling its legal responsibilities and meeting the
problems, an evaluation was conducted of the program.

Legal  Authority, Regulations and Policy
     The Colorado Statutes place various legal responsibilities regarding
public water supplies within the Colorado Department of Health (hereafter
the Department).  These statutes give the Department authority to adopt
and enforce drinking water standards, regulations including mandatory
disinfection, as well as a uniform plumbing code.  In  addition, the
statutes require water and wastewater plants to be under the supervision
of a certified operator.  Water well drillers  and pump installers must
also be certified.   Based on this authority, the Department has adopted
a thorough set of regulations and a policy statement to assure the
uniform application of the regulations.   Nevertheless, the water supply
program lacks authority in two major areas.

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     First, the water supply program does not have the authority to
require public water supplies to obtain approval  before construction
of new or modification of existing facilities.   Construction of water
supply facilities represents a major expenditure on the part of
municipalities.  If inadequate attention is given to the source water
or to the type of treatment, costly errors can result which also can
cause public health problems.  For example, all  four waterborne outbreaks
which occurred in Colorado during 1972 were due to inadequate treatment
of surface sources.  Many poorly designed small  water supply systems
are operating in Colorado as pointed out by the study findings.  A
good review and approval program can prevent many of these problems
from occurring.
     Secondly, the water supply program does not have the authority  to
administer a construction grant program for community water supplies.
The largest percentage of the communities with deficiencies in their
water supply systems have less than 1,000 people.  Many need additional
treatment facilities or new water sources so they can serve safe
drinking water.  Unfortunately, most of these small communities have
serious financial problems and can't  afford major capital improvements.
Presently, there are practically no reliable sources of funding for
such cases.  Although Colorado has a construction grant program for
sewage disposal facilities,  there is not a similar program for community
water supplies.  Such a program would help make  it possible for small
communities to have safe drinking water.

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Organization
     The water supply program is administered by the Engineering
Section under the Department's Engineering and Sanitation Division.
The Section is also responsible for the solid wastes, plumbing
inspection,swimming area regulation and individual sewage disposal
systems regulation programs.
     The Section's staff consists of ten public health engineers and
three secretaries.  Staff-time is divided between the various programs
reducing the effort in any one area.  During 1972 only 40 percent of
the total staff time was devoted to water supply activities.  The
engineers operate from Denver and have extensive districts to cover.

Budget and Staffing
     The funds and manpower available for drinking water protection in
Colorado are inadequate to support an effective program.  A total
of only $59,800 was allocated for the water supply activities of the
Engineering Section during fiscal year 1974.  This represents only
about 2.5 cents per capita for the engineering surveillance of public
water supplies which is less than one-half the national  average.  In
fact, the budget and the man-years available for water supply activities
are at the same level as they were in 1967 even though the number of
water supplies requiring surveillance has tripled,
     These limitations have prevented the water supply program from
fulfilling Us responsibilities.   As a result, important water supply
activities can't be performed or are being performed only in a cursory
manner reducing the program's effectiveness.

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Surveillance of Public Water Supplies
     The surveillance of water systems is one of the most important
duties of state and local health officials.   It demands constant
vigilance over water quality, water system facilities and operational
practices.  The bacteriological  and chemical  quality of drinking water
must be routinely monitored to detect possible contamination.   To
prevent serious health hazards from developing in a water supply, the
physical facilities and operational procedures must be reviewed regularly
by personnel trained in proper water supply practice.
     Although Departmental regulations and policy provide for a strong
surveillance program, the budget and staffing limitations have never
allowed it to be fully implemented.  Very few of the small community
supplies (serving 40-100 people) and the other small public supplies
(mainly supplies at motels, campgrounds, trailer parks and recreational
areas) are under routine surveillance.  Written reports on community
water supplies are completed only every five years.  Follow-up work to
check compliance with previous recommendations or unsafe bacteriological
and chemical results is inadequate.  Stronger enforcement of the regu-
lations is needed since as of January 1973, 27 percent of 394 community
water supplies still had  inadequate  treatment.  The limitation of
resources has also affected the water supply program's ability to
perform other important activities such  as operator training and
technical assistance.
     The  bacteriological  and chemical laboratory support functions
also need upgrading.  The bacteriological laboratories of the local

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health departments seem to be particularly overburdened.   The
Department's chemical laboratory is understaffed and operating in
very cramped quarters reducing its total capability.  As  the number
of water supplies under surveillance increases, these conditions will
continue to worsen.
     A false sense of security might well exist concerning the safety
of water supplies in Colorado.  Colorado's water supply program is not
meeting its responsibility of protecting the quality of water served
to the State's residents and visitors.   This situation is  a direct result
of the lack of resources allocated to water supply activities.   The time
has come to reverse this trend.  Waterborne disease outbreaks have
occurred in Colorado and in all the cases, it was shown that deficiencies
existed in the water supply systems during the time when  the disease
was transmitted.  Furthermore, these deficiencies either  were unrecognized
because of inadequate surveillance for public health hazards, or were
recognized but not remedied due to complacent water supply personnel
and ineffective enforcement by health officials.  Deficiencies  similar
to those responsible for the outbreaks are present in the  water supplies
of Colorado as indicated by this study.  The requisites for repetition
of the tragic waterborne outbreaks of the past, namely inadequate
surveillance of water supplies serving the public, and the presence of
diseased individuals, definitely exist in Colorado.   An increase in the
occurrence of waterborne disease obviously would cause needless human
suffering and might result in a sharp reduction in the $600 million which
tourism brings into the State each year.  In other words,  Colorado no
longer can afford to overlook the importance of the water  supply program

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and shirk its responsibilities to protect the public health  of  its
citizens.  The recommendations of this  report need to be implemented
if Colorado is to assure each resident  and visitor an adequate  and
safe supply of drinking water.

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RECOMMENDATIONS

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                             RECOMMENDATIONS
     A primary purpose of the evaluation  was  to  propose  recommendations
needed for Colorado to have an  effective  and  responsive  water  supply
program.
     1.  The water supply program must increase  and improve  its
         surveillance of public water supplies.   It is  recommended
         that the following critical  activities  be given a high
         priority:
              a.  On-site inspections (with written reports)of community
                  water supplies at least annually.
              b.  Follow-up inspections to check compliance  with
                  recommendations,
              c.  Frequent comprehensive reviews of bacteriological  and
                  chemical sampling records with prompt follow-up on  those
                  failing to meet sampling and quality  standards.
              d.  Maintenance of an up-to-date inventory of  public water
                  supplies.
              e.  Detailed plan review of proposed water system construction
                  and modification.
     2.  The fluoridation surveillance effort must be improved if the
         potential benefits of this program are to be realized.   Therefore,
         it is  recommended that:
              a.  Information should be gathered on the fluoridation equip-
                  ment and chemical compound used at each water supply.
                  This would be helpful in follow-up of reported problems.

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         b.  The number of check samples sent to the State Laboratory
             should be increased to at least one per month for every
             water system adjusting fluoride content.
         c.  The check sample records should be kept by the Engineering
             Section rather than the Dental Health Section.
         d.  More frequent review of fluoride check sample results
             and better communication between the State Dental Director's
             office and the Engineering Section is needed to ensure
             more efficient field follow-up in problem areas.
         e.  The Engineering Section should develop for the water operators
             standard forms for recording:
                  1.  Daily fluoride sample results.
                  2.  Amount of fluoride compound used, total  water
                      produced and other operational  information.

3.  Cooperative compliance with the regulations should continue to
    be emphasized.   However, if this fails  to achieve prompt
    compliance, strong enforcement measures should be taken to
    protect drinking water and public health.
4.  Legislation is  needed to give the Department of Health the
    authority to:
         a.  Require that a permit be obtained (from the water supply
             program) by a public water supply before construction of
             new or modification of existing water supply facilities
             could  begin.

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         b.   Issue regulations  concerning  the  requirements which
             must be met in  order to obtain  a  permit,  including prior
             approval of proposed sources  and  treatment.
         c.   Issue criteria  for the design,  construction  and  operation
             of water supply facilities.
         d.   Administer a construction grant (or combination  grant
             and low-interest loan) program  for those  community water
             supplies not able  to finance  the  improvements necessary
             to bring their  systems into compliance with  the  State's
             requirements.
5.  To implement the recommended expanded  authority described above
    the following regulations should be developed.   In the absence
    of legislation these could  still be issued as guidelines.
         a.   Requirements for obtaining a  permit to construct or
             modify water supply facilities.  These should require:
                  1.  Submission of preliminary engineering  reports,
                      plans  and specifications for review and approval.
                      These  should be prepared by a professional
                      engineer registered  in Colorado.
                  2.  Approval  of proposed water sources
                  3.  Compliance with the  program's criteria for
                      minimum acceptable  treatment.
                  4.  Compliance with the  program's criteria for
                      design and construction of water supply facilities,
                  5.  Regional  planning to discourage  the proliferation
                      of small, inefficient water systems.   Proposed
                      systems should be stimulated to explore the

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             possibilities  of consolidating with  other  systems
             before approval  is  given.
b.  Definition of minimum acceptable treatment for source
    waters.  Filtration of surface sources should be required.
c.  Minimum requirements for water treatment  and  distribution
    systems should be developed.  These should be flexible
    enough to allow the design engineers to make  full  use of
    available water treatment technology; but should insure
    continued production of a safe water supply.
d.  The engineering consultant should be required to provide
    inspection during construction to assure  that all work is
    done in accordance with the State approved plans and
    specifications.  Engineers from the water supply program
    should have access to the project at all  times during
    construction.
e.  All public water supplies should be required  to have a
    satisfactory bacteriological test and engineering  inspec-
    tion before being placed into service after construction
    or modification.
f.  Basic criteria concerning the operation and maintenance
    of water supply systems are needed.  These would outline
    such items as  the type and number of quality  control tests
    which should be conducted for various classes of systems
    and the periodic submission of standard operating  reports
    to the water supply program.  The operating reports can
    provide valuable information such as indicating when

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             systems  are experiencing difficulties.   In this  regard,
             water supplies which fluoridate should  be required to
             submit monthly check samples and monthly operational  reports
         g.  Criteria for the grant program.

6.  The current "Rules and Regulations for Water Well and Pump
    Installation  Contractors" need strengthening in order to achieve
    their stated purpose of protecting public health.  The water
    supply program should recommend changes to the Board of Examiners
    of Water Well and Pump Installation Contractors  as they see fit.
    Specifically, the following changes are recommended:
         a.  A definition of what constitutes an adequate grout
             mixture is needed.
         b.  A minimum grout thickness should be stipulated.
         c.  The present 10-foot minimum grout depth will not provide
             the intended protection where deep frost penetration
             occurs.   To be effective, the grout seal must be in
             contact with undisturbed earth.  Therefore, the regulations
             should require the grout to extend at least ten feet  below
             the frost line.
         d.  Regulations concerning non-ferrous well casing should be
             developed.  In particular, plastic well casing used in
             wells intended for domestic purposes should have National
             Sanitation Foundation (NSF) approval.
         e.  Regulations regarding the proper installation of pitless
             well adaptors and units are needed.

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                           17
 7.  Serious consideration should be given to using automatic
     data processing for storage and retrieval of water quality
     data, engineering report information, inventory data, etc.

 8.  Steps should be taken to achieve closer coordination between
     the water supply program and other governmental functions
     concerned with water supplies including the Department of
     Natural Resources and the local health departments.   Regulations
     of the other State agencies should reflect that the  principal
     authority for regulation of water supplies rests with the  water
     supply program.

 In order to fully implement the above, it is recommended that:

 9.  The annual budget for the water supply program be increased by
     the end of FY 1977 to:
               Engineering Surveillance      $421,200
               Laborabory Support            $267.000
                                   TOTAL     $688,200
10.   A Water Supply Section be formed within the Engineering  and
     Sanitation Division to be responsible for engineering surveillance
     activities for all  public water supplies.
11.   The engineering surveillance staff of the proposed Water Supply
     Section be increased to at least 17 professionals  and 6  secretaries
     by the end of FY 1977.  Annual  budgetary support for this  activity
     should be increased to approximately $421,200 during this  period.

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                            18

12.   Consideration be given to decentralizing the proposed Water Supply
     Section by establishing two offices  in western Colorado and two
     in eastern Colorado.
13.   The bacteriological  quality testing  program be modified by:
          a.  Allowing the community water supplies serving over 10,000
              people (category A) to conduct their own testing and
              submit monthly summaries to the water supply program.
          b.  Having the  Department's Laboratory Division  certify all
              laboratories doing bacteriological tests for public water
              supplies at least every three years.
H.   An evaluation of the local health departments' bacteriological
     laboratories is needed to determine  their requirements for an
     adequate testing program for public  and individual water supplies.

15.   Adequate staff, space and equipment  must be provided  for the
     chemical laboratory  in order to conduct routine drinking water
     analysis.  A total of eight man-years at an approximate cost
     of $172,800 annually would be required for an acceptable program.

16.   Serious consideration should be given to decentralizing the labora-
     tory services.  A laboratory in western Colorado could provide
     a much better surveillance program.

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                           EVALUATION
                             OF THE
                  COLORADO WATER SUPPLY PROGRAM

                          INTRODUCTION

     The American people take drinking water for granted.   They
naturally expect adequate and safe quantities of this essential
resource to be delivered continually to their homes.   The  dreaded
water-borne epidemics, which still threaten some parts of  the
world, no longer are a major concern in the United States  due to
the diligence of the water utilities and public health officials.
Unfortunately, this success has led to a certain complacency con-
cerning drinking water.  In addition, public and legislative emphasis
is being placed on other environmental concerns, such as water and
air pollution.  In order to meet the burgeoning requirements of
pollution control legislation, the states are having  to commit more
and more of their resources to these programs.  Therefore, less time
and money is being devoted to the drinking water activities, signi-
ficantly reducing the surveillance and regulation of  public water
supplies.  Although effective water pollution control is important
to minimize contamination of drinking water sources,  it alone cannot
assure the public will receive safe and reliable drinking  water.  Such
assurance can be gained only from a renewed awareness of the public
health importance of drinking water and the establishment of active
water supply programs at the state level.  The need for this awareness
was highlighted by the Community Water Supply Study]  which found that

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                              20
41 percent of the 969 water systems surveyed were delivering waters of
inferior quality to 2.5 million people, and 56 percent of the systems
had physical deficiencies in their facilities.  The increasing rates
of waterborne diseases is a further indication of the need to re-establish
a strong emphasis on the provision of safe drinking water for all
Americans.
     Recognizing these considerations, Mr. William N. Gahr, Director
of the Engineering and Sanitation Division for the Colorado Department
of Health, requested the U.S. Environmental Protection Agency (EPA) to
evaluate and determine the effectiveness of Colorado's water supply program.

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PLAN OF STUDY

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                              21

                          PLAN OF STUDY

                     Purposes of Evaluation
1.  Determine the general  condition of Colorado's public water supplies.
2.  Determine if the water supply program, as presently authorized and
    administered, is adequate to fulfill its responsibilities.
3.  Propose any recommendations necessary for Colorado to maintain an
    effective water supply program; thus assuring its citizens and
    visitors safe drinking water.
     After discussions with Mr. William N. Gahr, it was decided that
these purposes could be achieved by reviewing the records pertaining
to the public water supplies maintained by the Colorado Department of
Health.
                           Definitions
     For the purposes of this evaluation, drinking water systems were
defined as follows:
     1.  Public water supply system - any system which provides water
         for public consumption, excluding water sold in bottles or
         other closed containers.
         a,  Community water supply system - a public system that
             provides water to ten or more premises not owned or
             controlled by the supplier of water or to forty or more
             resident individuals.

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                             22
         b.  Small public water supply system - a public water supply
             system that:  (a) provides water to less than ten premises
             not controlled by the supplier of water or less than 40
             resident individuals; (b) provides water to any number of
             people on premise owned or controlled by the supplier of
             water; or (c) provides water to the traveling public.
     2.  Individual water supply system - a water supply system that
         serves a single dwelling unit occupied by one family.
                       Evaluation Criteria
Bacteriological Water Quality
     The bacteriological  records for the community water supplies
which routinely submit water samples to laboratories approved by
the Colorado Department of Health were examined.  A supply was given
an unsatisfactory rating if it did not meet, for one or more months,
the bacteriological quality requirements of the 1962 United States
Public Health Service Drinking Water Standards^, hereafter referred
to as the Drinking Water Standards.  These limits are summarized in
Appendix A.
Chemical Water Quality
     The available chemical records for the community water supplies
were reviewed.   The analysis for each supply was compared with the
Drinking Water Standards (Appendix A) and rated as either:
     1.  Meeting the standards for all limits.
     2.  Failing to meet one or more of the "recommended" limits but
         meeting all the "mandatory" limits;
     3.  Failing to meet one or more "mandatory" limits.

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Hater Supply Facilities
     The annual inspection reports for the community water systems
were reviewed.  The supplies were rated according to the adequacy of
treatment provided and existence of sanitary defects.

Water Supply Program
     The water supply program was evaluated on each of the following:
     1.   Surveillance of Community Water Supplies
         The records and procedures relating to bacteriological monitoring,
     chemical monitoring and inspections of water supply facilities were
     reviewed.  These activities were considered adequate if:
         a.  The number of bacteriological samples examined for each
             supply during 1972 met the number specified by the
             Drinking Water Standards for 11 of the 12 months.

         b.  A chemical analysis, including all the constituents listed
             in the Drinking Water Standards, had been performed within
             the previous three years.

         c.  The results of the bacteriological and chemical tests were
             reviewed and any necessary follow-up performed routinely.

         d.  Each supply received an annual inspection, including a
             prepared report, by an engineer from the Colorado Department
             of Health.
         e.  Follow-up surveys of those water supplies with facility and
             operational deficiencies were performed routinely.

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                         24

2-  Legislative Authority
    The existing legislative authority of the water supply program
was reviewed to determine if it has sufficient policy and regulation-
setting power to conduct its activities properly and protect the
public health.

3.  Regulations and Policy
    The water supply program's existing regulations and policy
were reviewed to determine if they were adequate and reflected
sound public health principles.
4,  Laboratory Support
    A survey of the bacteriological and chemical laboratories was
conducted to determine the capability of each laboratory to
provide adequate support to the water supply program.

5.  Program Activities
    Factors such as the level and adequacy of operator training
and certification, emphasis placed on fluoridation and cross-
connection control programs, as well as coordination with and
technical assistance given to other agencies concerned with public
water supplies were also evaluated.

6.  Budget and Staffing
    Based on the findings in the above categories, budget and
manpower requirements for an effective water supply program were
calculated and compared with those of the current program.

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STUDY FINDINGS

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                            25
                         STUDY FINDINGS
                   Water Supplies In Colorado
     Ninety percent of Colorado's 2.4 million citizens  are served by
an estimated 704 community water supplies.   Information concerning
these systems is summarized in Appendix B.   Significantly, 80 percent
of the community supplies serve less than 1,000 people  each.   As  shown.
by the Community Water Supply Study1 it is  these small  community  systems
which have the most difficulty in consistently providing safe drinking
water to their consumers.
     As shown by Table 1, there are an estimated 900 small public water
supplies located at residential areas, trailer courts,  campgrounds,
motels, and recreational areas.  These are of special concern since
they serve many of the 8.4 million people who travel in Colorado  each
year.
     Not all Coloradans are served by public water supplies.   Approxi-
mately 240,000 are either supplied by individual home water systems
(obtaining water from wells, springs, and surface sources) or do  not
have any source of drinking water conveniently available.
                    Community Mater Supplies

     The information  presented in this section was compiled by reviewing
the records maintained by the Colorado Department of Health.  Since only
394 of the community  water supplies (all those serving over 100  people)

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          Type
Community Water Supplies
  Serving over 100 people
  Serving 40-100 people
Samll Public Water Supplies
  Serving a Residential Population
    (less than 40 people)
  Serving the Traveling Public

Individual Supplies
          TABLE 1
Water Supplies in Colorado

        Number

         394
         310*
         100*
         800*

      60,000*
 Population Served

     2,083,000
        25,000*
         3,000*
Many of the 8.4 million
visitors annually*
       240,000*
re
en
*Estimates

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                             27
were under routine surveillance-as of January 1973, the information
primarily concerns these supplies.  Records for the remaining 310
supplies (serving 40-100 people)  were not adequate during the time
the study was conducted.  Based on studies completed in other states;
however, the conditions of these supplies would, in most cases, be the
same or worse than that reported below for the 394 supplies.4»5,6

Bacteriological Quality
     A review of the records maintained by the Colorado Department of
Health revealed that 102 (26%) of the 394 community water supplies
failed to meet the bacteriological limits of the Drinking Water Standards
for one or more months during 1972.  These systems were serving approxi-
mately 12 percent of Colorado's population with water potentially
containing disease producing organisms.  Significantly, 26 of these
supplies, as shown by Table 2, were not providing any form of disinfection,
Appendix C  presents further information on the supplies which failed
the bacteriological standards.
     The problem is made worse since many supplies are not submitting
the proper number of bacteriological samples each month for testing.
For example, during 1972, over 60 percent of the 394 community water
supplies did not submit the required number of samples for two or
more months.  Twenty-six percent  submitted less than one-half the
required number.

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                                             TABLE 2

               Conmunity Water Supplies Failing Bacteriological Standards in 1972
                    (By Number of Months Supplies Failed to Meet Standards)
Number of Months
Standards Failed
One
Two
Three
Four
Five
Number of CWS*
Failing
64
20
8
8
2
Percent of CWS*
Failing
16%
5%
2%
2%
1%
Population
Served
237,800
23,400
5,600
13,600
600
Number of Those Failing
Having No Disinfection
11
6
3
4
2





        TOTAL              102                 26%             281,000                26
*CWS - Conmunity Water Supplies - Includes only the 394 supplies unacr toutine surveillance ^ of
       January 1973.
                                                                                                           IV
                                                                                                           
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                              29
Chemical  Quality
     A review of the chemical quality data for the 394 community water
supplies  indicated that each supply had a chemical analysis within
the previous three years (1970 through 1972).  With the exceptions of
silver and carbon chloroform extract, the analyses included all the
constituents listed in the Drinking Water Standards.   Table 3 summarizes
the information obtained from this data.
     Thirty-three (8%) failed to meet at least one of the mandatory
limits of the Drinking Water Standards.  These supplies serve about
24,600 people with water that could cause adverse health effects.  In
addition, 78 supplies (20%), by not meeting one or more of the recommended
limits, are serving 142,600 people with aesthetically inferior water.
These results point out the importance of doing complete chemical
analyses of drinking water routinely to detect potential health problems.

Facilities Appraisal
     During 1972, 88 percent of the 394 community water supplies were
inspected by engineers from the Colorado Department of Health.  The
                                                                : i
remaining 12 percent had been inspected during the previous three
years.  Written  reports were prepared  only in a few cases since a
check sheet  (shown  in Appendix F)  is used.  A review of the latest
Inspection data  for the 394 community water supplies (summarized by
Table 4) revealed the following:

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Community Mater Supplies Not Meeting
Number of
Chemical DWS,1 CW$2 Wot
Constituent mg/1 Meeting Standards
RECOMMENDED LIMITS
Total Dissolved
Sol Ids 500. 67
Sul fates 250. 58
Iron 0.3 38
Manganese 0.05 22
Nitrate 45. 6
Z1nc 5. 1
TOTAL* 78
KAHDATORY LIMITS
Fluoride3 2.4 14
Selenium 0.01 9
Radium 226 3 plcocurles per liter 7
Chromium
(Hexavalent) 0.05 1
Arsenic n,ns 1
Cadmium 0.01 1
Lead 0.05 1
TOTAL4 33
30
TABLE 3


Drinking Water Standards For Chemical Quality
Population
Served

97,800
92.000
72,800
21 ,500
3,300
500
142,600

8.500
11,800
2,500
1,300
300
250
150
24,600
^WS - Drinking Water Standards - Limits are expressed 1n milligrams p
Possible Effects
When these limits are not met. more suitable
sources of water supply should be considered
Taste and laxative effects-
Taste and laxative effects-
Imparts stains to laundered goods and
plumbing fixtures.
Sane as Iron-
Can cause serious poisoning (methemogloblneipla)
in infants-
Bitter Taste.

Vlhen these limits are not met, the water supply
should be rejected.
Can produce objectionable staining of the teeth-
(Fluorosls)
Can cause disturbances in human physiologic
functions .
Accumulates 1n the bones and is a carcinogen.
Toxic to man and Induces skin sensltizations.
Toxic to man and can accumulate in the body.
Highly toxic to man.
Toxic tc man ind can accumulate In the body.

er liter except for Radium 226 which 1s in
       plcocuries per liter.
2CWS - Community Water Supplies  - Includes  only the  394  supplies  under  routine  surveillance  as of  January  1973.
3A11 of the excessive fluoride concentrations were  due  to naturally  occurring fluoride  compounds.
4The totals are not direct additions from the  table since some communities  failed to meet one or more standards.

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                              31

      1.   105 (27%),  serving  over  187,000  people, had  inadequate
          treatment.   As  shown  by  Table  4,  the majority of this problem
          was due to  the  78 systems  not  having disinfection; however,
          there were  also 27  supplies  not  providing adequate treatment
          (such as  coagulation  and filtration) for surface sources.

      2.   62  (16%)  serving about 258,000 people, had sanitary defects
          within  their systems,  which  included such problems as Improper
          source  protection,  cross-connections and uncovered finished water
          storage.

      3.   The systems serving less than  1,000 people had the most
          deficiencies.   For  example, of the 105 supplies having
          inadequate treatment,  84 percent served 100-1,000 people.
          This situation was  also  identified on a national basis by the
          Community Mater  Supply Study J

      These conditions indicate  the need for routine engineering
surveillance  to  identify deficiencies within public water supplies.
In addition, good follow-up procedures are essential  to assist the
communities  in eliminating the deficiencies.  These aspects  of the
Colorado water supply program are discussed in more detail  later  in
this  report.

Fluoridation
     Many years of medical and dental research  have shown fluoridation
to be a safe and beneficial practice.  The proper addition of  fluorides
to a water supply can reduce the incidence of tooth decay in children
by as much as 65 percent.

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                                               TABLE 4
                          Facilities Appraisal  of Community Water Supplies
     Deficiency
Inadequate Treatment
  Number of CWS1
  Population Served
Not Having Disinfection2
  Number of CWS1
  Population Served
Having  Sanitary Defects
  Number of CMS1
  Population Served
                                                     Population Range  Served
                                                         1,000 -       100 -
                                         Over 10.000  Under 10,000  Under 1,000       Total
1
100,600
0
0
4
224,000
16
54,500
13
39,200
9
16,400
88
32,700
65
23,100
49
17.400
105
187,700
78
62,300
62
257,800
     - Community Water Supplies -  Includes only the 394 supplies under routine surveillance as of
       January 1973.
2Supplies "Not Having Disinfection" also included under "Inadequate Treatment."
                                                                                                        co
                                                                                                        ro

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                               33
     Approximately 1.9 million persons in Colorado are served by water
supplies which contain a dentally significant amount of fluoride.  This
covers about 92 percent of the population served by community water
supplies.  Thirty-five of these supplies, serving approximately 1.2
million persons, adjust the fluoride content of the water to the optimum
level by adding a chemical compound containing fluoride.   For the maximum
beneifts to be realized, the fluoridation equipment must be well operated
and maintained.
     Responsibility for surveillance of fluoridation rests with the
Colorado Department of Health.  Engineers from the Department (Engineering
Section) are supposed to check on the operation and maintenance of the
fluoridation equipment during their annual inspections of the water
supplies.  However, field checks made by engineers of the EPA have
revealed that deficiencies are not being noted and corrected.  For
example, a few communities have been using the wrong fluoride chemical
compound.  Although this does not constitute a health hazard, it does
make fluoridation more expensive and creates operational  difficulties.
This indicates that inadequate attention is being given to fluoridation
during the inspections.  In addition, there is no place on the
inspection forms for information regarding fluoridation to be recorded;
therefore, the Department has very little file Information on the types
of equipment and chemicals being used.
     The actual level of fluoride in the distribution system is the single
most important factor in evaluating the adequacy of a community water-
fluoridation effort as well as the benefits which will be received.
However, communities which fluoridate are required to submit only one
check sample every three months to the Department's laboratory.  Water

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                              34

operators are not required by the Department to keep records on the
amount of fluoride compound used and daily test results.  Consequently,
there is little recorded information on how adequate the adjustment of
fluoride content is at these water supplies.  Spot checks have revealed
that it is not adequate at many supplies.  In all cases not enough
fluoride was being added to achieve the optimum concentration.  The
results of the check samples are monitored by the State Dental Director's
office.   In the past, many of these sample results have been misfiled
and information on needed field follow-up has not been transmitted to
the Engineering Section.
     In summary, the surveillance of fluoridation in Colorado is
inadequate.  Many communities are not receiving the benefits for which
they are paying and which properly managed fluoridation can achieve.

                   Small Public Water Supplies

     The Colorado Department of Health estimates that there are 900
water supplies located at small  residential areas, trailer courts,
campgrounds, motels, and recreational areas which serve a major portion
of the 8.4 million people who travel in the state each year.  Many of
these supplies receive little or no surveillance.  Although no field
surveys  were conducted during this evaluation, studies completed in
other states by the EPA showed that an average of 30 percent of these
supplies failed to meet the bacteriological quality limits of the
Drinking Water Standards.4»5,6
     During 1972, four waterborne outbreaks were associated with
supplies serving the traveling public in Colorado which illustrates
that such systems can pose significant health problems.

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                              35
                    Individual Water Supplies
     Approximately 240,000 Coloradans depend on individual  home
systems (wells, springs or surface sources)  for drinking water.
The Colorado Department of Health has no authority regarding these
suppliesi but, can provide technical assistance if requested.  Little
is known about the condition of the individual  water supplies or the
quality of water they produce.  A field study being conducted in
Jefferson County by the U.S. Geological Survey has shown that 20 percent
of the 800 individual water wells tested failed to meet bacteriological
quality standards.7   These results are similar to those obtained by the
EPA in other states.4'5'6  Practically all of the supplies  surveyed by
the EPA lacked proper sanitary construction.
     A definite need exists for more activity 1n the area of Individual
water supplies since the general public knows little of proper source
protection and sanitation.  During the last ten years, 73 percent of
recorded waterborne outbreaks were due to contaminated individual water
supplies.2
                      Water Supply  Program
     The preceding sections have presented  the study findings related
to the general condition of public water supplies in Colorado.  To
determine if  the State's water supply  program,,as presently  administered,
was capable of fulfilling  its legal  responsibilities and meeting the
problems, an  evaluation was conducted  of the program.

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                            36

Legal Authority
     The 1963 Colorado Revised Statutes place various legal  responsibilities
regarding public water supplies within the Colorado Department of Health
(hereafter called the Department).   These statutes are compiled in
Appendix D and summarized below:
     Section 66-1-7(6) - Authorized Department to "establish and
           enforce minimum general  sanitary standards as to  the quality
           of water supplied to the public, including the authority
           to require disinfection of such water, and to advise with
           municipalities, utilities, institutions, organizations, and
           individuals, concerning the methods of processes  believed
           best suited to provide the protection or purification of
           water to meet such minimum general sanitary standards..."

     Section 66-1-7(9) - Authorizes Department to establish  and approve
           laboratories to conduct examinations necessary for protection
           of the public health.

     Section 66-1-7(10) - Authorizes Department to establish standards
           for laboratory tests to which the laboratories must conform.

     Section 66-1-7(19) - Adopts the U.S. Public Health Service Drinking
           Water Standards as the "minimum general sanitary  standards
           as to the quality of water supplied to the public."

     Section 66-l-7(20)(g) - Authorizes Department to examine plans for
           the proposed construction of community water facilities if
           submitted for review.

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                          37
Section 66-1-8(5)(a) - Empowers the Department, through the Board
      of Health, to adopt rules, regulations, and standards
      necessary to administer the State's public health laws.

Section 66-1-14(1)(a)&(b) - Makes it unlawful for any "person,
      association, or corporation" to violate the public health
      laws, rules, regulations, and standards.

Section 66-1-14(1)(a)&(1) - Makes it unlawful to permit cross-
      connections between a public water supply and a supply
      which does not meet the Drinking Water Standards.

Section 66-1-14(4)  - Establishes penalties for the violation of
      public health laws.

Section 66-38 - Requires each water and wastewater treatment  plant
      to be under the supervision of a certified operator.   Establishes
      classes of operators and defines qualifications for them.
      Provides penalties for violations.

Section 106-2-37(1)(a)&(h) - Requires Departmental review of water
      quality for proposed subdivisions when submitted by county
      commissioners.

Section 142-1 - Authorizes Department to adopt and enforce a
      plumbing code that is uniform throughout the state.

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                              38
     Section 148-20 - Requires that well drillers and pump installers
           be certified.  The certification board, which includes  a
           representative from the Department, is within the State
           Engineer's office.  This board sets certification criteria
           and minimum standards for water well construction and pump
           installation.
     In addition, under the provisions of Section 139-32-1(35),  cities
and towns have the authority to protect their water sources within five
miles of their water supply intakes.

Regulations
     In accordance with the authority granted by the statutes, the
Department adopted a set of regulations entitled "Standards for  the
Quality of Water Supplied to the Public."  These regulations, included
in Appendix E, cover the following main topics:
     1.  Definition of Terms - Defines certifying authority, coliform
         group, standard sample and other terms used in  the regulations.

     2.  Source and Protection - Requires that a public  water supply be
         protected by adequate treatment.  Health hazards  are to be
         sought out and eliminated through routine surveillance.

     3.  Drinking Water Quality - Establishes sampling frequency and
         standards for the bacteriological, physical, chemical,  and
         radiological  quality of drinking water.  These  are essentially
         the same as found in the Drinking Water Standards.

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                             39
     4.   Recommended Analytical  Methods  -  Prescribes  the testing
         procedures to be followed to determine compliance with the
         standards.

     5.   Hazardous Cross Connection - Provides  that "a public water supply
         shall have no cross-connection  to a pipe, fixture, or supply
         any of which contain water of lesser quality."
     6.   Disinfection of Drinking Water  -  Requires that all public water
         supplies be disinfected.

Organization
     Figure 1, an organization chart of  the Department, shows that the
water supply program is administered by  the Engineering Section under the
Engineering and Sanitation Division.  Additional responsibilities of
the Section include the solid wastes, plumbing inspection, swimming area
regulation, and incifidual sewage disposal systems regulation programs.
The chemical and bacteriological testing is done by the Laboratory Division.
     The Engineering Section's current staff consists of ten public
health engineers (one of which serves as Section Chief) and three
secretaries.  The entire staff operates from the central office in Denver.
None of the public health engineers are assigned to a specific program;
therefore, staff-time is divided between the various programs reducing
the effort in any one area.  During 1972, for example, only 40 percent
of the engineers' time was devoted to activities relating to public
water supplies  (i.e., 4 man-years).

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Figure I  Colorado  Department of Health
                 Governor
                    I
    |Colorado Department of Health   {	1  State Board of  Health  |
                    I
          I Executive Director   |


i
1 Assistant Director |
i
1 1
~Adminis- W
trative Laboratory p
Services Division c
Division D


—Business Microbi-
Manage- ology
ment Section
Section
LChemistry
—Personnel Section
Section
—Records &
Statistics
Section
l|_ _ T 4- U
— Hea I th
Education
Section
—Data Pro-
cessing
Section
—Legal
Services
ann i ng
Section



I






| Assistant Director j

1 1
ater Engineering
Dilution and Sanita-
ontrol tion
ivision Division

. J
Air HOI lu-
tion Control
Division

1
Occupational
& Radiologi-
cal Health
Division


-Milk, Food -Radiological
& Drug Health
Section Section
-Engineering ^Occupational
Section Health
Section
-Water Supply Program
-Solid Wastes Program
-Plumbing Inspection
"Swimming Area Regulation
-Individual Sewage Disposal
Systems Regulation


1
j Assistant Director f

I
Special
Health
Services
Division

-Public
Health
Nursing
Section
-Social Work
Section
-Dental
Health
Section
-Migrant
Health
Section

^P
1
um id
Health
Services
Division

Preventive
Medical
Services
Division

Alcoholism
& Drug
Dependence
Division

Hospital &
Nursing
Home
Division

Community
Health
Services
Division

                                                                               o

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                                41
     Each of the engineers is responsible for a district within the
State.  As shown by Figure 2, most of these districts are extensive.
This not only requires a large amount of travel, but makes it difficult
for the engineers to provide adequate coverage,especially of the
counties in western Colorado.
     The staff is dedicated and well qualified.  There has been little
turnover, so most of the engineers have many years of experience.
Nationally, Colorado ranks about 22nd in average salary paid to staff
engineers ($15,000 for Public Health Engineer I).   This salary range
is slightly higher than other states in the region, which helps
maintain the low turnover rate.
Responsibilities
     The activities and responsibilities of the Engineering Section
concerning public water supplies, as outlined in the regulations are:
     1.   Engineering inspection  of public water supply facilities  and
         their operation.
     2.   Proposing rules,  regulations and criteria to secure protection
         of public water supplies.
     3.   Enforcement of sanitary standards to protect quality of water
         served to the public.
     4.   Surveillance of the quality of the water  being served to  the
         public.
     5.   Review of plans and specifications for new construction and
         modifications of  existing public water systems.
     6.   Advise municipalities,  utilities, institutions and individuals on
         the methods best  suited to provide protection or treatment of the
         water to meet the standards.

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 Figure 2
 Districts of the Public Health Enaineers
COLORADO
fiOTE:  Each number represents an engineer's district

-------
                             43
     In addition,  other  services  are  performed,  including:
     1.  Training  of water utility  personnel.
     2,  Providing technical  assistance to local  health  departments,
         state agencies, and  individuals.
     3.  Promotion of good water  supply practices.

Policy
     The Engineering Section  has  adopted a policy statement entitled
"Guidelines for Applying Drinking Water Standards to Regulations  -
Quality of Water Supplied to  the  Public" (included in Appendix F)
which  is used to assure, as much  as possible, the uniform application
and interpretation of the regulations regarding public water supplies.
The enforcement procedures to be  taken when supplies fall to meet the
Drinking Water Standards also are covered.
     The guidelines define a public water supply as any water supply
available to the public and establish the following categories:
                A               Serving over 10,000 persons
                B               Serving 1,000 - Under 10,000 persons
                C               Serving 100 - Under 1,000 persons and
                                having at least 25 service connections.
                D               Community water supplies serving 10
                                or more dwelling units not under control
                                of the owner or 40 - Under TOO resident
                                persons.
                E               Other  public water supplies not meeting
                                conditions for above  categories.

Therefore,  the  A,  B,  C, and  D  supplies would be  considered community
water'supplies  as  defined on page  3.

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                               44
     Before January 1973, when the guidelines were revised, only the
A, B, C, and D categories were listed.   The surveillance schedule called
for each A, B, and C supply to receive an annual  inspection by an
engineer from the Department.   At least one chemical  analysis  per year
also was required for these supplies.
     The revised schedule is shown by  Table 5.  With  the exception of
bacteriological testing, the new schedule doubles the activities of
the previous one.  The local health departments are responsible for
the surveillance of the category E supplies as well as for the
bacteriological and chemical sampling  program for all supplies within
the counties they serve.
Budget and^ j taff i ng
     Figures 3 and 4 present budget and staffing patterns of the water
supply program as compared to two other major environmental activities
administered by the Department.  The basic dilemma confronting the
water supply program is shown quite dramatically.  Whereas the water
pollution and air pollution control programs have realized significant
increases in their resources for the past several years, the water supply
program has remained practically static.  This has occurred although
the number of water supplies requiring surveillance have more than
tripled in the last seven years.
     The fiscal year 1974 (FY 1974) allocation for the water supply
program is $59,800.  This represents only about $85.00 for the engineering
surveillance of each of Colorado's 704 community water supplies, or about
2.5 cents per capita (based on the 1972 estimated population of 2,375,000).8
These levels are well below the national averages of $287.00 per water
supply and 5.3 cents per capita, respectively.  As a comparison, Colorado

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                                           TABLE 5

                       Colorado Department of Health Guidelines  for the
                             Surveillance of Public  Water Supplies  ]_/
Category of
Public Water
Supplies
A, B, C, & D
E
Frequency of Inspections
Engineering-.
Inspections—'
2 per year
1 per year
Sanitary.
Surveys—
1 every 5 years
At discretion of
inspecting
authority
Frequency of Analyses
Chemical-/
2 per year
At discretion
of insoectinq
authority
Bacteriological
According to
Drinking Water
Standards
1 per month
                                                                                                          en
V  Based on January, 1973 revisions to "Guidelines for Apnlying Drinking Water Standards to
    Regulations - Quality of Water Supplied to the Public."

2/  An inspection to check compliance with regulations.  Report is submitted on form included in
~   Appendix F.

3/  Detailed survey including a comprehensive written report on all aspects of the water supoly.

4/  Includes all constituents listed in the Drinking Water Standards.

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                            46

                         Figure 3

       Budget Comparisons of Environmental Programs
                     (From Appendix G)
1/1
to

o
a
*»-
o
in
o
Q>

•O

CO

r—

2
C

<
1.8


1.7

1.6


1.5


1.4


1.3


1.2


1.1


1.0


0.9


0.8

0.7


0.6


0.5


0.4


0.3


0.2


0.1

0.0
                                      Water Pollution
                                      Control  Progranf
                                      Air Pollution
                                      Control  Program
                                           Water Supply Program
                   I
                                     I
   1968    1969
                           1970     1971      1972     1973     1974

                               Fiscal  Year

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                                     47


                                 Figure 4


            Staffing Comparisons Between Environmental Programs
                             (From Appendix G)
     60
     50
     40
                        Air Pollution
                       Control Program-
t.
o
uu

v
o
ea

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                                 48

 expends  about  75  cents  per  capita  for water  pollution  control  and
 53 cents per capita for air pollution control activities.  Certainly,
 these environmental proqrams are important, but an effective drinking
 water program  is just as essential and should receive  a comparable
 level of funding and manpower.
     Why hasn't the water supply program kept pace with the growth
 experienced by the other environmental activities?  The answer is
 simply that public and  legislative emphasis have been  concentrated on
 other environmental concerns.  The Federal Government  has enacted
 strong legislation regardinn water and air pollution control which
 nlaced many legal requirements upon the states.  Federal funds are
 provided to enable the states to strengthen their programs and
 i mo lenient the  legislation.  For example, federal funds will account
 for one-third of the FY 1974 water and air pollution control budgets
 shown by Figure 3.  The remaining two-thirds are state funds which
 Colorado had to commit in order to qualify for the federal grants
 and comply with the legislative requirements.  Since Colorado does not
 have unlimited resources, priorities must be established.   Unfortunately,
more often than not, the low priority activities are those, such as
 the water supply program, which don't receive federal  funding.

 Engineering Surveillance of Public Uater Supplies
     The routine surveillance of public water supplies is  one of the
most important duties of health officials.   To prevent serious  health
hazards from developing, the physical  facilities and operational
 procedures of a water supply must be reviewed regularly by qualified
 personnel.

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                                 49
     As shown by Table 5, the Engineering Section has a DO!icy (as of
January 1973) of inspectinn each community water supply (categories
A, B, C, & D) twice each year.  Unfortunately, present staff and budget
limitations probably will never allow this schedule to be fully implemented.
In fact, the staff could never complete the annual  insnections of the
suoplfes under the previous surveillance schedule.   For example, in
1972, 12 percent of the A, B, C supolies were not inspected.   As
indicated earlier, surveillance of those sunplies which are fluoridating
has been particularly inadequate.  Very few of the D supplies were
surveyed.  Records for previous years revealed that 20 percent
of the A, B, and C supplies were being inspected  every two or three vears
rather than annually.
     Well-written reports, outlining the findings and recommendations of
the inspections, are essential to obtain desired  improvements.  Presently,
a complete written report is prepared only every  five years.   For the
intervening years an annual  inspection form (included in Appendix F)
is used.   This check-sheet is a general  measure of compliance with
regulations.   The form does provide a convenient  reporting method for
the inspections  which is  important in view of current staff limitations.
Nevertheless, the forms do pose the danger of making the inspections  too
routine.   The engineer might well fill out the entire form without
doing a thorough inspection to detect problems which would negate the
purpose of the surveillance effort.  A review of  completed inspection
forms revealed that this  problem is occurring, indicating the need for
a more detailed  reporting system.

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                               50
     After the initial inspections, follow-up surveys are important in
order to determine if the communities have properly implemented the
recommendations.  The lack of available staff time has prevented adequate
follow-up consultations and investigations.  Emphasizing this point is
that, as of January 1973, 27 percent of the 394 A, B, and C supplies
still had inadequate treatment.
     The surveillance of the quality of water being served by public
water supplies also requires additional follow-up work.  The community
water supplies are supposed to have at least one complete chemical
analysis each year.  They are required to submit samples for bacterio-
logical analysis each month.  Each engineer receives the results for
his district.  The engineers are responsible for following-up on the unsafe
results, requesting resamples, and for seeing that the systems are
submitting the proper number of samples.  During 1972, however, 60
percent of the 394 A, B, and C supplies did not submit the required
number of samples for two or more months, and very little
resampling was done.   Obviously, more-thorough follow-up and more
attention to the enforcement steps outlined in the "Guidelines for
Applying Drinking Water Standards to Regulations - Quality of Water
Supplied to the Public" by .the Engineering Section is needed.
     The community water supplies are not required to submit periodical
operating reports.  In fact, many supplies do not maintain adequate
records for their own use.  Good records are essential to the operation
of any water system.   Operating logs submitted to the Engineering
Section, on a periodic basis, would provide valuable information as

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                               51

well as indicating problems with which the supply needs assistance.
This would also encourage the operators to maintain good records.
     The community water supplies  are not required to submit plans and
specifications for the construction of new water supply systems  or the
modifications of existing systems.  In addition, there is no requirement
that the plans and specifications  must be prepared by an engineer
licensed to practice in Colorado.   All plans that are submitted  are
reviewed by the Engineering Section.  Approximately 140 plans
representing $16 million are reviewed annually.   A concentrated  effort
is made to carry out this activity often at the expense of other
important functions.
     Generally, the Recommended Standards for Water Works9 adopted by
the Great Lakes - Upper Mississippi River Board of State Sanitary
Engineers (the so-called Ten-State Standards) are used by the Engineering
Section when reviewing plans.  The Section has developed and published
its own criteria regarding distribution systems, disinfection systems
and finished water storage tanks.
     The Engineering Section provides technical  assistance to the  local
health departments, other state agencies and individuals upon request.
Unfortunately, lack of available staff and the distances involved  (from
Denver to Durango for example) limit the extent and amount of technical
assistance which can be offered.
     In summary, a definite need exists for more surveillance and  technical
assistance in order to help the communities improve the condition, opera-
tion and maintenance of their water supplies.  More follow-up work on

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                              52
inspection, chemical and bacteriological reports is needed to isolate
and correct deficiencies.  The present water supply program simply does
not have the resources to perform these functions adequately.
Training
     Operation of water supply systems must be by qualified persons.
Skilled operation not only protects a community's investment in its
drinking water facilities but safeguards the public health as well.
In view of these considerations Colorado enacted a mandatory certifi-
cation law (included in Appendix D) for water and wastewater system
operators.  The law requires that each water and wastewater system in
Colorado have a certified operator meeting specific qualifications.
     This has increased the demand  for operator training considerably.
At present, the only training offered is the Rocky Mountain Water and
Wastewater Plant Operators School held in Denver each year.  The week-
long school is conducted by the University of Colorado, Colorado
Department of Health, and Wyoming Department of Environmental Quality.
Between 75-100 operators attend the water treatment segment of the
school each year.  Even with the law; however, many communities
(especially the small ones) either cannot afford or simply do not care
to send their operators to the school.  Many of the small-town operators
also perform other duties (such as garbage collection and street repair)
and cannot be spared for an entire week.  In addition, many operators
criticize the school for presenting too much material in too short a
time.   Since the school does not appear to be meeting the operators'
needs, the sponsors should seriously consider modifications to the school's
approach.

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                               53
     In an attempt to alleviate some of these problems two of the
district engineers presented one-day short courses in two locations
in southwest Colorado.  The courses covered Departmental  regulations
regarding public water supplies, the why and how of bacteriological
testing as well as other fundamentals.  Both courses were extremely
successful.  The operators were relaxed and felt much freer to ask
questions.  They commented that they gained much more from the short
courses than from the operators school.  It appears that the short course
approach presented around the State could reap valuable benefits in
improved operation and maintenance.  Again, lack of staff-time and
funds are the major obstacles.
     Another important form of training which has been seriously
neglected by the Department is an on-going training program for the
district engineers.  Although they have engineering backgrounds,
they still need some form of periodic training to keep up with technical
advances and for professional development.  The water supply program
has no specific allotment for training; therefore, any funds for this
purpose must be "borrowed" from other activities.  This approach has
meant that few of the district engineers have attended training courses
other than those sponsored by the Department.

Local Health Departments
     The Colorado Revised Statutes authorize the formation of local
health departments at the county or municipal level.   Presently, there
are 13 organized local health departments serving 24 of Colorado's 63
counties (Figure 5).   These departments use a combination of local,

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 Figure 5
 Counties Served by Organized Local Health Departments
COLORADO
                                              GRAND     I BOULDER
NOTE-.  Each number represents an organized local health department

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                              55
state, and, in some cases,  federal  funds.   If the county  (or  counties)
provide at least $1.50 per  capita to support a local  health department,
the State will provide an additional $0.85 per capita.
     According to Departmental  policy (Appendix F)»  the local  health
departments have the following  responsibilities regarding public  and
individual water supplies:
     1.  Implementation of  the  bacteriological sampling requirements
         for all public water supplies in  their respective areas
         including submission of a monthly summary report of  tests
         conducted on category  A, B, C, and D supplies  to the Department.
     2.  Inspection and surveillance of the category E  and individual
         water supplies.
     3.  Investigation of complaints regarding public water supplies.
     4-  Reporting to the Department any findings from  investigations
         of complaints, abnormal conditions and any suspected waterborne
         disease outbreaks.
     Ten of the local departments provide laboratory services which
Include bacteriological testing of water supplies.  The local departments
provide some beneficial decentralization of the water supply  program.
The reaction to problems, such as unsafe bacteriological  results, can
be much quicker and more effective.  Unfortunately, the local departments
do not have the resources to fulfill the responsibilities. This  has
resulted  in inadequate sampling and few follow-up investigations  of
public water supplies.

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                                56
     The Drinking Water Standards specify a definite procedure to be
followed when unsafe bacteriological results are obtained.  Departmental
records indicate that the local departments are not following this
procedure.  Many times the Engineering Section or the water utility
have not been promptly notified of unsafe results.  The Engineering
Section often does not receive monthly summaries of results from the
local departments.  Obviously, these problems will have to be corrected
before the potential benefits of local health departments can be
realized by the water supply program.
Laboratory Support - Bacteriological
     Bacteriological testing of water supplies is conducted by the
Department, local health departments and, in some cases, by the
municipalities.  Most of this work is done by the Department's
Laboratory Division (Figure 1).  Approximately 9,800 water samples
from public supplies and 5,200 from individual supplies are tested
annually by the Division.  A staff of four conducts the tests; however,
they are also responsible for a large volume of work relating to the
water pollution control and milk sanitation programs.  The Division
estimates that it costs $2.00 to test each water sample.  No charges
are made to water utilities or individuals for this service.  The
results are sent to the Engineering Section for further action.  The
Laboratory's procedures and facilities were evaluated in 1971 by the
Environmental Protection Agency.  The report, included in Appendix H,
concluded that the laboratory generally met the provisions of the
Standard Methods for the Examination of Water and WastewaterJ0

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                               57

     Ten of the local health departments also do bacteriological  testing
of water supplies.  Their laboratories conduct about 8,000 tests  on
public water supplies each year.   There are indications that some of
these labs are under-staffed.  For example, there have been cases when
samples were not tested during periods when the microbiologist or lab
technician was on vacation.  The monthly summaries often have not been
submitted to the Engineering Section on a timely basis.  Obviously,
these problems hamper the surveillance program.  All of these labs are
visited at least once a year by someone from the Laboratory Division
(usually the Division Director) to evaluate procedures and provide
technical assistance.  Five of the laboratories must be formally
evaluated and certified every three years since they test samples from
water supplies which serve interstate carriers (airplanes, trains or
buses).  The Division estimates that each of these formal evaluations
costs $500 based on the man-hours and travel required.
     Some of the water utilities conduct their own bacteriological
testing.  These include Aurora, Colorado Springs and Denver, whose
results are accepted as official  since they are subject to the formal
certifications by the Laboratory Division.  These laboratories submit
summaries of their results to the Engineering Section.

Laboratory Support - Chemical
     The Laboratory Division conducts the chemical analyses on water
samples from the public supplies collected by the Engineering Section
as part of the surveillance program.  Analyses on about 440 of the 704
community water supplies are conducted each year indicating that each

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                               58
community supply has a chemical analysis every 20 months.  Each analysis
includes all the constituents in the Drinking Water Standards except
silver and carbon chloroform extract.  Pesticides analyses are conducted
upon request.  The Division estimates that each complete analysis
(excluding pesticides) costs $150.
     The present staff of four chemists and a technician are respon-
sible for conducting not only the water supply analyses but also a
large volume of water pollution control tests.  In fact, about 70% of
their time is devoted to the water pollution work.  This in conjunction
with the extremely cramped conditions in the chemistry laboratory
results in long turn-around times for water samples.  At times the
laboratory has had a four month backlog of samples for analysis.  These
delays affect the overall surveillance effort.

Other Agencies
     Water Pollution Control Division - The Water Pollution Control
Division, within the Department, is responsible for administering
Colorado's water quality control program.  This involves a wide variety
of activities including surveillance of domestic and industrial waste
treatment facilities, monitoring the water quality of streams and
effluents, comprehensive water quality planning, as well as setting
and enforcing water quality standards.  In conjunction with the EPA,
the Division processes applications for construction grants for sewage
facilities and for waste discharge permits.  Furthermore, the Division
has strong regulations concerning disposal of wastes by injection wells
or other subsurface means.  These are very important regulations in view

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                               59
of the increased interest in Colorado's underground resources.   By
helping to protect and improve the quality of water sources,  the
Division's activities benefit the overall  water supply program.   There
must be continual coordination between the water pollution control and
water supply programs if these benefits are to be realized.
     Department of Natural Resources - The Division of Water  Resources
(State Engineer's office) has the responsibility of carrying  out the
provisions of the Water Well and Pump Installation Contractors  Law
(Colorado Revised Statutes - Section 118-20) which went into  effect
July 1, 1967,
     The law established the Board of Examiners of Water Well and Pump
Installation Contractors under the Division of Water Resources.   The
Department of Health is represented on the Board.  The Board  has
adopted regulations to implement the act.
     Another major provision requires that well and pump installation
contractors must be certified by the Board in order to construct and
install pumps in water wells within Colorado.  A permit must  be obtained
from the State Engineer's office before construction or modification of
a water well.
     Well completion and pump installation reports (including a well log)
must be filed with the office within 60 days after construction (or
modification) is completed.  The Board has a staff consisting of a
registered professional engineer and three engineering technicians
(well inspectors) to enforce the regulations.  Since about 16,000 well

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                               60
permits are  issued each year it is impossible for the inspectors to
look at all  the installations.
     Unfortunately, the regulations are weak concerning proper grouting,
non-ferrous well casing and water quality testing after construction.
These vague regulations do not allow the true intent of the legislation,
to protect the public health through proper well construction, to be
implemented.
     Environmental Protection Agency - Under the Federal Interstate
Quarantine Regulations, the EPA must survey and classify those water
supplies providing water to interstate carriers (trains, planes, and buses)
This program consists of a joint EPA - State survey every three years
and a State survey during the intervening years.  A supply is  classified
as either "Approved", "Provisionally Approved" or "Prohibited" based
on the adequacy of the supply to provide water meeting the Drinking
Water Standards.  Presently, there are 12 supplies serving over 1.25
million people in Colorado which come under this program.   All but
three of these supplies have the "Approved" classification.

     Other Federal Agencies - The Forest Service and the National  Park
Service have water supplies which do not fall  under state jurisdiction.
These agencies are responsible for conducting  their own-surveillance
programs.   The Farmers Home Administration (FmHA)  provides loans to
rural communities and water districts (serving less than 10,000 people)
to construct water supply facilities.  The FmHA requires that  the plans
for proposed projects be approved by the Engineering Section before the
loans are granted.

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                              61
Data Management
     The Engineering Section must collect,  evaluate  and  file  an  immense
quantity of data in managing the water supply  program.   Information  such
as an inventory of supplies, engineering  inspections, bacteriological
results and chemical analyses is essential.   In  addition,  information
in connection with review of plans as  well  as  surveillance of small
public and individual water systems is necessary.  These items,  which
can run into the millions, must be retained and  be continuously  avail-
able for reference or analysis.
     Automatic data processing (ADP) could  provide an effective  means
for storage and retrieval of these data.   Presently, the only information
for which the Engineering Section uses ADP  is  that relating to the
activity reports (which lists how many hours spent on what activities)
kept by the engineers and a quarterly summary of the inspection  reports.
None of the bacteriological or chemical surveillance data are included.
These data require time consuming bookkeeping, filing and retrieval
procedures.  The present system is cumbersome, especially when informa-
tion on a large number of water supplies is needed.

Public Health Risk
     Since the middle of the nineteenth century, when Dr. John Snow did
his classical study  on the  transmission of cholera through a water
supply, it has been  recognized generally that disease epidemics can,
and do, result from  consumption of water containing pathogenic micro-
organisms.   Diseases most  commonly  associated with drinking water are

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                               62
cholera, typhoid fever, dysentery, and infectious hepatitis.   Spread
of these diseases occurs most often when body wastes from the infected
persons are ingested.
     While person-to-person contact is recognized as the common method
of transmission for low incidence levels currently found in this country,
the potential for catastrophic epidemics transmitted by drinking water
supplies which serve thousands of people, remains and demands constant
vigilance.
     Human body wastes from infected persons, when present in inadequately
treated drinking water, have caused waterborne disease outbreaks in
Colorado.  From 1963 - 1972 a total of eight outbreaks, resulting in
411 cases of waterborne disease, have been attributed to public water
supplies.  Fortunately, none of these outbreaks resulted in a fatality.
     All of the outbreaks were the result of contamination entering an
inadequately treated water supply.  Either no disinfection was being
provided or the disinfection equipment (chlorinators) was inoperative
due to poor operation and maintenance.  Four outbreaks involved surface
water sources with disinfection (inoperative much of. the time) as the
only form of treatment.  Six of the outbreaks (274 cases) occurred at
recreational areas such as ski resorts and summer camps.  These systems
have great potential for spreading waterborne disease because:
     1.  They are generally poorly constructed, operated and  maintained.
     2.  They receive little or no surveillance.
     3.  Large numbers of people use them in a relatively short period
         of time.  Those people that contract a disease can,  in turn,
         infect others as they continue their travels.

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                              63
     Since there are over eight million people who travel  in Colorado
each year, a public health risk does exist.   These outbreaks illustrate
the importance of routine surveillance of public water supplies.
     Appendix I presents a tabulation of significant diseases,  which
could be waterborne, and a comparison of the number of cases in Colorado
versus the number occurring nationwide for the past ten years.   While
Colorado has approximately 1.1  percent of the nation's population,  it
had for the period 1963-1972:
     1.  0.3 percent of the total  number of reported cases of amebiasis.
     2.  1.4 percent of the total  number of reported cases of viral
         hepatitis.
     3.  1.6 percent of the total  number of reported cases of salmo-
         nellosis.
     4.  2.2 percent of the total  number of reported cases of shlgellosis.
     5.  1.1 percent of the total  number of reported cases of typhoid
         fever.

     This data is not intended to imply that all reported cases were
waterborne.  It is intended, however, to point out that a portion of
these cases, plus an unknown number of unreported cases, may have been
waterborne.  In addition, body wastes from these diseased persons
pose the constant threat of contaminating public drinking water with
pathogenic microorganisms.
     While epidemiological records generally do not show widespread
incidence of waterborne disease, this actually may reflect incomplete
reporting,  inaccurate diagnosis and  the fact that much enteric illness

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                               64

is not treated by physicians.  This had led some authorities to suggest
that cases of such diseases as gastroenteritis and infectious hepatitis
actually may be as many as 100 times the number reported.
     In recent years, concern also has been directed to the possible
chronic diseases which may result from use of water containing certain
elements and chemicals.  These potentially dangerous substances include
heavy metals, pesticides and toxic industrial products.  Although  few
clinical cases are recorded, health agency statistics are limited  usually
to communicable diseases and affected individuals may have unrecognized
symptoms.   The heavy metals, such  as selenium, cadmium, lead, zinc,
and arsenic, occur naturally in the earth  therefore, they can be  present
in water sources.  As shown by Table 3, several public water supplies in
Colorado have concentrations of some of these elements exceeding the
Drinking Water Standards.  Therefore, it is important that every water
supply serving the public should have an adequate chemical analysis
performed routinely.
     In essentially all documented cases of waterborne illness, it has
been shown that definite deficiencies existed in the water supply  systems
during the time when disease was transmitted.  Furthermore, these
deficiencies either were unrecognized because of inadequate surveillance
for pqblic health hazards, or were recognized but not remedied due to
complacent water supply personnel  and ineffective enforcement by health
officials.  Deficiencies similar to those responsible for epidemics
definitely are present in the water supplies of Colorado.   The requisites
for repetition of the waterborne outbreaks of the past, namely inadequate
surveillance of water supplies serving the public and the presence of

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PROGRAM

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                                66
                            PROGRAM NEEDS
     The previous sections presented the study findings and their
relation to the current status of the water supply orogram in Colorado.
There is a definite need for a much stronger program especially in
terms of surveillance.  This section will discuss what is required to
give Colorado an adequate water, supply program.
                           Legal  Authority

     The Colorado statutes provide the Department of Health with
regulatory powers to establish and enforce standards to protect the
quality of water served to the public.  Unfortunately, the scope of
this authority is limited to drinking water quality standards and
mandatory disinfection.
     The water supply orogram does not have the authority to require
Public water suoplies to obtain aporoval before construction of new or
modification of existing water supply facilities,  Construction of water
suoDly facilities represents a major expenditure on the part of
municipalities.  If inadequate attention is given to the source water or
to the type of treatment, costly errors can result which also can cause
Public health problems.  For example, all four waterborne outbreaks which
occurred in Colorado during 1972 were due to inadequate treatment of
surface sources.  Many poorly designed small water supply systems are
operating in Colorado.  A good review program can prevent many of these
P^blems from occurring.  Therefore, legislation is needed to give the
water supply program the authority to:

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                                67
     1.  Require that a permit be obtained (from the water supply program)
         by a public water supply before construction of new or modification
         of existing water supply facilities could begin.
     2.  Issue regulations concerning the requirements which must be met
         in order to obtain a permit, including prior approval of proposed
         sources and treatment.
     3.  Issue criteria for the design, construction and operation of water
         supply facilities.
     Table 4 illustrates another problem of major concern which could be
alleviated with proper legislation,   The largest percentage of the
communities with deficiencies 1n  their water supply  systems have  less than
1,000 people.   Many need additional  treatment facilities or new water
sources so they can serve safe drinking water,   Unfortunately, most of these
small communities have serious financial  problems and can't afford major
capital Improvements.   Presently, there are practically no reliable sources
of funding for such cases,   The Farmers Home Administration (U.S.  Department
of Agriculture)  can provide loans (and grants  1n some cases)  to small
communities and districts (serving less than 10,000 people)  for water
supply facilities but  these funds are limited.   Although Colorado  has  a
construction grant program for sewage disposal  facilities, there is not  a
similar program for community water supplies.
     Many states have  similar situations.   Eight states, in an effort to
help those communities with fiscal  hardships,  have Implemented grant or  low-
interest loan  programs for construction of water supply facilities.
Although using a variety of approaches, all  of  these programs  have the common
purpose of helping make it possible  for small  communities to  have  safe
drinking water.

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                             68
     In view of the numerous small communities 1n Colorado with deficient
water supplies, it is recommended that legislation be enacted authorizing
a construction grant (or combination grant and low-interest loan) program
for community water supplies to be administered by the Department of
Health.  The program would be intended for those communities unable to
finance the improvements necessary for their water systems to meet the
State's quality or treatment requirements.  This program could result in
definite public health and economic benefits to Colorado.
                             Regulations

     The present regulations are adequate in terms of the water supply
program's existing statutory authority.  However, to implement the
recommended expanded authority the following regulations would be
needed.  In absence of legislation these could still be developed
and issued as guidelines:
     1.  Requirements for obtaining a permit to construct or modify
         water supply facilities.  These should require:
         a.  Submission of preliminary engineering reports, plans
             and specifications for review arid approval.  These shall
             be prepared by a professional engineer registered in Colorado.
         b.  Approval of proposed water sources.
         c.  Compliance with the program's criteria for minimum
             acceptable treatment.
         d.  Compliance with the program's criteria for design and
             construction of water supply facilities.

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                         69
    e.  Regional planning to discourage the proliferation of small,
        inefficient water systems.  Proposed systems should be
        stimulated to explore the possibilities of consolidating
        with other systems before approval is given.
2.  Definition of minimum acceptable treatment for source waters.
    Filtration of surface sources should be required.
3.  Minimum requirements for water treatment and distribution systems
    should be developed.  These should be flexible enough to allow
    the design engineers to make full  use of available water treat-
    ment technology; but should insure continued production of a safe
    water supply.
4.  The engineering consultant should  be required to provide inspec-
    tion during construction to assure that all work is done in accor-
    dance with the State approved plans and specifications.  Engineers
    from the water supply program should have access to the project
    at all times during construction.
5.  All public water supplies should be required to have a satisfactory
    bacteriological test and engineering inspection before being
    placed into service after construction or modification.
6.  Basic criteria concerning the operation and maintenance of water
    supply systems are needed.  These  would outline such items as
    the type and number of quality control tests which should be
    conducted for various classes of systems and the periodic sub-
    mission of standard operating reports to the water supply program.
    The operating reports can provide  valuable information such as
    indicating when systems are experiencing difficulties.

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                             70
        In this regard water supplies which fluoridate should be required
        to submit monthly check samples and monthly operational  reports.

    7.  Criteria for the grant program.

     The current "Rules and Regulations for Water Well and Pump
Installation Contractors" need strengthening in order to achieve their
stated purpose of protecting public health.  The water supply program
should recommend changes to the Board of Examiners of Water Well  and Pump
Installation Contractors as they see fit.   Specifically, the following
changes are recommended:
     1.  A definition of what constitutes  an adequate grout mixture
         is needed.

     2.  A minimum grout thickness should  be stipulated.

     3.  The present in-foot minimum grout depth will not provide the
         intended protection where deep frost penetration occurs.   To
         be effective, the grout seal must be in contact with undisturbed
         earth.  Therefore, the regulations should require the grout to
         extend at least ten feet below the frost line.

     4.  Regulations concerning non-ferrous well casing should be
         developed,  In particular, plastic well casing used in  wells
         Intended for domestic purposes should have National Sanitation
         Foundation (NSF) approval.

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                               71

     5.  Regulations regarding the proper installation of pitless well
         adaptors and units are needed.

     The recommended regulations would be important additions to the
present water supply program.  Their purpose would be to help foster
more careful planning and design of water supplies, effective operation
and maintenance of facilities as well as increased attention to quality
control.  All of these are essential to continued production of safe
drinking water.

                                 Policy

     The "Guidelines for Applying Drinking Water Standards to Regulations
Quality of Water Supplied to the Public" outlines the respective
responsibilities of the State and local health departments very well.
The guidelines should be followed to eliminate confusion regarding
surveillance of public water supplies.
     The policy statement (or guidelines) should remain flexible so
changes can be made easily.
                  Surveillance of Public Water Supplies

     The importance of routine surveillance of public water supply
systems cannot be overstated.  Only through an effective surveillance
and enforcement program can potential problems be detected and eliminated.
This is the area in which Colorado's water supply program needs the most
strengthening.
     As indicated earlier, the present staff is not adequate to visit
each community water supply at least once .each year.   This is especially

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                               72
true of the category C and D supplies which have most of the problems.
The need for more effective follow-up inspections and enforcement is
evident,si nee there are over 100 supplies in Colorado which  do not have
adequate treatment.  In fact, there are many supplies which  still  do  not
disinfect, although this has been State law since 1967.   The use of
penalties is distasteful in public health work and the Engineering
Section must be commended for the progress achieved in improving water
supplies without the use of force.  Unfortunately, there are those who
refuse to implement the recommendations.  Such cases call  for much
stronger action by the Engineering Section and, if necessary, the
Department.
     The present policy of using a check sheet (Form ES-ENG-1 in
Appendix F) for annual inspections is convenient but is poses the danger
of making the evaluations too routine.  If the inspections become just
"visits to the water plant" the whole purpose of routine surveillance is
negated.  The check sheets can serve as useful guides, but a written
report with recommendations should be submitted to each community water
supply at least once each year.  This provides a better basis for future
follow-up and enforcement action.
     More emphasis on bacteriological monitoring is needed.   The present
situation where over half of the community supplies are not submitting
the proper number  of samples must not be allowed to continue.  Even
more serious is the fact that some of these supplies fail to meet the
bacteriological quality standards for two to five months.  This indicates
a lack of follow-up and enforcement action.  There are definite enforcement

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                             73

steps outlined in the policy statement.  These should be followed more
closely.
     Presently, each community water supply has a chemical analysis about
every 20 months.  To improve the monitoring, the Engineering Section has
adopted the policy of requiring chemical analyses twice a year (Table 5).
Although this would be an excellent monitoring program, it would probably
be impossible to implement due to overburdened laboratory facilities.
Instead, the following schedule might prove to be more feasible and
still provide adequate monitoring:

                     Community Water Supplies
                       Surface Water Sources - Every Year
                       Ground Water Sources  - Every 3 Years
                     Small Public Water
                       Supplies              - Every 5 Years

More frequent analyses may be necessary to establish historic records
for sources or if sources have constituents approaching the limits  of
the Drinking Water Standards.
     The fluoridation surveillance effort must be improved if the
potential  benefits of this program are to be realized.   Therefore,  it
is recommended that;
     1.   Information  should be gathered on the fluoridation equipment
         and chemical compound used at each water supply.   This  would
         be helpful  in follow-up of reported problems.

     2.   The number  of check samples sent to the  State  Laboratory should
         be increased to at least one per month for  every water  system
         adjusting fluoride content.

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                              74
     3.  The check sample records should be kept by the Engineering
         Section rather than the Dental Health Section.

     4.  More frequent review of fluoride check sample results and
         better communication between the Dental Health Section and
         the Engineering Section is needed to ensure more efficient
         field follow-up in problem areas.
     5.  The Engineering Section should develop standard forms for
         recording:
         a.  Daily fluoride sample results
         b.  Amount of fluoride compound used, total water produced,
             and other operational information.
     In summary, the water supply program must be upgraded so that
it can meet its responsibilities to the citizens of Colorado.

           Staffing Requirements for Engineering Surveillance
     As indicated throughout this report, the primary need of the water
supply program is sufficient personnel  to implement an effective
surveillance effort.
     The Community Water Supply Study1indicated that an average of
1.2 man-days, per community water supply, are needed to make a
comprehensive field survey of facilities and operation.  However, this
single-visit-time-requirement does not allow for:
     1.  Making arrangements for field work.
     2.  Preparing the survey reports.

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                                75
     3.  Review of plans and specifications for new facilities.
     4.  Follow-up work to see that deficiencies are being corrected.
     5.  Activities related to training of water treatment plant
         operators.
These are essential if the program is to be successful in securing
proper water treatment practices throughout the State.  Therefore, it
has been estimated that at least four man-days per year are required for
each community water supply (the A, B, C, and D systems in Colorado).
In addition, one man-day per year is required for the supplies serving
the traveling public and the small public water supplies (category E
systems).
     Based on these estimates the personnel  requirements are:
     1.  Community Systems (categories A, B, C, and D)
         704 systems x 4 man-days = 2,816 man-days
                         system
     2.  Small Public Systems (category E)
         900 systems x 1 man-day = 900 man-days
                       system
         Total requirement = 3,716 man-days  or 17 man-years (assuming
         220 man-days per man-year).

Therefore, an adequate water supply program  in Colorado would  require a
total  of 17 professional man-years - 4% times the current level.
     Secretarial  support would be essential  to the effective operation
of the expanded water supply program.   It is recommended that  one
secretary be added for every three professionals.   Therefore,  a secretarial
staff of six would be required.

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                                76
     Since the local  health departments participate in the surveillance
of the small  public water supplies and the supplies serving the traveling
public, some  of the positions could be assigned to these departments.
Such a distribution was not considered as part of this study because:
     1.  The  needs of each local  health department were not evaluated.
     2.  77 percent of the counties are not covered by local health
         departments, therefore,  surveillance responsibility rests with
         the  Engineering Section.
However, to assure a coordinated  effort, the local health departments'
surveillance activities relating  to public water supplies should be
evaluated and considered to overall staffing patterns.
     The recommended annual personnel requirements represent more than
a four-fold increase over the current level.  This would enable
accomplishment of the activities  related to a fully satisfactory program.
Nevertheless, it is not considered advisable to add personnel at a
rate greater than they can be properly recruited, trained and assimilated
into the program.  In view of this, a phased increase is recommended.
     This means that priorities must be established in order to meet
the pressing responsibilities of the water supply program.  Among
these  critical activities are:
     1.  On-site inspections  (with written report) of community water
         supplies at least annually.

     2.  Follow-up inspections to  check  compliance with recommendations.
      3.   Frequent  comprehensive reviews  of bacteriological  and  chemical
          sampling  records with prompt  follow-up  on  those  failing to meet
          sampling  and  quality standards.

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                               77


     4.   Detailed plan review with on-site inspection of construction.


     5.   Review of operating reports with follow-up on those indicating

         problems.


     The first priority should be to accomplish the above tasks  for the

704 community water supplies (categories A, B, C and D).  The following

proposed staffing pattern would make this possible by the end of FY 1976.

Full services for the small  public supplies could not be provided until

the final staff increments were made during FY 1977.


                             Technical  Staff

                                                                Staff at
Fiscal  Year           Start of FY           During FY           End of FY

    74                      4                   0                   4

    75                      459

    76                      9                   4                  13

    77                     13                   4                  17
Existing Staff
Start of FY
4
4
9
13
Clerical
1
1
3
5
To be
During
0
5
4
4
Staff
0
2
2
1
added
FY








    74                      101

    75                      123

    76                      325

    77                      5                   1                    6

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                                 78


        Budget Requirements for Engineering Surveillance


     To estimate the annual costs that this increased level of effort

would entail, the following breakdowns were used:

     a.  Average cost per professional per year:


         Salary                          $12,000
         Fringe Benefits                   2,500
         Travel                            2,000
         Training                            500*
         Misc. (office supplies
                office space,etc.)         1,000

                                         $18,000

         Administration Costs (2Q%)        3,600
                              TOTAL      $217600

*Training costs based on the premise that each professional should
receive at least five days of training per year to keep abreast of
new developments.

     b.  Average cost per clerical employee per year:

         Salary                            $6,000
         Fringe Benefits                    1,500

                                           $7,500

         Administration Costs (20%)         1.500
                                           $9,000


     The recommended staff and budget for the water supply program are

summarized below.

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Professional
4
9
13
17
Clerical
1
3
5
6
Total
5
12
18
23
                               79

                   Staffing - Engineering Surveillance

FY                 Staff at End of FY
74
75
76
77
                    Budget - Engineering Surveillance
                              Additional Costs       Program Costs
£1                            Added During FY        at End of FY
74                                  -                 $59,800 (estimate)
75                              $161,600             $221,400
76                              $104,400             $325,800
77                               $95,400             $421,200
     A fully effective engineering surveillance program to insure that
Colorado's citizens and visitors are served safe drinking water would
require an annual expenditure of $421,200.  This represents $600 per
community water system or about 18 cents per capita - over seven times
the amount allocated to the present program.
                              Organization

     The Engineering Section Chief is responsible for directing and
coordinating the water supply program as well as the other activities
of the Section.  In terms of the water supply program's present level
of staff and activity this has  been a satisfactory approach.   Nevertheless,

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                               80
as the water supply program expands, as recommended by this evaluation,
a larger and larger administrative burden will  be placed on the Section
Chief.  This could result in decreased coordination and a less efficient
organization.  It is recommended, therefore, that a Water Supply Section
be formed within the Engineering and Sanitation Division to be responsible
for all activities concerning public water supplies.
     To make the water supply activities more responsive to the needs
of the communities and people, it is further recommended that the
proposed Water Supply Section be decentralized.  As a minimum, district
offices should be established in two locations  in western Colorado
such as Durango and Glenwood Springs.   Offices  in the Pueblo and Greeley
areas could also be beneficial.  This would allow the engineers to provide
better coverage of their districts resulting in an overall  improvement
of surveillance as well as an increased ability to respond  to emergencies.
Better coordination with the local  health departments could be achieved.
Hopefully these organizational changes would also serve to  increase
the visibility of the water supply program and  re-establish its importance.
                  Laboratory Support - Bacteriological
     The State and local health departments' laboratories conduct
approximately 24,000 bacteriological tests each year for water supplies,
This costs about $48,000 using the State's estimate of $2.00 per sample.
In addition, Denver, Colorado Springs, and Aurora are doing much of
their own testing for official purposes.
     As shown by Table 6 the expanded water supply program would be
testing about 20,000 more samples each year.  This would result in

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                                        TABLE  6
                        Bacteriological  Testing  Requirements

Water Supply
 Category
    A
    B
    C
    D
    E (Small Residential)      """                    ""                     "  ""                     °°
    E (Supplies Serving
      Traveling Public)
    Individual
                                                                           43,380

*Assumes that these supplies operate on a seasonal  basis.
Number of
Supplies
26
113
255
310
100
800
60,000
for Aurora,
Samples Req'd
Per Month
1,200
400
510
620
200
1,600
Colorado Springs and Denver
Samples Req'd
Per Year
14,400
4,800
6,120
7,440
2,400
6,400*
8,000
49,560
-6,180

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                               82

an additional annual  expenditure of at least $40,000.   Obviously,
additional staff at both the State and local laboratories  would be
necessary.
     This impact could be alleviated to some degree by allowing the
category A supplies to do their own bacteriological testing.   The
Department's responsibility, in this case, would be to assure that the
analyses are performed properly, which could be accomplished  through
the laboratory certification program.  Further monitoring  could be
achieved by conducting at least five percent of the monthly requirements
at the State and local health department laboratories.  A  decrease of
about 8,000 samples (and $16,000} would result, but 23 more laboratories
would have to be evaluated every three years.  At $500 per evaluation this
would cost approximately $4,000 each year but would still  represent a
net savings as compared to testing the samples.  This approach also
would allow closer surveillance of the smaller supplies where most of
the quality problems occur.  A cost summary of the proposed program is
shown below:
     Bacteriological Analyses:
       36,000 samples/yr. x $2.00/sample = $72,000/yr.
       72,000 + 20% x $7'2-,000 (Administration) = $86,400/yr.

     Laboratory Evaluation (on a triennial basis):
       39  laboratories  (local health departments and A supplies)
       x  $500/evaluation = $19,500  = $6,500/yr.
                             3
       $6,500 + 2Q% x $6,500 (Administration)  = $7,800/yr.
     TOTAL  = $94,200/yr.

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                                83

                    Laboratory  Support - Chemical

     The present chemical laboratory is hard-pressed to analyze the
nearly 450 water samples from public water supplies each year in
addition to their many other duties.  If the current sampling schedule
is adhered to, the expanded water supply program would place an impossible
burden upon the laboratory facilities which are already overcrowded
and understaffed.  To lessen this problem, the following sampling
schedule is recommended;
     Community Water Supplies (categories A, B. C. and D)
        Surface Water Sources - Every Year
        Ground Water Sources  - Every 3 Years
     Small Public Water Supplies (category E) - Every 5 years

     This means that approximately 520 samples would be analyzed
annually in Colorado (see Appendix J).   Additional analyses may be
necessary if sources have constituents  approaching or exceeding the
Drinking Water Standards.  Appendix J also indicates what this type of
monitoring program would require in terms of staff and budget.  A total
of eight man-years at an approximate annual cost of $172,800 would be
required to implement an adequate chemical  quality surveillance program.
This program could be phased in over a  three to four year period.
     The annual cost of the program could be reduced by conducting
only partial  analyses once a data base  has  been established for the
supplies.  For example, perhaps only the trace elements would be
conducted on a routine basis.  This eould save about $470 on each

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                               84
surface water sample and $180  on each ground water sample.   This  would
also allow more frequent analyses of water from problem areas.
     The present laboratory facilities are extremely crowded which
reduces efficiency and total capability.   Consideration should  be given
to expanding the existing facilities.  Decentralization of all  laboratory
services could also prove beneficial.  This in concert with decentrali-
zation of the engineering services could  greatly improve surveillance
of public water supplies.

                           Data Management

     Due to the immense quantity of data the expanded water supply
program will have to collect, review and file it is recommend that
serious consideration be given to the use of ADP.  A number of state
water supply programs are now using some form of ADP, so information
on how to set-up a system could be obtained.  This would certainly
reduce much of the time-consuming bookkeeping procedures now being
used for bacteriological, chemical and fluoride surveillance data.
The engineers would have quick access to a wide range of information
and allow them to keep better track of problem areas.

                Summary of Water Supply Program Costs

     Table  7 summarizes the estimated budget requirements for the
proposed Water Supply Branch  and compares them with the present  level
of funding.  The proposed budget would triple the  current  expendi-
tures  which is  a true  indication  of the  inadequacy at  the

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                              85
present program.   Colorado can no longer affort to overlook  the
importance of the water supply program and continue to shirk its  respon-
sibilities to protect the public health of its citizens.

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                                  86
                               TABLE 7
                    Water Supply Program Budgets
          Estimated Budget of Proposed Water Supply Program
Water Supply Branch
  Engineering Surveillance
Laboratory Support
  Bacteriological Surveillance
  Bacteriological Laboratory
    Certification
  Chemical Surveillance
Program Administration (20% of
  above costs)
                                     TOTAL
                                             or
$351,000

 $72,000

  $6,500
$144,000

$114,700
$688,200
$978/conmunity water supply
$0.29/capita
           Estimated Costs of Present Water Supply Program
Engineering Section
  Engineering Surveillance
Laboratory Support
  Bacteriological Surveillance
  Bacteriological Laboratory
    Certification
  Chemical Surveillance
Program Administration (20% of
  above costs)
                                     TOTAL
                                             or
 $59,800

 $55,200

  $1,800
 $79,200

 $39.200
$235,200
$330/community water supply
$0.10/capita

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REFERENCES (XTE

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                                87
                           REFERENCES CITED

 1.   Bureau of Water  Hygiene,  U.S.  Public Health Service.
     Community Water  Supply Study  - Analysis of National Survey
     Findings.  Washington, D.C.,  Government Printing Office
     1970. Ill p.

 2.   Craun, 6.F. and  L.J. McCabe.   Review of the Causes of Water-
     borne Disease Outbreaks.  American Water Works Association
     Journal 65:74-78.

 3.   U.S. Public Health Service.   Drinking Water Standards.
     Uashington, D.C., Government  Printing Office, 1962. 118 p.

 4.   Bureau of Water  Hygiene,  Environmental Protection Agency,
     Region IV.  Evaluation of the Tennessee Water Supply
     Program.  Atlanta, Government Printing Office, 1971. 208 p.

 5.   Bureau of Water  Hygiene,  Environmental Protection Agency,
     Region IV.  Evaluation of the Kentucky Water Supply
     Program.  Atlanta, Government Printing Office, 1972. 228 p.

 6.  Water Supply Branch, Environmental  Protection Agency,
     Region VIII.   Evaluation of the Wyoming Water Supply
    Program.  Denver, Government Printing Office, 1972. 236 p.

 7.  Jeffco Water Wells Contaminated.   Rocky Mountain News
     (Denver, Colorado), February 2, 1974.

8.  Monarch!,  David.   County Population Methods  and Estimates -
    1971 and 1972.   Colorado Population Trends  2:1-7.   Winter,
    1973.

9.  Great  Lakes  - Upper Mississippi River Board  of State Sanitary
    Engineers.   Recommended Standards  for Water  Works.   New York,
    Health Education  Service,  1968. 87  p.

10.  American Public  Health  Association, Standard  Methods for the
    Examination of Water and Wastewater.  13th ed.  New  York,  1971.
    874 p.

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ACKNOWLEDGEMENTS

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                       ACKNOWLEDGEMENTS


     The assistance and cooperation  of the  following  people  are

gratefully acknowledged:


       Mr. William Gahr,  Director, Engineering  and  Sanitation
         Division, Colorado Department of Health

       Mr. George Prince, Chief,  Engineering  Section,  Engineering
         and Sanitation Division, Colorado  Department  of Health

       Mr. Ralph Leidholdt, Water Supply Specialist,  Engineering
         Section, Engineering and Sanitation  Division, Colorado
         Department of Health

       Mr. Paul  Haswell,  Assistant Chief, Ground  Water Section,
         Division of Water Resources,  Colorado  Department  of
         Natural Resources

       Mr. Roger Lee, Chief, Surveillance and Technical Assistance
         Section, Water Supply Division, Office of  Water Programs,
         Environmental Protection Agency, Washington,  D.C.

       Mr. Albert V. Soukup, Chief,  Water Supply  Section,  Control
         Technology Branch, Water Division, Environmental  Protection
         Agency, Region VIII

       Mr. Dean R. Chaussee, Water Supply Engineer, Water  Supply
         Section, Control Technology Branch,  Water  Division,
         Environmental Protection Agency, Region  VIII

       Mrs. Caryl Phillips, Secretary, Control  Technology  Branch,
         Water Division, Environmental Protection Agency,  Region VIII


     A special thanks is expressed  to all the public  health  engineers

of the Engineering Section, Colorado Department of  Health  who  provided

much information and cooperated generously  in the evaluation.

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APPENDICES

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                 A  P.  P.IH  2  I X.    A

11 £ 1    H-  i-  P..  H..  S.     p. R  L N_ K  1 N. G
         WATER    STANDARDS

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       Tuesday, March tf, 1962
                          89

                    APPENDIX A

1962  U.S.P.H.S.   Drinking  Water  Standards
                                                                                                                    2152
   Title 42— PUBLIC HEALTH

Chapter  I— Public  Health  Service,
   Department of  Health,  Education,
   and  Welfare

PAiF 72— JNTERSTATE  QUARANTINE

     Drinking  Water Standards
  On July  27, 1961. notice of proposed
nue  making relating to the revision of
the  regulations In this  Subpart  J—
p-nkinsr Water Standards, and a re-
lated section was published in the  FBD-
«ML RCCISTIR  (28 r.B.  GY37J.   After
consideration of all relevant matter pre-
sented  regarding the proposed revision,
the  regulations as so  published  are
adopted, to become effective 30 days after
the  publication ol this  no'-lce in the
FEDIRAL REGISTER, subject to the changes
set out below.
  1.  Section 12,203: The  words "Figure
I" are  added  Immediately  below  the
graph in this section.
  3.  Section  7a.805(b)a>:  The  word
'fluoride"  Is substituted  for the word
'flourtde*  appearing  In  the  table  tn
Paragraph I.
   3. Section 72.206 (b) (2) : The concen-
tration in mg/1 for  chromium (Hexa-
valenti shown in the table Is amended to
read "0.05".
   4. Paragraph   (b)  ot   5 12.206  Is
amended.

   Dated:  February 21, 1962.
   [WAI]          Ltmoa L. TBIUJY,
                    Svrffeon General.
   Approved: February 28, 1962,
     ABRAHAM Roiconr.
       Secretary.
 § 72,1  lAntendmenl]
   l. Secttdn 73.1(11 is amended to readt
   <1>  Potable  water.  Water   which
meets  the standards prescribed  in the
 Public Health Service Drinking Water
 Btandwrda (see Bubpart  J ol this part).
   2 Subpart J Is amended to read as
 follows:

 Subpart J— Drinking Water Standard*
 See.
 "SOI  Definition of terms.
 I»-30a  Soutc* and protection.
        Bacteriological quality.
        phyrieal cfcaracterlBtlcs.
        CbtmlcU
        Ra«o*ctlTlty,
        Recommended. Uklytlccl method*.
   AOTHOMTT:  || 79.301   to  Tfl.307  Iciued
  wwto »«c. an, 68 Sttrt. 600, M mn«>  "Certifying Authority" means the
            Surgeon General cf  the United States
            Public Health Service or his  duly au-
            thorized  representatives. Reference  to
            the certifying  authority is  applicable
            only for those water supplies  to be cer-
            tified for use on carriers subject to this
            part.
              (d) "The ooliform group" includes all
            organisms considered  in the conform
            group as set forth in Standard Methods
            fov the  Examination of  Water  and
            Wastewater,  current  edition,  prepared
            and published jointly by the American
            Public Health  Association,  American
            Water Works Association, and Water
            Pollution Control Federation,
               "Health hasatds" mean any con-
            ditions, devices, or practices in the water
            supply system and  its operation which
            create, or may create, a danger to the
            health and well-being of the water con-
            sumer.  An example of a health hazard
            la a structural defect in the water sup-
            ply system, whether of location, design,
            or construction, which may regularly or
            occasionally prevent satisfactory purifi-
            cation of the water supply or  cause it to
            be polluted from extraneous sources.
 _.«>  ^Buttonw.  as  used  in  these
 Standards, means the presence of any
 foreign substance  (organic. Inorganic
 radiological,  or  biological)  in  water
 which tends to degrade its quality so as
 to constitute a hazard or impair the use-
 fullness of the water.
   (g)  "Reporting agencies" means  the
 respective official State health agencies .
 °r their designated representatives.
   (h)  '-The standard sample"  for  the
 bacteriological test shall consist of-
   (!)  For the bacteriological

   *              <
      Ten milUlitm uo ml>
   Cii) One hundred miliuiters   "Water  supply  system"  includes
the works and auxiliaries for collection
treatment, storage, and  distribution of
the water from the sources of waply to
the free-flowing outlet of the ultimate
consumer.

§72.202  Source and protection.
   (a) The water supply  should be ob-
tained from the  most desirable source
which is feasible,  and effort should be
made to prevent or control pollution of
the source.  If the source is not ade-
quately  protected by natural means, the
supply shall be adequately protected by
treatment.
   (b} Frequent  sanitary  surveys  shall
be made of the water supply system to
locate and identify health hazards which
might exist in the system. The manner
and frequency of making these surveys.
and the rate at which discovered health
hazards are to be removed shall he In
accordance with a program approv.   Approval of water supplies shell
be dependent in part upon;
  (1)  Enforcement of rules and regu-
lations to prevent development of health
hazards;

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Tuesd<
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 2154

 In  any month shall  show the presence
 or  the coliform group.  The presence of
 the colifonn croup  In  all  five  of the
 100 ml portions of a standard  sample
 shall not be allowable a this occurs:
   (1) In two consecutive samples;
   (11)  In more  than one  sample per
 month when less than flve are examined
 per month; or
   (ill) In more than 20 percent of the
 samples when five or  more are examined
 Per month.

 When organisms of the coliform group
 occur  in all  flve of the 100  ml portions
 01  a single standard  sample, daily  sam-
 ples from the same sampling point shall
 pe  collected promptly and examined un-
 til  the results obtained from at least two
 consecutive samples  show the water to
 be  of satisfactory quality.
  (3)  When the membrane  filter tech-
 nique Is used, the arithmetic mean eoll-
 rorm density of all standard  samples ex-
 amined per month shall not exceed one
 Per 100  ml.  Coliform   colonies  per
 standard sample shall not exceed 3/50
 ml. 4/100 ml. 7/200 ml, or  13/500 ml In:
  (i> Two consecutive samples;
  (11)  More  than one standard sample
 wnen  less than 20  are  examined per
 month; or
  (111) More than flve  percent  of the
 standard samples when 20 or more are
 examined per month.

 When coliform colonies In a single stand-
 ard sample exceed the above values, dally
 "*mP1« *rom the same  sampling point
 , «) be.coll«ted promptly and examined
 antil the results obtained from at  least
 two consecutive samples show the water
 to be of satisfactory quality.
 S 72.204  Physical eharaclerhties.
  (a) Sampling.   The  frequency  and
 manner of sampling shall be determined
 oy -the reporting agency and the certi-
 fying authority.  Under normal circum-
 stance* samples should be collected one
 or more times per week from represent-
 «SI* polnt8  m tbe distribution system
 and  examined  for   turbidity,  color,
 "^snold odor, and taste.
 «.«i. •   m'**-  Drinklng  water  should
 contain no impurity which would cause
 r?^!86 w the  sense  of sight, taste,  or
 smell.  Under general use,  the following
 Umits should not be  exceeded:
  TurbWlty-SunlU.
  Color—15 unite.
  Threshold odor number—3.
 § 72.205  Chemical charocteristics.
   Sampling,    a)  The  frequency
 *nj! manner of sampling shall be deter-
 ™med,by the reporting agency and the
 M™ *  ^ ftuth°r%-  Under normal cir-
     anc«.  analyses  for  substances
      ,below  "«ed.be made  only semi-
      lly.   if,  however,  there  is  some
 presumption of unfltness because of the
 Presence of undesirable elements, corn-
 Pounds, or  materials, periodic  deter-
minations for the suspected toxicant or
material should be made mere frequent-
 y and  an exhaustive sanitary survey
^ould be made to determine the source
w ine pollution.  Where the  concentra-
"on of a substance is not expected to
"wrease in processing and distribution.
                    91

      RULES AND REGULATIONS

 available and acceptable source water
 analyses performed In accordance with
 standard methods may be used  as evi-
 dence of compliance with these  Stand-
 ards.
   (2)  Where experience, examination,
 and  available  evidence  Indicate  that
 particular  substances  are consistently
 absent from a water  supply  or below
 levels of concern, semi-annual examina-
 tions  for  those   substances  may  be
 omitted when approved by the report-
 ing agency  and the certifying authority.
   (3)  The  burden of  analysis may  be
 reduced in many  cases  by  using  data
 from  acceptable   sources.   Judgment
 concerning  the quality of water supply
 and  the  need  for performing specific
 local analyses may depend  in part  on
 Information produced by such agencies
 as <1) the U.S. Geological Survey, which
 determines  chemical quality of surface
 and ground waters of the United States
 and publishes these data In "Water Sup-
 ply Papers" and other reports, and (11)
 the U.S.  Public Health  Service which
 determines  water quality related  to pol-
 lution (or the absence of pollution)  in
 the principal rivers of the Nation and
 publishes these data annually In "Na-
 tional Water Quality Network."  Data
 on pollution of waters as measured  by
 carbon chloroform extracts (CCE)  may
 be found in the latter publication.
     The  presence  of the  following
substances in excess  of the concentra-
tions listed shall constitute grounds for
rejection of  the supply:
                           Concentration
            Substance.        in mall
 Arsenic  (As) -------------------    * o 
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Tuesday, March 6, 1962

recommended by the  Federal Radiation
Council and approved by the President.
Water supplies shall be approved with-
out  further  consideration  of  other
sources of radioactivity  intake  of  Ra-
dium-226  and Strontium-90 when the
water  contains  these  substances in
amounts not exceeding 3 and 10 ^pc/liter.
respectively.  When these concentrations
are exceeded, a water supply shall be
approved  by  the certifying authority if
surveillance of  total  intakes of  radio-
activity from all sources indicates  that
such intakes  are within the limits  rec-
ommended by'  the Federal  Radiation
Council for control action.
  (2) In the known absence* of Stron-
tium-90 and  alpha emitters, the water
supply Is acceptable when the gross  beta
concentrations do not exceed 1,000  upc/
liter.  Gross  beta concentrations in ex-
cess of 1.000 p/tc/llter shall be grounds for
rejection  of  supply except when more
complete analyses Indicate that concen-
trations of nuclldes  are  not likely to
cause exposures  greater than the Radia-
tion Protection  Guides as  approved by
average exposures of suitable samples of an
exposed population group will not exceed the
upper value of Range n (30 **c/day of Ha-
dlum-226 and 200 /me/day of 8trontlum-80)."
  • Absence U taken here to mean a negligi-
bly small fraction of the above specific limits,
where the limit for unidentified alpha emit-
ters U taken as the listed limit for Radium-
226.
                 92

         FEDERAL  REGISTER

the President on recommendation of the
Federal Radiation Council.
§ 72.207  Recommended analytical
     methods.
  (a) Analytical  methods to determine
compliance  with the  requirements of
these Standards shall be those specified
in Standard Methods for the Examina-
tion of Water and Wastewater. Am. Pub.
Health Assoc.. current edition and those
specified as follows:
  (1) Barium: Methods for the Collec-
tion and Analyses  of Water Samples.
Water Supply Paper No.  1454.  Rain-
water, F. H.  &  Thatcher.  L.  L., UJ3.
Geological Survey, Washington, D.C.
  (2) Carbon   Chloroform  Extract
(CCE): Manual for Recovery and Iden-
tification of   Organic   Chemicals  in
Water, Middleton, F. M.. Rosen, A. A.,
and Burttscbell,  R. H.. Robert A. Taft
Sanitary Engineering Center, PHS, Cin-
cinnati, Ohio.
  (3) Radioactivity: Laboratory  Man-
ual   of  Methodology,   Radlonucllde
Analyses  of  Environmental  Samples,
Technical  Report  RB9-6.  Robert  A.
Taft Sanitary  Engineering Center. PHS,
Cincinnati, Ohio,  and Methods of Radio-
chemical Analysis, Technical Report No.
173, Report of  the Joint  WHO-PAO
Committee, 1959,  World Health Organi-
zation.
  (4) Selenium:  Suggested  Modified
Method for Colorimetric Determination
                                 2155

of Selenium in Natural Water, Magln,
G. B.. Thatcher, L. L., Rettig,  8., and
Levine. H., J. Am.  Water Works Assoc.
59,1199 (I960).
  (b)  Organisms of the coUform group.
All of the details of techniques in the
determination of bacteria of this group.
Including the selection and preparation
of apparatus and media,  the  collection
and  handling of samples and the inter-
vals  and conditions of storage allowable
between collection  and examination of
the water sample, shall be in accordance
with Standard Methods for the  Exami-
nation of Water and Wastewater, cur-
rent edition, and the procedures shall be
those specified therein for:
  (1) The Membrane Filter Technique.
Standard Test, or
  (2) The Completed Test, or
  (3) The Confirmed Test, procedure
with brilliant green lactose bile broth,'
or
  (4)  The Confirmed Test, procedure
with Endo or eosln methylene blue agar
plates.1

(Fit.  Doc.  02-3191;  Filed,  liar. B. 1882;
              8:49 ajn.)
  •The Confirmed Test Is allowed, provided
the value of this test to determine the sani-
tary  quality of  the specific  water  supply
being examined  1*  established beyond rea-
sonable doubt by comparisons  with Com-
pleted Test* performed on the  same water
•upply.

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 A P. P.E.N.J) i X. £

ML^NJ.TY,  WATE.R.
IN  COLORADO

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                                  93
                             APPENDIX  B
                               TABLE 1
           Summary - Community Water Supplies  In  Colorado
Population
Range
Served
Over 10,000
1,000 - Under
10,000
100 - Under
1,000
40 - Under 100
TOTAL
Number
CWS I/
26
113
255
31 Ol/
704
Percent
of
Total
4%
16%
36%
44%
100%
Population
Served
1,622,000
363,000
98,000
25.0002/
2,108,000
Percent of
Pop. Served
by CWS
77%
17%
5%
1%
100%
]_/ CWS - Community Water Supply
2/ Estimate

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APPENDIX B
TABLE 2
Summary of the 394 Community Water Supplies Under
Routine Surveillance as of January, 1973
(By Population Range Served)
Population
Range
Served
Over 10,000
1,000 - Under
10,000
100 - Under
1,000
TOTAL
Number
of
CWS
26
113
255
394
Percent
of
Total
7%
28%
65%
100%
Population
Served
1,622,000
363,000
98,000
2,083,000
Percent of
Pop. Served
by CWS
78%
17%
5%
100%
Number of
CWS
Disinfected
26
100
190
316
Percent of
CWS
Disinfected
100%
88%
75%
80%
Percent of Population
Using CWS Served
Disinfected Water
100%
89%
76%
97%
vo

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APPENDIX B
TABLE 3
Summary of the 394 Community Water Supplies Under
Routine Surveillance as of January, 1973
(By Source of Supply)
Source
of
Supply
Surface
Ground
Combined!/
TOTAL
Number
of
CWS
145
242
7
394
Percent
of
Total
37%
61%
2%
100%
Population
Served
1,614,000
346,000
123,000
2,083,000
Percent of
Pop. Served
By CWS
78%
16%
6%
100%
Number of
CWS
Disinfected
139
170
*
316
Percent of
CWS
Disinfected
96%
70%
100%
80%
Percent of Population
Using CWS Served
Disinfected Water
99%
83%
100%
97%
                                                                                                                       vo
                                                                                                                       01
!_/  Using Both  surface and ground sources

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     £2 M Ml IX WAT££  iH.
£ A ! LI N. i  iA£Iiilo.k0.iICAL.
               IN  1972

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                                               APPENDIX C
                   Community Water Supplies Failing Bacteriological Standards in 1972
                                     1.   By Population Range Served
Population
Range Served
Over 10,000
1,000 - Under
10,000
100 - Under
1,000
TOTAL

Source
of Supply
Surface
Ground
Combined
TOTAL
Number of
CWS*
26
113

255
394

Number of
CWS*
145
242
7
394
Number
Failing
4
84

64
102
2. By
Number
Failing
50
52
0
102
Percent
Failing
15%
30*

25%
26%
Source of Supply
Percent
Failing
34%
22%
0
26%
Population
Served
149,000
104,000

28,000
281 ,000

Population
Served
213,000
68,000
__
281 ,000
Number of These Failing
Having no Disinfection
0
4

22
26






Number of Those Failing
Having No Disinfection
8
18
— •»
25



                                                                                                               to
*CWS - Community Water Supplies - Includes only the 394 supplies under routine surveillance as of January 1973.

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                                                         APPENDIX       D
COLORADO        W • A   T   £  R       !S   U   P   P   L   Y        LEGISLATION

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                                 97

                             APPENDIX D

                  Colorado Water Supply Legislation
                             CHAPTER 66

                              ARTICLE 1

                     DEPARTMENT OF PUBLIC HEALTH


        66-1-7.  POWERS AND DUTIES OF THE STATE DEPARTMENT OF PUBLIC HEALTH--
(1)  The state department 01 public health shall have and exercise,.in addition
to all other powers and duties imposed upon it by law, the following powers
and duties:

        (6)  To establish and enforce minimum general sanitary standards as
to the quality of water supplied to the public, including the authority to
require disinfection of such water, and to advise with municipalities,
utilities, institutions, organizations, and individuals, concerning the methods
or processes believed best suited to provide the protection or purification of
water to meet such minimum general sanitary standards; and also to establish
and enforce minimum general sanitary standards as to the quality of wastes
discharged upon land and as to the quality of fertilizer derived from excreta
of human beings or from the sludge of sewage disposal plants;

        (9)  To establish,  maintain and approve chemical, bacteriological and
biological laboratories, and to conduct such laboratory investigations and
examinations as it may deem necessary or proper for the protection of the
public health;

        (10)  To make, approve and establish standards for diagnostic tests
by chemical, bacteriological and' biological laboratories, and to require such
laboratories to conform thereto; and to prepare, distribute and require the
completion of forms or certificates with respect thereto;

         (19)  The phrase "minimum general sanitary standards" as used in
this section shall mean the minimum standards reasonably consistent with
protection of the public health, and in the case of minimum general sanitary
standards as to the quality of water supplied to the public,  the same shall
in no event be less than the drinking water standards of the  United States
Public Health Service.  The word "standards" as used in this  section shall
mean standards reasonably designed to promote and protect the public health;

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                                   98
             (20)  (a)  To examine plans,  specifications,  and other related data
    pertaining to  the  proposed  construction of any and all publicly or privately
    ownel community water facilities submitted for review of sanitary engineering
    features prior to  construction of such facilities.


              66-1-8.  POWERS AND DUTIES OF THE STATE  BOARD OF HEALTH.  -  -  (1)   In
    addition  to all other powers and duties conferred and  imposed  upon the  state
    board of  health by  the provisions of  this article,  the board  shall have and
    exorcise  the  following specific  powers and duties:
              (5)  (a)   To  issue  from  time  to   ime  such  orders,  to  adopt  such

     rules and regulations,  and to establi«u such standards as the board may deem
     necessary or proper to  carry out the provisions and purposes of this article and
     to administer and enforce the public health laws of this state.


              66-1-14.   UNLAWFUL ACTS --PENALTIES.  --(1)   (a)   It  shall  be  unlawful
     for  any  person,  association,  or  corporation,  and the  officers thereof:

              (b)   To willfully violate,  disobey  or disregard  the  provisions of  the
     public health laws or the terms  of .any lawful notice,  order,  standard, rule  or
     regulation  issued  pursuant  thereto;  or


            (i)   To make,  install, maintain,  or permit any cross-connection
 between any  water system supplying drinking water to the public  and any pipe,
 plumbing fixture, or water  system which contains water of a quality below the mlnimuffi
 general sanitary standards  as to the quality of drinking water supplied to the
 public;  or to fail to remove such connection within ten days after being ordered
 in writing by the department to remove  the same.   For the purposes of this
 paragraph (1) (i), the term "cross-connection" shall mean any connection which
 would  allow  water to flow from any pipe,  plumbin'g fixture, or water system into
 a water system supplying drinking water to the public.  (Source:   Chapter 56,
 Pg.  478, Colo.  Session Laws, 1964).

           (4)  Any person,  association, or corporation, or the officers thereof, wh.P
shall violate any  provision of  this  section, upon conviction, shall be  fined not
to exceed one thousand dollars  or be imprisoned 'for  not to exceed one year, or
he both  fined and  imprisoned, and in addition to such  fine and imprisonment shall
be liable for any  expense incurred by health authorities in removing any nuisance,
source of filth, or cause of  sickness.  Conviction under the penalty provisions
of this article or any other  public health law shall not relieve any person from
any civil action in damages that may exist for an injury resulting  from any
violation of  the public health  laws.

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                               99
(Reproduced by the Colorado Department of Health)



                                CHAPTER 66

                                ARTICLE 38



              PROVIDING FOR THE CERTIFICATION OF WATER AND

                  WASTEWATER TREATMENT PLANT OPERATORS


66-38-1.   Legislative declaration.             66-38-6.  Wastewater treatment
66-38-2.   Definitions.                                  plant operator.
66-38-3.   Plant operators certification       66-38-7.  Certification procedure.
           board - composition.                66-38-8.  Fees.
66-38-4.   Duties of the board.                66-38-9.  Use  of title.
66-38-5.   Water treatment plant operator.     66-38-10.  Violations - penalty.


      66-38-1.  LEGISLATIVE DECLARATION ~ To assure adequate operation of water
and wastewater treatment facilities,  and to preserve the  public peace, health,
and safety, the provisions of this article and regulations  authorized pursuant
thereto are enacted to provide for the examination,  classification, and certi-
fication of water and wastewater treatment plant operators  and to establish
minimum standards therefor based upon their knowledge and experience, to provide
procedures for certification, to encourage vocational education for such op-
erators, to provide a penalty for the wrongful use of the title "certified
operator", to require each water and  wastewater treatment plant to be under the
supervision of a certified operator,  to provide for  the classification of all
water and wastewater treatment plants in the state,  and to  provide a penalty for
the operation of a water or wastewater treatment plant without supervision of
a certified operator.

      66-38-2.  DEFINITIONS.--(1)  As used in this article, unless the context
otherwise requires:

      (2)  "Board"means the plant operators certification board.

      (3)  "Certificate" means the certificate of  competency  issued by the board
stating that the operator named thereon has met the requirements for the speci-
fied operator classification of the certification  program.

      (4)  "Certified operator" means the person who has  direct responsibility
for the operation of any treatment facility covered under this article and is
certified in accordance with the provisions of this article.

      (5)  "Department" means the Colorado department of  health.

      (6)  "Wastewater treatment plant" means the  facility  or group of units
used for the treatment of wastewater from sewer systems and for the reduction
and handling of solids and gases removed from such wastes.

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                                100
Providing for the Certification of Water
and Uastewater Treatment Plant Operators
Chapter 66, Article 38
Page 2

     (7)  "Water supply system" means the system of pipes, structures, and
facilities through which a water supply is obtained, treated, and sold or dis-
tributed for human consumption or household use.

     (8)  "Water treatment plant" means the facility or facilities within the
water supply system which can alter the physical, chemical, or bacteriological
quality of the water.

     66-38-3.  1'IANT OPERATORS CERTIFICATION BOARD - COMPOSITION.--(1)  (a)  There
is hereby created the plant operators certificntion board which shall constitute
a section of the division of administration of the department and shall consist
of nine members, five of whom shall be as follows:

     (b)  A certified Class A water treatment plant operator;

     (c)  A certified Class A wastewater treatment plant operator;

     (d)  A representative from the Colorado municipal league;

     (e)  A representative recommended by the Colorado board of health;

     (f)  A representative recommended by the Colorado water pollution control
commission.

     (2)  All members of the board shall be appointed by the governor.

     (3)  Appointments to the initial board shall be as follows:

Three of the members shall be appointed for a three-year term, three for a two-
year term,  and three for a one-year term.   Thereafter all board members shall serve
for a term of three years.  No member shall serve continuously on the board for
more than nine years.

     66-38-4,  DUTIES OF THE BOARD.—(1)  The board shall elect a chairman and  -
secretary each year, establish" rules and regulations setting forth the requirements
governing application, admission to the examinations, and recording and issuing of
certificates for the class of operator for which the applicant is found to be qual-
ified.   The board shall furnish the examination material and collect fees  as set
forth in section 66-38-8.   The board shall set  the times, dates,  and places for
holding examinations,  one of which shall'be given at least annually, grade exami-
nation papers, and evaluate work experience of  applicants.  The board shall maintain
an office provided by the department for contact with operators and employers to
receive applications and fees, conduct such examinations as may be directed by the
board,  record the results thereof, notify applicants of results,  issue certificates.
and prepare and distribute an annual report.

    . (2)  The board shall promote and assist in regular training schools and pro-
grams designed to aid applicants and other interested persons to acquire the nec-
essary knowledge to meet the certification requirements of this article.

     (3)  The board shall establish not less than four classes of certified water
treatment plant operators and not less than four classes of wastewater treatment
plant operators, which classes shall differentiate the various levels of complex-
ity to be encountered in water and wastewater treatment plant operation.

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                              101
 Providing  for the Certification of Water
 and Wastewater Treatment Plant Operators
 Chapter  66, Article 38
 Page  3

       (4)  The board shall, after due consideration,establish for each water and
 wastewater treatment plant a minimum class of certified operators required for
 its direct supervision.  Compliance for all such treatment plants shall be
 mandatory by January 1, 1976.

       (5)  The board shall establish a procedure whereby any decision of the
 board can be subject to appeal.

       (6)  The board shall exercise such other powers and duties as are deemed
 necessary within the scope of this article.

       (7)  Members of the board shall serve without compensation, but shall be
 reimbursed for their necessary expenses.

       (8)  The board shall exercise its powers and perform its duties and
 functions as if it were transferred to the department by a type 1  transfer under
 the "Administrative Organization Act of 1968", being article 28 of chapter 3.
 C.R.S. 1963.

      66-38-5.   WATER TREATMENT PLANT OPERATOR.—(1) (a) Persons who by exami-
 nation and experience are found to be qualified for certification as water
 treatment plant operators shall be certified as having the minimum qualifications
 required for each of the respective classes, as follows:

      (b)  Class D.  An applicant must indicate by written examination his
 knowledge of basic water treatment principles, chlorination procedures, bacter-
 iological testing techniques and standards.department water quality standards,
 pumping and storage principles, and good housekeeping and safety practices.

      (c)  Class C.  In addition to the knowledge required for a Class D. appli-
 cant, the Class C applicant must indicate by written examination his knowledge
 of control procedures,  including but not limited to the purpose, use, and
 procedures used for the basic chemical, physical, and biological tests.  The
 applicant must  also have two years' experience working in a water treatment
 facility.

      (d)  Class B.  In addition to the knowledge required for a Class C appli-
cant, the Class B applicant must indicate by written examination his knowledge
of the operation and maintenance of filter units, the principles of coagulation
and sedimentation,  the  maintenance and safety of auxiliary equipment, and the
principles of taste and odor control.   The applicant must also have three years'
experience working in a water treatment facility.

      (e)  Class A.  In addition to the knowledge required for a Class B appli-
cant, the Class A applicant must indicate by written examination his knowledge
of the interpretation of results of chemical, physical, and biological control
analyses; maintenance and operational  procedures; housekeeping; customer rela-
 tions; corrosion control; cross-connection control; and supervisory control
 techniques.  The applicant must also have four years'  experience working in a
water treatment facility.

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                               102
 Providing for  the  Certification of Water
 and  Wastewater Treatment Plant Operators
 Chapter  66, Article  38
 Page 4

      66-38-6.  WASTEWATER TREATMENT PLANT OPERATOR.—(1)  (a) Persons who by
 examination and  experience are found to be qualified for certification as waste-
 water treatment  plant operators shall be certified as having the minimum quali-
 fications required for  each of the respective classes, as  follows:

      (b) Class D.  A  Class D applicant must indicate by written examination
 his  knowledge  of basic  principles concerning pumping, grit, grease, sludge,
 sedimentation, hydraulics, chlorination, pumps, motors, state water pollution
 control  commission stream standards, and good housekeeping and safety practices.

      (c) Class C.  In addition to the knowledge required for a Class D appli-
 cant, the Class  C  applicant must indicate by written exandnation his knowledge
 of   wastewater treatment principles, settling characteristics of solids and grit,
 separate sludge  digestion, sludge processing, sampling, and basic chemical,
 physical, and  biological tests.  The applicant must also have two years'
 experience working in a wastewater treatment facility.

      (d)  Class B.  In  addition to the knowledge required for a Class C applicant,
 the  Class B applicant must indicate by written examination his knowledge of the
 maintenance and  operation of biological units, sedimentation units, and aux-
 iliary equipment,  and his experience in performing basic chemical, physical, and
 biological tests.  The  applicant must also have three years' experience working
 in a wastewater  treatment faciliiy.

      (e)  Class A.  In addition t_ the knowledge required for a Class B applicant]
 the  Class  A applicant must indicate by written examination his knowledge in
 the  interpretation of the results of chemical, physical, and biological control
 analyses;  maintenance and operational procedures; and record-keeping, customer
 relations, corrosion control, cross-connection control, and supervisory control
 techniques.  The applicant must also have four years' experience working in a
 wastewater treatment facility.

      66-38-7.   CERTIFICATION PROCEDURE.—(1)  Any individual possessing the "
 required  experience may apply to the board on such forms as required and
 furnished by the board.   The application shall be accompanied by such fee as
 required  by section 66-38-8.   The board shall admit for examination those appli-
 cants who meet the minimum qualifications as established by regulations of the
 board for certification.

      (2)  When  an individual desires certification in a field  other than that
 in which  he has experience,  his experience shall be evaluated by the board.
 The  certificate  issued  is to be based upon the knowledge demonstrated by the
 applicant through examination and his verified record of work experience in
water and wastewater treatment plant  operation.

      (3)  Certificates shall be awarded by the board for a period of five
 years only to  those applicants successfully meeting all of the  requirements.

      (A)  Certificates  shall be renewed upon payment of the required renewal
by the applicant or at  any transfer in  class accomplished by the applicant's
 successful completion of a board examination.
                                                                         •*
      (5)  The board, upon application  therefor, may  issue a certificate,
without  examination,  in  a comparable  classification to any person who holds  a
certificate in any  state,  territory,  or possession of the United  States or any
country, providing  the requirements for certification of operators under which

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                               103


Providing for the Certification of Water
and Wastewater Treatment Plant Operators
Chapter 66, Article 38
Page 5

the person's certificate was issued do not conflict with the provisions of this
article and are of a standard not lower than that specified by regulations
adopted under this article and providing further that reciprocal privileges
are granted to certified operators of this state.

      (6)  Certificates of proper classification shall be issued without exam-
ination, upon appropriate application, to applicants who have been the operators
of any facilities covered under this artlclo on or before July 1, 1973.  A cert-
ificate so issued shall be valid only for that particular treatment plant or
system and for the classification determined by the board on the basis of exper-
ience and education of the operator, and shall remain in effect unless revoked
by the board pursuant to the provisions of article 16 of chapter 3, C.R.S. 1963.

      (7)  Certification in an appropriate classification shall be Issued to
operators who on or before July, 1973, hold certificates of competency
attained by examination under the voluntary certification program within the.
state of Colorado during the time immediately preceding July 1, 1973.

      66-38-8.  FKES.—Each application for certification shall be accompanied
by a fee in the amount of fifteen dollars which is not refundable and  which
will include the expenses for the first examination taken by the applicant.
Examination fees in the amount of ten dollars shall be paid for each additional
examination taken in any class.  Re-examination fees in the amount of  ten
dollars will be paid for second and succeeding examinations in any class.
Renewal fees in the amount of five dollars shall be paid prior to the  issuance
of a renewal certificate by the board.  All moneys received by the board shall
be deposited with the department of the treasury pursuant to the provisions of
section 3-6-3, C.R.S. 1963.

      66-38-9.  USE OF TITLE.—Only a person who has been qualified by the board
as a certified water treatment plant operator or certified wastewater  treat-
ment plant operator and who possesses a valid certificate attesting to this
certification in this state shall have the right and privilege of using the
title "certified water treatment plant operator, Class 	" or "Certified
wastewater treatment plant operator, Class _,	".

      66-38-10. VIOLATIONS - PENALTY.—(1)  It is unlawful for any person to
represent himself as a certified water treatment plant operator of any class,
or a certified wastewater treatment plant operator of any class without first
being so certified by the board and without being the holder of a current valid
certificate issued by the board.  Any person violating the provisions  of this
portion of this article is guilty of a misdemeanor and, upon conviction thereof,
shall be punished by a fine of not more than three hundred dollars.

      (2)  It is unlawful for any owner of a water treatment plant or  a waste-
water treatment plant in the state of Colorado to allow the plant to be operated
without the supervision of a certified operator of the classification  required
by the board for the specific plant.  Any owner violating the provisions of
this portion of this article is guilty of a misdemeanor and, upon conviction
thereof, shall be punished by a fine of not more than three hundred dollars for
each violation.  Each day of violation constitutes a separate offense.

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                                  104
   WATER WELL AND PUMP INSTALLATION
             CONTRACTORS  LAW

         (As amended through 1972)

   148-20-1.  Declaration of policy.—  It has
been, established by scientific evidence that improp-
erly constructed water wells and improperty instal-
led pumps  and pumping equipment  can adversely
affect the public health.   Consistent with its duty
to safeguard the  public  health  of  this  state, the
general assembly therefore declares that  the proper
location,  construction, repair,  ami abandonment of
water wells, and the proper installation  and repair
of pumps and pumping equipment, as well as the
licensing and regulation of persons engaging in the
business of contracting cither for the construction of
water  wells  or for the  installation  of  pumps or
pumping equipment, is essential for the protection
of the public health.

   148-20-2.  Definitions.— (I)   As used  in
this article, unless  the  context otherwise requires:

   (2)   "License" means the granting of a license
by the state board of examiners of water well and
pump  installation contractors, to  qualified persons
making application therefor, authorizing such per-
sons to engage in I lit: business (if water well drilling
or the business of  pump installing, or both.
   (3j   "Construction  of water  wells"  means  all
acts necessary to obtaining ground water by any
method for human consumption  or other use, in-
cluding, without limitation, the location  of and the
excavation  for the well, but not including prospect-
in};, surveying, or  other  acts preparatory thereto,
nor the installation of pumps and pumping equip-
ment,
 ficial recharge, or acquisition of ground water, but
 such term docs not include an excavation made for
 the purpose of obtaining or for prospecting for oil,
 natural  gas,  minerals, or products of  mining or
 qunrr> ing, or  for inserting media to rcpressure oil
 or natural gas-bearing formation or for storing pet-
 roleum, natural gas, or othey products,

    (11)   "Water well contractor" means any in-
 dividual, corporation,  partnership, association, poli-
 tical subdivision, or public agency  in  immediate
 supervision of and responsible lor the construction,
 test pumping  or equipping, or development of an
 individual well or wells, either by contract or for
 hire or for any consideration whatsoever.

    (12)   "Private driller"  means  any  individual,
 corporation, partnership, association, political  sub-
 division,  or public agency which shall construct a
 well or wells  entirely for his or their own use on
 property  owned or  controlled,  with  equipment
 •owned and operated,  by him or them.

    (13)   "Irrigation,   industrial,  or  commercial
 well"  means any well  construction for the purpose
 of obtaining water to  be used beneficially but not
 for human consumption.

    (14)   "Artesian well" meanj  a  well obtaining
 water from an aquifer under hydrostatic pressure.

    (15)   "Drainage well"  means a well construc-
 tion for the purpose  of lowering the water table.

   '(16)   "Aquifer" means a geological formation
 that contains or  transmits ground water.

    (17)   "Domestic well"  means a  well used for
 ordinary household purposes, the watering of farm
 livestock,  poultry,  and domestic animals, and  the
 irri«nlion f  the following persons:
The  state engineer or a representative designated
by him;  a  representative of  tho  dcp.irtment  of
health di'signaU'd by  the executive director of the
department; and three members appointed by the
 governor,  two ol  whom  shall be  water well con-
tractors, each with a minimum of ten years exper-
ience in  the water  well  contracting business pre-
ceding his appointment; and one nl  whum shall be
an engineer or geologist with a minimum of  ten
years experience  in water supply and  water well
 construction preceding his  appointment.

    (2)   The governor shall make I;is first throe ap-
 pointments within thirty days after July 1,  1907, to
 serve the following leans; One lor a lean expiring
 June 30, 1909, one for a term expiring June 30,
 1970, and otic for a trrm expiring June 30. 1971.
 Thcit-afler all members shall  be appointed  for four-
 year terms, but no member shall be rcappoinlcci  to
 serve more than  twu  consecutive loin-year terms.
 Kiicll member shall  hold olficc until the expiration
 of his term or  until a  successor is appointed.  Any

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                                    105
vacancy occurring In the board membership of the
governor's  appointees,  other  tliun by expiration,
shall be filled by the governor 1>\; appointment for
tbc niicxpircd lain.   Members shall serve without
compensation but shall be reimbursed for actual ex-
penses necessarily incurred in their official business.

   (3)   The board shall meet within sixty days af-
ter July 1. 1957 and not less than once every three
mouths thereafter, and at such  other times  as  it
deems neces,«arv or advisable.   Special meetings  of
the- board may be called at any time on order of the
chairman or Yitc'-chairman or any three members
of the bonrd.  The time and  place of all meetings
shall be determined by the board, but one meeting
\villiin tlirc-e ineinths after the first appointment  of
the board shall be held in'Denver, at which time a
chairman,  vice-chairman, and a  secretary shall be
selected.   Three; members of  the board shall con-
stitute a (murum, and  the affirmative vote of three
members shall bu required  to pass any action or mo-
tion of the board.  The board may  adopt bylaws
to govern its own procedure.

   148-20-4.   Duties of the board,—

    (1)  (a)  The board shall:

    (b)  Be responsible for the administration  ol
this article, and  with respect to such administration
shall enforce the provisions of this article and any
rules adopted pursuant thereto, and shall take such
other  actions as may be  reasonably  necessaiy  to
carry out the provisions of this article;

    (c)  Have  general supervision and  authority
over the construction nnd abandonment  of water
 wells  nnd the installation of  pumps and  pumping
 equipment, as  provided by sections 148-20-0 and
 148-20-10;
 pumping equipment, shall obtain a license from the
 board, ami in the case of any water well contractor,
 shall stt-urc a registration from the board for-each
 well drilling rig to be operated by him.

    (2)   (a)  The board shall issue a  license to
 each applicant who shall file an application upon a
 form and in such manner us the board prescribes,
 accompanied by «uch fees and bond as required by
 section 1-18-20-7; and who  furnishes evidence sat-
 isfactory to tbc board that he:

    (b)   Is at least twenty-one years of  age;

    (c)   Is a  citizen of  the United States or has
 declared his intention to become a citizen;

    (d)   Is of good moral character;

    (c)   Has had not less than two yean experience
 in the  work for which he is applying for a license;
 and

    (f)   Demonstrates professional competence  bv
 passing a written and oral examination prescribed
 by the board.

    (3)   Upon investigation of the application and
 other evidence suhmittcd, tin: board shall, not less
 than thirty days  prior to the  examination, notify
 each applicant that the  application and evidence
 submitted lor  licensing is satisfactory and accepted,
 or unsatisfactory and rejected;  if rejected, said no-
 tice shall state the reasons for such rejection.

    (4)   The  place of examination shall be desig-
 nated in advance by the biurd, and shall be given
 annually, and  at such other times as, in the opinion
 of the hoard, the number of applicants warrants.
 Tliu board rnay, if the applicant meets all other  re-
    (d)  Adopt, and from time to time revise, such
 rules not inconsistent with law, as may bo necessary
 to effectuate the provisions of this article, all such
 rules to be adopted in accordance with article 16
 of chapter 3, C.R.S. 1903;

    (o)  Employ,  within funds available, personnel
 necessary for the proper performance of its work
 under this article;

    (f)   Examine  for,  deny, approve,, revoke, sus-
 pend, and renew the licenses of applicants and lic-
 ensees as provided  in this article;

    (g)  Conduct hearings upon complaints with
 respect to any licensee under this article, and with
 respect to the denial,  revocation, or suspension of
 a license, all such  hearings to be conducted in con-
 formity with article 16 of chapter 3, C.H.S. l'963;

    (h)  Prepare and transmit annually, in the form
 and manner prcsribcd  bv the controller pursuant to
 the provisions of section 3-3-17,  C.H.S. 1963, a re-
 port  accounting to  the  governor and the general
 assembly for the efficient discharge of all responsi-
 bilities assigned by  law or directive to the  board.
 Publications of the  board  intended for  circulation
 in  quantity outside the board  shall bo  issued in
 accordance with  fiscal ruins promulgated by the
 controller  pursuant to  the  provisions  of section
 3-3-17, C.R.S. 1963;

    (i)   Cause the prosecution and enjoinder of all
 persons  violating  this article and  incur  necessary
 expenses therefor.

    148-20-5.   Licensing—registration of rigs.
 —(1)  Ever}' person, before engaging in the busi-
 ness  of  contracting  cither for the construction of
 water wells or for the installation  of  pumps cr

 quirempnts  issue  a  temporary license, not  to ex-
 ceed 90 days, until the next examination by the
 board.

    (5)  The  examination  shall consist of an oral
 and written examination, and shall fairly test the
 applicant's  knowledge and application  thereof in
 the following subjects: llasics of drilling  methods
 and_ basics  of  construction;  state  laws'and local
 ordinances  concerning the construction  of  water
 wells or installation of pumps and pumping  equip-
 ment, or both, and rules promulgated in connection
 therewith.

   (0)   In the event nn applicant fails to receive a
 passing grade on the examination, he may reapply
 for examination within ninety clays.

   148-20-6.   Persons previously licensed—
exemptions.—(1)  Any  person  possessing  the
qualifications prescribed in  subsections  (2)  (a)
through  (2) (e) of section 148-20-3 and who has
been licensed in the business  of a water well con-
tractor immediately prior to July 1. 1907, shall upon
application mado within onu  year of said date, ac-
companied by satisfactory proof to the board that
ho was so licensed, and accompanied by pavment
of the required fee  and the  furnishing of the- re-
quired bond, be gran'cd a license as a water well
contractor without fulfilling the requirements that
he pass the examination prescribed by subsection
 (2)  (f) of section 148-20-5.

   (2)   A license  shall not be required of any per-
son who performs  labor or services at the direction
and under the personal  supervision ol" a  licensed
water well contractor or pump installation contrac-
tor,

   (3)   A private driller shall be exempt from all
license requirements under this article, except that

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                                      106
 he shall lie a resident of the .state of Colorado, and
 shall comply with minimum construction standards
 as required by suction 1-1S-20-10.

   148-20-7.  Fees and bonds.— (1)  All fees
 from applicants sacking n license tinder this article,
 and all renewal fees, shall he credited to the gener-
 al fund of Ihi: state.   No  feos shall be  refunded.
 A license shall be nontransfcrahlc and unassignable.

    (2)  The board shall charge an application fee
 of ten dollars to accompany each application from a
 resident of the state of Colorado, and a further fee
 of twenty-five dollars upon successful completion  of
 examination before  issuance of a  license.  In ad-
 dition each  successful resident  applicant shall file
 with the board a performance and compliance bond
 in the amount of five thousand dollars with a cor-
 porate surety authorized to  do business in the state
 of Colorado, conditioned  that  such licensee  will
 comply with the laws of the state of Colorado  in
 engaging in the business for which he  receives a
 license, and the rules of the board promulgated  in
 the regulation of such business.

   (3)  The board shall charge an application fee
 of twenty-five dollars to accompany each applica-
 tion from  a nonresident of the state of  Colorado,
 and  a further nonresident fee of two hundred  dol-
 lars  upon successful completion of examination be-
 fore issuance of a license.   In  addition each  suc-
 cessful nonresident  applicant  shall file  with  the
 board a performance and compliance  bond in the
 amount of  ten  thousand dollars with  a  corporate
 surety authorized  to do business  in the state of
 Colorado, conditioned that such licensee will com-
 ply with the laws of the state in engaging in the
 business for which he receives  a license, and the
 rules of the board promulgated in compliance there-
 with.

 148-20-10 and the rules of the  board promulgated
with respect thereto.

   (2)  No  license shall be withheld, denied, re-
 voked,  or  suspended  except in conformity with
article 16  of  chapter 3, C.11.S. 1963.

   148-20-9.   Further scope of article.—
 In addition to the licensing of water'well and pump
 installation contractors as  required by  this article,
 no water  well shall  be located,  constructed,  re-
 paired, or  abandoned and  no  pump or  pumping
 equipment shall be installed or repaired, contrary
 to the provisions of this article and applicable rules
 of the board promulgated  to effectuate  the  pur-
 poses of this article.   The provisions of this article
 shall  apply to any water well,  pump,  or  pumping
 equipment not otherwise subject to regulation  un-
 der the laws of tins state, and  to any distribution
of water therefrom; but this article shall  not apply
to any distribution of water beyond the point of
discharge  from the pressure lank,  or  beyond  the
point oi  discharge from the pump if  no pressure
tank  or an  overhead pressure tank is employed.

   148-20-10.   Basic principles and minimum
 Standards.— (1)   (a)  The following basic prin-
 ciples, general in scope and fundamental in char-
 utter, shall govern the cunst'niction, repair, or aban-
 donment of any water well, and the installation or
 repair of rtiiy pump  or pumping equipment:

   (b)   £i)   Water  wells shall be:

   (ii)   Located,  in  such  manner  that  the  well
 dud  its surroundings can be kept in a sanitary con-
 dition;

   (iii)   Adequate in size to permit the installation
 of a pump to pump the volume of water  sought to
 be obtained;
    (4)  Ever)' water well  contractor or pump in-
 stallation contractor in this  italo shall  annually pay
 to the board during the month of January of each
 year, beginning in the year immediately subsequent
 to his initial licensing, a fee of twenty-five dollars,
 and shall annually file a new performance and com-
 pliance bond  in the  amount required upon  initial
 licensins, and the secretary  shall thereupon issue a
 renewal license for one year.  The license of anv
 water well or pump installation contractor who shall
 fail to have his license renewed during  the month
 of January in  each  and every ycslr shall  lapse.
 Any lapsed license may be renewed within a period
 of two years after such lapse, upon payment of all
 fees in arrears, or  thereafter,  upon payment of a
 renewal fee of  twenty-five  dollars.

    (5)   The  board shall charge an  annual  regis-
 tration fee of  five dollars for each well drilling rig
 to be operated by a water well contractor.


   148-20-8.   Denial—revocation  or suspen-
 sion of license.— (1)   (a)   The  board,  by an
 affirmative vote of  three of  its five members, may
 withhold, deny,  revoke,  or suspend  any license
 issued or applied for in accordance  with the provi-
 sions  of  this article, upon proof that  the licensee
 or'applicant:

   (b)   Has used fraud or deception in applying
 for a  license or  in taking  an examination provided
 for in tins  article;

   (c)   Has willfully or  negligently violated any
 of the provisions of tins article  or of the  "Colorado
 Ground Water Management Act";

   (d)   Has failed, in engaging in  the business of
water well  or pump installation contractor, to com-
ply with minimum standards prescribed by section


    (iv)   Constructed in such a manner as to main-
  tain natural protection against pollution of water-
  bearing formations and  to exclude known sources
  of contamination.

    (c)   (i)   The pumping equipment shall be:

    (ii)   Located iiv such a manner that the pump
  and  its surroundings can be kept in a sanitary con-
  dition;

    (iii)  Selected, constructed, and  installed:  To
  meet the water yield and drawdown  characteristic
  of the well; to be durable and reliable in character; ,
  of such material that no toxic or otherwise objec-
  tionable condition  will be created  in  the water; in
 such a manner  that continued operation without
  priming is assured at the  time of installation;  to
  provide adequate  protection  against pollution  of
  any  character  from  any  surface  or  subsurface
 source.

    (2)  The board shall adopt, and may from time
 to time amend, rules reasonably necessary to effect-
 uate  the basic  principles and  minimum standards
 prescribed by subsection  (1)  of this section.  The
 board shall have authority to require such informa-
 tion relating to any such construction or  installation
 as it may deem necessary.

   148-20-11.  Violation and penalties.—
 (1)  (a)   It shall  be  a  misdemeanor after  six
 months from July 1,  1007:

    (b)   For any person  to represent  himself as a
 water well  contractor or  a  pump installation con-
 tractor who is not licensed under this  article, or to
 so represent himself after his license has been sus-
 pended, revoked, or  lapsed;  or

    (c)   For any person not  licensed under this
 article to advertise or issue any sign, card, or other

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                              107
                       .vice winch would indicate that he is a licensed
                       alcr well contractor or a pump installation con-
                      .•aclor; or

                        (<1)   For any person to otherwise violate any
                      of the provisions of this article.

                        (2)   Such misdemeanor  shall be punishable
                      upon conviction  \>y a fine of not more than three
                      hundred dollars,  in liy imprisonment in tlic county
                      jail fur not more than ninety days, or by both such
                      fine and imprisonment.

                        148-20-12.   Injunctive proceedings.—
                      (1)  The board may. through the attorney general
                      of the state of Colorado, apply for an injunction in
                      any court of competent jurisdiction to enjoin any
                      person from committing any act declared to be a
                      misdemeanor by this article.

                        (2)   Such injunctivc proceedings  shall be in
                      addition to and not in lieu of any other penalty or
                      remedy in this article provided.

                        148-20-13.   Effective date.— This  article
                      shall take effect  July 1, 1907,
                                CHAPTER  142

                                  PLUMBERS


         142-1-1.  RULES GOVERNING PLUMBING.--The  department of public health,
in pursuance  of its general power of  supervision  over the  interest  of the
health and life of the  citizens  of this state,  and of the  sanitary  conditions
under  which they live,  is hereby authorized and empowered  to make,  prescribe,
enforce, amend  and repeal rules  and regulations governing  the plumbing, drain-
age,  sewerage,  and plumbing ventilation of all  buildings  in this  state, and
thereby to establish  and maintain minimum standards, which shall  be unifona
throughout the  state, which rules and regulations shall have the  force and
effect of law,  when not in conflict with the  statutes of  the states  of Colo-
rado.   This article shall not  be conotrusd to  deny any municipal ii:y  the right
to adopt and  enforce  such rules  and regulations in the premises,  as are not
inconsistent  with the laws of  the state.

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                  A P P E N D I X  E
COLORADO   WATER  SUPPLY   R E G U t A T-KO K S

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               APPENDIX E

  Colorado  Water Supply  Regulations

         COLORADO DEPARTMENT Or HEALTH

       STANDARDS FOR THE QUALI TY OF WATER
              SUPPLIED TO THE PUBLIC

EOULATIONS:   QUALITY OF WATER  SUPPLIED THE PUBLIC

JTHORITY:     Sec. 66-1-7 (6) 4 (19), COLO. Rev.
              STATUTES 1963, A3 AMENDED, (1967
              PERM. CUM. SUPP.)

X3PTED:       COLO. STATE BOARD or HEALTH FEB.  12,
              1963-SEc. 9, AMENDED OCT. 17, 1967.
       1,  Definitions of terms.
       As used  In  this  subpart,  the following tens
       shall  have the meanings set out belo*:
            (a)  "Adequate protection by natural means"
       involves one or more of the following  processes
       of nature that produces water consistently meet-
       ing the requirements of these Standards:   dilu-
       tion,  storage, sedimentation, sunlipht, aeration.
       and the associated physical  and biological proc-
       esses which  tend  to accomplish natural  purifica-
       tion  in surface  waters and, in  the case  of
       ground waters, the natural  purification of water
       by  infiltration  through soil and percolation
       through  underlying naterlal and storage belo*
       the ground water  table.
             (b) "Adequate protection by treatment"
       leans  any one or any combination of the  con-
       trolled processes  of coagulation, sedimentation,
       absorption,  filtration, disinfection, or other
       processes which  produce a water consistently
       meeting the requlrenents of these Standards.
       This protection  also  Includes processes which
       are appropriate to the source of supply; works
       which  are of adequate capacity to Beet naxUua
       demands without  creating health hazards, and
       which  are located, designed, and constructed to
       eliminate or  prevent  pollution:  and  conscien-
       tious  operation  by well-trained  and  competent
       personnel whose qualifications are connensurate
       with  the responsibilities  of  the  position and
       acceptable to the reporting  apency and the cer-
       tifying  authority.

              (c)   "CERTIFYING AUTHORITY" MEANS THE
        COLORADO DEPARTMENT or HEALTH
             (d)  "The  conform group" includes all
       organisms considered  in the coll Torn croup as
       i>et forth in Standard Methods for the Examina-
       tion  of  Hater and  Wastewater, current edition,
       prepared and published jointly by the American
       Public Health Association,  American Water  Morns
       Association, and  tuter Pollution Control  Federa-
       tion.
             (e) "health hazards" mean  any conditions.
        devices, or practices  in the water supply system
        and its  operation which create, or nay create, a
       dancer  to the health and well-beinn of the  water
        consumer   ta example of a health hazard Is a
        structural  defect In the water supply systes.
        whether of  location,  design, or construction.
        which nay regularly or occasionally prevent sat-
        isfactory  purification of the water supply or
        cause  it to be polluted  from extraneous sources.

             (n "Pollution1,  as used in these Stand
        arjs,  means the presence of  any  foreign sub-
        stance  (organic,  inorganic,  radiological, or
        bioloflcal)  in water which tends  to degrade  its
        quality so  as  to constitute a hazard or iapair
        the usefulness of the  water

             (r) "Heportine agencies" leans the respec-
        tive official state  health  agencies or their
        designated representatives.

             (h) "'the standard sample" for  the bacte-
        riological test shall  consist of

               (I)  Kor the bacteriological fernentation
        tube  test, five (f) standard portions  of either:
108
             (1)  Ten BillUlters (10 al)
             (il)  one hundred milliter* (lOOal)
            (2)  For the  membrane filter  technique,
     not  less than fifty milliners (SO •!).
          (1)  "Water  supply systea" includes the
     works and  auxiliaries for collection, treatment,
     storage, and distribution of the water from the
     •sources of supply  to the free-flowing outlet of
     the  ulttiate consumer.

     2.   Source and Protection
          (a)  The water supply should be obtained
     froi the  lost  desirable source which is fea-
     sible, and effort should be Bade  to  prevent or
     control pollution  of the source.  If the  source
     it not adequately protected by natural  leans,
     the  supply shall be adequately  protected by
     treatment,
           (b)   Frequent  sanitary surveys shall be
     nade of tne  water supply systei  to  locate and
     Identify health hazards which tight exist in the
     system,   'ihe manner and frequency of  Baking
     these surveys,  and the  rate  at which discovered
     health hazards are to be removed shall be in
     accordance  with a program approved  by tne
     reporting agency and the certifying authority.

           (c)   Approval  of  water supplies shall be
     dependent  In part  upon.
            (1)  Enforceaent of rules and  regulations
     to prevent development of health hazards;
             (2)  Adequate protection  of the water
     quality throughout  all parts  of  the systei.as
     demonstrated by  frequent  surveys;
            (3)  Proper operation of the water supply
     system under the responsible charge of personnel
     whose qualifications  are  acceptable  to the
     reporting agency  and the certifying authority;
             (4)   Adequate  capacity to  ieet peak
     deiands without development of  low pressures or
     other  health hazards,  and
             (5)   Record of laboratory examinations
     showing consistent coipllance with the water
      quality requirements of  these Standards.
            (d)    Kor  the  purpose of application  of
      these Standards,  responsibility for  the condi-
      tions in  the water  supply  system shall  be con-
     sidered to be held by:
             (\)   The water  purveyor fro» the source
      of  supply'to the connection to the Customer's
      service piping; and
             (2)  The owner  of the property served and
      the municipal, county,  or other authority having
      legal  jurisdiction iron the point of connection
      to the custoner's service piping to the free-
      flowing outlet of the  uluiate consuaer.

      3.   bacteriological  quality
           (a)  SAMPLING.
             (1)   Conpllance with the bacteriological
      requirements of these  Standards  shall be based
      on  examinations  of samples collected  at rep-
      resentative points  throughout  the distribution
      systei.   The frequency of sampling and the loca-
      tion  of  sampling points  shall be established
      jointly by  the  reporting agency and the certify-
      ing authority after investigation by either
      agency, or  both, of the source, tethod of treat-
      aent.  and protection of the water concerned.
             (2)   'Ihe mlnimuci nunber of samples to be
      collected  from the water  supply and exaalned
      each tenth should be  as follows:   For  supplies
      serving less than 2,000 persons  -  2 per lonth;
      for supplies serving froi 2,000 to  100.ooo per-
      sons - l  per month per 1.000 persons served;  for
      supplies  serving over 100.000 persons -  as taken
      fron the  graph in the u. s. Public Health Serv-
      ice Drinking Water Standards.

             (3)   In determining  the  number of samples
      examined monthly, the following  sanpies nay  be
      included, provided  all results  are  assembled and
      available for inspection and the  laboratory
                          l
                                                                             -2-

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                                              109
 methods  and technical competence  of the lab-
 oratory personnel are approved by the reporting
 agency and the  certifying authority:

          (1)  Saipleg examined by the reporting
 agency.

          (11)   Samples exaHned by local govern-
 ment laboratories.

          (Ill)   Saiples examined by  the  water
 works authority.

           (Iv)  Samples  exanlned by commercial
 laboratories.

         (4)   The laboratories  In which  these
 examinations are nade and  the tethods  used In
 making them shall be  subject to inspection at
 any time by the  designated representatives of
 the certifying  authority and  the reporting
 agency.   Conpllance with the specified proce-
 dures and the results  obtained shall be used as
 a basis  for certification of the  supply.

        (5)   Dally samples collected following a
 bacterlologlcally unsatisfactory sample as pro-
 vided In  paragraph (b) (1),  (2),  and (3) of this
 section  shall be  considered as special  samples
 and shall not be Included in the  total number of
 samples  examined.  Neither shall such special
 saiples  be used as  a basis  for prohibiting the
 supply:   Provided.  That  (1)  when waters'of un-
 known quality are being  examined, simultaneous
 tests  are made on multiple portions of a geomet-
 ric series to determine a definitive conform
 content,  (11) Immediate  and active  efforts are
 nade to locate the  cause  of  pollution,  (111)
 Immediate  action Is  taken to  eliminate the
 cause, and (Iv)  sanples taken  following  such
 remedial  action  are  satisfactory.

      (t>1  Llnlts.  The presence of organisms  of
 the conform group as indicated by samples  exam-
 ined shall not exceed the following  limits:

        (1)  When 10  mi  standard portions are
 examined, not more than 10  percent  In  any  month
 shall  sho*  the  presence of  the coll fora group.
 The presence of the  conform group  In three  or
 more  10 ml portions  of a standard sample  shall
 not be allowable If  this occurs:

         (1)   In two  consecutive  sanples;

         (11)  In  more  than one  sample  per  month
 when less than 20  are examined per month; or

         (111)   In more than five  percent of the
 sanples when 20  or store are  examined per month.

 »hen organises  of the conform  group occur  In
 three or more of the 10 01  portions  of a single
 standard  sample,  dally samples  from the same
 sampling point shall be collected promptly and
 examined until the  results obtained from  at
 least two consecutive samples show the water  to
be of satisfactory quality.

       (2)   Wien  loo ml  standard portions are
 examined, not more than 60 percent In any month
 shall show the presence of  the coll form group.
The presence of the conform group  In all  five
of  the  100  ml portions  of a standard  saiple
shall not  be  allowable if this  occurs:

         (1)  In two consecutive sanples;

         (11)  In  more than  one sample per month
when less  than five are exailned per  month; or

         (ill)  In more than 20  percent of the
samples  when five  or more are  examined per
month,

When organisms  of the  coll form group  occur In
all five  of the  IOC  ail  portions of  a  single
standard  sample dally sanples from the same sam-
pling  point  shall Le  collected  promptly and
examined  until  the  results obtained from at
least two consecutive  samples show the water to
be of satisfactory quality.

       (3)  When th.e membrane  filter technique
Is used,  the  arithmetic mean  conform density of
all standard samples exanlned per month  shall
not exceed one per 100 ml.   Collfora  colonies
per standard sample  shall not exceed  3/50 ml,
 4/100 ml. 7/200 al.  or  13/MO il in:

         (1)  Two consecutive samples;
          (11)   More than one standard sample
 when less than 20 are examined per month;  or
          (111)  More than five percent of the
 standard samples when 20 or more  are examined
 per month.

 then conform colonies  in  a single standard sam-
 ple exceed  the above values,  dally samples from
 the  same sampling point shall be collected
 promptly and examined until the results obtained
 from at  least  two consecutive samples show the
 water to be of satisfactory quality.

 4.  Physical characteristics.

     (a)  Sampling.  The frequency and  manner of
 sampling shall  be  determined by the reporting
 agency and the certifying  authority. Under nor-
 mal circumstances samples should be collected
 one or more  times per week froi representative
 points In the distribution system  and examined
 for turbidity, color, threshold odor, and taste.

     (b)  Limits. Drinking water should contain
 no impurity which would  cause  offense to  the
 sense of sight, taste,  or  smell.  Under general
 use.  the following  limits should not be  ex-
 ceeded :
     Turbidity -  5 units
     Color - is units
     Threshold odor number - 3

 5.  Chemical characteristics.
     (a)   Sampling.

       (l)   The frequency  and manner of sampling
 shall be determined  by  the reporting agency  and
 the certifying authority.   Under normal circum-
 stances,  analyses for  substances listed below
 need be  made only semi-annually.   If. however.
 there is some presumption of unfltness because
 of the presence  of  undesirable elements,  com-
 pounds,  or  materials,  periodic determinations
 for the suspected toxicant or material  should be
 made more frequently and  an exhaustive  sanitary
 survey should be  made to determine the  source of
 the pollution.  Where the concentration  of a
 substance is not expected to increase in  proc-
 essing and  distribution,  available and accept-
 able source, water analyses performed in accord-
 ance with standard  methods may be used as  ev-
 idence of compliance with  these Standards.

       (2)   Where experience, examination,  and
 available evidence Indicate that particular- sub-
 stances  are consistently absent  from a water
 supply or below  levels of concern, semi-annual
 examinations for  those substance* may be omitted ,
 when approved by the reporting agency and  the
 certifying authority.
       (3)   The  burden of analyses may be  re-
 duced in many cases by using data  fron accept-
 able sources.  Judgment concerning the quality
 of water supply and the  need for performing
 specific local analyses  may depend in part on
 information  produced by such agencies as (1)  the
 u. s.  Geological  Survey,  wnlch  determines  chem-
 ical quality of surface and ground waters of the
 united Statea and publishes these data  in "Water
 Supply Papers" and other  reporti,  and (11)  the
 u. s. Public Health Service  which dtternlnei
 water quality related to  pollution (or the  ab-
 sence of pollution) in the principal rivin of
 the Nation and publishes these data annually In
 "National Water Quality Network".   Data on  pol-
 lution of waters as measured by carbon chloro-
 form extracts (CCE)  may be found in the latter
publication.

     (b)  Units.  Drinking water  shall not con-
 tain Impurities In concentrations which may be
 hazardous to the health of the  considers.  It
 should not be excessively  corrosive  to the water
 supply system.  Substances  used  in  Its treatment
 shall  not renaln  In  the water In concentrations
greater  than required  oy  good  practice.   Sub-
 stances  which may have deleterious physiological
                            -3-
                                                                                -4-

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                                                 no
 effect,  or for which physiological effects are
 not  known, shall not be introduced  into the sys-
 te«  in a manner which would pernlt  then to reach
 the  consumer.

        (i)  The following chealcal  substances
 should  not be present In a water supply in ex-
 cess of  the  listed  concentrations  where,  in the
 Judgment of the reporting agency  and the cer-
 tifying  authority,  other more suitable supplies
 are  or can be Bade available.

                                   Concentration
            Substance              in ag/1
 Alkyl Benzene Sulfonate (ABS)	0.5
 Arsenic  (As)	0.01
 Chloride (Cl)	250
 Copper (Cu)	1.0
 Carbon CM or of or n Extract  (CCE)-  -  - -  0.2
 Cyanide  (CN)	0.01
 Fluoride (F)	(•)
 Iron (Fe)	0.3
 Magnesium	125
 Manganese (Mn)	0.05
 Nitrate  J(NO,)	45
 Phenols- - -	0.001
 Sulphate (S04)	250
 Tbtal Dissolved Solids 	  500
 Zinc 'Z«)	    5

      * See 5 (b) (3)

      1 In areas In which  the nitrate content of
 •ater Is known to  be In  excess of the  listed
 concentration, the public  should  be  warned of
 the  potential dangers of using the  water  for
 infant feeding.
        (2)   The presence  of the  following sub-
 stances  in excess  of the  concentrations  listed
 shall constitute grounds  for rejection  of  the
 supply;

                                  Concentration
            Substance             in ng/1
 Arsenic (As)	0.05
 Bariua (Ba)	1.0
 CadBlua (Cd)	• -  -«	°-01
 ChroaluB (Hexavalent) (Cr +• °) - - • •   0.05
 Cyanide (OO	0.2
 fluoride (F)	(•)
 Lead (Pb)	0.05
 Selenium (Se)	0.01
 Silver (Ag)	0.05

      *See  5  (b>  (3)
       (3)  (1)   When fluoride is naturally pres-
 ent  in drinking water it is  recommended that  the
 concentration should not average itore than  the
 Appropriate upper Holt  In  Table I.   Presence of
 fluoride in average concentrations  greater than
 two  tines  the  optimum'values  in Table I shall
constitute  grounds  for rejection of  the supply.
         (11)  Where fluorldatlon (supplementa-
 tion of  fluoride in  drinking  water)  is prac-
 ticed, the average  fluoride concentration shall
»e kept  within the  upper and lower  control Un-
its in Table  I.
                      Table I
Annual  average of
•MliuB daily,air
le«peratures a
                       Recommended  Control
                       Limits (Fluoride
                       concentrations  In mg/lJ

                       L ovier   Optlaum  Upper

                                  1.2      1.7
                                  1.1      1.5
                                  1.0      1.3
                                 0.9      1.2
                                 0.8      1.0
                                 0.7      0.8

  Based on temperature  data  obtained for a Bin-
inun> of five years.

          (ill)  In addition to the  sampling
required by paragraph (a) of this section, flu-
oridated  and  defluorldated  supplies  shall  be
samples with  sufficient frequency to deternlne
tnat the desired fluoride concentration Is main-
tained,

53,8-58 3 	
58.4-83 8........
63 9- 7ft A........
70 7.79 9 	 ----
79.3.90 5-- 	

*
0.9
00
Op

On
Of-

                                                      6.  Radioactivity.
                                                           (a)  Sampling.
                                                              (1)  The frequency of sanpllng and anal-
                                                      ysis for  radioactivity shall be determined  by
                                                      the reporting agency and the certifying author-
                                                           after con-'	  -' "  	"   '   "
                                                      ity
           consideration  of  the likelihood  of
                                                      significant  amountJL-belng present.   Where con-
                                                      centrations of Ra •**" or Sr80 may vary consider-
                                                      ably. quarterly samples composited over a period
                                                      of three  Bontns are reconmended.  Samples for
                                                      deteruinatlon of gross activity should be taken
                                                      and analyzed more frequently.

                                                             (2)   As  Indicated In  (a), data from ac-
                                                      ceptable sources may be used to indicate compli-
                                                      ance with these  requirements.
                                                           (b)   Limits

                                                             (1)  The  effects of human radiation expo-
                                                      sure are  viewed  as  harmful  and any unnecessary
                                                      exposure to ionizing radiation should be avoided
                                                      The concentrations  of radioactivity  specified
                                                      below for drinking  water are Intended to limit
                                                      Intake of these  substances by this route so that
                                                      total radiation exposure  of population  groups
                                                      does not exceed  appropriate Radiation Protection
                                                      Guides  recommended by the Federal  Radiation
                                                      Council,   Concentrations  which exceed,  on the
                                                      average,  the values  presented below for a period
                                                      of one year shall constitute grounds  for  rejec-
                                                      tion of the supply.  Where the total  Intake of
                                                      Ra226 and Sr90 froa all  sources has been  deter-
                                                      alned,  these limits may be adjusted by the
                                                      reporting agency and the certifying authority so
                                                      that  the  total intake of Ka226 ^a Sr?0 will not
                                                      exceed  7.3  uuc per  day  and  73 iiuc per day
                                                      respectively.

                                                      Radlonuclldes       Concentrations In uuc/llter
                                                      RadlUB226 .................  3

                                                      StrontluB90  ................ 10

                                                      Grow Beta Activity  {Strontini*0 and
                                                               alpha eim«» absent1) .....  1000

                                                         Absent is taken here to. Bean a  negligibly
                                                      small fraction of  the above specific limits.
                                                      where the limit for unidentified  aloha emitters
                                                      Is taken as  the  listed limit far Ra"6
       (2)  When mixtures of RadlumZZB,  stron-
tium90,  and other radlonucl Ides are present,  the
above Hitting values shall be modified  to  as-
sure that the combined intake is  not likely to
result In  radiation exposure in excess  of  the
Radiation Protection Guides reconmended  by  the
Federal  Radiation Council,

7.   Hecommended analytical methods

     (a)  Analytical methods to deternlne com-
pliance with the requirements of these Standards
shall be those specified  in Standard Methods  for
the  Examination of Water and  Wastewater,  Am
Pub. Health  Assoc. ,  current edition and those
specified as  follows:

       (1)  Barium:   Methods for  the Collection
and  Analyses of Water  Samples,  Water Supply
Paper No. 1454, Rainwater, F.H. A Thatcher, L.L.,
LI.  E. Geological Survey   V'ashington, D.C.
        (2)   Carbon Chloroform Extract  (CCF,):
Manual for  Recovery and Identification  of  Or-
ganic  Chemicals In Water,  Middleton.  F.  M. .
Rosen, A. A., and Hurttschell.  R.  H. .  Robert A.
Taft Sanitary Engineering Center, PHS, Cin-
cinnati,  Ohio.

       (3)  Hadloactivity:  Laboratory Manual of
Methodology,  Radlonucl Ide Analyses of Envi-
ronmental  Samples. Technical  Report  R59-6.
Robert A. Taft Sanitary Engineering Center,  l'na,
Cincinnati. Ohio,  and Methods  of  Radio-cneisical
Analysis,  Technical  Report  No.  173, Report of
the  Joint WHO-FAO Committee   1959,  World  Health
Organization
       (4)  Selenium:  Suggested Modified Method
for  Colorimetric Determination of  Selenium In
Natural  Water,  Magin,  C. b. , Thatcher,  L,  L.,
                 -5-
                                                                                 -6-

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                                                    Ill
RCTTIQ, S. AND LEV INC, H.J., AMERICAN WATER
WORKS ASSOCIATION, 52, 1199, (I960).

         (a)  ORGANISMS or THE COL I FORM GROUP.
ALL or THE DETAILS or TECHNIQUES IN THE DETER-
MINATION Or BACTERIA Or THIS OfiOUP, INCLUDING
THE SELECTION AND PREPARATION Or APPARATUS AND
MEDIA, THE' COLLECTION AND HANDLING Or SAMPLES
AND THE INTERVALS AND CONDITIONS or STORAGE
ALLOWABLE  BETWEEN COLLECTION AND EXAMINATION
Or THE WATER SAMPLE , SHALL BE I N ACCORDANCE
WITH STANDARD METHODS FOR THE EXAMINATION or
WATER AND  WASTEWATER, CURRENT EDITION, AND THE
PROCEDURES SHALL BE THOSE SPECIFIED THEREIN
FOR:
            0)  THE MEMBRANE FILTER
                 TECHNIQUE, STANDARD TEST, OR
            (z)  THE COMPLETED TEST, OR
            (3)  THE CONFIRMED TEST, PROCEDURE
                 WITH BRILLIANT GREEN LACTOSE
                 BILE BROTH' , OR
            (4)  THE CONFIRMED TEST, PROCEDURE
                 WITH ENDO OR EOS IN MCTHYLENE
                 BLUE AQAR PLATES. 1
                    CONFIRMED  TEST  is  ALLOWED,
 PROVIDED THE  VALUE  Or THIS TEST  TO DETERMINE THE
 SANITARY QUALITY  OF THE  SPECIFIC WATER  SUPPLY
 BEING EXAMINED  IS ESTABLISHED BEYOND  REASON-
 ABLE DOUBT  BY COMPARISONS WITH COMPLETED  TESTS
 PERFORMED ON  THE  SAME WATER SUPPLY.

 8.  HAZARDOUS CROSS-CONNECTION

 A PUBLIC WATER  SUPPLY SHALL HAVE NO CROSS-
 CONNECTION  TO A PIPE, FIXTURE OR SUPPLY ANY
 OF WHICH CONTAIN  WATER OF LESSER QUALITY.

 9.  DISINFECTION  or DRINKING  WATER.

 ALL DRINKING  WATER  SUPPLIED TO THE PUBLIC
 SHALL BE DISINFECTED  BY  CHLORINATION  OR
 OTHER MEANS OR  METHODS OF EQUAL  EFFICACY
 IN THE  KILLING  OR REMOVAL Or  ORGANISMS  CAP-
 ABLE Or CAUSING INrtCTION.  WHEN CHLORINA-
 TION  IS EMPLOYED, A SUFFICIENT AMOUNT OF
 CHLORINE SHALL  BE ADDED  TO THE WATER  TO
 MAINTAIN A  MEASURABLE CHLORINE RESIDUAL AT
 ALL POINTS  IN THE DISTRIBUTION SYSTEM FROM
 WHICH WATER HAY BE  WITHDRAWN.

          (A)  THE COLORADO DEPARTMENT or
 HEALTH  MAY  UPON WRITTEN  APPLICATION TO  THE
 DIVISION Or ADMINISTRATION AND THE SUB-
 MISSION Or  COMPETENT  EVIDENCE TO ESTABLISH
 THAT THE WATER  BEING  SUPPLIED TO THE  PUBLIC
 BY THE  APPLICANT'S  r ACUITIES is REASONABLY
 SArE  AND  FREE rROM  CONTAMINATION,  WAIVE THE
 REQUIREMENT FOR DISINFECTION  AS  HEREIN
 PROVIDED.   THE  APPLICANT SHOULD  SUBMIT
 DATA  OR OTHER EVIDENCE PERTINENT TO THE
 WATER  SOURCE, DISTRIBUTION SYSTEM  AND
 WATER  QUALITY BASED UPON ITS  PHYSICAL,
 CHEMICAL,  BACTERIOLOGICAL AND RADIOAC-
 TIVITY  CHARACTERISTICS.   Ir THE  EVIDENCE
 ESTABLISHES THAT  THE  WATER BE I NO FURNISH-
 ED MEETS THE  STANDARDS SET FORTH IN SEC-
 TIONS  2 THROUGH 8 OP  THESE REGULATIONS,
 DISINFECTION  MAY  NOT  BE  REQUIRED.   IN CASE
 THE  REQUEST FOR WAIVER  IS DENIED,  THE
 APPLICANT  MAY REQUEST A  HEARING  PURSUANT
 TO SECTION 66-1-9,  COLORADO REVISED
 STATUTES  1963.
         (B)  SAMPLES TROW WATER SUPPLY SYSTEMS FOR WHIO
WAIVERS HAVE BEEN GRANTED SHALL BE SUBMITTED FOR
ANALYSES AS REQUESTED BY THE DEPARTMENT.   Ir AT ANY
TIME IT APPEARS THAT THE WATER BEING FURNISHED  IS
NOT REASONABLY SAFE TO DRINK AND IN COMPLIANCE WITH
THE STANDARDS, THE WAIVER MAY BE SUMMARILY WITH-
DRAWN BY THE DEPARTMENT AND NOTICE GIVEN THAT DIS-
INFECTION IS REQUIRED.
10.
            CLAUSE.
Ir ANY PROVISION OF THESE REGULATIONS OR THE APPLICA-
TION THEREOr TO ANY PERSON OR CIRCUMSTANCE  IS HELD
INVALID, SUCH INVALIDITY SHALL NOT AFFECT OTHER
PROVISIONS OR APPLICATIONS OF THE REFLATIONS ARE
DECLARED TO BE SEVERABLE.

REFERENCE:

   t.
  2.
       CHAPTER 66-17(6)  (19)  CRS '63 -
       AUTHORITY  ro« WRITING  REGULATIONS.

       DEPARTMENT OF DEW,  PHS - INTERSTATE QUARANTINE
       DRINKING WATER STANDARDS, AS APPROVED BY
       THE  SECRETARY, JULY 20, 1961.

   3.   STAFF REPORT  OF THE FEDERAL  RADIATION COUNCIL,
       SEPTEMBER  1961.  REPORT No.  2 "BACKGROUND
       MATERIAL FOR  THE  DEVELOPMENT OF RADIATION
       PROTECTION STANDARDS11.

   4.   COLORADO STATE BOARD OF HEALTH REGULATIONS
       PERTAINING TO ICE,  ADOPTED AUGUST 14, 1950.

   5'   o™?*1*0.?™™..80*1"5 or HEALTH REGULATIONS
                                 VENDORS, ADOPTED


   6.   COLORADO STATE BOARD OF HEALTH REGULATIONS
       PERTAINING TO PLUMB,NQ (TECHNICAL PLUMB. NG
       21    Ofil *MENDCO  N°«MBER 13. 1961, AUOUST
       21,  1968,  AND JULY  16, 1969.

                      APPENDIX
REFERENCE 4

COLORADO STATE BOAAO or HEALTH REGULATIONS PERTAINING
TO ICE ADOPTED AUGUST 14,1950.
                              OR FOR COOLING FOOD
                           SHALL BE MADE FROM WATER
                          WMER ^PLY STANDARDS.
                     MAINTAIN IN ALL PARTS OF THE
REFERENCE 5.


STANDARDS or THE QUALITY or WATER TO BE SUPPLIED TO
           "* VENDORS« °"«NSING TANKS, WATER
                BOTTL"» *NO CONTAINERS OTHER THAN
               U "U8LIC W*TER SUM>«-Y THROUGH DIS-
          PJPE3, ADOPTED BY THE COLORADO STATE
BOARD OF HEALTH OCTOBER 18. 1954.         TATE
               E
                                                      OF HEAL
                             CULINARY AND ABLUTIONARY
                               OR GIVEN TO THE PUBLIC
                           TANKS* WATER HAULER TANKS>
                        OTH£R ™fo T^ PUBL'C WAT£R
                            DISTRIBUTION PIPES SHALL
                         **"«• SANITARY STANDARDS
                  ,      ^^lED TO WE PUBLIC AS

                         TIME BY ™E STATE BOAR°
                   -7-
                                                                               -8-
                                                               UPDATED: SEPTEMBER  15,  1959

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                        APPEND  IX     F
CO L  0  R A  DO    W A T  E R    SUPPLY    P  0  L I  C Y

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                                    1T2
                                                        January 31, 1973
                               APPENDIX  F

                      Colorado Water Supply  Policy
COLORADO DEPARTMENT OF HEALTH
Division of Engineering it Sanitation


           GUIDELINES FOR APPLYING DRINKING WATER STANDARDS TO

         REGULATIONS - QUALITY OF WATER SUPPLIED TO THE PUBLIC


                                                       March, 1966
                                                       Revised March, 1969
                                                       Revised January,  1973 .


These guidelines are established as Departmental Policy to aid State Health
Department Personnel and Local Health Department Personnel in applying the
Drinking Water Standards to categories of water supply coining under State
Board of Health Regulations Jl Quality of Water Supplied to the Public!',
effective November 15, 1967, and to interpret and supplement current
Drinking Water Standards as established by the State Boe.rd of Health.  The
guidelines are also designed to help personnel.in making as uniform as possible
their approach and ultimate solution of problems involving drinking water  supplies.
These standards will also serve as a more exact way of fixing responsibilities
in efforts to secure safe and adequate supplies of water.

A.  DEFINITIONS:

     1.  A Public Water ftupply is any water supply which is available to
         the public.  All public water supplies and those used in the
         preparation of food or for drinking pin _>oses when offered in any
         establishment to the public shall coroe within the purview of
         thp.se guidelines.  The following examples are given by way of
         explanation and not by way of limitation:

         a.  A water supply serving a municipality, water district,
             community or a rural domestic water supply system;

         b.  A water supply serving more than one dwelling unit or
             residence, an apartment house, condominium, ntotel, hotel
             or lodging house;

         c.  A supply serving any establishment licensed by the state of
             Colorado or any of its subdivisions, or a restaurant, dairy,
             dairy farm, hospital, nursing home, public institution or jail;

         d.  A supply used in preparation of food1,  drink, or drugs, or
             used by the persons working in such establishments -

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                                     113
      e.   A supply serving a  service  station,  roadside  atop,  campsite,
          school,- business establishment,  public  building,  trailer parks,
          mobile home  parks,  industrial.'plants, work station, mercantile
          establishment,  park,  beach  area, picnic ground,  public swimming
          pool,  country club, or place,of  public  assembly.

2.    The categories of Public  Water  Supplies  are as follows:

          A                        Serving over  10,000 persons

          B                        Serving 1,000 to 10,000 persons

          C.                       Serving 100  to 1,000 parsons and having
                                   at  least 25  service' connections

          D •                       Community  water supplies serving 10 or more'
                                   dwelling wiits not  under control of the
                                   owner  or 40  or more resident persons.

          E                        Other  public  water  supplies not meeting
                                   conditions for above categories.

3.    The Annual Inspection is  to be  made  twice  each year and reported on
      Drinking Water Supply System -  Annug1 Inspection  form E? ENG 1; it
      consists of an examination of such system features as involve source
      and protection,  sanitary defects  an'd health hazards,  bacteriological
      quality, chemical quality, physical  quality, radiological quality,
      and disinfectant residual and overall compliance  with the state
      law and "Regulations -  Quality  of Water  Supplied  to the Public."

4.    Sanitary Survey is  a comprehensice examination and written report
      made of the entire  water supply system once each  five years.  It
      will include all the details of the annual inspection but in more
      detail.  Information about the  coiroiunity,  such as ordinances, future
      plans-for w. ter improvement, enlargement,  financing, and overall
      compliance with state law and regulations is to be written in a
      narrative fora incluJin;; schematic drawings.  Procedure for written
      form is outlined in Operations  Memorandum Narrative Reports,
      October 20, 1965.

5.    Department means the health department having jurisdiction.

6.    Local Health Department is defined to be a department organized
      and operated in accord with Chapter 66,  Article 2, CRS 63, as amended.

7.    A Purveyor  is an individual or organization responsible for providing
      'facilities  through which water may be processed and transported from
      a water source to a connection with the consumer's service piping.

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                                      114
      8.  Inspecting Authority - The inspecting authority is the Colorado
          Department of Health for all public water supplies serving 40 or
          more resident persons or 10 or more dwelling units regardless of
          location.  For other public water supplies, the local health
          departments are the inspecting authority in their jurisdiction,
          and the Colorado Department of Health is the inspecting authority
          In areas not served by local health departments.

Note:  Additional information may be found in "Definition of Terms" in the
       Regulations - quality £f Water Supplied tjo the Public.

B.    RESPONSIBILITIES

      1.  The water purveyor is responsible that the water which he serves
          the public meets the Regulations'- "Quality of Water Supplied to
          the Public."

      2.  The Colorado Department of Health and local health departments
          (organized under 66-2, 1963 CRS) are responsible for enforcing
          compliance with current regulations adopted by the State Board
         -of Health and for implementing other provisions of public health
          laws pertaining thereto.   The current regulations as of this date
          are entitled "Regulations - Quality of Water Supplied to the Public."
          It is understood that state Department 'of Health personnel and
          local health department personnel'will work together to achieve
          confortnance with those requirements.

      3.  In order to avoid duplication of effort, the following general
          division of duties will apply:

          a.   The Colorado Department of Health will have the following
               responsibilities:

               (1}  Revicv of plnrs and specifications for new water works or
                    modifications to existing facilities.

               (2)  Make serai annual inspections and written reports on public
                    water supply systems serving over 40 resident persons or
                    over 10 dwelling units.   Make a periodic complete sanitary
                    survey of these water supplies.  Provide follow up and
                    enforcement on  these water supplies.

               (3)  Provide local health departments with copies of all inspection
                    reports., correspondence and official actions concerning water
                    supplies in areas served by local health departments.  Discuss
                    problems with local department personnel.

               (4)  Surveillance on all public water supplies in areas not served
                    by local health departments.

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                                       115
               (5)  Provide consultation and assistance as requested by  local
                    health departments.

          b.   The Local Health Departments will be responsible for:

               (1)  Implementing the sampling requirements for all public water
                    supplies in their  area.  Reporting to the State Department
                    of Health, monthly, a summary of all tests run on public water
                    systems directly inspected by the state.  (The District Enginee*
                    will supply to'the local department a current list -of such
                    systems to be sampled).

               (2)  Direct inspection  and surveillance of private water  supplies
                    and public supplies not under direct surveillance of the state-

               (3)  Interpreting to the public, state recommendations concerning
                    public water supplies.  Investigating complaints and conditions
                    coming to their attention.

               (4)  Reporting to the state, findings from investigation  of
                    complaints and remedial action taken concerning those supplies
                    directly inspected by the state.  Requesting the state for
                    assistance as needed.  Reporting- immediately any abnormal
                    conditipns coming  to their attention either from emergency
                    or breakdov/n, or unusual bacteriological findings.  Reporting
                    any disease outbreak where a water supply may be suspect.

C.    PERIODS OF INSPECTION

      All public water supply systems  In Categories A, B, C and D are to be
given an inspection twice annually and a report made by a public health engineer
of the'Colorado Department of Health ( Only those serving 10 or more dwelling
units or 40 or nsore resident persons) .

Where these supplies are located within a local health department juri-sdictit i,
the engineer will coordinate the Inspection trip with the director- of the
appropriate ,dc'.p.n-;;ir.ent.  Upon conviction of the inspection, the findings and
recommendations vill be discussed with tha most responsible purveyor representative
available and a report left with him.  If the findings are significantly adverse
or if the recommendations are of a major nature, the findings and re'co^nmepdr.tions
shall be confirmed by a letter from the state Department of Health and follow up
instituted by the assigned engineer.

The annual inspection shall set forth the status of compliance with the
Drinking Water Standards for water quality,  adequacy of treatment and freedom
from hazards.  The Sanitary Survey will include a complete evaluation of the
water source,- treatment facility, operating procedure, control programs and other
matters of sanitary significance'as well as general information pertaining to
the community'

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                                        116
Public water supplies which are listed under Category E (Sampling Schedule
applying to Drinking Water Supplied the Public) in local health department
jurisdictions and which arc not regularly inspected by the state shall be
inspected and samples taken as the situation requires in the judgment of
the responsible inspecting authority.   However, inspections with written
report to owner of system at least once annually are suggested.

Category E (Public Water Supply)  located within a local health department
jurisdiction is to be sampled according to "Sampling Schedule applying to
Drinking Water  Supplied to the Public" which follows.

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                                      117
 D.   SAMPLING SCHEDULE APPLYING TO DRINKING WATER'SUPPLIED THE PUBLIC:
Characteristic
Category A, B, C, D   All supplies serving
over 10 dwelling units or 40 resident persons
Category
BACTERIOLOGICAL
      &
CHLORINE RESIDUAL
Follow requirements established in current
State Board of Health Regulations to the
Public.

Numbers of samples collected per month
shall be based upon population served.

Note:  Enter chlorine residual on Bact.
       results report.
Discretion of
inspecting
authority.

One per month
recommended.
PHYSICAL -
   TURBIDITY
PHYSICAL -
    COLOR
 PHYSICAL -
   THRESHOLD
       ODOR
CHEMICAL
RADIOACTIVITY
A minimum of four -samples per year for
surface waters and two samples per year
for grouixd water.
A minimum of two samples per year.
A minimum of two samples per year.
A minimum of two samples per year.
A minimum of two samples per year.
 Discretion

    t>f

 inspecting

  Authority.
                  Every six months from any water supply known to
                  contain radioactive substances; collect one sample
                  min imum.

                  E- Regularly inspected by local health department, if
                      available.
                  D  - Regularly inspected by state

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                                      120
          RESPONSIBILITIES IN LOCAL HEALTH DEPARTMENT AREAS
Inspections,
Reports and
Follow-up
Correspondence
Enforcement
COLORADO DEPARTMENT
OF HEALTH

All supplies serving 10 or
more dwelling units not under
control of owner, or serving
40 or more resident persons.
 LOCAL   HEALTH
   DEPARTMENTS

 All supplies serving less
 than 40 resident persons.
 Establishment supplies.
 Private supplies.
Sampling
Coordination
All  public water  supplies,
Minimum of 2  samples  for
bacteriological tests  per
month  or 1 per month  per
1,000  population, whichever
is greater, on those  inspects
by the state; others,  as
required.
Sample
Reports,
Bacteriological,
Physical,
Chemical,
Radioactivity
Analyze reports,
Notify purveyors of
non-compliance
Monthly  summary of bacterio-
logical  analyses  to state by
•5th of following  month on
system!;  inspected by the
state.   Forward individual
sample reports directly to
water purveyor as soon as
possible.  Notify state as
soon as  possible  of all
unsafe sample results from
supplies inspected by state.

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                                      121
       COLORADO DEPARTMENT OF  HEALTH

      DIVISION OF ENGINEERING & SANITATION
          DRINKING WATER SUPPLY SYSTEM

               ANNUAL INSPECTION
             A     B     C     D
 CATEGORY  f~7  I  7   /  7  /  7
File No.
Facility Name:
                                             Street or P.O.  Box_
                                             Ci ty;_..  	

                                             Date:
Population Served:
                        _County_
                         jColo.,  Zip_
        ITEM
                                                     AS  FOUND
1. COMPLIES WITH MINIMUM LEGAL REQUIREMENTS
2. MEETS QUALITY STANDARDS



3. DISINFECTION PROVIDED
4. ADEQUACY OF TREATMENT
Disinfection-all supplies unless waivered .
Coagulation, -settling-turbid surface sources
5. FREE OF SANITARY DEFECTS



6. SOURCE
No upstream contamination controllable by entity
Yes No
LJLJ
rjrj
	
. 	
	
LULU
rjrj
LJLJ
	
	
	
O£7
	











Source:
Mayor or Manager:
Treatment:
Person Interviewed:
Cap. M.G.D.:_

Number Taps:
Inspecting Engineer:
Local Health Dept. Rep;  .
"X" in "NO" column indicates  unsatisfactory
 condition                                   Letter to:
                                             Letter to Follow:  Yes  f~J    No /~~7
ES ENG 1 (Rev,3-69-20)

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        A      N  M X
BU.2GE.T.   AN.D   MAN[£



       COMPARISONS

-------
                               122
                          APPENDIX G

   Budget and Manpower Comparisons - Environmental Programs
Fiscal
Year
1968
Budget
Man-Years
1969
Budget
Man-Years
1970
Budget
Man-Years
1971
Budget
Man-Years
1972
Budget
Man-Years
1973
Budget
Man-Years
1974
Budget
Man-Years
Water Pollution
Control
$167,900
14
$212,800
18
$238,000
21
$415,900
23
$616,200
25
$417,200
29
$1,774,600
44
Air Pollution
Control
$227,500
14
$219,400
16
$213,200
18
$310,200
21
$585,400
36
$682,400
44
$1,265,500
52
Water
Supply
$59,100
2
$59 ,900
2
$68,500
2
$52 ,900
4
$52,200
4
$55 ,400
6
$59,800
4
NOTE:  Budget figures rounded off to nearest $100,  Man-years rounded off
       to nearest man-year.

Source:  Colorado Department of Health Budget Reports

-------
                 APPENDIX   H
BACTERIOLOGICAL  LABORATORY  SURVE.Y

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                            123

                          APPENDIX  H

              Bacteriological Laboratory .Survey
                          Report of a Survey of the
                    Colorado Department of Public Health
                             Water Laboratory
                           4210 East llth Avenue
                          Denver, Colorado 80220
                             October 19, 1971

                                    by

                           Harry D, Nash,  Ph. D.
                              Microbiologist
                      Water Supply Programs Division
                          Office of Water Programs
                     Environmental Protection Agency
                             5555 Ridge. Avenue
                          Cincinnati, Ohio 45268
The equipment and procedures employed in the bacteriological analyses of
water by this laboratory conformed with the provisions of Standard Methods
for the Examination of Water and Wastewater (13th edition - 1971) and with
the provisions of the Public Health Service Drinking Water Standards,
except for the items marked with a cross "X" on the accompanying'form
EPA-103 (Rev.  3-71).  Items marked with a "U" could not be determined
at the time of the survey.  Items marked "O" do not apply to the procedures
programmed in this laboratory.  Specific deviations are described with
appropriate remedial action for compliance in the following recommendations:

                             Recommendations

Item 4     Transportation and storage

The sample sheet accompanying each sample should plainly state the source
of the supply, the exact location sampled and the chlorine residual found at
the time of sampling.  Information on these sheets may be an important aid
in the interpretation of results.

A records examination of approximately 300 municipal samples received in
August, 1971, revealed that 25% of the samples were received after 48 hours
and 10% after 78 hours.  This review indicated that the delay could be
attributed to shipping of samples to the laboratory toward the end of the
week and holding samples over the week-end before examination. Samples
should be examined within 48 hours after collection or discarded.  The
practice of accepting samples older than 48 hours can result in data ranging
from misleading to totally false.  Bacterial flora can undergo marked

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                               124
unpredictable changes in the presence of toxic or nutritive substances,
especially at temperatures above 15°C.  The  greatest concern is that unsafe
potable supplies will be reported as safe due to coliform die-off during
transit.  Such die-off may result from metal ions,  adverse pH, toxic meta-
bolites and competition from non-coliforms present in the water.

It is recommended that individuals  be instructed to check mail schedules
so that sample collection and shipment can be coordinated, reducing the
overall time delay before examination of samples.  The importance of
collecting and shipping samples at the beginning of the week and not prior
to holidays should be  stressed in the instructions for taking samples,

Item 5      Record of Laboratory examination

Laboratory records

It is suggested that the laboratory itself maintain records  indicating the
number of tests conducted yearly.  These records should show the number
•of samples received from municipal and private supplies,  the total number
of samples examined,  the number of positive and negative tests,  and the
number of completed tests conducted.

Prompt resampling for unsafe samples

A review of the Colorado State  Public Health Engineering Section records
indicated that there is no  remedial  action initiated for resampling when an
unsafe sample is reported by the laboratory.  However, a letter is sent to
municipalities at the end of each month if bacteriological tests indicate that
their water  supply did not meet minimum requirements for water purity
for  that month, figure  1.  Records  further indicate that three of nine
samples collected from a  water supply which serves interstate carriers,
examined by the San Juan Basin Health Unit Laboratory located in Durango,
were reported as too numerous to count to the Colorado State Public Health
Engineering Section without  any remedial action being initiated.  In addition,
data relating to samples from the La Junta water supply system which
serves interstate carriers,  examined by the Pueblo City-County Health
Department Laboratory,  have not been submitted to the Colorado State
Public Health Engineering Section since January, 1971.  Again apparently
no action has been taken to correct  non-compliance with existing regulations.
It is recommended that regulations  outlined in the Public Health Drinking
Water Standards,  1962 and the Surgeon General's memorandum dated
February 15,  1963, be followed especially regarding water supplies serving
interstate carriers.

Item 6     Laboratory evaluation program

Dr.  C. D. McGuire, Director of Laboratories, is designated as the State
Water  Laboratory Survey Officer.  According to information obtained at the

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                                   125
                                          - 3-
8TATE 0:: COLORADO DEPARTMENT  O"  PUBLIC  HEALTH

                     4210 EAST 11TH AVENUE • DENVER, COLORADO 80220 • PHONE 388-6111
                                                         R. L. CLBERB, M.D., M.P.H., DIRECTOR
                Dear Sir:

                The results of bacteriological tests made on. samples of water
                collected from your water supply show that your water did not
                meet the minimum requirements for water purity for the month
                of""          	•

                This indicates the need for'improved treatment facilities
                or improved operation of the facilities that you do have,
                or both.

                Should you have any questions concerning this do not hesitate
                to let us know.

                                 Yours very truly,

                                 FOR DIRECTOR, ENGINEERING & SANITATION DIVISION
                                 George A. Prince, P.E., Chief
                                 public Health Engineering Section
                rb
                        Figure 1.  Letter sent to municipalities

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                          126
                                    - 4 -

time of this survey,  nine laboratories, Table 1, conduct water bacteriological
analyses.  The first seven have not been evaluated since the State evaluation
program was reviewed in October,  1968.  The  Larimer County Health Depart-
ment laboratory located in Fort Collins has never been surveyed.

The basic concept of the laboratory evaluation program is to extend technical
consultation to personnel in any laboratory conducting water bacteriological
analyses with regard to procedures, techniques and equipment and to assure
that these conform with provisions set forth in  "Standard Methods for the
Examination of Water and Wastewater" and the Public Health Service Drinking
Water Standards.  Such a consultant type program benefits the overall service
of the laboratory and insures the  reliability of data.   Laboratory evaluations
should be conducted under the State program on all laboratories at a frequency
which will assure compliance with recommended procedures for water bacter-
iological analyses.  The ultimate goal in this program is to up-grade techniques
and procedures used in all types of laboratory which examine water so that the
data is acceptable for official use in monitoring public water supplies and also
known to be of reliable status when used as legal evidence.
                                  Table 1.

           Laboratories Conducting Water Bacteriological Analyses
Name of Lab
Boulder County Health
Department Lab
Colorado Springs Health
Department Lab
Weld County Public Health
Department Lab
Northeast Colorado
Health Dept. Lab
Mesa County Health
Dept. Lab 1C*
Pueblo City-County
Health Dept. Lab 1C
San Juan Basin
Health Unit Lab 1C
Larimer County Health
Dept. Lab
Denver Board of Water
Commissioners Lab 1C
Location Survey Officer
Boulder McGuire
Colorado Springs "
Greely "
ti
Grand Junction "
Pueblo "
Durango "
Fort Collins "
Denver "
Date of
Last Survey
1966
1966
1966
1967
1968
1968
1968
«
1970
 *IC Laboratories examining samples from supplies serving interstate carriers

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                             127
                                     - 5 -

Item 33     pH Measurements

The pH of all batches of culture media should be checked after sterilization
and the pH of each batch recorded with the date and medium lot number.  As
an absolute minimal requirement, the pH of at least one batch of sterilized
medium from each new bottle of commercial medium must be determined to
assure its quality. By monitoring final medium pH, a check can be made on
possible errors in weighing, excessive heating and sterilization resulting
in lactose hydrolysis,  chemical contamination or deterioration of ingredients
that might occur during storage after stock packages are opened.

Item 34     Sterilization of media

It is recommended that liquid media containing carbohydrates be sterilized
at 121°C for 12 minutes.  This will reduce the possible chance of lactose
hydrolysis resulting from excessive exposure of lactose to heat.  Such
hydrolysis produces glucose and galatose which can be fermented by non-
coliform organisms resulting in false-positive reactions.

Item 48     Completed test

The confirmed test can yield positive reactions  in the absence of the coliform
group  (false-positive test).  Therefore, it is necessary to establish the
validity of the confirmed test by comparison with the completed test.  The
number of comparative procedures for establishing the confirmed test for
use in  water quality examination by comparison with the completed test
depends on the individual location.  Approximately 20 tests each three months
should be sufficient when good agreement is secured.  The number should be
increased if results from the confirmed and completed tests differ.  The
completed test is the reference standard.

Item 59     Reference  material

Since it is required that all equipment and procedures employed in the bacter-
iological analyses of water conform with the provisions of Standard Methods
for the Examination of Water and Wastewater,  it is essential that the labora-
tory be supplied with a copy of the current edition (13th edition - 1971) for
reference.

                            Personnel Approved

Mr. Paul Maifarth, Senior Microbiologist, and Mrs.  Lori Green, Laboratory
Assistant, are approved for the  application of the total coliform multiple-tube

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                          128
                                    - 6 -

fermentation procedure to the bacteriological examination of drinking water
and for the application of the fecal coliform test as used in stream quality
measurements.

                                Conclusions

The procedures and equipment in use at the time of the survey complied in
general with the provisions of Standard Methods for the Examination of
Water  and Wastewater (13th edition - 1971) and the Public Health Service
Drinking Water Standards,  and with correction of deviations listed, it  is
recommended that the results be accepted for the bacterial examination of
waters under interstate regulations.

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                              129
ENVIRONMENTAL PROTECTION AGENCY
           Water Quality Office
         Water Hygiene Division
        Bacteriological Survey for
           Water Laboratories  .
   Indicating conformity with the 13th
   edition of Standard Methods for the
   Examination of Water and Waste-
   water (1971).
Survey By
            ftoriy £>. Wash
X = Deviation    U =  Undetermined
           O = Not Used
Laboratory Crit
_    • *
Location
                 "««»«•. A •> . «-
                 i*tu»»vw>»
Date
ia/13/tt
                        Sampling and Monitoring Response

1.  Location and Frequency
       Representative points on system
       Frequency of sampling adequate	

2.  Collection Procedure
       Faucets with aerators should not be used	
       Flush tap  1 min. prior to sampling	
       Pump well 1 min. to waste prior to sampling
       River, stream, lake, or reservoir sampled at least
          6 inches below surface and toward current
       Minimum  sample not less than 100 ml	
       Ample air space in bottle for mixing
       Promptly  identify sample legibly and  indelibly  	

3.  Sample Bottles
       Wide mouth, glass or plastic bottles of	 capacity
       Sample bottles capable of sterilization and rinse  	
       Closure:
          a.  Glass stoppered bottles protected with metal foil,
              rubberized cloth or kraft type paper .  	
          b.  Metal or plastic screw cap with leakproof liner
       Sodium thiosulfate added for dechlorination
              Concentration 100 mg/1 added before sterilization
       Chelation agent for stream samples (optional)
              Concentration 372 mg/1 added before sterilization

4.  Transportation and Storage
       Complete and accurate data accompanies sample
       Transit time for potable  water samples should not exceed
          48 hrs, preferably within 30 hrs	
       Transit time for source waters,  reservoirs,  and natural
          bathing waters should not exceed 6 hrs
       All samples examined within 2 hours of arrival
 EPA-103 (Cin)
(Rev. 3-71)

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                             130
Laboratory  C:tevt.*z Dt&. df P-ftl«C H^fl^ocation 4210 E. J.lMiAW.
        Water Iji)).                         Denver, Ccto. 0023 0
 Date
10/19/71
4.   Transportation a ad Storage (Continued)
       Sample refrigeration mandatory on stream samples,
          optional on potable water samples		

5.   Record of Laboratory Examination
       Results assembled and available for inspection		
       Number of Tests per year
          MPN Test - Type of sample Muatcipal & Private (July 1070 to July 1971)
              Confirmed (+)	  (-)	  (Total) 1S.Q31
              Completed (+)	  (-)	  (Total)	

          MF Test - Type of sample	O
              Direct Count  (+)	 (-)_	(Total)  O
              Verified Count (+)	 (-}        (Total)  Q
       Data processed rapidly through laboratory and engineering sections .
       Unsatisfactory sample defined as J5 or more positive tubes per
          MPN test
       High priority placed on alerting operator to unsatisfactory(unBafe)
          potable water results	
       Prompt resampling for unsatisfactory samples	 .  ,   X
6.  Laboratory Evaluation Service
       State program to evaluate all laboratories which examine
          potable water supplies.		
       Frequency of surveys on a   1     year basis	    X
       State survey officer (Name)pr. C. David McGulra	.  .  .  .    "
       Status of laboratory evaluation service.	  	
          Total   9   labs known to examine water

                  S   approved laboratories

               	provisional laboratories
                              Laboratory Apparatus

7.  Incubator
       Manufacturer Precision Scientific	Model     00«B
       Sufficient size for daily work load	
       Maintain uniform temperature in all parts (± 0.5° C)	
       Accurate thermometer with bulb immersed in liquid on
          top and bottom shelves	
       Daily record of temperature or use of recording thermometer
          sensitive to 0.5° C change	
       Incubator not subject to excessive  room temperature variations
          beyond a range of 50 - 80° F	  . . . .
 EPA-103 (Cin)
 (Rev. 3-71)

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                              131
Laboratory  C rfawif* £>
-------
                              132
Laboratory  Colorado Dcpw of Pi'Mic     I Location  4210;:'. UthAve.
   Health YSfotor I^o.                     Denver, Colo. &0220
   Date
10/19/71
13. pH Meter
       Manufacture r	Photovolt	Model   Digicord
       Electronic pH meter accurate to 0.1 pH units	
14. Balance
       Balance with 2 g sensitivity at 150 g load used for general
          media preparations,  Type_
       Analytical balance with 1 mg sensitivity at 10 g load used
          for weighing, quantities less than 2 g ,  Type
       Appropriate weights of good quality for each balance		

15.  Microscope and Lamp
       Preferably binocular wide field, 10 to 15 diameters magnifi-
          cation for MF colony counts, Type		    O
       Fluorescent light source for sheen discernment		

16.  Colony Count
       Quebec colony counter,  dark-field model preferred for
          standard plate counts	    O

17.  Inoculating Equipment
       Wire loop of 22 or 24 gauge chromel, nichrome, or platinum
          iridium,  sterilized by flame	  .  .  	
       Single-service transfer loops of aluminum or stainless steel,  pre-
          sterilized by dry heat or steam		
       Disposable single service hardwood applicators, pre-
          sterilized by dry heat only		
18.  Membrane Filtration Units
       Manufacturer	_Type	
       Leak proof during filtration	    O
       Metal plating not worn to expose base metal		

19. .Membrane filters
       Manufacturer	     Type	
       Full bacterial retention, satisfactory filtration speed	    O
       Stable in use, glycerin free.  .		
       Grid marked with non-toxic ink	_		
       Presterilized or autoclaved 121° C for  10 min	  	

20.  Absorbent Pads
       Manufacturer	Type	
       Filter paper free from growth Inhibitory substances	    O
       Thickness uniform to permit 1.8 - 2.2 ml medium absorption  ....   	
       Presterilized or autoclaved with membrane filters		
 EPA-103 (Gin)
 (Rev.  3-71)

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                               133
Laboratory Ce!oro<2o
             ui*.
of i
Location *31
         Colo*
  HthAve, |   Date
cosao      |io/ie/n
21.  Forceps
       Preferably round tip without corrugations
       Forceps are alcohol flamed for use in MF procedure


                   Glassware, Metal Utensils and Plastic  Items

22.  Media Preparation Utensils
       BW8raisat#ljB*f . .  • •	  	
       Stainless steel	
       Utensils clean and free from foreign residues or
          dried medium

23.  Pipets
       Br^nd      *»"»                    Type    ^13* tip
       Calibration error not exceeding 2.5%.  .  .  . . .  .  .  .. .  .  .
       Tips unbroken, graduation  distinctly marked	
       Deliver accurately and quickly.	
       Mouth end plugged with cotton (optional)	

24.  Pipet Containers
       Box, aJutirtfiunf or stainless steel
       Paper wrapping of good quality sulfite paper (optional) »

25.  Petri Dishes
       Brand	Type
       Use 100 mm x 15 mm dishes for pour plates
       Use 60 mm x 15  mm dishes for- MF cultures
       Clear,  flat bottom,  free from bubbles and scratches	
      . Plastic dishes may be reused if sterilized in 70% ethanol for
          30 min. or by ultraviolet radiation	
26.  Petripish Containers
       Alumihumor stainless steel cans with covers,  coarsely woven
          wire baskets, char-resistant paper sacks or wrappings  	

27.  Culture Tubes
       Size sufficient for total volume of medium and sample portions
       Borosilicate glass  or other corrosive resistant glass

28.  Dilution Bottles or  Tubes
       Borosilicate or other corrosive resistant glass .	
       Screw cap with leak-proof liner free from toxic substances
          on sterilization	
       Graduation level indelibly marked on side of bottle or tube
EPA-103 (Cin)
(Rev. 3-71)

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                             134
Laboratory Colorado Eter« of Public
 Health Water Lab.
                                     Location  42*,, E. llth A ve.
                                     Denver* Colo.  80220
    Date
10/19/71
29.
                         Materials and Media Preparation
Cleaning Glassware
  Dishwasher Manufacturer  Hetnlcfce
                                             Model
       Thoroughly washed in detergent at 160°F, cycle time   7 mjn.
       Rinse in clean water at 180° F(  Cycie time   7 mint.          '.  .  .'
       Final rinse in distilled water,  cycle time  2.5mln.        ~.  •  •
       Detergent brand Helnicho  B-3	^
       Washing procedure leaves no toxic residue	
       Glassware free from acidity or alkalinity	
30.  Sterilization of Materials^
       Dry heat sterilization (1 hr at 170°C)
          Glassware not in metal containers	
       Dry heat sterilization (2 hrs at 170°C)
          Glassware in metal containers	
          Glass sample bottles	
       Autoclaving at 121° C for 15 min	
          Plastic sample bottles	
          Dilution water blanks	

31.  Laboratory Water Quality
       Still manufacturer                   Construction Material	
       _ '  ,     ..      . "  Cuoliitonuu                           —————
       Demineralizer with	once a month    recharge frequency
       Protected storage tank	
       Supply adequate for all laboratory needs	  .
       Free from traces of dissolved metals or chlorine	.  .  .
       Free from bactericidal compounds as measured
         by bacteriological suitability test	
       Bacteriological quality of water measured once each year
         by suitability test or sooner if necessary	

32.  Buffered Dilution Water
       Stock phosphate buffer solution pH 7.2	
       Prepare fresh stock buffer when turbidity appears .	
       Stock buffer autoclaved and stored at 5 -  10° C	
       1. 25 ml stock buffer per 1 liter distilled water	
       Dispense to give 99 ± 2 ml of 9 ± 0.2 ml after autoclaving	

33.  pH Measurements
       Calibrate pH meter against appropriate standard buffer prior to use
       Standard buffer brand	pH    7.0  	
       Check the pH of each sterile medium batch or at least one batch
         from each new medium lot number	
EPA-103  (Cin)
(Rev. 3-71)

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                                135
Laboratory  C
        Wstor
                  i ,'t> fop**  of
 Location  «J3 K«  Hth Aw.
Denvvr* Colo. 80229
   Date
1D/J9/T*
33.  pH Measurements (Continued)
       Maintain a pH record of each sterile medium batch,
          the date and lot number. 	

34.  Sterilization of Media
       Carbohydrate medium sterilized 121° C for 12 min
       All other media autoclaved 121°C for 15 min
       Tubes packed loosely in baskets for uniform heating and cooling.
       Timing starts when autoclave reaches 121°C
       Total exposure of carbohydrate media to heat not over 45 min
       Media removed and cooled as soon as possible after sterilization

35.  Storage
       Dehydrated media bottles kept tightly closed and stored
          at  less than 30°C
       Dehydrated media not used if discolored or caked	
       Sterile culture media stored in clean area free from
          contamination and excessive evaporation
       Sterile batches used in less than 1 week
       All media protected from sunlight	
       If media is stored at low temperatures,  it must be incubated
          overnight and any tubes with air bubbles discarded  	


                          Culture Media -  Specifications

36i  Lactose  Broth
       Manufacturer	Lot No.
     •  Single strength composition 13 g per liter distilled water 	
       Sinrle strrrseth pH 6. 9 ± 0.1, double strength pH 6. 7 ± 0.1
       Not less than 10 ml medium per tube
       Composition of medium  after 10 ml sample is added must
          contain 0.013 g per ml dry ingredients	
37.  Lauryl Tryptose  Broth
       Manufacturer    '   Plfe<» 	 Lot No.   8g443S
       Single strength composition 35. 6 g per liter distilled water
       Single strength pH 6. 8 ± 0.1, double strength pH 6. 7 ± 0.1
       Not less than 10 ml medium per tube
       Composition of medium  after 10 ml sample is added must
          contain 0. 0356 g per  ml of dry ingredients

38.  Brilliant Green Lactose Bile Broth
       Manufacturer           **h™                Lot No.   63S783
EPA-103 (Gin)
(Rev. 3-71)

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                            136
Laboratory  Colorado Dcpt. of Public
  Health Water Lab.
Location 4210 £.  llth Avo.
 Denver, Colo.  80220
  Date
10/10/71
38.  Brilliant Green Lactose Bile Broth (Continued)
       Correct composition, sterility and pH 7. 2		
       Not less than 10 ml medium per tube		

39.  Eosin Methylene Blue Agar
       Manufacturer    pjfco 
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                              137
Laboratory C^lorfcda J>ep|, of PotllO    I ''Location  4SIOE.  I Uh Avtl,   I Date
      m Water Lab,                      |  tcnvor, Cola SOZaft        £3/19/71
45.  _ _ Agar (Continued)
       Correct composition and pH
                           Multiple Tube Coliform Test

46.  Presumptive Procedure
                                      lauryl tryptose broth_
       Shake sample vigorously	
       Potable water:  5 standard portions, either 10
       Stream monitoring:  multiple dilutions	
       Incubate tubes at 35° ± 0. 5°C for 24 ± 2 hr	
       Examine for gas	any gas bubble positive. . .
       Return negative tubes to incubator	
       Examine for gas at 48 ± 3 hr from original incubation
47.  Confirmed Test
       Promptly submit all presumptive tubes showing gas production
          before or at 24 hr and 48 hr periods to Confirmed Test  .  .
       a. Brilliant green lactose broth
          Gently shake presumptive tube or mix by rotating	
          Transfer one loopful of positive broth or one dip of applicator
             from presumptive tube to brilliant green lactose broth.  .  .
          'Incubate at 35° ± 0. 5°C and check at 24 hrs for gas production.
          Reincubate negative tubes for additional 24 hrs
             and check for gas production	
          Calculate MPN or report positive tube results	
       b.  TJffncrW eosin methylene blue agar plates adequate streaking
             to obtain discrete colonies separated by 0.5 cm
          Incubate at 35° ± 0.5° C for 24 ±2 hr
          Typical nucleated colonies with or without sheen are conforms
          If atypical unnucleated pink colonies develop,  result is
             doubtful and completed test must be applied
          If no colonies or only colorless colonies appear, the
             confirmed test is negative.  ......... ......

48, Completed Test
       Applied to all potable water samples or a proportion each three
          months to establish the validity of the confirmed test in
          determining their sanitary quality.  .  .  ,  . .
       Applied to positive confirmed tubes or to doubtful colonies
          on differential medium .....        ..... •
       Streak positive confirmed tubes on Endo or EMB plates for
          colony isolation.  ..........  .
EPA-103 (Gin)
(Rev.  3-71)

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                              138
Laboratory Colorado Dept. of Public
   Health Water Lab.
Location 4210 E.  HthAve.
 Denver, Colo,  80220
 Date
10/19/71
48.  Completed Test (Continued)
       .Choice of selected isolated colony for verification should be one
          typical or two atypical to lactose or lauryl tryptose broth and
          to agar slant for Gram  stain	
       Incubate at 35° C ± 0. 5°C for 24 hrs or 48 hrs	,
       Gram negative rods  without spores and gas in lactose tube
          with 48 hrs in positive Completed Test	  ,
	                     Membrane Filter Coliform Test

49. . Application as Standard Test
	  Use as a standard test for determining potability of water after
	•  • demonstration by parallel testing that it yields information
	'  " equal to that from the multiple-tube fermentation procedure  .    .  .  Q

50.  MF Procedure
       Filter funnel and receptacle sterile at start of series. .  .  .  .  .  . .  . _O_
—:—  Rapid funnel resterilization by UV,  flowing steam or boiling water
          acceptable	,	O
	    .Membrane filter cultures and technician eyes should not be
          subject to UV radiation leaks  .   . .  .  ...  ..» ...  ...  . .  .  Q
       Filtration volume  not less than 50 ml for potable water; multiple
          dilutions for stream pollution .   .	  .  Q
~	"""• Rinse funnel by flushing several 20  - 30 ml portions of sterile buffered
	 _     water through MF	  .  ...  ......  .  Q
   "'   Remove filter with sterile forceps	O
       Roll filter over M-ENDO medium pad or agar so air bubbles
          will not form	Q

51.  Incubation	    •   •
	  In high humidity or in tight fitting culture  dishes	Q
       At 35°C ± 0. 5° C for 22 - 24 hrs		

"52." "Counting
   _   -All colonies with a metallic yellowish green surface sheen
       If coliforms are found in potable samples,  verify by transfers
          to lactose broth, then to BGB broth for evidence of gas
          production at 35°C within 48 hr limit......  . .  .  .  .  .  . .  .	
       Calculate direct count in cdliform density per'100 ml.		

53"."" Standard MF test with Enrichment
       Incubate MF after filtration on pad saturated with lauryl tryptose
          broth for  1  1/2 - 2 hr at 35°C ±0. 5°C  .  .............  Q
 EPA-103 (Ciu)
 (Rev.  3-71)
                                     10

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                               139
Laboratory CotofaOfli f*?S»t
        Wattr
Location 4210.., IUHAV9.
 Denver. Colo.  £0339
 Date
10/10/71
53.  Standard MF test with Enrichment (Continued)
       Transfer MF culture to M-Endo medium for a final
          20 - 22 hr incubation at 35°C ± 0.5° C
       Count sheen colonies, verify if necessary,  and calculate
          direct count in coliform density per 100 ml
                      Supplementary Bacteriological Methods

54.  Standard Plate Count
       Plate not more than 1 or less than 0.1 ml (sample or dilution)	Q
       Add 10 ml or more liquefied agar medium at a temperature                 ~"
          between 43 - 45°C	•  .  .	
       Melted medium stored for no more than 3 hr at 43 - 45° C	
       Liquid agar and sample  portion thoroughly mixed by gently
          rotating to spread mixture evenly	
       Count only plates with between 30 and 300 colonies, exception
          being 1 ml sample with less than 30 colonies	
       Record only two significant figures and calculate as "standard
          plate count at 35C C per 1 ml of sample".	
55.  Fecal Coliform Test
       a.  Multiple Tube Procedure
          Applied as an EC broth confirmation of all positive
             presumptive tubes	• .  .  7
          Place EC tubes in water bath within 30 min of transfers	1
          Incubate at 44. 5°C ±0.2° C for 24 hrs	]  ]  '	
          Gas production is positive test  for fecal coliforms	]    ]	
          Calculate MPN based on combination  of positive EC tubes  !  .  !  !  !	
       b.  Membrane Filter Procedure
          Following filtration place MF over pad saturated with
             M-FC broth.		
          Place MF cultures in water-proof plastic bag and submerge
             in water bath within 30 min	
          Incubate at 44. 5*C ±0.2° C for  24 hrs  ......:....'.'.  '.
          All blue colonies  are fecal coliforms	
          Calculate direct count in density per 100  ml  .  .  .  '.	'  .  ,

56.  Delayed-Incubation Coliform Test
       After filtration, place MF over pad of M-Endo containing 3. 2  ml
          of a  12% sodium benzoate solution per 100 ml of medium .....  .	
       Addition of  50 mg cycloheximide per  100 ml of preservative
          medium  for fungus suppression  is optional	
       Transport culture by mail service to laboratory within 72 hours  .  .  .  .

 EPA-103 (Gin)
 (Rev.  3-71)                                                                   11

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                            140
Laboratory  Colorado Dfc^*. of Public     I Location 42h» E. llth Ave.   I  Date
  Health Water Lab.	j  Denver, Colo.  80220        [10/.9/71

56.  Delayed-Incubation Coliform Test (Continued)
       Transfer MF cultures to standard M-Endo medium
          at laboratory		
       Incubate at 35°C ± 0. 5°C for 20 - 22 hr	  .	
       If at time of transfer, growth is visible,  hold in refrigerator
          till end of work day then incubate at 35° overnight
          (16 - 18 hr period)		
       Count sheen colonies, verify if necessary, and calculate
          direct count in coliform density per 100 ml		
57.  Additional Test Capabilities
       Fecal streptococci        	  Method 	
       Pseudomonas aeruginosa  	___  Method _________________
       Staphylococcus           _______  Method        '
       Salmonellae              	Method	'
       Biochemical tests         	  Purpose •
       Serological tests          	  Purpose 	
       Other                    	  Purpose
                          Laboratory Staff and Facilities

58.  Personnel
       Adequately trained or supervised for bacteriological
          examination of water	
       Laboratory staff      3	(Total) Prep room staff	(Total)"

59.  Reference Material
       Copy of the current edition of Standard Methods available
          in the laboratory	
       State or federal manuals on bacteriological procedures for
          water available for staff use	
60.   Physical Facilities
       Bench-top area adequate for periods of peak work in
          processing samples	
       Sufficient cabinet space for media and chemical storage.  .
       Office space and equipment available for processing water
          examination  reports and mailing sample bottles .  .  .  .
       Facilities  clean, with adequate lighting, ventilation and
          reasonably free from, dust and drafts	
61.  Laboratory Safety
       Proper receptacles for contaminated glassware and pipettes,
 EPA-103 (Cin)
 (Rev.  3-71)                                                                   12

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                             141
Laboratory  Colorado
    Health Water Lab.
                            of Pulilto
Location 42*,. E. llth Aw.      Date
Denver, Colo.  80220         10/19/71
 61. Laboratory Safety (Continued)
        Adequately functioning autoclaves with periodic inspection
           and maintenance	
        Accessible facilities for hand washing	
        Proper maintenance of electrical equipment to prevent fire
           and electrical shock	
        Convenient gas and electric outlets.	
        First aid supplies available and not out-dated	,
 62.  Remarks
EPA-103  (Gin)
(Rev. 3-71)
                                                                             13

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                              APPENDIX     I
INCIDENCE     OF    WATER BORNE    DISEASES

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                           142
                       APPENDIX  I
Incidence of Potential Water-borne Diseases  in Colorado

        Ameblasis   Hepatitis   Saltnonellosls   Shlgellosls    Typhoid
1963
Colo, cases
U.S. cases
% in Colo.
1964
Colo, cases
U.S. cases
% in Colo.
1965
Colo, cases
U.S. cases
% in Colo.
1966
CoTo". cases
U.S. cases
% in Colo.
1967
Colo, cases
U.S. cases
% in Colo.
1968
Col o . cases
U.S. cases
% in Colo.
1969
Colo, cases
U.S. cases
% in Colo.
1970
Colo, cases
U.S. cases
% in Colo.
1971
Colo, cases
U.S. cases
% 1n Colo.
1972
Colo, cases
U.S. cases
% 1n Colo.
TOTAL
Colo, cases
U.S. cases
% 1n Colo.

5
?886
0.2%

10
3304
0.3%

11
2768
0.43!

6
2921
0.2*

6
3157
0.2%

6
3005
0.2%

6
2915
0.2%

5
2888
0.2%

16
2752
0.6%

10
2199
0.5%

81
28,795
0.3%

573
42,974
1.3%

622
37,740
1.6%

403
33,856
1.2%

318
32,859
1.0%

328
38,909
0.8%

773
45,893
1.7%

724
48,416
1.5%

1,017
56,797
1.8%

842
59,606
1.4%

754
54,074
1.4%

6,354
451 ,124
1 ;4%

357
15,390
2.3%

330
17,144
1.9%

218
17,161
1.3%

376
16,841
2.2%

296
18,120
1.6%

197
16,514
1,2%

225
18,419
1.2%

305
22,096
1.4%

291
21 ,928
1.3%

281
22,151
1.3%

2,876
185,764
1.6%

300
13,009
2.3%

476
12,984
3.7%

259
11,027
2.4%

354
11,888
3.0%

408
13,474
3.0%

415
12,180
3.4 %

175
11,946
1.5%

100
13,845
0.7%

156
16,143
1.0%

300
20,207
1.5%

2,943
136,703
2.2%

7
566
1.2%

4
501
0.8%

1
454
0.2%

3
378
0.8%

13
396
3.3%

7
395
1.8%

3
364
0.8%

3
346
0.9%

3
407
0.7%

2
398
0.5%

46
4,205
1.1%

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               A P.P.E.N.D I X.   i

      £iHHAT£D   RE.IOURC; E.S
CHEMICAL   L A B 0 R A T 0 R Y   S U P P 0 R T

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                                143


                          APPENDIX J

                      Estimated Resources
                  Chemical Laboratory Support


I.  Frequency of Analysis

                                           Frequency of
Supply                    Number             Analysis           Number/Year

Community (A, B, C, & D)
  Surface water sources   152              Every year               152
  Ground water sources    552              Every 3 years            184

Small public and those
  serving traveling
  public (E)              900              Every 5 years            180

                                           TOTAL                    516


II.  Manpower to Analyze for Constituents in Drinking Water Standards.
     (Based on EPA Experience)


         Chemical                             Man Days/Sample
         Analysis                 Surface Water Source  Ground Water Source

Wet Chemistry                              0.65                0.65

Trace Elements                             0.65                0.65

Carbon Chloroform Extract
  (Organics)                               1.00

Radiochemical                              1.20                1.20

Pesticides (chlorinated
  hydrocarbons and herbicides)             2.00                	

                     TOTAL                 5.50                2.50

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                              144


III.   Annual  Manpower Required and Costs

Community Water Supplies

  Surface Water Sources - 152 samples  x 5.50 man-days  = 836 man-days
                               year           sample

  Ground Water Sources - 184 samples x 2.50 man-days = 460 man-days
                              year          sample


Small Public Water Supplies and Supplies Serving the Traveling Public

             180 samples x 2.50 man-days* = 450 man-days
                  year          sample


TOTAL = 1,746 man-days/year

1,746 man-days/year  = 7.9 or approximately 8 man-years
220 man-days/man-year

8 man-years x $21,600/man-year = $172,800 annual costs (including 20%
  administrative costs)

*Assumes that these are all ground water supplies


IV.  Approximate Costs Per Sample

     Surface Water Sources

     (5.50 man-days) x ($21,600/man-year) = $540/sample
          220 man-days/man-year


     Ground Water Sources

     (2.50 man-davs) x ($21,600/man-year) = $245/sample
          220 man-days/man-year


     Trace Elements Only

     (0.65 man-davs) x ($21,600/man-year) • $64/sample
          220 man-days/man-year

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