ENVIRONMENTAL STRATEGIES
FOR METRO-DENVER
An Integrated Environmental Management Project
Report to the
ESP Advisory Committee
ISSUE PAPERS
Indoor Air Quality* Outdoor Air Quality # Water Quality
Solid and Hazardous Waste • Environmental Lead
Prepared by ESP Staff
April 1988

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ISSUE PAPERS
Background Information on 19 Environmental Issues
Facing Metropolitan Denver
Prepared for the Environmental Strategies Project
Advisory Committee
APRIL 1988
by ESP Staff
Ken Lloyd, Project Director
Environmental Protection Agency
Region VIII
U.S.EPA REGION 8
Technical Library 80C-L
999 18th Street, Suite 500

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PLEASE NOTE
The results described in this report should only be
considered within the context of discussions of the Environmental
Strategies Project. Consistent with the original ground rules of
the ESP Advisory Committee, we strongly recommend that Committee
members and Work Group participants not discuss or distribute the
information with individuals not associated with the project
until the Advisory Committee as a whole has had a chance to
discuss the implications.
This material can easily be misinterpreted, and if
misconstrued could jeopardize the ultimate goal of the project —
an objective discussion comparing environmental issues in the

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INTRODUCTION
Environmental Strategies Project Issue Papers
The issue papers contained in this document provide a brief
overview of topics being considered by the Environmental Strategies
Project (ESP). These papers were prepared for the ESP Advisory
Committee to supplement their understanding of metro Denver
environmental issues. As such, these papers are intended only as
snapshots of each topic, not exhaustive descriptions.
For each of the selected topics, the issue papers outline the
findings of the ESP work groups and background risk assessment
reports where such work was performed. The risk assessments, which
were performed for 13 of the 19 issues discussed herein, used
existing data to develop rough estimates of the health risks posed
by certain pollutants.
Several caveats are needed to put the ESP risk assessment results
in proper context. These analyses were conducted to highlight
major differences between the issues. The results are not intended
as accurate estimates of the risk. In most cases upper-bound
estimates were used for worst case comparisons. The actual risks
are probably lower than the upper-bound estimate. The lower-bound
in each case may be zero, but the lower-bound estimates given are
probably more reasonable.
The ESP risk assessments did not address all potential health
effects, but attempted to deal with significant health concerns
related to these issues. Other limitations of the risk assessments
are described in the issue papers. Additional detail on the risk
assessments are available in full reports prepared for the ESP.
In addition to information on health effects, the issue papers
contain a brief description of economic/welfare effects and
ecological effects associated with each issue. The papers also
present information on environmental management factors, including
public perception and political pressure, regulatory status, and
possibilities for further control.
The issue papers were prepared by ESP staff and reviewed by EPA,
state, and local program managers, whose assistance is greatly
appreciated. The ESP staff, however, is solely responsible for the
content of the issue papers.
A further description of the information presented in the issue

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ESP Issue Papers
Definition of Categories of Information
I. ISSUE DESCRIPTION
Brief overview of the issue in the Denver metropolitan area
and potential health and environmental effects.
II. IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1 . Environmental Strategies Project Analysis
Where the ESP performed a risk assessment on an issue,	this
section describes the analytical approach, information	on
human exposure, and impact on human health used in the	ESP
assessment.
2. Other Health Issues/Limitations of the ESP Analysis
Brief overview of health issues not addressed in the ESP
analysis; uncertainties and limitations of the ESP analysis
B. Economic/Welfare Effects
Potential effects of the problem, if unabated, on the area
economy and economic development opportunities; impacts on
property, materials, and quality of life.
C. Ecological Effects
Impacts on ecosystems resulting from habitat modification and
pollution. Both plants and animals may be effected in fresh

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III. ENVIRONMENTAL MANAGEMENT FACTORS
A. Public Perception and Political Pressure
Description of the extent of public concern; degree to which
it is expressed.
B. Regulatory Status
1. Legal Requirements: brief outline of federal and state
statutes and regulations; pending regulatory changes.
2. Current Activities: brief overview of specific pollution
reduction strategies being pursued by federal, state, and
local authorities; special initiatives by public and private
organizations
3. Public Expenditures: federal and state expenditures for
pollution reduction—Fiscal Year 1988
C. Possibilities for Further Control
Other potential control options
IV. WORK GROUP FINDINGS
Gaps in technical data and other findings identified by the

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Issue Papers
TABLE OF CONTENTS
Item	Page
A.	Indoor Air Quality:
1.	Radon in homes and buildings	1
2.	Environmental tobacco smoke	7
3.	Other indoor air pollutants	11
B.	Outdoor Air Quality:
1 . Carbon monoxide	14
2.	Fine particulate matter	20
3.	Ozone	26
4.	Air toxics	30
C.	Water Quality:
1.	Drinking water quality	34
2.	Groundwater quality	39
3.	Surface water quality	43
D.	Solid and Hazardous Waste:
1.	Emergency response/SARA Title III	48
2.	Superfund sites	52
3.	Underground storage tanks	57
4.	Active municipal landfills	62
5.	Inactive municipal landfills	66
6.	Hazardous waste generators	69
7.	Transportation of hazardous	73
materials
8.	Hazardous waste treatment, storage	77
and disposal facilities

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A. INDOOR AIR QUALITY
1.	Radon in Homes and Buildings
2.	Environmental Tobacco Smoke
3.	Other Indoor Air Pollutants

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RADON IN HOMES AND BUILDINGS
I. ISSUE DESCRIPTION
Radon is a colorless, odorless, radioactive gas produced by
the spontaneous decay of heavy elements Uranium and Thorium that
are found naturally in soil and rock. Once emitted, the radon
gas can migrate from the soil, through cracks and other
foundation openings, and ultimately into buildings where it is
trapped. While trapped inside a home or other building, the
radon gas continues to decay, forming short-lived radioactive
progeny of radon that can attach to sensitive lung and bronchial
tissues when inhaled. Alpha particles emitted by these progeny
can impact cell tissue and can cause lung cancer.
Monitored in the Denver area suggests that the current
lifetime cancer risk from indoor exposure to radon progeny is
significant and may affect most residents. However the problem
can be corrected with readily available solutions.
II. IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
In the spring of 1987 EPA sponsored a monitoring program
that measured radon levels in homes in Colorado and nine other
states. Two-day samples from 272 homes in the Denver metro area
were gathered by the Colorado Department of Health and the
Colorado Geological Survey as part of the Colorado effort.
Data from this study were used in a risk assessment model
developed by ESP staff with assistance from local technical
experts. The model is based on an extensive body of health data
from epidemiological studies of uranium miners exposed to radon
in Colorado and around the world over the past 40 years.
Several factors can influence the estimation of the
magnitude of cancer risks from radon. The model employed in this
analysis accounts for these factors and allows for their
variation in order to make the estimates more realistic. Factors
considered include:
o Range of cancer potency risk factors from studies conducted
by EPA, the National Academy of Science, the National
Institute for Occupational Safety and Health, and the
International Commission on Radiological Protection;

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o Seasonal variation of radon exposure levels;
o Time people spend in three different breathing environments
indoor home, other indoor areas outside the home, and
outdoors;
o Lower radon concentrations found in the upper levels of
homes as compared to the basement where most monitoring is
done;
o Percentage of radon progeny that remain in the breathable
air instead of attaching to room surfaces (i.e., equilibrium
rate);
The knowledge, experience, and informed judgments of local
technical experts were used to apply the model and estimate the
lifetime cancer risks to the Denver population. Many of these
experts are health professionals who have been involved in
Colorado radon issues since the late 1960's.
o Information on Human Exposure
The human exposure pathways to radon progeny are found
almost everywhere. Highest concentrations are usually found
indoors in basements and lower levels of unventilated structures
during the spring and winter months. While outdoor exposures are
generally lower than in most homes, they can still be significant
in the calculation of lifetime risk. Most people typically spend
10% to 25% of their time outdoors, with about 50% of the
remaining indoor time spent in their own home.
EPA has recommended a radon action level in homes of 4
picocuries per liter of air (pCi/1), above which a homeowner
should consider taking additional steps. The average radon
concentration measured in the 272 Denver area homes monitored was
about 5 pCi/1. The lowest levels found in the sampled homes were
about 0.5 pCi/1 while the highest level sampled was about 40
pCi/1. Since these data were gathered a few homes have been
found with initial levels above 100 pCi/1.
It is currently not possible to identify which homes might
have elevated levels of radon without monitoring each structure.
High radon levels were found throughout the metro-area.
o Impact on Human Health
The primary impact of inhaling radon progeny over a lifetime
is the possibility of premature death resulting from lung cancer.
Applying the risk model to the 272 homes monitored resulted
in an average individual cancer risk of about one in 100 if
exposure to these levels of radon continued over a lifetime. The

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distribution of risk for most of the 272 households tested ranged
from a low of 3 in 1000 to a high of 3 in 100, though there is a
small number with risks on the order of 7 in 100. Every
household measured has some radon resulting in some level of
lifetime cancer risk.
2. Other Health Issues/Limitations of the ESP Analysis
While the radon risk analysis is based on solid data using a
realistic modeling approach, there are still several
uncertainties and limitations that impact estimated health risks
for Denver-area residents. These are summarized below:
The analysis assumes people will continue to be exposed to
current radon levels over their lifetime — without correction.
The additional risk to cigarette smokers who have in the
past been exposed to elevated levels of radon is not included in
the risk estimates. Many researchers believe that the combined
effects of exposure to tobacco smoke and radon are multiplicative
(i.e., the combined risk is greater than the sum of the two
individual risks).
The radon monitoring data used to estimate risks are short
term (2-day) samples instead of the year-long samples preferred
for estimating lifetime exposure. The seasonal corrections
applied in the model have since been found comparable to a year-
long radon monitoring effort recently completed in Fort Collins.
The radon sample size was limited to 272 homes monitored in
the Denver area instead of the 595 planned. However, additional
monitoring conducted this spring does not appear to change the
result.
The risk calculation method that was used to estimate
lifetime risk assumes that the epidemiological data from uranium
miners are transferable to the home environment. One of several
possible differences is the evidence that indicates that the
percentage of more toxic radon progeny not yet attached to air-
borne particles may in fact be higher in the cleaner air found in
homes, resulting in more harmful radon progeny being inhaled. Is
is not clear whether the combined effect of all of the
differences between homes and uranium mines would result in
higher or lower cancer risk. More basic research is needed in
order to understand these differences.
The analysis includes the additional risk that can occur
when children are exposed. Some researchers are now suggesting,
however, that if radon exposures are reduced while children are
young they may be able to recover somewhat and thereby reduce
their lifetime risk.

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B. Economic/Welfare Effects
A temporary loss of property value can occur until any
necessary retrofit is completed, which in turn may raise the cost
of housing.
An area-wide loss to the Colorado economy could occur if the
national perception were to shift toward a belief that, because
of radon problems, Colorado is not a desirable place to live or
relocate businesses.
C. Ecological Effects
There are virtually no additional effects on the natural
environment — radon has historically been as much a part of the
planet as the planet itself.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A. Public Perception/Political Pressure
The population as a whole has a low but growing awareness of
radon as a health problem that may be affecting them. When
individuals discover they have elevated levels of radon in their
home, their reaction is mixed, ranging from "a" to "p" — apathy
to panic.
Political pressure so far is small but polarized. On one
hand, a health concern segment is expressing appeals for action.
On the other hand, an economic segment is cautioning that over-
reaction could create economic problems, particularly in the real
estate market.
B. Regulatory Status
1.	Legal Requirements
No statutory authority specific to radon exists yet.
Legislation is pending in the U.S. Congress to share the cost of
establishing state radon technical assistance programs. The
Senate passed a bill last summer, but a companion bill in the
House remains in committee. Pressure is also being applied for a
health-based standard below the current EPA action level of 4
picocuries per liter. Many states are considering radon
statutes, although Colorado has yet to do so.
2.	Current Activities
Formal comprehensive radon control strategies have not yet
been developed state-wide or for the Denver area. Limited
technical assistance is being provided on request by local,

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state, and federal environmental health organizations. The
current primary method of radon control occurs when private firms
perform radon monitoring and corrective retrofit at the request
of homeowners and building managers who can afford it.
The Governor's Indoor Radon Policy Task Force was formed
during the summer of 1986 and remains in place to investigate
radon issues and influence Colorado policy. Some localities are
considering building code requirements for new construction.
Local building and trade associations are considering their own
initiatives. Some financial and relocation institutions require
screening test measurements of radon activity to be below 4
picocuries per liter before a home is purchased.
EPA is currently sponsoring a radon risk communication
research project with the University of Colorado. This joint
effort aimed at developing and testing the effectiveness of
several radon risk communication protocols applied to the Denver
area.
3. Public Expenditures
State and local agencies are not yet funded specifically for
regulatory or technical assistance radon efforts.
C. Possibilities for Further Control
Most professionals in the field believe that most of the
problems can be solved in a five year period. There are cost-
effective solutions available for remediating individual radon
problems. Solutions usually involve sealing foundation cracks
and venting or pressurizing basements. An average cost of
retrofit for a Colorado homeowner varies from $300 to $500, with
a few severe cases costing as much as $5,000.
The ultimate solution to the problem depends heavily upon:
(1) providing effective risk and solution communication to
homeowners and building managers who can take action, (2)
identifying high radon homes early in the effort, (3)
establishing an institutional method for providing technical
assistance, and (4) formulating a comprehensive radon control
strategy.
IV. WORK GROUP FINDINGS
The ESP Indoor Air Work Group, with support from local
technical experts, developed three main messages after
consideration of radon issues in the Denver area:
o Lifetime cancer risks from radon are high, but
relatively easy to resolve;

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o It is important to deal with our radon problem in a
positive way that does not cause panic to people and
the economy;
o It is important to simultaneously communicate.both the
problem and the solution to those who can and should
take action.
The Work Group further recommended that a long-term radon
monitoring program be conducted in the Denver area. This will
supplement the existing short-term data with data collected over
one year in homes, other public buildings, and outdoors. The
monitoring would answer some of the remaining questions on which
control needs should be emphasized (homes vs. public buildings,
structures located on geological hot spots, low-income housing,
etc. ).
The Work Group believed the additional data should be
collected before communicating final risk estimates because of
the public and economic sensitivity to the radon problem.
Interpretation of the data will help design and implement
institutional strategies needed to address the problem.

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ENVIRONMENTAL TOBACCO SMOKE (ETS)
I. ISSUE DESCRIPTION
The high cancer risks incurred voluntarily by smokers of
tobacco products are well known since the Surgeon General's 1964
report. It is the leading cause of lung cancer. Nonsmokers are
also exposed to lung cancer risk from tobacco smoke, particularly
in indoor environments. Many of our state, local, and federal
environmental health professionals believe this largely
involuntary exposure to environmental tobacco smoke is the
largest environmental contributor to lung cancer — along with
indoor radon.
II. IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
No risk analysis specific to Denver was done for ETS.
Literature surveys of national data and risks were performed.
This work was reviewed and related to the Denver area by
experienced Denver area health professionals and a panel of four
national experts on indoor air pollution assembled to advise the
Indoor Air Work Group.
o Information on Human Exposure
Individual exposure to ETS varies significantly depending on
the presence of tobacco smokers in indoor environments. Most
people appear to spend 75% to 90% of their time breathing indoor
air.
o Impact on Human Health
The 1986 Surgeon General's report on smoking, unlike the
original 1964 report, focused more on the health risks of
exposure to Environmental Tobacco Smoke (ETS). Nationally the
range of individual cancer risk varies from a low of one in
10,000 to a high of three in 100 of acquiring lung cancer from
exposure to ETS. A related National Academy of Science study
found that non-smoking spouses of smokers have a 25% greater
chance of contracting lung cancer than those married to
nonsmokers. Nationally 5,000 lung cancer deaths per year are
attributed to ETS.

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For Denver, no major reasons have been found to suggest that
Environmental Tobacco Smoke is any less of a problem for Denver
area residents than is reflected in the national data.
Current research suggests a link with prior indoor radon
exposure that increases the lung cancer risk for tobacco smokers
and those exposed to ETS that is greater than the sum of the
risks from exposure to each separately.
2. Other Health Issues/Limitations of the ESP Analysis
The analysis does not provide hard data on exposure to ETS
that is specific to the Denver population; instead it relies on
the assumption that the Denver risks are similar to national
risks.
B.	Economic/Welfare Effects
Businesses and service establishments may suffer economic
damage if indoor environments free of ETS are not provided for
employees, customers, and other users; particularly as public
awareness of ETS problems continue to increase.
Some businesses may experience economic losses as ETS free
environments are provided. The losses may occur consistent with
the extent to which the business relies on consumers that are
hardcore smokers with other alternatives.
Some materials such as clothing, furniture fabrics, and
drapes may lose their value or require cleaning to eliminate
soiling and smells from ETS exposure.
C.	Ecological Effects
No deleterious effects are known for the outdoor ecology.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A. Public Perception/Political Pressure
The public appears to be more aware of the lung cancer risk
from voluntary "first hand" smoking than they are of the risks
from involuntary "second hand" exposure to ETS.
Public concern about ETS is growing nationally and in Denver
— customers and employees are demanding smoke free indoor
environments. There are a few organized interest groups lobbying
the state legislature for ETS restrictions. These concerns are
supported locally by health professionals.

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B. Regulatory Status
1.	Legal Requirements
Nationally more than half of the states have passed laws
restricting smoking in public places. The private and the public
sector is also moving their workplace and employment practices in
that direction.
Colorado has not yet adopted an ETS statute but is expected
to continue working on bills that have been introduced in the
past.
A federal ban prohibits smoking on scheduled airline flights
with durations of two hours or less.
So far 28 Colorado communities have passed ordinances
restricting smoking in the workplace or public places. In the
Denver area, 14 communities and 3 counties have ETS restriction
in place. They are: Boulder, Longmont, Denver, Westminster,
Arvada, Aurora, Golden, Englewood, Lakewood, Thornton,
Louisville, Wheatridge, Broomfield, Littleton, Boulder County,
Jefferson County, and Arapahoe County. Most of the ordinances
restrict smoking in the workplace, in portions of larger
restaurants (with seating over 25, 30 or 50 depending on the
community), in stores and public places, and in supermarkets.
2.	Current Activities
Smoking is prohibited in some public buildings and in places
of employment.
3.	Public Expenditures
Very little is spent specific to ETS.
C. Possibilities for Further Control
Opportunities exist to extend smoking control strategies
being started locally and nationally.
An indirect limit on the control of ETS depends in part on
the extent to which indoor smoking of tobacco can be reduced at
the sources. Assistance programs can be made available to
smokers who want to quit smoking. National evidence suggests
that more than half of the current smokers would like to quit.
Nicotine addiction is being recognized as a serious physical
addiction by the Surgeon General and other researchers, so
"kicking the habit" can be very difficult for some smokers.

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IV. WORK GROUP FINDINGS
The Indoor Air Work Group found that the health risk
evidence for tobacco smoking and subsequent Environmental Tobacco
Smoke exposure is sizeable enough to warrant community focus on
control efforts rather than major efforts to research ET.S risks
specific to the Denver area.
The Work Group recommended that the Environmental Strategies
Project research and document the available national and local
risk and solution information into a communication package that
could assist and focus control efforts.

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OTHER INDOOR AIR POLLUTANTS
I. ISSUE DESCRIPTION
A variety of potentially harmful air pollutants are known
to be present inside homes and other buildings. This type of
contamination is now referred to as indoor air pollution, and is
receiving increasing attention from federal and state health
officials.
Other indoor air pollutants is the third category of indoor
air pollutants considered by the Denver Environmental Strategies
Project. It is the composite of all other indoor air pollutants
remaining after (l) Environmental Tobacco Smoke and (2) Radon are
considered separately. These include: asbestos; formaldehyde;
lead; volatile organic compounds (VOC's); pesticides; oxides of
carbon, nitrogen, and sulfur? particulate matter, and biological
contaminants.
Sources of indoor air pollution are numerous and include:
building materials, solvents, outdoor air, and pollutants from
combustion sources like furnaces and stoves.
II. IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
No monitoring or analysis specific to the Denver area was
done. Instead, the ESP took advantage of the expertise on the
Indoor Air Work Group and information available through a search
and analysis of national literature. Additionally, four national
experts on indoor air pollution were invited to advise the Indoor
Air Work Group on what problems and solutions could be expected
in the Denver area based on their experience.
o Information on Human Exposure
Individual exposures vary significantly depending on what
sources of pollutants are present in the indoor environment.
Most people appear to spend 75% to 90% of their time breathing
indoor air.
o Impact on Human Health
Nationally, individual cancer risks from some of these
indoor air pollutants can vary from 1 in a million to as high as

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1 in a thousand. For example the California Indoor Air Quality
Program regards Volatile Organic Compounds together with
Environmental Tobacco Smoke as second only to Radon in health
priority concern. Taken all together, the abundance, diversity
and prevalence of these pollutants suggest a high risk potential
for many structures.
These pollutants are also associated with a number of non-
cancer health problems that include lung disorders, headaches,
neurotoxic effects, and reduced attention span.
2. Other Health Issues/Limitations of the ESP Analysis
The ESP analysis does not provide hard data on the composite
of indoor air pollutants that is specific to the Denver
population. It relies instead on the assumption that the Denver
risks are similar enough to national risks.
B.	Economic/Welfare Effects
Property values can be temporarily reduced for some indoor
air pollutants that require retrofit of permanent building
materials, such as asbestos and lead paint.
Seldom known and not fully understood effects on
productivity, mental and emotional capability, and quality of
life are believed to occur.
C.	Ecological Effects
No deleterious effects are known for the outdoor ecology.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Public understanding and perception of indoor air problems
in the home and other buildings is very limited as is public
pressure to address the indoor air pollution issue. There are no
obvious public or professional champions.
B.	Regulatory Status
1. Legal Requirements
There is currently a limited federal role for pollutants in
regard to indoor air pollution. EPA currently regulates asbestos
and OSHA has regulatory responsibilities for indoor environments
in the workplace. HUD has some authority with building standards
under the Clean Air Act and the Toxic Substance Control Act.

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A more comprehensive Indoor Air Quality Act of 1987 was
introduced in the U.S. Senate by Senator Mitchell last summer.
In 1983 Congress formed an Interagency Committee on Indoor Air
Quality.
2.	Current Activities
Limited technical assistance is provided by area health
professionals to home and building owners on request.
3.	Public Expenditures
Very little is spent specific to indoor air. Mitigation
costs are typically incurred by home and building owners.
C. Possibilities for Further Control
An area-wide strategy focusing on risk and solution
communication, technical assistance, and research appears
plausible.
IV. WORK GROUP FINDINGS
The Indoor Air Work Group believed the risks from individual
and combined indoor air pollutants are high and getting higher,
but are relatively easy to resolve. They stressed the importance
of simultaneously communicating both the problem and the solution
to those who can and should take action. Concern was also
expressed that the other indoor air pollutants appear to be a
newly emerging area of real concern that is not getting much
attention -- as was once the case for ETS and radon.
The work group recommended that the Environmental Strategies
Project research and document the available national and local
risk and solution information into a communication package that
could assist and focus control efforts.

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B. OUTDOOR AIR QUALITY
1.	Carbon Monoxide
2.	Fine Particulate Matter
3.	Ozone
4.	Air Toxics
STAFF CONTACT:	Patrick Cummins 293-1621

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CARBON MONOXIDE
I.	ISSUE DESCRIPTION
The metro Denver area frequently exceeds EPA's 8 hour air
quality standard for carbon monoxide (CO) and registers CO
concentrations that are among the highest in the country. Motor
vehicles are the major source of CO emissions. CO concentrations
are particularly high during the winter in the downtown and other
heavily urbanized portions of the city. The area's altitude,
topography and winter meteorological conditions all contribute to
the severity of Denver's CO problem.
II.	IMPACT ASSESSMENT FACTORS
B. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
The impact of carbon monoxide on public health in Denver
was evaluated based on a review of the literature on CO-induced
health effects. The information from the literature was
considered with respect to the level of exposure likely to be
experienced by people living in Denver.
o Information on Human Exposure
In 1982 EPA sponsored a Personal Exposure Monitoring (PEM)
study in Denver in order to estimate actual levels of exposure to
CO by the general population. This involved actual measurements
of CO exposures to a sample of subjects throughout their everyday
personal activities.
The results of this study and a companion effort in
Washington, D.C. indicate that the effects of personal activities
and actual CO exposures in microenvironments greatly influence
personal exposure. CO exposures in microenvironments associated
with motor vehicles, such as riding in or working with vehicles
or walking along busy streets, are higher than exposures in
microenvironments not associated with motor vehicles.
The Denver study also found that most microenvironment
exposures to CO are influenced to some degree by ambient levels,
but only indirectly. Indoor sources of CO, such as gas stoves,
smokers, and attached garages, can also be significant
determinants of individual CO exposure.

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o Impact on Human Health
The major health impacts expected to result from exposure to
carbon monoxide at levels typically found in metro Denver include
cardiovascular and neurobehavioral effects. Results from the
Denver PEM study indicate that individuals living in the metro
area are exposed to levels of CO that at times may be sufficient
to result in these effects.
Cardiovascular effects primarily affect persons already
suffering from certain types of heart disease and include
aggravation of angina. Reduced vigilance (ability to
concentrate, react, etc. ) is the primary neurobehavioral effect,
and this may be a problem for healthy people as well as for those
with pre-existing medical conditions.
2. Other Public Health Issues/Limitations of the ESP Analysis
Information on the level of exposure to CO that will cause a
specific health problem is highly uncertain. As a result, it is
not possible to accurately predict the likelihood that an
individual will actually experience an adverse health effect
given a certain level of CO exposure. Instead, we simply know
that above a certain CO level, a person may experience an effect.
EPA is undertaking a periodic review of the ambient air
quality standard for CO. As part of this review, the Agency
is reviewing the most recent literature and clinical studies on
the health effects of CO, including the effects at high altitude.
B. Economic/Welfare Effects
Though not a visible deterrent like the "Brown Cloud,"
Denver's CO problem has nonetheless had an adverse effect on the
area's image. Much has been made of Denver's ranking at the top
of "EPA's list" of non-attainment areas for CO. Combined with
the concern over the Brown Cloud, the CO problem in Denver has
been the source of widespread concern on the part of business and
political leaders because of the potential adverse on economic
growth and development. Several surveys of companies around the
country have reported that Denver's air quality would negatively
affect economic development and business location decisions,
although air quality does not appear to be the overriding factor.
Since the Denver area does not yet attain EPA's ambient
standard for CO, the metro area runs the risk of sanctions being
applied by EPA. Highway funding approaching $30 million could be
at stake, while a ban could be placed on new stationary sources
emitting carbon monoxide.

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C. Ecological Effects
No direct effects on ecosystems have been attributed to CO.
However, sources that contribute carbon monoxide to the
atmosphere (primarily motor vehicles) are also suspected
contributors to more far-reaching global pollution problems that
affect the earth's ecosystem.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception and Political Pressure
The CO problem in Denver has received much public and
political attention and focus in recent years. The Better Air
Campaign has heightened the public's awareness of the issue. In
recent polls, over 80% of the public lists air pollution as a
major problem confronting the metro area. In the political
arena, Governor Romer has taken tough stances on strategies to
combat the CO problem. Senators Armstrong and Wirth have been
strong proponents of Congressional action to address CO problems
in high-altitude cities like Denver. Mayor Pena has emerged as a
spokesman for cities in the West with air pollution problems.
Despite the attention and efforts underway, voluntary
efforts by citizens to reduce individual contributions of CO have
not yet been totally successful. While many citizens comply with
voluntary efforts, widespread awareness of the problem has not
translated into sufficient individual action. Voluntary driving
restrictions during the 1987-88 Better Air Campaign reduced
vehicle miles travelled in the metro-area less than ten percent.
Some of the inaction may be explained by a perception
problem with CO. Since CO is colorless and odorless, it is
difficult for the public to visually comprehend the extent of the
CO problem. In fact, the public often confuses or includes CO
with the visible Brown Cloud.
B.	Regulatory Status
1. Legal Requirements
Under authority of the Clean Air Act, EPA has established a
health-based ambient standard for CO that has to be met in all
areas of the country. In 1987, Denver exceeded the standard on
greater than 20 days, with the highest ambient level around twice
the standard.
Last year the Colorado Department of Health (CDH) and the
Metropolitan Air Quality Council (MAQC) developed a draft
implementation plan to meet the federal standard, although the
plan failed to demonstrate attainment by the statutory deadline

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of December 31, 1987. In the face of widespread non-attainment
of the CO and ozone standards throughout the country and, lacking
reauthorization of the Clean Air Act, a proposed EPA policy would
require local areas not meeting the standard to achieve a 3%
annual reduction in CO levels until the standard is achieved.
Congress is currently considering reauthorization and
amendments of the Clean Air Act. The deadline for attaining
standards was extended until August 31, 1988 in order to preclude
imposition of sanctions against local areas until Congress can
act. Many provisions are being considered that will have direct
effects on CO control strategies in Denver.
The State of Colorado has adopted many regulatory programs
to address the CO problem, most notably the inspection/
maintenance program, the Better Air Campaign, woodburning bans on
high pollution days, and the oxygenated fuels program. In the
current session of the Legislature, several bills were considered
that potentially could impact additional CO control strategies.
None of these bills passed, although a scaled-down version of one
bill remains under consideration.
2. Current Activities
Controlling CO emissions has been the focus of air pollution
activities in the Denver area during the decade of the 1980's.
The primary strategies include:
o Federal Motor Vehicle Control Program, which automobile
tailpipe standards and results in reduced emissions as older
cars are retired.
o Better Air Campaign that targets voluntary no-drive days
during the high-pollution season to reduce vehicle miles
travelled.
o Woodburning bans in some local cities.
o Strengthened automobile inspection/maintenance program.
o Oxygenated fuels program during the high-pollution season,
implemented January 1, 1988.
Projections indicate the Denver area will attain the CO
standard sometime in the late 1990's with current control
strategies. However, the gains will soon be eroded by projected
increases in vehicle miles traveled unless further programs are
put into place to reduce driving.

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3. Public Expenditures
The CDH Air Pollution Control Division, the prime
implementor of CO control strategies, has an overall FY-88 budget
of nearly $6.0 million, of which over $1.4 million comes, from an
EPA grant. Nearly half of the APCD budget ($2.8 million) is
devoted to developing and implementing CO control strategies
along the Front Range. EPA supplies over $400,000 to this
effort.
The annual budget for the MAQC approaches $250,000 annually,
of which nearly half goes towards CO control strategies.
C. Possibilities for Further Control
Improvements can obviously be made in all of the current
control strategies. Congress is considering tightening emission
standards for automobiles. High altitude and cold start
requirements would also help. Many believe a centralized I/M
program could result in additional in-use emission reductions.
Greater use of ethanol as an oxygenated fuel could further reduce
emissions. More extensive wood-burning restrictions are also
under consideration.
While air quality benefits from these more stringent
strategies could be significant, greater emission reductions can
be generated from programs which further reduce driving and
vehicle miles travelled. Transit improvements, mass transit, HOV
lanes and more aggressive carpool programs are transportation
strategies that are being considered, as well as further
incentives to convince citizens to simply reduce their driving.
IV. WORK GROUP FINDINGS
The ESP Outdoor Air Work Group recognized carbon monoxide as
a serious air quality problem facing the metro area. The Work
Group did not dwell on health or economic effects from CO, nor on
technical data gaps. Instead, the Work Group focused on
implementation issues that are impeding attainment of the federal
standard. While no attempt was made at the time to come to
consensus on these issues and make specific recommendations,
members generally supported the observations presented below.
The Work Group felt strongly that the metro area can no
longer rely solely on voluntary efforts the citizenry to improve
air quality. Economic and regulatory incentives and
disincentives have to be applied, leading to behavioral and
lifestyle changes that discourage driving and other individual
activities that pollute. However, in order to modify behavior,
the public has to have alternatives available. In this regard,

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the Work Group advocated improving and expanding the mass
transportation system throughout the metro area. In addition,
greater public education efforts are needed in order to convince
the public that changes in lifestyle are needed to achieve
cleaner air.
While advocating reduced driving as a strategy that needs
more emphasis, a majority of the Work Group also favored more
stringent emission requirements for automobiles (such as high
altitude testing and cold weather certification) and supported
lobbying efforts on this issue at the national level.
Finally, the Work Group recognized the significant role
local governments must play in implementing air pollution control
strategies. Local governments need technical and implementation
assistance so that they can effectively integrate air quality
considerations into their local land use and transportation
planning decisions.

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FINE PARTICULATE MATTER
I.	ISSUE DESCRIPTION
The term particulate matter refers to condensed liquids and
solid particles suspended in our ambient air. The sources of
particulate matter are numerous and include emissions from gas
and diesel motor vehicles, power plants, industrial sources and
wood stoves, as well as sand and dirt from roadways.
Several measurements of particulate matter are used
depending on the size of the particles being measured. EPA's new
ambient standard addresses PM-10, which is a measure of fine
particulate matter less than 10 microns in size. This health-
protective standard is based on evidence that it is these smaller
particles which are primarily responsible for causing respiratory
problems and exacerbating lung disease. The major portion of
Denver's "Brown Cloud" results from fine particulate matter below
2.5 microns in size suspended in the air.
In addition to its suspected effects on human health, fine
particulate matter has an adverse aesthetic impact, increases
maintenance costs for buildings and equipment through soiling and
materials damage, and may even be affecting economic growth in
the metro area by discouraging business expansion and relocation.
II.	IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
The best available scientific information from health
effects studies conducted in other parts of the U.S. and Europe
was used to estimate health effects caused by fine particulate
matter in metro Denver. These studies give estimates of the
number of cases of a given health effect as a function of
pollution levels. Particulate levels in metro Denver during
1984, 1985, and 1986 were averaged to establish a baseline
scenario from which reductions were assumed. Estimates of the
annual number of cases prevented if the metro area were to meet
the federal standard were then made.
o Information on Human Exposure
It is virtually impossible for an individual living in
metro-Denver to avoid exposure to some level of ambient fine
particulate matter on a daily basis. To estimate exposures to
the population of the entire study area, data from the ten
monitors operated in recent years were used to calculate a

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pollution level for each census tract based on levels at the
monitors nearest to each tract.
o Impact on Human Health
Studies have not yet demonstrated a direct link between high
levels of fine particulates and premature mortality or other
health effects. The studies do however show a statistically
significant relationship between the two. Chronic obstructive
pulmonary disease (COPD) is probably the most significant health
effect associated with high ambient concentrations of fine
particulates. Aggravation or worsening of this condition can
lead to premature mortality, increased emergency room visits, and
individual restricted activity days.
The analysis conducted for the ESP estimates that if the new
standard for fine particulates was met, approximately 20
premature mortalities, 1,200 emergency room visits, and 180,000
individual restricted activity days might be avoided each year in
the metro Denver area. These numbers can be thought of as the
"best estimate" provided by the analysis. It is important to
note that under a range of plausible assumptions the annual
estimates of these health effects vary from between 0 and 114
premature mortalities, 100 and 8,300 emergency room visits, and
between 255,000 and 1.5 million restricted activity days.
2. Other Health Issues/Limitations of the ESP Analysis
Applying the results of studies conducted in other places
to a local situation like Denver requires use of the best
estimate of the relationship between fine particulate matter and
health effects found in these studies. Correlating these studies
to Denver is complicated by such things as the variability in the
chemical composition of fine particulate matter from place to
place and the intensity of pollution insult. These factors,
which could not be corrected for in our study, could change the
expected effect of the pollution on human health in Denver.
Fine particulate matter is also a source of air toxics which
are suspected carcinogens and can cause other serious health
effects. Heavy metals and organics that attach to fine
particulate matter are pollutants of concern that are undergoing
much evaluation in the health community.
B. Economic/Welfare Effects
Much concern has been raised over the potential adverse
economic impact resulting from Denver's Brown Cloud. The most
direct impact on growth would come from a potential ban
construction of new sources of air pollution and withholding of
highway construction funds if Denver fails to meet EPA's air
pollution standards. A more widespread concern, though, is the

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postulated impact on economic growth because new businesses do
not wish to locate in an area with such a visible air quality
problem. The adverse publicity resulting from the Brown Cloud
also damages the Denver area's national reputation. Several
surveys of companies around the country have reported that
Denver's air quality would negatively affect economic development
and business location decisions, though air quality does not
appear to be the overriding factor.
Fine particulate matter can also result in materials and
soiling damage to residential, industrial, and commercial
property. An analysis for the ESP indicated soiling damage in the
Denver area could result in a $100 million loss annually. In
addition, fine particulate matter results in visibility
degradation. Studies conducted in several U.S. cities indicate
that households value the prevention of visibility degradation
due to its aesthetic effects alone.
C. Ecological Effects
Many of the sources that contribute particulate matter to
the atmosphere are possible contributors to more far-reaching
global pollution problems that affect the earth's ecosystem.
Man-made pollutants are suspected of affecting the earth's
atmosphere, resulting in global warming.
Concern has also been raised by some scientists regarding
the impact of Denver's air pollution on sensitive mountain lakes
on the eastern side of the Continental Divide.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A. Public Perception/Political Pressure
Because of the obvious nature of the problem (the visible
Brown Cloud) and the perceived health effects on high pollution
days, the public seems very aware of the issue. In recent polls,
over 80% of the public listed air pollution as a major problem
confronting the metro area. Government officials feel pressure
from the citizenry to improve air quality. Governor Romer has
recently been in the forefront of state action on the issue.
While public attention has been focused recently on CO
control strategies, the citizenry has not yet been asked to do
much regarding Brown Cloud strategies, other than wood burning.
Much more individual action will be needed in the future to
combat the problem.

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B. Regulatory Status
1.	Legal Requirements
EPA recently replaced the TSP (Total Suspended Particulates)
ambient standard with a standard addressing fine particulate
matter less than 10 microns in size (PM-10) in order to more
accurately address suspected health concerns. The Metropolitan
Air Quality Council (MAQC) and the Air Quality Control Commission
(AQCC) must develop a State Implementation Plan (SIP) by April
1989 that will outline control strategies to meet the PM-10
standard. The State will be responsible for enforcing the
regulations, which are likely to include local ordinances like
wood-burning bans.
2.	Current Activities
Most of the air pollution activity in recent years in the
metro area has addressed carbon monoxide. In comparison, fine
particulate matter control efforts have not been as aggressive
and extensive. However, this is quickly changing as renewed
emphasis is being placed upon PM control strategies as a result
of concern over the Brown Cloud and the upcoming PM-10
requirements. While some strategies have been implemented (such
as episodic wood-burning bans) extensive further action will be
required to fully address fine particulate problems.
Development of control strategies for fine particulates
(both PM-10 and Brown Cloud) awaits the results of research
efforts being conducted by CDH, EPA and private sources. Of
particular interest is a million dollar research study, funded
primarily by private sources and coordinated by the Greater
Denver Chamber of Commerce, that is looking at the contributions
of sources to the Brown Cloud.
The Governor also appointed a blue-ribbon Diesel Task Force
to make recommendations to address diesel vehicles, a major
source of fine particulate matter in the metro area. The panel's
highest priority recommendations were: diesel I/M, roadside
opacity enforcement, idling ordinances, and heavy duty mass
emissions laboratory.
Several air pollution bills were introduced during the
current session of the Legislature. A bill requiring a diesel
I/M program and diesel fuel standards recently passed.
3.	Public Expenditures
The Colorado Department of Health has budgeted over $800,000
for PM-10 control activities statewide in FY-88, of which nearly
$60,000 came from a grant from EPA. While the bulk of this money
goes to Front Range areas, rural areas in the state also have a

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PM-10 problem and are receiving state attention. The annual
budget for the MAQC approaches $250,000, of which greater than
50% goes for PM control activities.
C. Possibilities for Further Control
Concerted efforts to control sources of fine particulate
matter are just beginning and are going to require tough choices
throughout the metro area. Control strategies under
consideration include:
—	controls on diesel vehicles, including inspection/
maintenance, fuel standards, and alternative fuels;
—	further wood-burning bans and restrictions;
controls on power plants and other industrial sources,
including possible conversion from coal to natural gas;
-- better methods of street sanding and street cleaning to
reduce reentrained dust;
-- transportation improvements, including mass transit, to
reduce driving.
Most of these strategies are technically feasible, but the
economic and political feasibility have yet to be fully assessed.
IV. WORK GROUP FINDINGS
The ESP Outdoor Air Work Group considered many aspects of
the particulate matter issue in the Denver area. The Work Group
discussed the PM benefits analysis conducted for the ESP, as well
as other health and economic impact concerns associated with the
problem. Members suggested specific changes to the ESP analysis,
which were incorporated by staff in the final draft report.
The Work Group recognized the limitations of the ESP
analysis and concluded that while more specific information on
health and economic effects would be helpful, such information
would be difficult and expensive to obtain. The existence of a
health standard that will not be met in Denver and the concern of
the business community are sufficient evidence to indicate that
the problem should be addressed. The Work Group felt the focus
of future activities should be solving the problem in the most
cost/effective manner.
Many of the overall findings of the Work Group presented in
the paper on carbon monoxide ultimately apply to fine particulate
matter as well. Less reliance on solely voluntary efforts,
reduced driving and individual polluting activities, and public

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education are all necessary concerns for addressing cleanup of
the Brown Cloud.
The Work Group discussed at length the considerable lack of
technical understanding related to control strategies for the
Brown Cloud. Many gaps currently exist in our knowledge'and
effective control strategies can not be developed without
additional basic data.
Information on high altitude emission factors are still
lacking, which will hinder assessments of the effectiveness of
control strategies. Much uncertainty surrounds the contribution
of street sanding and cleaning activities to the Brown Cloud and
the effectiveness of various control options.
Many of the questions on source contribution are expected to
be answered by the Denver Brown Cloud Study and other efforts
underway by CDH and EPA.

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OZONE
I. ISSUE DESCRIPTION
Ozone is a pollutant that forms in the atmosphere in the
presence of hydrocarbons, nitrogen oxides, and sunlight.. Sources
of these ozone precursors include automobiles, power plants, and
other sources of fossil fuel combustion. Ozone can impair lung
functions in people with existing respiratory problems. People
in good health may even be affected, experiencing effects such as
chest pain and shortness of breath.
The Denver area will probably meet the federal ambient
standard of .12 ppm for ozone some time this year. However,
continued maintenance of the standard has not yet been
demonstrated.
II. IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
For this analysis, 1986 ozone levels in the Denver metro
area were used as the baseline from which benefits of reducing
ozone concentrations were calculated. Health effects estimates
are based on evidence from published epidemiological studies
concerning human populations exposed to ozone. Information from
these studies gives the number of cases of a given health effect
as a function of the pollution level.
o Information on Human Exposure
Ozone exposures in the metro Denver area were estimated
using data from the six ozone monitors operating in 1986. A
pollution level for each census tract was calculated based on
levels at the monitors nearest to each tract. This approach is
the same as that which was used in the analysis of fine
particulate matter.
o Impact on Human Health
Clinical studies in which subjects have been exposed to a
known amount of ozone in a controlled setting have demonstrated
that ozone is irritating to the nose and throat and causes
temporary reductions in lung function. These effects have been
found in adults with chronic respiratory conditions and in
healthy children and adults. Quantitative relationships are
difficult to identify from these types of studies, but the

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findings support the epidemiological studies that have found a
relationship between ambient ozone levels and occurrences of
respiratory restricted activity days or asthma attacks.
The analysis conducted for the ESP estimates that if the
ozone standard had been met in 1 986, approximately 150 a.sthma
attacks, 6,900 restricted activity days, and 15,400 cases of eye
irritation might have been avoided.
These numbers should be thought of as the "best estimate"
provided by the analysis. It is important to note that under a
range of plausible assumptions the estimates could range from
between 35 and 445 asthma attacks and between 5,900 and 7,900
restricted activity days if the standard were met.
2. Other Health Issues/Limitations of the ESP Analysis
The estimates of human health effects presented above are
based on available information concerning the effects of ozone on
public health. A great deal of uncertainty remains about much of
the research on which these estimates are based. To address this
uncertainty, upper and lower range estimates are presented when
there is sufficient information in the literature to suggest a
likely range. These are not intended as absolute bounds, but as
ranges within which the actual damages are likely to fall.
There is some evidence that increased incidence of chronic
respiratory illnesses may be associated with exposure to elevated
levels of ozone, but there is considerable doubt about whether
such an association has been adequately demonstrated. There is
insufficient quantitative evidence available to estimate the
potential magnitude of such effects.
B. Economic/Welfare Effects
Because of its chemically reactive nature, ozone may
accelerate the aging of many materials, such as nylon, other
synthetics, dyes, paints, and rubber products. A number of
commercially important rubber-based products, including
automobile tires, rubber seals, and pharmaceutical goods, are
particularly sensitive to ozone damage.
Reduction in social welfare due to ozone pollution induced
materials damage can be expressed in terms of increased costs to
producers and consumers. These costs may be a result of
accelerated replacement, and maintenance and repair costs, or of
increased avoidance costs when industries use additives to avoid
or minimize damage.
While not necessarily applicable to the Denver urban
area, there is also evidence to indicate ozone can detrimentally
affect the yield from agricultural cash crops.

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C. Ecological Effects
Ozone can affect many forms of vegetation. In addition to
the effects on cash crops, recent findings have led many
scientists to believe that ozone is a major contributor to the
decline in growth of many species of trees. Limited data
suggests ozone pollution may have played a role in the loss of at
least some forests in several areas of the continent.
Many of the sources that contribute ozone precursors to the
atmosphere are suspected contributors to more far-reaching global
pollution problems that affect the earth's ecosystem. Man-made
pollutants are suspected of affecting the earth's atmosphere,
resulting in global warming.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Since ozone pollution is not as significant a problem in
Denver as carbon monoxide and fine particulates, the issue has
not received widespread attention on the part of the public.
In many instances confusion exists in the minds of the
public between stratospheric ozone and ozone pollution.
Stratospheric ozone is the desirable layer that protects us from
harmful solar rays and is suspected of being depleted by man-made
chemicals.
B.	Regulatory Status
1.	Legal Requirements
The legal requirements for ozone under the Clean Air Act are
similar to those for CO and fine particulates. EPA has
established a health-based standard and the State has developed
an implementation plan to meet the standard.
Based on recent data, the Denver area is very close to
meeting the federal standard of .12 ppm. While the standard may
be met this year, EPA will not consider the area attainment for
ozone until the State can demonstrate maintenance of the standard
for several years in the future.
2.	Current Activities
Controlling sources that contribute to ozone formation
focuses on controlling hydrocarbon emissions from automobiles and
stationary sources. Colorado's inspection/maintenance program
reduces hydrocarbon as well as CO emissions from gasoline-powered
vehicles.

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The State is required to regulate other sources of volatile
organic compounds (VOCs) such as gas terminals, dry cleaners, and
users of paints and solvents.
3. Public Expenditures
The CDH Air Pollution Control Division budgeted nearly
$725,000 for ozone attainment efforts in FY-88, primarily in the
Denver area. EPA provided over $115,000 of this amount in a
grant to the State.
C. Possibilities for Further Control
As indicated, the State will have to demonstrate maintenance
of the standard in the future. Continued reductions resulting
from cleaner cars taking the place of older cars will be offset
in part by increases in vehicle miles travelled throughout the
metro area. Unlike CO and fine particulate matter, some of the
highest levels of ozone in the metro area occur in the distant
suburbs of Denver (such as the Highlands Ranch area).
Greater compliance with VOC regulations will also be
required from stationary sources in order to maintain the
standard.
EPA is also considering lowering the national ambient
standard for ozone based on new evidence of health, welfare and
ecological effects. If this occurs, further control efforts may
be required in the future.
IV. WORK GROUP FINDINGS
The ESP Outdoor Air Work Group did not address ozone
pollution since the group did not consider it to be as
significant a problem as carbon monoxide and fine particulates.

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AIR TOXICS
I. ISSUE DESCRIPTION
A number of air pollutants, which are commonly referred to
as air toxics, have been identified as having the potential to
cause cancer and other health problems when inhaled by humans.
An analysis completed by EPA in May 1985 indicates that most of
the cancer risks from air toxics are caused by metals, volatile
organic compounds, and products of incomplete combustion (PIC).
In the EPA analysis, approximately fifteen pollutants or
pollutant groups were identified as being responsible for most of
the cancer risk from air toxics. These are chromium, cadmium,
arsenic, benzene, carbon tetrachloride, chloroform, ethylene
dibromide, ethylene oxide, formaldehyde, perchloroethylene,
trichloroethylene, PIC, asbestos, radionuclides, and gasoline
vapors.
Not surprisingly, an examination of emissions associated
with these pollutants shows a diverse and complex group of
sources including motor vehicles, power plants, industrial
processes, wood burning, chemical and petroleum refining, solvent
usage, dry cleaning facilities, and marketing of gasoline. The
variety of pollutants and sources increases the difficulty of
regulating this potential problem.
II. IMPACT ASSESSMENT FACTORS
B. Public Health Issues
1.	Environmental Strategies Project Analysis
A major component of the ESP is a program to collect ambient
air toxics data in the Denver metro-area and to assess the risks
to the population from these pollutants. The monitoring program,
which used state-of-the-art sampling and analysis techniques,
collected data for the past year, concluding at the end of
February. Analysis of this data is underway, though the risk
assessment will not be completed until September 1988.
2.	Other Public Health Issues
The May 1985 EPA study of the air toxics problem nationwide
examined 45 air toxic compounds and concluded that exposure to
these compounds may cause 1300 to 1700 cases of cancer each year.
Large point sources were found to be responsible for the highest
individual lifetime risks and up to 25% of the cancer incidence
attributable to air toxics.
Individual risks associated with specific area sources were

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generally found to be low in the EPA study. However, because
these sources often are located in populated urban areas, they
account for about 75% of the cancer incidence from air toxics.
In addition, measurements of ambient concentrations of 10 to 15
air toxics in five large urban areas indicated that the air
toxics "soup" in these cities may be responsible for additive
individual lifetime risks of 1 in 1000 to 1 in 10,000.
Because of the high levels of carbon monoxide and
particulate matter in the Denver area, it is suspected that
Denver may also have an air toxics problem since air toxics come
from many of the same sources. In addition, many compounds in
particulate matter are considered toxic air pollutants.
B.	Economic/Welfare Effects
Since air toxics pollution is still only an emerging issue
in the Denver area, there has not been any discernible discussion
of potential adverse economic and welfare effects locally. If
air toxics are a significant problem in the Denver area, this
will only add to the current image problem resulting from air
pollution.
A potential welfare effect is decreased property values
around point sources of air toxics. People generally do not want
to live in areas surrounded by air toxics sources. This is
probably not a widespread problem in the Denver area, but rather
more of a localized problem around the few significant point
sources in the area (such as around the Globeville smelter and
sources in the Commerce City area).
C.	Ecological Effects
Substantial uncertainty exists pertaining to the potential
ecological effects of air toxics. Little data have been
collected nationally, although EPA reports there is growing
evidence of adverse regional impacts, such as in the Great Lakes
region. No data have been collected in the Denver area.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A. Public Perception/Political Pressure
Public awareness of air toxics issues in the metro area is
growing, but still remains relatively low. Air toxics problems
are generally associated with heavily industrialized areas with
refineries, smelters and other point sources. Since Denver is
not a heavily industrialized area, Denver's potential problem
with areawide sources may not be widely recognized.

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B. Regulatory Status
1.	Legal Requirements
Under the Clean Air Act, EPA is required to establish
standards for hazardous air pollutants (NESHAP). To date, eight
pollutants have been listed under NESHAP: asbestos, beryllium,
vinyl chloride, coke oven emissions, benzene, arsenic,
radionuclides, and mercury. The Agency is currently evaluating a
host of other chemicals for possible listing.
In June 1985 EPA issued its air toxics strategy to address
the control of both routine and accidental releases of toxic air
pollutants. In addition to using EPA's authority under the Clean
Air Act to regulate chemicals and sources of national concern,
the strategy also relies upon state and local control programs to
control high risk sources of local concern that are not
appropriate for federal regulation.
CDH is implementing the various components in its Air Toxics
Multi-Year Development Plan to address the air toxics problem
statewide. The plan outlines a program to enforce EPA's NESHAPs,
control high risk point sources, assess high risk urban areas,
and build the technical, regulatory, and administrative
capabilities needed to implement an effective program.
2.	Current Activities
CDH is still in the early stages of developing its air
toxics program. Much of the effort is devoted to the collection
of data in order to determine the extent of the areawide problem.
Until these data are collected, control strategies aimed
specifically at air toxics cannot be developed. The State is
also building its basic program and targeting high risk point
sources, such as the Globeville smelter.
EPA and CDH have embarked upon a comprehensive effort to
gain more data on air toxics through the Denver Air Toxics Study.
This study will characterize the extent of the air toxics problem
in the metro area and provide information for the development of
control strategies. Important parts of the study are:
o Ambient air toxics monitoring, sponsored by the ESP, to
provide data on ambient concentrations at four sites in
the metro area;
o Development of high-altitude emission factors for air
toxics from woodburning sources and gasoline and diesel
vehicles;
o Inventory of air toxics and volatile organic emissions
from stationary sources in the metro area;

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o Survey of woodburning practices in the metro area to
aid in modeling air toxics and PM-10 concentrations;
o Modeling of concentrations and source contributions of
air toxics throughout the metro area based on data
collected in earlier steps;
o Assessment of health risks from air toxics in the metro
area based on the modeling and monitoring efforts.
3. Public Expenditures
In FY-88, CDH budgeted nearly $300,000 to continue
developing its air toxics program. Over half of this amount
comes from an EPA grant. In addition, EPA, through the
Environmental Strategies Project and other special initiatives,
has contributed over $600,000 directly to the Denver Air Toxics
Study over the past two years.
C- Possibilities for Further Control
Many sources of air toxics are currently being regulated by
existing programs addressing other pollutants: CO, PM, and VOCs.
Further control efforts may be needed if specific air toxics
concerns are not being adequately addressed by current programs.
However, this will not be known until the extent of the air
toxics issue is further defined.
IV. WORK GROUP FINDINGS
The ESP Outdoor Air Work Group did not specifically address
air toxics issues. After a briefing on the Denver Air Toxics
Study, the Work Group delayed further discussion pending results
from the ongoing data collection and analysis efforts.

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C. WATER QUALITY
1.	Drinking Water Quality
2.	Groundwater Quality
3.	Surface Water Quality
STAFF CONTACT:
Patrick Cummins 293-162 1

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DRINKING WATER QUALITY
I. ISSUE DESCRIPTION
Consumption of contaminated drinking water poses a threat to
human health. While public water supplies are required to comply
with federal and state regulations designed to be protective of
human health, monitoring is not required for all possible
contaminants. Contaminants may also reach people's taps when
treatment processes malfunction.
Public water supplies in metro Denver are believed to
provide a very high quality product, although there have been
some widely publicized cases of contamination.
II- IMPACT ASSESSMENT FACTORS
A. PUBLIC HEALTH ISSUES
1. Environmental Strategies Project Analysis
o Analytical Approach
The drinking water risk assessment conducted by the ESP used
recent data from four local public water supplies (Denver,
Thornton, Arvada, and South Adams County) to estimate risk to
human health.
EPA-approved information on carcinogenic potency was used to
calculate the risk of contracting cancer from exposure to
contaminants detected in the four systems.
Levels of non-carcinogenic contaminants were compared to
EPA-approved "acceptable levels" to examine their potential for
posing a threat to human health.
In addition to using the information supplied by these four
systems, additional monitoring data were collected from two
studies previously conducted on Denver area water supplies in
order to estimate the upper bound risks from drinking water. A
worst case water sample was constructed by assuming that
contaminants were present at the highest measured levels reported
in the data from the four systems or in the other studies.
o Information on Human Exposure
Approximately 75% of the metro Denver study area is served
by the systems examined in the ESP analysis. Risks for the
remaining 25% of the population were estimated based on the
information from the four systems studied.

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Human intake was calculated using the standard EPA
assumption that the average adult drinks 2 liters of water per
day for seventy years, and weighs 70 kilograms.
o Impact on Human Health
The ESP risk assessment calculated both cancer and non-
cancer risk for the population of metro Denver. Carcinogenic
risk was calculated for only those contaminants which have an EPA
established carcinogenic potency factor.
The lower bound on carcinogenic risk was estimated using
only those contaminants that were reported in the data supplied
by the four systems. Arsenic was excluded from the lower bound
estimate because of uncertainty regarding its potency.
The lower bound estimate of carcinogenic risk suggests that
less than one excess cancer cases can be expected in the metro
area every five years from exposure to carcinogens in drinking
water.
The upper bound estimate of carcinogenic risk suggests that
approximately 10 excess cancer cases can be expected in the metro
area every year.
No non-cancer health effects are expected to occur from
exposure to contaminants in drinking water at the levels found in
this analysis. The issue of lead in tap water is discussed
separately.
2. Other Health Issues/Limitations of the ESP Analysis
Limitations of the ESP analysis exist at two levels. First,
it is important to note that not all public water supplies in the
study area were examined in this analysis.
Also, data provided by the systems studied do not include
information on all possible contaminants.
In some cases, there was data available on contaminant
concentrations, but no EPA-approved information on human health
ef fects.
Finally, there was no analysis of private wells or very
small supply systems. Because many of these supplies rely on
untreated ground water, there is the possibility that
contamination problems unlike those in the larger systems may
exist.
B. Economic/Welfare Effects
In South Adams County, a $17 million water treatment

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facility was recently built to correct a ground water
contamination problem. This case points out the potential for
large economic and welfare costs for correcting contaminated
drinking water supplies.
More stringent monitoring and treatment requirements under
the 1986 Amendments to the Safe Drinking Water Act may mean that
public water supplies will be spending more money in the near
future to upgrade water treatment facilities. These increased
costs will be passed on to customers.
Other economic effects include costs to individual
homeowners who pay for replacement of home plumbing that is
affected by corrosive water supplies.
C. Ecological Effects
Ecosystems may be impacted by purification plant discharges
to streams or from land application of sludges.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Publicity surrounding drinking water contamination problems
in the metro area has raised the public's awareness of the
potential for problems with drinking water supplies.
Most of the political pressure that has been brought to bear
on this issue is the result of efforts on the part of the limited
number of people directly affected by particular problems with
drinking water supplies.
B.	Regulatory Status
1. Legal Requirements
Public drinking water supplies are defined as those systems
which serve 25 or more people for at least 60 days per year.
Every public water supply in the country must comply with EPA1s
Primary Drinking Water Regulations which currently set standards
for 33 contaminants.
The 1986 Amendments to the Safe Drinking Water Act (SDWA)
require EPA to set standards for 50 more contaminants by June
1989, for another 25 by January 1991, and for 25 more every three
years thereafter.
EPA has delegated Primary Enforcement authority to the State
of Colorado for regulations under the SDWA. EPA gives the state
an annual grant to carry out this responsibility.

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2. Current Activities
The 1986 Amendments to the SDWA contain requirements for
more extensive treatment and monitoring of public water supplies.
A Safe Drinking Water Bill was introduced in the Colorado
Legislature this year. The bill would allow the State to set
standards for contaminants which the federal government does not
regulate, and would allow the State to take legal action against
polluters.
EPA Region VIII has identified four priority contaminants
for further attention in the near future. These four are the
contaminants produced as by-products of the disinfection process
(trihalomethanes), microbiological contamination in small
systems, radionuclides, and lead that results from in-home
plumbing fixtures.
3. Public Expenditures
EPA's grant to the State in FY88 to carry out their
responsibilities as primary enforcers of the SDWA was
approximately $425,000. EPA Region VIII has a state project
officer who maintains oversight of the designated program.
The State of Colorado has 6 FTEs in the Drinking Water
Program at the CDH. This staff is supported by field engineers,
laboratory technicians, and an epidemiologist.
County health departments also conduct inspections of public
water supplies within their jurisdictions.
C. Possibilities for Further Control
All public water supply systems will be required to monitor
for a greater number of contaminants as new standards are set.
These increased monitoring efforts will decrease the possibility
of harmful contaminants going undetected.
Based on monitoring results, additional treatment processes
may have to be employed to meet the new standards.
IV. WORK GROUP FINDINGS
The ESP Drinking Water Work Group concluded that:
o Data from the four systems analyzed suggests that municipal
drinking water supplies in metro Denver provide a very high
quality product which poses low risk to human health;

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o The 1986 Amendments to the Safe Drinking Water Act are
intended to effectively address most of the outstanding
concerns about municipal drinking water supplies;
o Drinking water being consumed from private wells or small
systems is of concern because it is unregulated, untreated,
and because little is known about the actual use of these
sources in the metro area;
o In order to fully assess the risks from drinking water in
the metro area, additional data on the presence of
contaminants and their effects on human health are needed.

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GROUND WATER QUALITY
I. ISSUE DESCRIPTION
Contamination of ground water by industrial, agricultural,
and urban sources diminishes the value of the resource for future
use and may threaten human health if the water is used for
drinking, cooking, or bathing.
While use of ground water in metro Denver is limited
relative to the use of surface water, ground water is utilized by
individual homeowners, small water districts, and as a
supplemental source by large municipal systems in the area.
In general, wells that draw from shallow alluvial aquifers
are at greater risk than those that draw from deep, confined
aquifers because the shallow aquifers are more easily
contaminated. Deep, confined aquifers may also be at risk from
poorly constructed or abandoned wells which can provide direct
conduits for contaminants.
II. IMPACT ASSESSMENT FACTORS
A.	Public Health Issues
The Environmental Strategies Project did not conduct
specific analysis of the human health risks or economic impacts
from ground water contamination.
A limited number of ground water wells were examined as part
of the analysis of public drinking water supplies. The ESP
analysis of hazardous waste issues examined some of the potential
threat to human health from hazardous waste contaminating ground
water. However, the drinking water analysis did not examine
threats to ground water from sources such as agricultural
contamination from application of fertilizers or pesticides,
petroleum spills or leaks from underground storage tanks, or
nitrate contamination by septic systems.
B.	Economic/Welfare Effects
When ground water is being used as a drinking water source,
expensive treatment techniques may have to be employed to purify
the water. In South Adams County, a $17 million dollar water
treatment facility was built to correct a ground water
contamination problem.
Ground water contamination at local Superfund sites will
cost the government and private parties millions of dollars to
remediate.

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Ground water can also be valued as a future resource. Clean
ground water will be an important source of drinking water in the
event of a prolonged drought which diminishes surface water
supplies, or if growth in the area increases water demand beyond
current capacity.
C. Ecological Effects
Most sources of ground water contamination also contaminate
soils. This may lead to contaminants entering the food chain and
disruption of fragile ecosystems.
Contaminated ground water that discharge to surfaces water
bodies has the potential to adversely impact plant and animal
life dependent on the water.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Publicity surrounding contamination of ground water serving
as drinking water sources in the metro area, and publicity
surrounding problems at area Superfund sites, has heightened
public awareness of this issue.
Concern over ground water contamination by both industrial
and agricultural sources has prompted several states and the U.S.
Congress to begin examining ground water protection legislation.
B.	Regulatory Status
1. Legal Requirements
Regulations promulgated under authority of the various
federal hazardous waste laws, primarily the Resource Conservation
and Recovery Act (RCRA) and Superfund, have instituted stringent
standards for the protection and cleanup of ground water at
hazardous waste treatment, storage and disposal sites.
The Underground Injection Control Program that is part of
the Safe Drinking Water Act (SDWA) requires a permit for
injection of material through a well. This is designed as a
measure to control ground water contamination.
Ground Water used for drinking water by a public water
supply must comply with regulations under the SDWA.
The SDWA Amendments of 1986 also established a Wellhead
Protection Program whereby states are required to develop
protection programs by 1989. Colorado is not currently

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implementing this program due to a lack of funding.
In May 1984, the Colorado Water Quality Control Commission
adopted a Ground Water Protection Program which sets standards
for ground water quality in five different use categories. To
date, no ground waters in the State have been classified under
this program.
It is the responsibility of the State Engineer's Office to
issue permits for the use of ground water in Colorado.
2.	Current Activities
Senator David Durenberger (R-MN) recently introduced the
Ground Water Protection Act of 1988. The bill would provide a
comprehensive strategy for protection of the nation's ground
water and would be financed through a hazardous waste disposal
tax, a solid waste disposal tax, a water supply assessment, and
an excise tax on non-agricultural pesticides sold in the lawn and
garden market. Several other ground water protection bills have
been introduced in this session of the U.S. Congress.
The Colorado Department of Health is in the process of
adding additional organic chemicals to those currently included
in its classification system.
The State Engineer's Office is developing new regulations
for well construction which will be more protective of ground
water.
3.	Public Expenditures
The Ground Water Branch in the Water Management Division of
EPA Region VIII has 5 FTE working on ground water issues in the
six state region. The Ground Water Branch has approximately
$25,000 in contract dollars annually.
The Colorado Department of Health has 5 FTE devoted to
ground water issues, and received a grant of approximately
$90,000 in FY88 from EPA.
C- Possibilities for Further Control
Although preventing degradation of ground water quality is
receiving increased attention at the national, state, and local
level, to date nearly all efforts have been directed toward
remediating ground water contamination. Remediation has proven
to be very expensive, and therefore preventing future
contamination is important for minimizing economic impacts.
National hazardous waste laws have stringent standards for
protection and cleanup of ground water, but other potential

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sources are not as well regulated.
Ground water contamination from agricultural use of
pesticides is a suspected problem receiving increased attention
in rural areas. Changing methods of application and exploring
ways to reduce the need for pesticides are being examined.
IV. WORK GROUP FINDINGS
The ESP did not convene a work group to examine the ground
water issue.
The Drinking Water Work Group captured some issues related
to ground water and concluded that drinking water being consumed
from private wells and small systems is of concern because it is
unregulated, untreated, and because little is known about the
actual use of these sources in the metro area.

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SURFACE WATER QUALITY
I. ISSUE DESCRIPTION
Surface water bodies in the metro area serve a variety of
purposes: irrigation, drinking water, recreation, and wildlife
support. The waterways are also managed for flood control.
II. IMPACT ASSESSMENT FACTORS
A.	Public Health Issues
Surface water quality potentially affects human health when
used as drinking water for contact sports, or when contaminated
fish or shellfish are consumed. However, the ESP considered
drinking water health issues separately, and available data do
not suggest that the remaining potential human health effects are
significant at present. Consequently, for analytic purposes, the
surface water issue was defined only in terms of the economic
value of recreation.
B.	Economic/Welfare Effects
1. Environmental Strategies Project Analysis
The ESP conducted a study of the value of recreation
improvements which could occur with certain water quality
improvements at five sites: Clear Creek above Golden, Sloan Lake,
Segment 15 of the South Platte River, Adams County Gravel Pits,
and Cherry Creek Reservoir. (Cherry Creek estimates were from
another study.)
o Analytical Approach
For each site, a water quality change was postulated. For
Clear Creek, Segment 15 and the Adams County Gravel Pits, the
water quality changes were improvements. For the remaining
sites, the water quality change was in terms of prevention of
degradation. Then, the magnitude of changes in recreational
activity that might occur based on the proposed water quality
change was estimated. Three types of recreation activity changes
were considered: 1 ) changes in participation in existing
activities; 2) changes in quality of existing activities; and 3)
addition of new activities. A dollar value was assigned to the
changes in recreation activity based on data from other studies
and the ESP economic consultant's professional judgement.
o Results
The results are a range of values for each site, and a range
for the summation of the five sites. The range reflects

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uncertainties in the available data. For individual sites, the
annual value of changes in recreation activity based on the
postulated water quality change range from $300,000 to $3 million
in 1986 dollars; the five-site summation ranges from $4.2 to $8.5
million dollars.
2. Other Economic Issues/Limitations of the ESP Analysis
The estimates presented in the ESP analysis represent a
lower regional bound. An upper bound was not estimated since a
limited number of sites were examined and secondary economic
values were excluded. We emphasize that these values are not
that of the resource itself, but only of the specified recreation
improvements.
Other possible economic effects which were not studied in
the ESP include those that could occur: if an industry's decision
to locate in the area is influenced by water quality and
associated requirements; when waterways are well-developed
amenities that attract new business; when adjacent property
values are affected due to the influence of the waterway's
quality on development potential. In addition, costs may be
incurred by industrial, agricultural, or municipal users for
cleaning up surface water to meet their needs or to meet
applicable requirements.
C. Ecological Effects
Ecological effects were not studied in the ESP analysis.
However, most water quality issues addressed through the existing
regulatory process to date relate to protection of aquatic life.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
The public probably perceives that water quality issues are
not as significant as, for example, air quality issues.
Nevertheless, interest groups become actively involved and debate
can be heated during regulatory activities.
Some public concern is shown by the fact that the recent
bond issue to upgrade Denver Metro Central was overwhelmingly
approved (although voter turnout was small). In addition,
anecdotal information suggests that primary contact users are
aware of water quality problems affecting recreation experiences.
B.	Regulatory Status
1. Legal Requirements

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The primary legal authority for protection of surface water
quality is the 1987 Clean Water Act. The objective of the Act is
to restore and maintain the chemical, physical, and biological
integrity of the nation's waters. The Colorado Water Quality
Control Act is the parallel state law. The State Legislature is
currently considering revisions in response to the 1987 federal
amendments.
The Colorado Water Quality Control Commission of the
Colorado Department of Health implements the key regulatory
programs mandated by the Act. Through the National Pollutant
Discharge Elimination System (NPDES) Permitting Program, the
State issues permits to point sources which limit concentrations
of specified pollutants as necessary to meet water quality
standards (promulgated by the Water Quality Control Commission)
and minimum technology-based requirements. Industries that
discharge into municipal wastewater treatment facilities are
required to remove certain toxics prior to discharge. Permits
are enforced by the State with EPA oversight.
The EPA provides oversight, technical and administrative
assistance, and funding to state and local agencies. The Denver
Regional Council of Governments plans and coordinates local
government efforts.
The other public and private entities which affect the
river's use and the degree to which the potential benefits of
water quality are realized include: the Urban Drainage and Flood
Control District, the U.S. Army Corps of Engineers, the Colorado
Division of Wildlife, the non-profit Greenway foundations,
several city agencies within the metro-area, irrigators, sewage
districts, and other dischargers.
2. Current Activities
Examples of significant current activities include permit
conditions that require upgrading the Metro Denver Central Sewage
Plant, and the Commission's triennial review of regulations
establishing the South Platte Basin Use Designations and
associated Water Quality Standards to be completed by spring.
New programs to control point sources established by the
1987 revisions to the Act require States to develop permit
programs for stormwater discharge as well as to improve control
of toxic point source dischargers. The 1987 revisions also
intensify efforts to control nonpoint sources (NPS's) by
requiring States to develop a NPS Assessment Report and a
Management Plan. Section 319 provides implementation funds which
have not yet been appropriated by Congress.
Although NPS control (the authority for which typically
rests at the local level) has not been mandated in the past, the

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law has directed the State and DRCOG to prepare basin plans and
updates of the 208 Areawide Plan which focus on NPS's. In some
areas, DRCOG and the various local governments have exceeded the
requirements of state and federal law in these efforts. In
response to the 1987 revisions, the State is initiating a
statewide NPS Assessment. Exploration of the relationship
between point and NPS's will take several years of substantial
effort.
Sub-basin plans have been prepared for Cherry Creek
Reservoir and Chatfield Reservoir which emphasize phosphorus
control. In Cherry Creek Reservoir, an innovative control
approach has been adapted from the "bubble concept" originally
developed for Lake Dillon which enables point source dischargers
to modify their allowable point source discharge based on clean
up of NPS's. Local entities in some basins have adopted control
measures such as best management plans for erosion control during
subdivision construction, and/or considered measures such as
subdivision siting controls, retention/detention, and load
allocations.
Under DRCOG's direction, major special studies are under way
for Bear Creek Reservoir and for Segment 15 of the South Platte
and the lower reach of Big Dry Creek. Through the Commission's
triennial review of water quality standards, Barr Lake and
Standley Lake have surfaced as potential major issues.
Several significant projects are taking place outside the
water quality regulatory framework. The Denver City Council
spearheaded a special effort to improve water quality in several
park lakes by dredging two lakes. In addition, various city
agencies and nonprofit organizations have ongoing projects to
develop parks and commercial activities around key waterways.
3. Public Expenditures
The Annual Workplan for 1987-88 for the Water Quality
Control Division of Colorado Department of Health shows total
state-wide funding of more than $3.5 million for water quality
management activities.	The EPA provided nearly $2 million
to the State in FY 88 for state wide water quality efforts. On
the order of 50% to 75% of these funds is expected to be directed
towards the metro-area.
DRCOG expenditures were approximately $210,000 which
includes $50,000 from EPA, $25,000 from DRCOG itself, $35,000
from donors such as Denver Metro, and about $100,000 in local
funds for special basin studies.
Voters recently approved a $97 million dollar bond issue to
upgrade metro Denver's waste water treatment plant.

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Various private organizations and governmental entities
contribute undetermined amounts to water quality management and
development of waterways in general.
C. Possibilities for Further Control
Efforts are underway to improve understanding and control of
NPS's as well as toxics. Opportunities may also exist to improve
the overall value of our waterways by encouraging the various
management entities to work together.
IV. WORK GROUP FINDINGS
The ESP Work Group concluded that surface water is a
valuable resource affecting the quality of life for metro-Denver
and downstream users. Ongoing programs and regulations have been
effective in protecting water quality and significant progress
has been made through the years. Nevertheless, continued
development of tools and innovative approaches needed to both
protect water quality and to maximize the value of the surface
water resource as a whole are needed.
Specifically, the Work Group noted that surface water is
managed by a number of agencies, each of which focuses on a
selected parameter (e.g. flood control, water quality, wildlife,
recreation, etc.). No single entity is responsible for
developing overall goals to maximize the value of our urban
waterways by integrating these separate but related activities.
Consequently, opportunities to develop the full biological,
recreational, and visual potential of surface water have not been
fully explored. The Work Group suggested that a conference be
planned where key actors could share information and develop
goals and mechanisms for improving surface water management.
In addition, the Work Group found that actions to encourage
habitat improvements such as innovative approaches to NPDES
permits and wetlands protection are potentially valuable.
Several data gaps were also identified: need for an improved
metro-area Lake Dynamics Model for standard-setting purposes;
need for data on NPS's, including information such as water
quality data on urban runoff "streams" such as Harvard Gulch.

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D. SOLID AND HAZARDOUS WASTE
1.	Emergency Response/SARA Title III
2.	Superfund Sites
3.	Underground Storage Tanks
4.	Active Municipal Landfills
5.	Inactive Municipal Landfills
6.	Hazardous Waste Generators
7.	Transportation of Hazardous Materials
8.	Hazardous Waste Treatment, Storage and
Disposal Facilities
STAFF CONTACT:
Debbie Welles 293-1454

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EMERGENCY PLANNING AND RESPONSE/SARA TITLE III
I.	ISSUE DESCRIPTION
Title III of the Superfund Amendments and Reauthorization Act
of 1986 (SARA), also known as the Emergency Planning and Community
Right-to-Know Act, was created in response to several problems.
First, communities have become interested in knowing what hazardous
materials are being stored or transported through their
neighborhoods. Second, in order to be prepared to respond safely
and responsibly to a hazardous material incident, emergency
response teams need to know what materials are being stored in
their district, where, by whom, and in what quantities.
II.	IMPACT ASSESSMENT FACTORS
A.	Public Health Issues
1.	Environmental Strategies Project Analyses
Due to the difficulty in locating usable data on the acute
effects of accidental releases, the ESP did not attempt to evaluate
this type of risk.
2.	Other Health Issues/Limitations of the ESP Analysis
An important concern associated with emergency planning and
response is to avoid (or lessen) potential acute health effects
from a release. An acute effect is one which occurs immediately
after exposure to a harmful substance. Such an effect may either
be reversible such as a headache, or irreversible as in permanent
lung damage.
B.	Economic/WeIfare Effects
If local governments do not know what hazardous materials are
being stored at a plant it is very difficult to encourage
facilities to develop their own emergency response plans. In the
event of a spill, a lack of this type of information can put the
emergency response authority in the position of having to respond
without the benefit of background information on the types and
quantities of substances they are likely to encounter. Risk to the
responder and to the community has both a dollar value and a
quality of life concern attached.
In the event that a facility or transporter experiences a
significant release, the community is likely to incur damages to
property and materials.
C.	Ecological Effects
The longer it takes to clean up a release, the greater the

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opportunity the substance has to permeate various environmental
systems. Depending on the nature of the substance released,
combined with a host of additional factors, e.g., weather, quantity
released, media through which substance is traveling, etc., varying
degrees of environmental damage may occur.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Occasional releases of toxic gases in other locations, such as
Bhopal, India, have sensitized people to the need for emergency
preparedness and efficient response programs.
B.	Regulatory Status
1.	Legal Requirements
a.	Title III of the Superfund Amendments and Reauthorization
Act requires state, local governments, citizens and
industry to cooperate in planning and assessing local
emergency response capabilities.
b.	Facilities handling threshold quantities of certain
chemicals are required to report such information to the
State Emergency Planning Commission (managed by CDH),
their local fire department and the local SARA Title III
planning committee.
c.	In the event of a hazardous substance release, the law
requires a facility or transporter to provide information
to federal, state and local governments, and to the
public concerning the hazards associated with such an
incident.
2.	Current Activities
To date, the Local Emergency Planning Committees have been
attempting to determine how they will comply with the complexities
of SARA Title III. Because they have received no direct funds from
either the State or EPA, compliance has been inconsistent.
Existing compliance strategies are localized and highly dependent
on the interests of the individuals involved. It is important to
reiterate that it is the responsibility of business and industry to
provide the information requested in SARA Title III to the local
committees, who in turn are responsible for managing this
information and making it available to the public.
3.	Public Expenditures
As of March 1988 EPA Region VIII has less than 1.5 FTE working

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on the SARA Title III program in Colorado. The Region has no
contract dollars to spend on SARA Title III.
The State of Colorado has no budgeted FTE and no contract
dollars to expend on SARA Title III.
Most local governments argue that without implementation
dollars from somewhere they will have trouble fully operating this
program. On the other hand, some communities are using fire
department and hazardous waste emergency response dollars to
incorporate Title III requirements as a way of organizing
information and database systems.
C. Possibilities for Further Control
A practical drawback related to SARA Title III is the fact
that the law creates a costly information management problem. To
date, Congress has provided no funding mechanism to assist in the
implementation of this task. The problems that SARA Title III is
designed to mitigate can be controlled as long as the act is
complied with and control mechanisms are in place. In order for
this to occur, the program will need funding.
If at some future date, communities have readily accessible
data bases containing the kind of information required under SARA
Title III, and if they are well trained in the upkeep and
appropriate use of these data, it is hoped that prevention as well
as emergency response will be more effective and that risks will be
reduced.
IV. WORK GROUP FINDINGS
The Hazardous Waste/Materials Work Group felt strongly that
acute risks need to be addressed in addition to longer term
problems such as municipal landfills in order to understand overall
health risk in the metro Denver area. Regardless of the fact that
the SARA Title III information is mandated by law, the work group
found that this information is and will continue to be difficult to
collect and cumbersome to manage. In reality, most communities are
still trying to understand what institutions should be reporting
and need assistance with this basic task.
The suggestion was made to single out a community in the metro
area which has the most advanced approach to managing the
requirements of SARA Title III, and to help it completely develop
and test a prototype database which could in turn be used by other
metro area counties. The work group recognized that there have
been other efforts around the country to develop such databases and
believe that the metro area should be aware of these as it strives
to develop its own.
Any effort on the part of the ESP should be coordinated with

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the Colorado Department of Health (as well as other potential
users) as they also need access to this information and are in a
good position to recommend how to make it fit multiple needs.

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SUPERFUND SITES
I.	ISSUE DESCRIPTION
As of March 1988, there are six Superfund sites in metro
Denver which have been placed on the National Priorities List and
which require remedial actions to address existing or potential
risks to human health or the environment. These sites are listed
below.
Broderick Wood Products
Denver Radium
Lowry Landfill
Rocky Mountain Arsenal (Excluding Basin F)
Sand Creek Industrial
Woodbury Chemical
Three additional sites are proposed for inclusion on the
National Priorities List and are currently being assessed as part
of the Superfund program. These are:
Martin Marietta
Rocky Flats
Rocky Mountain Arsenal, Basin F
II.	IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
Three sources of information were used to characterize the
range of potential risks: 1 ) exposure levels and risk estimates
described in public documents, 2) the judgement of local officials
familiar with the sites, and 3) national estimates of the number o
people who might be exposed to releases at Superfund sites.
The conclusions relied primarily on worst case scenarios and
assume that no remedial actions have been, or will be taken. Whil
many of the worst case scenarios are unlikely to occur, they were
developed to allow comparison of Superfund risks to other ESP
issues also assessed under worst case conditions.
Health risks related to the Rocky Mountain Arsenal and Rocky
Flats were not assessed to the same level of detail as the others
because of their high level of complexity. Risks associated with
these sites are uncertain and are undergoing evaluation through
other efforts by EPA, CDH, and responsible parties.

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o Information on Human Exposure
Analysis of metro Denver Superfund sites (not including Rocky
Mountain Arsenal or Rocky Flats) suggests that worst case exposure
conditions at the Denver radium sites represent individual risks
that are unlikely to be exceeded at any of the other sites in the
analysis, assuming no remedial action is taken. Individual risks
for the more likely scenarios were based on a review of published
information on the sites, and local judgments about the most likely
exposure pathways.
Upper-bound estimates of the total number of adverse health
effects (i.e., population risks) were developed by assuming worst
case conditions at Denver Radium. The lower end of the range is
based on national exposure estimates.
o Impact on Human Health
Under worst case conditions, individuals breathing radon
stored in the soil and building materials at the Denver Radium
sites over their entire lifetime could experience a 1 in 10
increased risk of developing lung cancer.
Assuming development of the Denver Radium sites without
remedial action, this high individual risk translates into
approximately three additional lung cancer cases per year. Current
conditions at the Denver Radium Sites do not lead to risks nearly
this high because they are not developed to the extent assumed
under the worst case scenario. Worst case risks at other sites
could be as high as those at the Denver Radium sites under similar
assumptions about worst case exposures.
The other Superfund sites are unlikely to generate individual
risks that exceed the risks associated with worst case conditions
at Denver Radium. At some sites the risks would most likely be
significantly lower. In fact, sites with limited access or with a
low potential for off-site contaminant migration may well pose
minimal health risks.
2. Other Health Issues/Limitations of the ESP Analysis
The very wide range of predicted risks for metro-Denver
Superfund sites indicates that there may be substantial variation
in potential health risks among sites. Although it is not possible
for this study to provide precise estimates of risks at individual
Superfund sites until completion of more detailed analyses of the
sites, we believe it is unlikely that either individual or
population risks will be found to greatly exceed the estimates
provided in this analysis.

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As indicated earlier, the Rocky Mountain Arsenal and Rocky
Flats are major sites that are undergoing considerable assessment.
While actual risks at these sites are not yet known, they are of
particular concern on the part of EPA, CDH, responsible parties,
and the general public.
In reviewing the Superfund risk estimates, the reader should
note that the analysis only provided estimates for chronic health
risks at Superfund sites. There is concern about potential acute
health effects, especially to on-site workers (e.g., at Rocky
Flats), but no quantitative estimates of these risks were available
for the Environmental Strategies Project analysis.
B.	Economic/Welfare Effects
Economic effects of the Superfund sites include opportunity
costs of land which can not be used for other purposes, devaluation
of land near the Superfund sites, and replacement cost of
groundwater contaminated by the sites. In addition, national
attention given to some of these sites has damaged metro Denver's
image as a healthy place to live.
C.	Ecological Effects
Pollution from Superfund sites may well have negative
environmental impacts on one or more of the following:
groundwater, surface water, air, soil, wetlands, plants, and/or
wildlife. Contamination of groundwater and soil has been found at
most of the sites, while testing continues on air pollution
impacts.
Some analyses indicate that damage to habitats of unique and
highly valued wildlife species may be of particular concern at the
Rocky Mountain Arsenal.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A. Public Perception/Political Pressure
Public awareness of environmental problems connected with many
of the Denver area Superfund sites is high. Potential hazards from
the Rocky Mountain Arsenal, Lowry Landfill, Martin Marietta, and
Rocky Flats are widely recognized problems, while the remaining
sites have less widespread visibility.
Pressure to clean metro Denver's Superfund sites focuses on
potential health effects as well as the opportunity to use land at
or near these sites for other purposes.

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B. Regulatory Status
1.	Legal
a.	Superfund regulations are derived from the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA) program, as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA).
b.	Superfund sites are included on the National Priorities
List (NPL) on the basis of quantity and type of hazardous
wastes present, pathway, and magnitude of affected
populations.
c.	Once Superfund sites are identified, a remedial
investigation and feasibility study (RI/FS) is performed
to determine the degree of migration of wastes from the
site and impacts on human health. This activity is
underway for nearly all of the Denver area Superfund
sites.
d.	EPA is required in CERCLA Section 121 to give preference
to remedial actions which reduce the volume and toxicity
of hazardous wastes on-site, minimizing the need for
transportation or long term storage.
e.	The State of Colorado has a statute authorizing the
Colorado Department of Health (CDH) to take part in
Superfund cleanup efforts. In 1988, the State
Legislature enacted a law extending this authority.
2.	Current Activities
Governor Roy Romer has appointed a special task force of
public officials and citizens to provide advice regarding cleanup
of hazardous wastes at Rocky Flats.
3.	Public Expenditures
Superfund expenditures are cited according to the FY 1988 SCAP
(Superfund Comprehensive Accomplishments Plan of 8/24/87), a
planning document which describes Fund Financed Projects. Fund
financed refers to sites on which the clean-up is funded by
Superfund when no potentially responsible party (PRP) can be found,
or when a PRP litigates and payment is delayed.
The FY 1988 SCAP indicates that for FY 1988, EPA planned to
budget $12,496,910 for the eight Superfund sites in the metro area.
This amount covers remedial investigations and cleanup for EPA and
EPA contractors for the eight Superfund sites.

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Also referencing the SCAP, EPA planned to transfer $185,000 to
the State of Colorado via a cooperative agreement for management
assistance for FY 1988. Other non site-specific funds budgeted to
CDH by EPA included $200,000 for preliminary assessments and site
investigations statewide and $250,000 for core program development.
In addition to funds transferred to the state from EPA for the
eight referenced sites, CDH budgeted $36,200 for personnel and
$12,800 for operating costs. In addition, CDH budgeted an
additional $187,000 under CERCLA for the Rocky Mountain Arsenal.
The Department of Defense (DOD) and Department of Energy (DOE)
have also budgeted funds for remedial investigations and cleanup at
the Rocky Mountain Arsenal and Rocky Flats. For FY 1988, DOD
budgeted approximately $80 million for Rocky Mountain Arsenal
Superfund activities. DOE has budgeted approximately $30 million
during FY 1988 for Rocky Flats cleanup activities.
The EPA, state, and federal budget numbers do not include
legal e.g. litigation/ enforcement support costs. It should also
be noted that the money spent on Superfund sites may be partially
or fully recovered from potentially responsible parties. In the
case of the Rocky Mountain Arsenal, Shell Oil has already agreed to
repay a large portion of the cleanup costs.
C. Possibilities for Further Control
Further control options for each site are being very carefully
reviewed and developed under the remedial investigation/feasibility
study process.
IV. WORK GROUP FINDINGS
Given the current level of regulatory attention being given to
Superfund sites, the work group decided to focus its attention on
other environmental problems.

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UNDERGROUND STORAGE TANKS
I. ISSUE DESCRIPTION
The Colorado Department of Health estimates that there are
approximately 25,000 underground storage tanks (USTs) in Colorado.
Roughly 7,500 of these USTs are located in the six county
metropolitan Denver area.
Of the total number of USTs nationwide, EPA estimates that 5-
20% may be leaking. Applying this national factor to the estimated
7,500 USTs in metro Denver, EPA estimates that between 375 to 1,500
USTs may be leaking in the metro area.
Most underground storage tanks contain petroleum products
e.g., gasoline, diesel fuel, heating oil, and jet fuel. It is
estimated that 1% of the USTs in Colorado contain chemical
substances which have been defined as hazardous by EPA. Potential
hazards from both types of USTs include leakage into groundwater or
sewer lines, fires and explosions.
II. IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
Health risks were calculated by estimating the risks from a
1977 underground storage tank leak at a gas station in Northglenn.
This estimate was then used to determine the potential risks
associated with all metro-Denver USTs.
The leaking UST in Northglenn was selected because: 1) the
amount of material that leaked from the site represents an upper-
bound on the size of expected future leaks; 2) leaks from gas
stations are the most common type that might occur in the future;
and 3) data on concentrations of gasoline released and measured in
the environment were available.
Health risks were evaluated by applying standard EPA risk
assessment methods to the actual levels of gasoline detected at the
site, and to levels that could exist under worst case assumptions.
o Information on Human Exposure
The exposures to gasoline used in the analysis were a
combination of actual conditions and hypothetical worst case
conditions. For releases to groundwater and to the air, individual

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worst case exposures were calculated assuming pollutant
concentrations that the least sensitive person in the population
would be expected to smell or taste. Exposures were also
calculated for actual levels of gasoline detected after the
Northglenn leak.
Estimates of the total number of adverse health effects were
based on the expected number of leaking USTs in Denver, national
estimates of the number of persons exposed per leaking tank, and
the individual risk levels calculated for the worst case and for
the Northglenn scenarios.
o Impact on Human Health
The analysis of human health risks considered the effects of
the primary toxic constituents of gasoline (benzene, toluene and
xylene). The health information on the chemicals is based on
Agency approved studies. Under worst case scenarios at the
Northglenn release, the risks to an individual breathing gasoline
vapors are higher than those to an individual drinking contaminated
groundwater.
In the worst case, inhalation risks could be as high as 2 in
1,000 of developing cancer from a lifetime of exposure to
concentrations just below the level at which a person would detect
their presence.
Under more likely exposure scenarios, the risks could be
between 10 and 100 times lower using national data on average
failure, release and exposure rates. Given the assumptions of the
study, the risks across the population under worst case conditions
would result in less than one additional cancer case annually.
Non-cancer effects from toluene and xylene would not be expected to
occur at the levels detected at Northglenn. Health effects data
were not available to estimate non-cancer health effects from
benzene.
2. Other Health Issues/Limitations of the ESP Analysis
The analysis of human health risks posed by USTs in metro-
Denver focused primarily on the chronic risks attributable to
leaking petroleum tanks. Uncertainties about the actual number of
leaking tanks in Denver, the number of persons potentially exposed
to contaminants and the levels of these exposures are reflected in
the range of individual and population risks.
Risks from underground storage tanks are unlikely to exceed
the upper-bound estimates given the conservative assumptions
underlying these scenarios. While the risks could be less than the
lower bound estimates (in the event of very small release events or
in situations where no one is actually exposed), risks are more
likely to fall within the predicted range.

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In evaluating the risks posed by USTs, it is important to
recognize the possibility of other types of risks not analyzed for
the Environmental Strategies Project. These include acute risks
from short-term exposures or from events such as explosions. Data
were not available to analyze the magnitude of acute risks.
The ESP analysis examined only health effects from exposure to
the primary constituents of gasoline. Risk levels might be higher
for chemical tanks leaking substances that are more toxic than
common petroleum products, although there are only a relatively
small number of such tanks in metro-Denver. Risks from leaking
chemical tanks could be as high as those estimated in the analysis
of hazardous waste treatment facilities.
B.	Economic/Welfare Effects
A city with environmental contamination from widespread leaks
and spills could suffer some loss of economic activity. Fires and
explosions from UST leaks and spills may damage commercial and
residential property. In the event that a responsible party is not
identified, clean-up costs will be incurred by some level of
government.
C.	Ecological Effects
Leakage of petroleum products and hazardous chemicals into
groundwater or surface water supplies can potentially inhibit its
quality for years.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Awareness of the environmental problems posed by underground
storage tanks and pressure for action exists primarily in areas
which have experienced groundwater contamination, spills, or fires.
The extent to which such events have been publicized by the media
also influences public perception.
B.	Regulatory Status
1. Legal Requirements
An interim prohibition established in the Resource
Conservation and Recovery Act (RCRA) includes requirements that new
USTs be protected against corrosion or structural failure and be
made of material compatible with tank contents.
EPA has proposed regulations for the UST program that will
replace the interim prohibition. These regulations will become
effective on October 1, 1988. The new regulations include the
requirements that:

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Leak detection standards be met within 3-5 years,
Corrosion and spill prevention measures be in place within
ten years,
UST owners maintain the capacity to pay for cleanup, usually
through liability insurance, at a minimum coverage of $1
million per occurrence.
In October 1986 Congress established the Leaking Underground
Storage Tank (LUST) trust fund for program development, conducting
investigations, enforcement, and cleanup activities. This fund is
to operate as a revolving account, beginning with $500 million in
revenues to be raised through taxes on fuel and other commodities.
The Colorado Department of Health uses LUST fund dollars for
program development and leak investigations, but does not have the
legislative authority to use the funds for enforcement, cleanup, or
cost recovery.
2.	Current Activities
Colorado has not adopted legislation authorizing state
implementation of EPA's proposed UST regulations. If ths State
Legislature does not approve such legislation, EPA could administer
portions of the program when the regulations are final through a
memorandum of understanding with the State. However, this would
not be a comprehensive or effective response to the problem as EPA
is very limited in what it would be able to do.
A steering committee consisting of public and private sector
officials prepared and proposed legislation which would have
allowed adoption of the proposed federal UST program. This
legislation was defeated in the 1988 Colorado State Legislative
session. It is anticipated that new legislation will be introduced
in the 1989 session.
3.	Public Expenditures
The State of Colorado received $200,000 in LUST trust fund
moneys in FY 1987 to be used in FY 1988 and beyond. Additional
allocations may be made in FY 1988 and FY 1989.
After the proposed Federal UST regulations become effective,
allocations of LUST Trust Fund money to the State will require the
State to provide a 10% match.
In FY87 and FY88, EPA provided a grant to Colorado for the
development and implementation of the UST program. In FY 88 the
state UST program budget was approximately $200,000, of which 75%
came from an EPA grant and the remainder from the state.

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C. Possibilities for Further Control
As of April 1988, CDH has a well-developed UST database
capable of cataloging the location of all known USTs. CDH intends
to update this database regularly as new information becomes
available. However, it must be noted that it is particularly
difficult, and in some cases impossible, to locate USTs which are
no longer in use. Control options for these abandoned USTs are
basically limited to leak detection and/or research and removal of
old tanks.
However, there are a range of technical options available to
reduce the likelihood of a release of toxic material from USTs
brought into use in the future. EPA, for example, is currently
exploring five regulatory options designed to reduce the likelihood
of tank failure. The baseline option requires corrosion protection
for all new tanks and quarterly leak detection within 3 years of
the adoption of new regulations for all existing and new tanks.
Under more extensive options, periodic tightness tests for
existing tanks and secondary containment with interstitial
monitoring for new tanks are required in addition to the baseline
level controls.
The costs associated within these options vary between $3,000-
$4,000 per tank. It is anticipated that these incremental costs
should result in long-term savings to tank operators by reducing
the opportunity for groundwater contamination and thus lowering
future liability and cleanup costs.
IV. Work Group Findings
The work group was interested in this issue and endorsed further
data collection on leaking USTs. In both 1987 and 1988, state
legislation pertaining to USTs has been introduced but not passed.
If the State is to have authority to deal with leaks, it needs
legislative authority to do so.

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ACTIVE MUNICIPAL LANDFILLS
I.	ISSUE DESCRIPTION
There are seven active municipal landfills receiving solid
wastes from homes and businesses located in the Denver metropolitan
area. Small quantities of hazardous household chemicals are being
disposed of in active municipal landfills. Of these landfills, two
are located in Weld County (which is outside the six county
metropolitan study area). If toxic materials stored in these
landfills penetrate landfill barriers, wells and other water
supplies may be contaminated.
II.	IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
The potential risks associated with the Jefferson County
landfill were characterized and then used to estimate the potential
risks associated with the other active landfills in metro-Denver.
Inactive landfills were not considered due to the limited data on
these facilities. However, some officials believe inactive
landfills may pose an even greater risk than active landfills.
The Jefferson County Landfill was selected for the analysis
because: 1 ) Aside from Lowry Landfill, Jeffco is the largest
municipal landfill in the study area, 2) Jeffco Landfill had
experienced a seepage incident in the past, and 3) People are
drinking ground water from private wells nearby. Due to the
potential for ground water contamination, the study determined that
Jeffco Landfill might pose risks greater than those at the other
facilities in the study area. Please note that Lowry Landfill was
not included in the active municipal landfill analysis. Instead,
it was included as part of the Superfund analysis.
Health risks were assessed by applying standard EPA methods to
contaminant levels that could exist if the leachate entered nearby
drinking water supplies. A variety of exposure scenarios were
evaluated to generate a likely range of risk.
o Information on Human Exposure
Exposures to contaminants at landfills were developed by
modeling potential concentrations at drinking water wells and
surface water supplies under a range of site conditions, e.g.
ground water flow, number of people drinking from potentially
contaminated wells and various leachate constituents which could
potentially exist at the Jefferson County Landfill.

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By varying the exposure scenarios, a range of potential risks
was calculated. To estimate the number of people affected
throughout metro-Denver, ESP applied estimates of the range of
individual risks at the Jefferson County facility to the number of
potentially exposed individuals at the other facilities^
o Impact on Human Health
The toxicity information used in the analysis was based on EPA
approved laboratory experiments with animals. Under worst case
conditions at the Jefferson County site, the risks to individuals
drinking contaminated ground water are estimated to be 9 in 10,000
of developing cancer from a lifetime of exposure to maximum
concentration of representative landfill contaminants. The risks
are roughly 100 to 10,000 times lower under more likely exposure
scenarios.
For the total population of metro Denver, even under worst
case conditions, less than one additional cancer case is expected
per year as a result of toxic contamination of drinking water by
active municipal landfills. This result is attributable to the
limited number of people drinking from wells near active municipal
landfills. However, under worst case conditions small numbers of
people could drink water with levels of toxics high enough to cause
non-cancer health effects. Under more likely conditions, these
levels are not expected to pose a threat to human health.
In the Jefferson County Landfill study, risks from ingestion
of surface water were found to be substantially lower primarily
because of the dilution of the contaminant in the surface water)
than those associated with drinking contaminated groundwater from
private wells.
2. Other Health Issues/Limitations of the ESP Analysis
The wide range of predicted individual and population risks is
a reflection of the uncertainty inherent in the health risk
estimates for municipal landfills. Significant uncertainties are
introduced as a result of (1) our less-than-complete knowledge of
release rates and hydrogeologic conditions at the Jeffco Landfill
and (2) the process of extrapolating from one representative
landfill to the other area sites.
Despite these uncertainties, we are relatively confident that
the actual risks from active municipal landfills will not exceed
the upper bound estimates identified in this study. These upper
bounds are based on worst case assumptions about contaminant
release rates, groundwater flows, and the location and number of
persons exposed.
A more significant uncertainty arises from the limited scope

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of the analysis. As mentioned above, only active municipal
landfills were analyzed.
Regarding other health hazards associated with active
landfills, CDH reports that landfills in the Denver metro area are
generally in much better shape than active municipal landfills in
much of the rest of the State. CDH attributes this to the fact
that Denver's landfills have a predictable stream of revenue based
on volume and dependability of clients and consequently they have a
level of management not possible elsewhere.
B.	Economic/Welfare Effects
Off-site contamination may limit opportunities for land use
near landfills. Increased traffic caused by the passage of garbage
trucks also has a potential impact.
C.	Ecological Effects
Improperly managed landfills may well have detrimental impacts
on floodplains, endangered species, groundwater, soil, air, and
surface water.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A. Public Perception/Political Pressure
Public concern is frequently voiced over the environmental
effects of Denver-area landfills. It is also known that people
fear the effect a landfill or a transfer station may have on their
property values. Lowry Landfill is often referred to as an example
of the detrimental effect having a landfill next door can have on
property values. It must be remembered, (and often people forget
or do not know) that Lowry is a product of both solid landfilling
and industrial waste dumping. Clearly, Lowry is not a classic
municipal landfill.
B. Regulatory Status
1. Legal
a. Regulation of solid waste disposal is covered by Subtitle
D of the Resource Conservation and Recovery Act (RCRA).
Subtitle D uses the following mechanisms to address
active municipal landfills:
o Minimal technical standards for all solid waste
disposal facilities,
o A provision under which any person may begin a civil
action on his own behalf against any person or
governmental agency allegedly in violation of RCRA

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Subtitle D.
b.	States are the implementing authority for Subtitle D.
c.	New federal regulations are pending which place more
specific requirements on the operation and closure of
municipal landfills. EPA is expected to issue a draft of
these regulations in 1988.
2.	Current Activities
The Denver Regional Council of Governments (DRCOG) has
performed an issues analysis for solid waste management in the
Denver region and is attempting to raise funds to develop a
Regional Solid Waste Management Plan during 1988-89. The plan
would assess the region's solid waste management problems, evaluate
options for dealing with solid waste in the region, develop a set
of regional goals and policies regarding solid waste management and
implement these goals and policies. In order for this effort to
succeed, DRCOG will need metro-wide encouragement.
3.	Public Expenditures
RCRA subtitle D was designed to be a state effort and is not
funded by the federal government. However, the Colorado Department
of Health has not been able to get an appropriation to fully
perform this function. Hazardous waste programs are an exception
and receive federal funds.
C. Possibilities for Further Control
There are several strategies for approaching the management of
solid wastes in landfills. One certainly is to build better
disposal sites. Another involves using alternative disposal
practices such as incineration, waste-to-energy, recycling,
separation, etc.. And yet another considers ways to reduce the
bulk of solid wastes before they become a problem, e.g. waste
minimization. State officials have indicated the need to consider
all three approaches.
IV. WORK GROUP FINDINGS
The work group acknowledged the difficulty the metro area has
had in implementing a regional solid waste plan and in developing
better metro-wide cooperation for waste disposal. They agreed that
the problem can no longer be defined as a lack of data or
insufficient technological options or information. Consequently,
the work group recommended strategies for promoting a workable and
lasting institutional solution to the problem.

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INACTIVE MUNICIPAL LANDFILLS
I.	ISSUE DESCRIPTION
Inactive municipal landfills can cause environmental problems
when precautions to inhibit contamination of groundwater, surface
water, and air have not adequately been incorporated into the
initial landfill design or retrofitted before the landfill was
closed.
The extent of this problem is not known. Many questions exist
regarding off-site contamination from inactive landfills: some data
are available but many sites have not been tested or documented.
Furthermore, the rate at which problems develop is also not well
understood.
II.	IMPACT ASSESSMENT FACTORS
A.	Public Health Issues
1.	Environmental Strategies Project Analysis
Due to time and budget constraints the potential health
effects of inactive landfills were not assessed by the
Environmental Strategies Project.
2.	Other Health Issues
Potential health effects include injuries or deaths from
methane gas explosions, collapse of poorly stabilized soils,
erosion and leachate seepage.
B.	Economic/Welfare Effects
Development opportunities for land on and around inactive
landfills may be limited by contamination. In the event of a fire
or explosion caused by leaking gases, nearby homes and businesses
may be damaged. Future settling of the soil in a landfill may make
it impractical to build structures above the old landfill.
C.	Ecological Effects
Leakage and off-site migration of toxic and hazardous wastes
can cause contamination of air, groundwater, and surface water.

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III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Public awareness of potential hazards posed by inactive
municipal landfills is generally limited to the area surrounding a
particular problem site. Public concern has been voiced in
Jefferson County, where there is potential groundwater
contamination from two inactive landfills—the Leyden and Rooney
Landfills. Methane explosions that killed several people in Adams
County several years ago caused a great deal of local concern.
B.	Regulatory Status
1.	Legal Requirements
a.	Management of inactive landfills is not directly
addressed by the Resource Conservation and Recovery Act
(RCRA). However, if an inactive landfill meets certain
stringent criteria, it can potentially fall under the
Superfund program.
b.	Active landfills which become inactive must comply with
post-closure requirements stated in county permits. The
Colorado Department of Health requires landfill owners
receiving a certificate of designation (CD) from a county
agency to monitor off-site contamination for ten years
following closure of the facility. Because this
requirement has been in place less than 5 years, those
facilities which closed prior to the new requirement are
not necessarily being monitored.
2.	Current Activities
CDH is in the process of developing a Waste Site Inventory
system which would identify inactive landfills. The development of
this system is dependent both on funding and on the availability of
location information. The data system is a long-term project and
may require several years to bring on as an active database.
3.	Public Expenditures
No State or EPA Region VIII dollars were allocated to any
aspect of inactive landfills (other than Superfund dollars) in FY
1988. To date, the Legislature has chosen not to fund a
comprehensive solid waste program in Colorado. As a result, the
conditions of the inactive landfills are not under any review
except whatever limited effort is conducted at the local level.

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C. Possibilities for Further Control
Known problems are being addressed to the extent possible by
Superfund. For other possible problems there is a lack of funding.
The attitude of some local governments is that they, will
address a problem caused by an inactive landfill if and when it
becomes obvious or pressing. The attention and efforts to mitigate
potential harm from methane explosions in the late 70s is a
relevant example.
IV. WORK GROUP FINDINGS
The work group was divided in its opinion as to whether or not
inactive sites pose significant long-term hazards to the Denver
metro area. As a result, it concentrated its efforts on problems
for which more extensive data were available.

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HAZARDOUS WASTE GENERATORS
I.	ISSUE DESCRIPTION
There are approximately 815 generators of hazardous waste in
the metro Denver area. Most of these generators (90%) produce less
than 2,200 lbs/month and are considered small quantity generators
(SQGs). The remainder (10%) produce more than 2,200 lbs/month and
are considered large quantity generators (LQGs). The LQGs produce
more than twice the total amount of hazardous waste than the SQGs,
7,857 metric tons for LQGs compared with 3,255 metric tons for
SQGs .
Mishandling of hazardous waste either by small or large
quantity generators can result in contamination of groundwater,
surface water, soil, or air--posing health risks to nearby
populations.
II.	IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1.	Environmental Strategies Project Analysis
The lack of data on the types and frequency of LQG and SQG
waste management practices make it extremely difficult to quantify
potential risks associated with hazardous waste generators. A
analysis produced the following conclusions:
o For generators in compliance with regulations, the only
significant risks are those posed by short-term storage
of wastes. The likelihood of releases from such storage
is low.
o Facilities not complying with regulations may well pose
significant risks. Releases to air, groundwater or
surface water may be caused as a result of poor storage
practices, discharge to publicly operated treatment works
or illegal disposal. Due to the larger number of
facilities, non-complying SQGs probably pose a greater
hazard than the LQGs.
2.	Other Health Issues
Health risks from hazardous waste generators may result from
improper disposal of wastes, for example into the sewers and other
forms of "midnight dumping". Also of concern are accidental
releases of waste materials. In order to reduce the incidence of
improper disposal, practical alternatives need to be available,
affordable and convenient.

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In reference to accidental releases, if generators follow
emergency response procedures, exposure from such releases is
likely to be short-term and the health risk will be relatively
low. Generators not complying with such procedures can cause
health risks that equal or exceed risks associated with other waste
management facilities.
B.	Economic/Welfare Effects
Most impacts from the migration of hazardous waste
constituents from generation sites are localized in nature.
However, in cases where migration causes widespread contamination
of a city's drinking water supply or other resources, such damage
can dissuade people and business from locating in the area and/or
encourage existing residents and businesses to move elsewhere.
Mismanagement of hazardous waste can lead to fires or
explosions, as well as to health and environmental effects.
Damages can include destruction of buildings, damage to crops and
fisheries, and loss of work hours.
C.	Ecological Effects
Improper management or accidental releases of such substances
can create long-term damage to water resources, vegetation,
wildlife and wetlands.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Public concern about hazardous waste generators is generally
limited to companies which are obvious waste producers, e.g.,
chemical companies. Service businesses, high technology companies,
and small businesses are often overlooked as waste generators.
B.	Regulatory Status
1. Legal
a.	The Resource Conservation and Recovery Act (RCRA)
initially required generators of more than 2,200
lbs/month of hazardous waste to: notify EPA of their
activities; to ship wastes only to certified treatment,
storage, or disposal facilities; and to comply with EPA
regulations regarding the handling and storage of these
wastes.
b.	As set out in the Hazardous and Solid Waste Amendments
(HSWA) of 1984, the federal regulations for hazardous
waste management were modified to bring businesses that
generate more than 220 lbs per month of hazardous waste

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into the regulatory system. Previously, small quantity
generators that generated less than 2,200 pounds of
hazardous waste in a calendar month had been exempt from
most hazardous waste regulations.
2.	Current Activities
a.	The Colorado Department of Health (CDH) is responsible
for implementing RCRA regulations with regard only to
large generators. Regulatory activities for small
quantity generators is handled by EPA pending delegation
of HSWA authority to the State.
b.	CDH issues permits to businesses generating hazardous
waste according to the amount generated per month and
enforces these requirements. CDH also issues guidelines
and public information for use by individuals and
companies producing quantities of hazardous waste less
than 220 pounds.
c.	During 1987 the Colorado Association of Commerce and
Industry (CACI) conducted educational seminars for small
generators on RCRA requirements.
3.	Public Expenditures
Small and large quantity waste generators fall under the
purview of RCRA. The RCRA budget is organized along functional
lines which do not exactly correspond to the specific environmental
problems analyzed by the ESP.
As stated in the FY 1988 STATE EPA AGREEMENT (SEA), the FY
1988 budget for RCRA programs, including those related to
generators and TSDFs (treatment, storage and disposal facilities),
included an allocation of $680,000 to the State of Colorado to be
used for RCRA contract expenditures. This number does not include
the amount EPA Region VIII, itself, spends in Colorado on RCRA
personnel and contracts spent on RCRA programs which are not passed
through the State. In FY88 the State of Colorado allocated
$246,500 (includes cash plus general fund) to RCRA activities.
C. Possibilities for Further Control
The regulatory mechanism is in place but in order to insure
full compliance by all generators, more funding is necessary.
IV- WORK GROUP FINDINGS
The work group was interested in the lack of available data in
regard to the waste management practices of small quantity
generators. The suggestion was made to work with small business
trade associations in an effort to improve both business' and

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policy-makers' understanding of such practices. Once the magnitude
of the problem is more clearly understood, remedial efforts may
need to be increased-

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TRANSPORTATION OF HAZARDOUS MATERIALS
I- ISSUE DESCRIPTION
Proper shipping and tracking of hazardous materials is
critical to protect the public from potentially harmful¦health
risks. An accidental release of such materials during
transportation can affect a large segment of the population, as
well as harm the natural environment.
Hazardous materials include petroleum, chemicals, explosives,
hazardous waste, and other substances. While hazardous waste is
the only type of hazardous material regulated under RCRA, other
hazardous materials make up a larger volume of total hazardous
materials being shipped.
II. IMPACT ASSESSMENT FACTORS
A.	Public Health Issues
1.	Environmental Strategies Project Analysis
The initial Environmental Strategies Project analysis
only looked at the risks associated with the transportation of
hazardous wastes. The results of this analysis have not been
included in this report but are available upon request. In order
to grasp the actual risks associated with the transportation of
hazardous materials, the work group strongly recommended that the
ESP expand its analysis to encompass hazardous materials.
2.	Other Health Issues
The primary concern associated with hazardous materials
transportation is the potential acute health effect from an
accidental release. An acute effect is one which occurs
immediately after an exposure to a harmful substance. Such
effects may be reversible as in the case of a headache, or
irreversible as in permanent lung damage.
B.	Economic/Welfare Effects
Accidental releases of hazardous materials during
transportation may cause fires and long term damage to property.
Economic loss and disruption may also occur from road closure for
emergency response activities. In cases where cities heavily
regulate transportation of materials on local roads, some loss of
business activity may occur.
C.	Ecological Effects
Contamination from transportation spills can cause damage to
nearby vegetation, surface water, groundwater, and air quality.

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III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
A few accidents have heightened the awareness of potential
dangers from hazardous materials transportation. A toxic substance
spill from a train and a freeway incident where a truck carrying
torpedoes overturned, both of which occurred in north Denver, have
increased public concern about hazardous materials being shipped
through the metropolitan area.
Several cities in metro Denver have adopted ordinances
restricting the use of certain urban roadways for the
transportation of hazardous wastes. Public involvement in helping
to determine these routes has been moderate.
B.	Regulatory Status
1. Legal Requirements
a.	In 1974, Congress adopted the Hazardous Materials
Transportation Act (HMTA). The HMTA authorized the U.S.
Department of Transportation (DOT) to adopt rules regulating the
transportation of hazardous materials.
b.	The Department of Transportation (DOT) has issued rules
governing the packaging, marking, and placarding of all
hazardous materials. DOT works with EPA and the Colorado
Department of Health (CDH) in regulating the
transportation of hazardous waste under RCRA.
c.	The Resource Conservation and Recovery Act (RCRA),
Subtitle C, requires transporters of hazardous waste to
register with the EPA, deliver waste only to permitted
treatment, storage, or disposal facilities (TSDFs) using
the manifest provided by the waste generator, and deal
with any waste spills in accordance with EPA regulations.
d.	Recently enacted legislation in Colorado SB 156 (1987)
established statewide regulations for the transportation
of hazardous materials. The law establishes a permit
system and a fee schedule for hazardous material
carriers. It requires the Colorado State Patrol to
designate routes and establishes penalties for deviation
from routes or violation of permit and fee provisions.
It also establishes the Colorado Safety Institute to
train personnel involved in transportation and cleanup of
hazardous materials.
e.	The Colorado Public Utilities Commission administers
regulations regarding permitting of hazardous and
radioactive waste carriers, enforces permit compliance

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and obtains records of insurance compliance.
f.	The Colorado Department of Public Safety (DPS) currently
promulgates routes for hazardous materials carriers- It
provides enforcement and emergency response in
conjunction with local police and fire departments,
initiates emergency response planning activities in
counties and municipalities and inspects nuclear waste
shipments that originate in Colorado. The Colorado State
Patrol, the newly established (1987 S.B. 156) Colorado
Safety Institute and the Division of Disaster and
Emergency Services (DODES) all fall under DPS. Each of
these divisions has a role in reference to this topic.
g.	The Colorado Department of Revenue, Ports of Entry, is
responsible for enforcement of vehicle safety standards
for cargo carrying vehicles. Hazardous material vehicles
are inspected for proper placarding and safety features.
Ports of entry issues trip permits for carriers entering
the State.
h.	The Colorado Department of Highways is responsible for
designating routes for radioactive waste shipments.
Safety and policy analysis is conducted to determine the
best routes.
i.	EPA Region VIII's Hazardous Materials Response Team
responds to spills incurred by hazardous waste
transporters in accordance with responsibilities under
the Superfund Amendments and Reauthorization Act, SARA
Title III.
2. Current Activities
The Interagency Task Force on Hazardous Materials
Transportation is an effort which is intended to provide
coordination and planning among state and local governmental
agencies. This task force has been run out of the Governor's
office since the mid-1970s.
3. Public Expenditures
This "line item" is particularly complex due to the fact that
so many different budgets are tapped to handle transportation
incidents. All of the agencies and divisions mentioned above,
including local fire departments, and in some areas, emergency
response teams are involved. Therefore, it was not possible to
obtain a relevant public expenditures figure for this issue.
C. Possibilities for Further Control
Once decision-makers have a better understanding of the
basics: what is being transported, where, how often, etc.,

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additional control options should become more obvious.
IV. WORK GROUP FINDINGS
After an overview of this topic, the work group decided to
recommend a well coordinated metro-wide data analysis effort which
would, at a minimum, take the following factors into consideration:
current and anticipated hazardous materials transportation routes;
adequacy of emergency response coverage and areas of high and low
population. If integrated and updated, this information could
enhance decision-makers' ability to manage this area of public
policy.

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HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL
FACILITIES—TSDFS
I.	ISSUE DESCRIPTION
There are 13 active and 16 inactive hazardous waste treatment,
storage, and disposal facilities (TSDFs) in the metro-Denver area.
The 13 active facilities manage an estimated 75% of the hazardous
waste generated in the Denver metropolitan area, much of which is
eventually shipped offsite. Nine of the 13 active facilities
manage wastes generated soley by their own operations. The
remaining four active facilities handle wastes from other
generators.
If improperly stored or treated waste migrates off the site,
contamination of drinking water, air or soil may occur.
II.	IMPACT ASSESSMENT FACTORS
A. Public Health Issues
1. Environmental Strategies Project Analysis
o Analytical Approach
The risks associated with hazardous waste releases at TSDFs
were analyzed by modeling the releases under a range of conditions
at a hypothetical facility, and then extrapolating the results to
Denver's existing facilities.
The hypothetical facility was developed because site-specific
data for metro Denver TSDFs were not adequate to assess risks. The
hypothetical facility is a composite of waste, hydrogeologic
conditions, and exposure pathways that could, in theory, exist at
the 29 active and inactive TSDFs in metro Denver.
Standard EPA risk assessment methods and health information
were used in combination with exposure information from the
hypothetical facility to estimate the range of potential risks.
o Information on Human Exposure
A range of exposure conditions possible at metro Denver TSDFs
was considered. The primary pathway evaluated was a release of
organic solvents to a drinking water aquifer.
Risks from contaminated surface water were judged to be less
than the risks associated with contaminated ground water because
most surface water is treated prior to consumption while ground
water often is not.
Exposures to air releases were not considered because of
inadequate data. An estimate of the number of potentially exposed

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people across the study area was developed using local data on the
number of people living around TSDFs in the study area and the
percentage of these people likely to be served by drinking water
from untreated wells.
o Impact on Human Health
The primary objective of the TSDF analysis is to provide
information on the range of chronic human health risks which might
be caused by releases of hazardous substances from metro-Denver
waste management facilities. The upper-ends of the individual and
population risk ranges identify maximum levels that are unlikely to
be exceeded even under worst-case assumptions about waste release,
groundwater transport and human exposure conditions in metro-
Denver .
The range of potential risks from TSDFs could be wide.
Applying worst case conditions, individuals drinking contaminated
ground water over a lifetime could experience a 1 in 100 chance of
developing cancer.
Under more likely TSDF conditions, the risks could be 100 to
10,000 times lower. Because only a small percentage of the
population is likely to drink from affected wells, less than one
additional case of cancer per year would be expected even under
worst case conditions.
Lower bounds represent risks under relatively optimistic
assumptions (e.g., those resulting in low risk) about the quantity
and toxicity of pollutants released and the location and number of
people exposed. In the event that no one is actually exposed,
these lower bounds would overestimate risks. However, we believe
overall that risks are more likely to occur within the predicted
range than at either the upper or lower bounds.
The basis for these risk estimates is exposure to benzene, a
known carcinogen that can also cause non-cancer health effects. It
is important to note that one would not expect to find benzene at
every TSDF.
2. Other Health Issues/Limitations of the ESP Analysis
In reviewing the risk ranges for TSDFs, the reader should
recognize that data and/or resources were not available to analyze
all possible exposure pathways. Our assessment considers only
chronic risks from off-site ingestion of contaminated groundwater.
Chronic exposures to pollutants released to air and surface water
and acute exposures due to accidental releases were not be
considered in this analysis. In general, the risks due to air and
surface water releases are expected to be lower than those posed by
contaminated groundwater.

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B. Economic/Welfare Effects
Widespread contamination of air or water resources by
hazardous wastes not properly treated, stored, or disposed of can
discourage people and business from locating in the area, and
reduce revenues from tourism and recreation.
Releases of hazardous waste constituents into groundwater or
surface water used for human or livestock consumption can have
negative impacts on personal and business income. Airborne
hazardous substances can damage crops, livestock, fisheries, and
other sources of income.
C. Ecological Effects
Improper treatment, storage, or disposal techniques can result
in releases of chemicals into soil, groundwater, surface water, or
air. Such releases can cause long term damage to water resources,
vegetation, wildlife, and wetlands.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
Local residents are often concerned about potential migration
of pollutants from TSDFs. TSDF releases can affect ground water,
air and surface water. In some cases residents believe TSDF's have
the potential to lower property values.
TSDFs causing public concern include Rocky Flats, Rocky
Mountain Arsenal, Martin Marietta and the Denver-Arapahoe Chemical
Waste Processing Facility. The permit issued to Browning-Ferris
Industries to operate a major commercial disposal facility in Adams
County generated a great deal of attention and concern.
B.	Regulatory Status
1. Legal
a.	The Resource Conservation and Recovery Act (RCRA)
requires treatment, storage and disposal facilities
(TSDFs) to obtain a permit from EPA to ensure their safe
operation. Most TSDFs are operating under interim status
pending review and approval of permits by the State and
EPA.
b.	The Hazardous and Solid Waste Amendments (HSWA) of 1984
provided additional authority for corrective action at
TSDFs to remedy past problems. The Land Ban provision
phases in restrictions on land disposal of untreated
wastes.

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2. Current Activities
a.	The Colorado Department of Health (CDH) is responsible
for implementation of RCRA responsibilities for TSDFs,
with EPA's oversight and assistance. Responsibilities
under HSWA have not yet been delegated to the-State. The
State has submitted its HSWA application which is
currently under review by EPA. Colorado is expected to
receive authorization in Summer 1988.
b.	CDH issues site-specific permits for TSDFs specifying the
type of treatment, storage, or disposal activities which
may take place. These permits may be effective for up to
10 years.
c.	CDH is also responsible for reviewing and approving
closure plans of TSDFs, which are required when a
facility ends its operations. In this process, as well
as the permitting process, CDH involves local agencies
and the general public through public review and comment.
d.	As noted in the Superfund issue paper, the Governor has
formed a special citizens task force to monitor Rocky
Flats activities and recommend further cleanup
activities.
3. Public Expenditures
TSDFs fall under the purview of RCRA. As is described in
several other issue papers, the RCRA budget is organized along
functional lines which do not exactly correspond to the specific
environmental problems analyzed by the ESP.
Budget figures for RCRA programs including those related to
generators and TSDFs were quoted in the FY 1988 STATE EPA AGREEMENT
(SEA) as follows. For FY 1988, EPA Region VIII indicated plans to
allocate $680,000 to the State of Colorado to be used for RCRA
contract expenditures. This number does not include the amount EPA
Region VIII, itself, spends in Colorado on RCRA personnel and
contracts spent on RCRA programs which are not passed through the
State.
FY 88 the State of Colorado to allocated $246,500 to RCRA
activities. In addition to some State General Fund money, the
Colorado TSDF permitting program is cash funded by permit fees and
annual operating fees collected by the State.
C. Possibilities for Further Control
The regulatory mechanism for TSDF control exists, however,
full implementation of this program will require increased funding.

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IV. WORK GROUP FINDINGS
The Land Ban provisions and RD&D (Research, Development and
Demonstration) program created under the 1984 RCRA amendments (and
the Superfund program) have given considerable national impetus to
the development of more economic and effective means of .treating
wastes. In light of an interest in promoting local innovation, the
work group discussed the desirability of exploring ways to
streamline the new technology permitting process so that an
entrepreneur who engages in such innovation has a measure of
assurance that a newly developed technology will be permitted under
EPA standards.

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E. ENVIRONMENTAL LEAD EXPOSURE

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ENVIRONMENTAL LEAD EXPOSURE
I. ISSUE DESCRIPTION
Lead toxicity is a prevalent and persistent environmental
health problem. Lead poisoning is known to cause anemia,
neurological disorders, reproductive problems, and other effects.
Recent studies have shown adverse effects at lower blood lead
levels than were previously recognized as harmful. These effects
include decreased mental development in children, hypertension in
adults, and lower birth weights in infants.
Lead in the environment to which humans can be exposed
originates from numerous sources including leaded solder on water
pipes, lead-based paint in older homes, and lead in gasoline.
II. IMPACT ASSESSMENT FACTORS
A. PUBLIC HEALTH ISSUES
1. Environmental Strategies Project Analysis
o Analytical Approach
Several EPA studies have calculated the relationship between
environmental lead concentrations and blood lead levels. The
results of these studies were used in conjunction with data on lead
in drinking water from four Colorado communities, and data on lead
in Denver's air, to estimate 1986 blood lead levels in metro
Denver.
These blood lead levels were then used to predict the
incidence of lead-related health problems.
o Information on Human Exposure
Nationwide information on the relationship between blood lead
levels and lead concentrations in air and drinking water was used
with estimates of Colorado environmental lead concentrations to
predict 1986 blood lead levels in metro Denver.
Information on the age of Denver's housing was combined with
local demographic information to estimate the number of children
that might be expected to experience elevated levels of lead in
their blood as a result of exposure to lead in paint or dust.
o Impact on Human Health
Researchers have documented a variety of adverse health
effects caused by exposure to lead. These include kidney,

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neurobehavioral, and reproductive effects. Of particular concern
are neurological effects in children. Childhood exposures to
levels of lead previously believed safe are now thought to affect
certain cognitive functions as measured by reduced IQ.
The ESP analysis estimated the number of adverse health
effects attributable to exposures to lead in the air, in drinking
water, and in paint. The results indicate that as many as 1,150
children in metro Denver may be at risk from exposure to lead
paint.
The number of effects attributable to lead in air and drinking
water are substantially lower than those attributable to lead in
paint. Furthermore, air and drinking water exposures are expected
to diminish over time as leaded gasoline is taken off the market
and as Colorado's ban on leaded solder used in the plumbing
industry takes effect.
2. Other Health Issues/Limitations of the ESP Analysis
While the ESP analysis of exposure to environmental lead in
metro Denver examined all of the major health issues, there is a
great deal of uncertainty in the results of this analysis.
The uncertainty in the analysis stems from the fact that very
little is known about blood lead levels in the metro Denver
population. Because of this lack of data, blood lead levels had to
be estimated using limited Denver specific information along with
the results of nationwide studies.
B. Economic/Welfare Effects
An EPA analysis of the benefits of reducing lead in drinking
water (Dec. 1986) estimates the net annual monetized benefits to
the nation from lowering the level of lead in drinking water from
50 micrograms per litre to 20 micrograms per litre at approximately
$800 million.
This estimate includes children's medical costs, costs of
children's decreased mental development, savings from fewer heart
attacks, strokes and deaths in adult males, and benefits of reduced
corrosion damage to materials. Scaling this estimate to the metro
Denver population correlates with net benefits of approximately $6
million annually for a similar decrease in the level of lead in
drinking water.
If, as the ESP analysis indicates, and as some area health
professionals believe, the effects of lead-based paint are more
severe than the effects of lead in drinking water, particularly for
young children, the magnitude of these monetized economic and
welfare effects could be significantly higher.

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C. Ecological Effects
Lead in soils can be taken up by plants and enter the food
chain through animals that feed on the plants.
III. ENVIRONMENTAL MANAGEMENT FACTORS
A.	Public Perception/Political Pressure
There is little evidence to suggest that members of the
community perceive exposure to environmental lead to be a serious
problem.
B.	Regulatory Status
1.	Legal Requirements
EPA has an established Maximum Contaminant Level for lead in
drinking water, and no systems in the Denver area are in violation
of this standard. However, because most lead occurs in drinking
water as a corrosion by-product of in-home plumbing, the sampling
method used to determine compliance with the standard does not
indicate actual levels at the tap.
The 1986 Amendments to the Safe Drinking Water Act require
states to conduct a public notification that provides information
on the sources of lead in drinking water, potential health effects
ways to reduce exposure, and information on public water supplies
that are taking measures to address the issue.
Colorado recently instituted a ban on the use of leaded solde
on water pipes, as required by the Safe Drinking Water Act.
Regulations under the Clean Air Act to phase down the amount
of lead in gasoline have been in place since the early 1970's. At
that time, lead levels in gasoline were as high as 5-6 grams per
gallon. Today, leaded gasoline can contain no more than 0.1 g/gal
2.	Current Activities
EPA is in the process of reexamining the Maximum Contaminant
Level (MCL) for lead in drinking water, and is expected to lower
the standard by more than half, and to change sampling requirement
significantly. Initial projections are that some area water
supplies may be out of compliance with the newly proposed MCL.
Some public water supplies in the metro area have distributed
informational pamphlets on lead in their monthly bills to
customers.

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3. Public Expenditures
Personnel in the public water supply sections at both EPA and
CDH are spending substantial amounts of time on the issue of lead
in drinking water. Much of this time is being spent on education.
State employees have produced the public notification document
which will be published in May of this year.
C. Possibilities for Further Control
The ban on lead solder should be effective in reducing lead in
drinking water in the near future. Educating people about the
potential problem and things they can do to reduce their risk of
exposure to lead in drinking water can help minimize problems
almost immediately.
IV. WORK GROUP FINDINGS
The ESP did not convene a work group to examine the
environmental lead issue, however, the drinking water work group
discussed the ESP lead analysis and recommended a comprehensive
sampling effort to better understand human exposure to lead in
drinking water.
In discussions with Advisory Committee members and their staff
prior to the last meeting, several people suggested undertaking a
blood lead sampling effort. This type of effort is needed due to
the lack of data on blood lead levels in metro-Denver.

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