ENVIRONMENTAL PROTECTION AGENCY
ROCKY MOUNTAI4-PRARIE REGION
ACCOMPLISHMENT PLAN
REGION VIII
SOUTH PLATTE RIVER BASIN
DENVER AREA
JANUARY 1972

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ACCOMPLISHMENT PLAN
REGION VIII
SOUTH PLATTE RIVER BASIN - DENVER AREA
JANUARY 4972
DAVID D. EMERY
STRATEGY COORDINATOR
JOHN A. 	
REGIONAL ADMINISTRATOR

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OUTLINE
SECTION	PAGE
1.0 GENERAL	1
2.0	BROAD OBJECTIVES	2
2.1	Water Quality	2
2.2	A1r Quality	3
3.0	SPECIFIC TASKS AND ACCOMPLISHMENT PLANS	4
FOR WATER QUALITY IMPROVEMENT
3.1	Upgrade Classification of the South Platte	4
3.1.1	Hold Negotiations	5
3.1.2	Hold Hearings	6
3.1.3	Develop Public Information Program on the	7
Need to Upgrade Use Classification
3.2	Ensure Adequate Provision for Present and	8
Future Water Needs and Waste Loads
3.2.1	Survey Waste Water Treatment Plants	8
3.2.2	Provide Training and Technical Assistance	13
3.2.3	Expedite Construction Schedules	14
3.2.4	Develop Efficient Utility Management Program	17
3.2.5	Develop Program on Optimizing Water Use,	19
Emphasizing Reduction 1n Water Usage and
Recycling
3.3	Process Fifty Permits	24
3.4	Sample and Monitor Industrial Outfalls and	26
Ambient Stream Conditions
3.5	Hold Enforcement Conference	30
3.6	Issue 180-Day Notices	31
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SECTION	PAGE
3.7	Develop Water Quality Management Plans for	31
the Basin and Metropolitan Regional Areas
3.8	Supplement DRC06 3(c) Planning Activity to	33
Achieve Allied Regional Objectives for South
Platte Basin
3.9	Develop Control Program for Oil and Hazardous	34
Materials
4.0	Specific Tasks and Accomplishment Plans for	37
Air Quality Improvement
4.1	Problems Assessment and Proposed Solutions	37
Relating to Mobile Source Pollutants
4.2	Problems Assessment and Proposed Solutions	39
Relating to Particulate Matter
4.3	Develop Public Information Program Concerning	40
Automobile Pollutants and the Practicality of
Alternative Transportation Svstems
4.4	Contact Members of State Legislature and	43
Impress Needs for Legislation Relating to
Transportation Sources of A1r Portion
APPENDIX A — SUMMARY SCHEDULE
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SECTION 1
GENERAL
The South Platte River Basin - Denver Area has been selected as one
of Region VIII1s highest priority areas for an abatement and control pro-
gram for Fiscal Years 1972 and 1973. Denver 1s the largest metropolitan
area within the Region, exceeds 50% of Colorado's population, and has the
related Industrial and convnerclal waste discharges. In addition, Denver
has severe air quality problems. Heavy automobile use, unfavorable atmo-
spheric conditions, and other conditions such as high altitude are
factors which make Denver a critical air pollution area. This situation
has caused Denver to be one of six cities with the highest national air
Improvement needs.
This Accomplishment Plan addresses the needs of the South Platte
River Basin - Denver Area. Specific tasks and plans of accomplishment
have been developed to set the course for meeting Region VIII's air and
water quality objectives.
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SECTION 2
BROAD OUJLCTIVES
Water Quality
To Improve quality of the South Platte River to permit beneficial
not now provided as follows:
a.	Water quality upstream from Denver will be improved to permit
recreation, including swimming, and drinking water supply
through reduction of fecal coliform levels. Existing fecal
coliform levels will be reduced by approximately 50% to the
compliance level of 100 per 100 ML by December 31, 1973.
b.	Quality of water in the Denver area and downstream to the
Colorado-Nebraska State line will be Improved to permit
drinking water supply and warm water fisheries through reduc-
tion of fecal coliform and through an Increase in the
dissolved oxygen level. Existing fecal coliform levels in
excess of 10,000 per 100 ML will be reduced by 30% below
Greeley, Colorado by December 31, 1972. Fecal coliform levels
1n the entire reach In and below Denver will be brought to
the compliance level of 1,000 per 100 ML by December 31, 1976.
Dissolved oxygen compliance level of 5,0 milligrams per liter
will be met 1n this reach by December 31, 1976 through a
reduction of 40,000 pounds of biochemical oxygen demand per

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day by the end of 1972, and 95,000 pounds of biochemical oxygen
demand per day by the end of 1976.
2.2 A1r Qua!1ty
To obtain compliance with National Ambient A1r Quality Standards 1n
the Denver-Metro area for the three parameters not now 1n compliance as
follows:
a.	Reduce current average annual concentration of particulate
matter by 50% July 1, 1975, to the primary standard of 75 micro-
grams per cubic meter and 70% by June 1, 1977, to the secondary
standard of 60 milligrams per cubic meter.
b.	Reduce average eight-hours concentration of carbon monoxide
by 25% by July 1, 1975 and 50% by July 1, 1977 to meet the
primary and secondary A1r Ambient Standards of 10 milligrams
per cubic meter.
c.	Reduce average three-hour concentration of hydrocarbons and
oxidants by 30% to meet the primary and secondary A1r Ambient
Standards of 160 milligrams by July 1, 1975 and 50% by July 1,
1977.
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SECTION 3
SPECIFIC TASKS AND ACCOMPLISHMENT PLANS
FOR WATER QUALITY IMPROVEMENT
3.1 Upgrade classification of the South Platte.
Purpose of the Plan
To develop a strategy to obtain recreation use classification
upstream from Denver and a public water supply classification for the
entire main stem.
Need for the Plan
Legal rights to the use of water from the South Platte for domestic
supply exists throughout the South Platte Basin. Existing streams classi-
fication does not provide for this beneficial use. The South Platte
upstream from Denver is presently used for body contact recreation and
significant water-orientated recreation projects are under construction
(Chatfleld Dam) or proposed (Littleton Flood Plain Park). Present strean
classification does not provide for body contact recreation, nor 1s such
classification proposed by the State of Colorado.
Attempts to classify the South Platte for domestic water supply, 1n
the opinion of the Colorado State Attorney General, was not accomplished
1n keeping with the necessary administrative procedures. Therefore, the
State Water Pollution Control Commission must again go through the standard
setting process for the South Platte River, and Its tributaries to accom-
plish the desired upgrading.
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3.1.1 Hold negotiations.
Approach and Milestones
The State of Colorado Water Pollution Control Commission by their
early effort to upgrade the South Platte River has demonstrated the desire
to upgrade water quality In this stream. The regional strategy 1s geared
to make an Immediate Impact on the commission to encourage them to quickly
take the steps necessary to adopt the desired classification 1n a manner
that satisfies the procedural requirements of the State and Federal Govern-
ment. This Impact can be best achieved by marshalling the other state
Interests that support the Region's position to convince the Executive
Committee of the urgency of the need for the reclassification and to then
present the matter to the main body of the Colorado Water Pollution Control
Commission. In this regard, EPA has established the following milestones:
1.	Begin Identifying and establishing contact with state agencies
with an interest in water quality of the South Platte River to
enlist support for the proposed upgrading of use classification,
February 1, 1972.
2.	Present position to Executive Committee of Colorado Water Pollu-
tion Control Commission at next scheduled meeting (date 1s
currently unknown, probably late February, 1972).
3.	Adoption of standards, June 30, 1972.
Unresolved Policy Issues and Constraints
The specific accomplishment date of this objective cannot be precisely
Identified due to the nature of the negotiations.
Project Manager: Patrick J. Godsll, Planning Section
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3.1.2 Hold hearings.
Approach and Milestones
Convene Water Quality Standards hearing to upgrade the water quality
standards 1n the South Platte River Basin 1f the State of Colorado falls
to reclassify the South Platte and request the Administrator's approval.
If necessary and timely, this hearing could be combined with the recon-
vened South Platte River Enforcement Conference hearings.
1.	State of Colorado completes their reclassification procedures
and submits changes to Administrator for approval. June 15, 1972.
If this occurs, the need for a standards-setting conference 1s
negated.
2.	If the State of Colorado falls to take action as stated 1n
Milestone 1 above, public notice for convening standards-setting
conference will be published. July 15, 1972.
3.	Standards-setting conference convened. September, 1972.
4.	Changes 1n standards recommended to Administrator. October, 1972.
5.	Approval of changes. January, 1973.
6.	Full Implementation of changes. December, 1976.
Unresolved Policy Issues
Present Colorado law does not recognize 1n-stream uses such as recrea-
tion, fishery, etc., as being beneficial water use. In order to fully
Implement our objectives, this legal viewpoint will have to be changed and
1t 1s planned that the conferees will consider this and recommend appropriate
changes.
Project Manager: Thomas T. Rogers, Chief, Enforcement Branch
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3.1.3 Develop Public Information Program on the need to upgrade use
classification for the South Platte River.
Approach and Milestones
As a first step, EPA must work closely with State and local officials
to develop a meaningful public relations program incorporating the ideas
of all agencies concerned. From a Public Affairs standpoint, the public
must be convinced of two facts: one, the South Platte can be upgraded to
permit drinking water and recreational use; and two, 1n addition to treat-
ment Installation, etc., these uses may be threated 1f they are not legally
protected. A number of suggestions for achieving this follow below:
1.	Encouraging Colorado Magazine to publish a story or stories from
the past, proving that trout fishing once was good In the South
Platte and suggesting that 1t can be again.
2.	Utilizing EPA-Log, the regional publication, outlining in detail
each time what 1s being accomplished In the way of clean-up, who
Is doing the work and obstacles yet to be overcome.
3.	Coordinating programs with citizen, student and youth groups,
publicizing the situation and interesting them 1n the crusade to
upgrade the South Platte. Clean-up or grass planting programs
to be undertaken, accompanied by publicity.
4.	Radio spot saturations, informing the public of current develop-
ments and prospects for the future.
5.	Aiming for domestic and contact recreational uses of the South
Platte 1n time for Colorado's 100th anniversary and the Nation's
b1-centenn1al celebration.
Project Manager: Jack R. Hallowell, Public Affairs Division
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3.2 Ensure adequate provision for present and future water needs and
waste loads.
3.2.1 Survey waste water treatment facilities.
Purpose of the Plan
This plan Involves an evaluation of selected municipal waste water
treatment facilities to assess the needs and direct the regional activities
to effect improved operation and maintenance practices at facilities within
the area addressed by this plan.
Need for the Plan
More efficient operation and maintenance practices of waste water
treatment facilities can provide improved effluent quality. This Improved
effluent quality 1n turn allows an Improvement 1n the quality of the re-
ceiving stream.
Plants will be selected for evaluation based on input from the Denver
Regional Council of Governments (DRCOG), the State Department of Health,
the County Health agencies, EPA's National Field Investigations Center at
Denver, and cities and sanitary districts.
Each facility to be visited will be evaluated to determine the
following Information:
1.	With present facilities and loadings, 1s the operation and main-
tenance adequate to achieve an optimum level of performance with
regard to B0Dg and suspended solIds removal?
2.	Are laboratory control procedures and staffing practices adequate
to maintain a consistently high quality effluent?
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3.	Could operational practices at this facility be applied at other
facilities to improve their performance?
4.	What are the projected loads on the plant and what 1s the
short-term needs for waste water treatment works construction?
5.	How effective are present disinfection practices 1n reducing
bacterial solution (i.e., conform concentration in the effluents
discharge to surface waters)?
6.	Would operation training help to improve performance and thus
effluent quality?
7.	Would other regional resources such as Research and Monitoring,
laboratory assistance, technology transfer Information, etc.,
Improve performance and thus effluent quality?
As a guide to determining this 1nfonnat1on, a standard performance
evaluation questionnaire (FWPCA Form 12) will be utilized at each facility
visited. Results or findings of each evaluation will be reported to the
municipalities or sanitary districts involved and to the Colorado State
Department of Health and other Interested agencies.
The representatives to serve as the three-man field survey team for
EPA are as follows:
1.	Joseph D. Lipps, Manpower Development and Training, Air and
Water Programs Division.
2.	Max Orem, Operation and Maintenance, A1r and Water Programs Division.
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3. Bob Hegg, Operation arid Maintenance, Surveillance and Analysis
Division.
The planned activities, Including arranging survey appointments,will
be coordinated with State offices and with the DRCOG prior to arranging
specific appointments with the various plant superintendents.
Plants have been selected 1n the Metropolitan Denver area for Initial
evaluation. It 1s anticipated that this list will be expanded as the
operation and maintenance evaluation progresses and as more Input 1s re-
ceived by the various agencies Involved.
The following represents the Initial 11st of facilities:
1.	City of Longmont plant.
2.	City of Brighton plant.
3.	City of Englewood plant.
4.	City of Littleton plant.
5.	South Lakewood Sanitary District plant.
Several plants outside of the metro area have been recommended for
evaluation and assistance. However, initial focus will be on Denver-Metro
area. Future efforts will attempt to Include these facilities outside this
area.
Interrelat1onshi ps
A brief summary of the Interrelationships that exist are outlined
below:
1. Colorado State Department of Health.
The State Department of Health has responsibility for operation
and maintenance of waste water treatment facilities within its
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boundaries as well as authority to enter these facilities to make
various Inspections. The State is, therefore, aware of those
facilities which may need assistance and also can assist in gaining
access to these facilities. Therefore, to be successful 1n the
accomplishment plan, will require full cooperation and approval
from the Colorado State Department of Health.
2.	County Health Departments.
Several counties have specifically requested EPA to Inform them
of all our activities that are to be conducted In their county 1n
order that they may plan to have personnel accompany EPA on pro-
posed surveys. Notification of our planned survey activities will
be given to the appropriate counties.
3.	National Field Investigations Center (EPA) at Denver.
The National Field Investigations Center (NFIC) recently com-
pleted a survey of numerous waste water treatment facilities 1n
the Metro-Denver - South Platte area. Although the results of
this survey are not yet published In report form, NFIC can pro-
vide valuable Information concerning the plants 1n the selected
target areas.
4.	Denver Regional Council of Governments (DRCOG).
DRCOG 1s also planning an evaluation survey of the plants 1n the
Metro-Denver area. It has been established, however, that DRCOGls
objectives do not conflict or overlap those Included in this plan.
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It 1s Important to point out that valuable information will be
collected by DRCOG and lines of communication will be established
and maintained throughout EPA's survey to allow a free exchange
of information concerning activities and results.
5.	Metropolitan Denver Sewage Disposal District No. 1.
Many of the plants 1n the area are satellite plants to MDSDD #1.
This, 1n addition to other planned activities, will necessitate
keeping MDSDD #1 well informed of our planned activities.
6.	Cities and Sanitary Districts.
The cities and sanitary districts that operate the various treat-
ment facilities will be kept informed of our planned survey
activities. It 1s anticipated that the State Department of Health
will assist 1n this activity.
Results and Milestones
The results expected from surveylrg wastewater treatment facilities
will be a 11st of those facilities where regional resources can be used to
effect Improved water quality.
Complete the survey of the five selected plants In the metropolitan
area. March 1, 1972.
Complete evaluation of data collected and make recommendations con-
cerning follow-up actions. April 1, 1972.
Project Manager: Stanley M. Smith, Municipal Waste Water
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3.2.2 Provide Training and Technical Assistance.
Purpose of Plan
To develop a program for and Initiate action to provide technical
assistance and training to upgrade operation and maintenance for waste
water treatment facilities.
Need for Plan
The need for the plan will be determined by the Accomplishment Plan
which provides for an Initial O&M survey of facilities and an evaluation
of their operation, maintenance, training, and technical assistance needs.
Approach
Those facilities selected for follow-up assistance will be provided
formal or on-site training. Typical assistance projects will consist of
the following:
1.	Provide formal training to plant operators concerning operation
of wastewater treatment facilities.
2.	Provide on-site training 1n conducting and Interpreting control
tests for the purpose of controlling the plant's operation.
3.	Provide training 1n conducting laboratory analyses so that the
plant's performance can be monitored.
4.	Investigate various unit processes and plant facilities to
determine 1f modifications or different facilities would be
desirable.
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5. Monitor plant performance and report on changes in effluent
quality. Also make recommendation as to operational modes to
be sued, plant modifications that would be of benefit, main-
tenance procedures to be followed, etc.
Following the O&M survey and interpretation of results, a meeting
will be held with the State, DRCOG, and other Interested parties to estab-
lish a priority list of the plants that are to receive follow-up assistance.
This meeting 1s scheduled to be held prior to April 15, 1972. Follow-up
programs will be Initiated by May 1, 1972. Again, these dates are only to
be used as guidelines since the results of the evaluation survey can be
highly variable.
Results
Results expected from this Accomplishment Plan are Improved perform-
ance and effluent quality.
Milestones
No specific milestones can be established since these are a function
of the outcome of the O&M survey.
Project Manager; Stanley M. Smith, Municipal Waste Water Branch
3.2.3 Expedite construction schedules.
Purpose of Plan
To complete a feasibility study of the Metro-Denver Sewage Disposal
District No. 1 program for sewage treatment plant Improvements and determine
1f earlier construction date Is possible.
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Need for Plan
The Metro-Denver Sewage Disposal District No. 1 treatment project
consists of a $20,000,000 Improvement program to increase plant capacity,
upgrade treatment efficiency, and provide for adequate sludge disposal.
The project 1s currently divided Into two parts: a $9,000,000 project and
an $11,000,000 project. A grant offer has been made for the part of the
project with an estimated $9,000,000 cost. An application 1s pending for
the $11,000,000 portion.
Based on the $9,000,000 project, the District is committed to placing
the project under construction approximately 540 days after the grant offer
was accepted, which would be approximately April 15, 1973. Another 540 days
1s estimated as necessary to complete construction of the project which
would be approximately October 15, 1974. It 1s estimated that the
$11,000,000 portion of the project would require the same general schedule
of elapsed time to complete construction and place the project In operation.
Since this plant has considerably more Impact on water quality 1n
the South Platte River than any other plant 1n the metropolitan area, water
quality Improvement 1n the river will be closely related to the date by
which the $20,000,000 Improvement project can be completed. It 1s felt
that a feasibility study might show the possibility of reducing either the
time required to prepare and receive approval of the plans and specifica-
tions or the time required for construction of the project, or both.
At the present time, the District's consulting engineer is working
on the engineering study preliminary to the preparation of final plans
and specifications. Local financing of the project must also be
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accomplished before It can be placed under construction. This Is
complicated by pending Federal legislation and whether or not State
matching grant funds will be available. At the present time a bond
election seems to be indicated to meet local financial needs.
Approach and Milestones
Tender a grant offer to the District for the $11,000,000 portion of
the project by April 1, 1972 with the condition that this portion of the
project be placed under construction no later than the time required for
the first portion of project and with the condition that construction be
completed 1n no less than 540 days after contracts are awarded and 1n
substantially less time 1f possible.
Following completion of the preliminary engineering study, 1t 1s
proposed that a meeting or series of meetings be held with the District,
the District's consulting engineer, and the Colorado Department of Health
to explore possibilities of setting an earlier completion date. Consider-
ation will be given to the following means for reducing the time for
completion of the project:
1.	Reduce the time required for preparation of plans and specifi-
cations, either without Increased cost to the applicant or
with Increased cost.
2.	Reduce the time required for review and approval of plans and
specifications through pre-construct1on meetings between
regulatory agency personnel, District personnel, and their
consultants.
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3. Reduce the time allowed for construction by asking bidders
to submit alternate bids based on different completion dates
and comparing the extra cost for completion dates of less than
540 days against the benefits to be obtained by Improved water
quality.
Project Manager: Stanley M. Smith, Municipal Waste Water Section
3.2.4 Develop efficient utility management program for the Denver public
waste water treatment system.
Need for the Plan
The present water and sewage rate structure of Denver-Metro Sewage
Disposal District No. 1 does not discourage excessive water use and thus,
may contribute to overloadlngs 1n the system, contribute to the need for
larger than necessary treatment facilities, and not provide adequate fin-
ancing for necessary upgrading, replacement, and expansion of the treatment
system.
Approach and Milestones
Conduct a study to address the following major points:
1.	Application of a utility management concept to the waste water
treatment system.
2.	The adequacy of the charges and the Institutional arrangement
of the system for meeting financial requirements 1n operation,
maintenance, upgrading, replacement, and expansion 1n the waste
water treatment system.
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The study will be conducted by contract administered by the assigned
project officer. Coordination 1s necessary between the Planning, Water
Supply, and Municipal Waste Water Sections of the A1r and Water Programs
Division. External coordination 1s necessary with the Denver Regional
COG 3(c) project and the Denver Metropolitan Sewage Disposal District No. 1
to ensure Implementation of study findings.
The study will provide a financing system capable of meeting the
present and future waste water treatment needs. Such a financing system
would incorporate the Federal, State, local, residential, Industrial, and
commercial responsibilities for waste water loadings, growth, and up-
grading into a revenue-producing and capital-raising arrangement.
Rate structures geared to users' loading should result 1n a reduc-
tion 1n total loadings on the treatment system, thereby reducing immediate
overloadings and future plant requirements.
The following milestones are incorporated 1n the plan:
1.	Meet with Denver Metro and 3(c) project manager to discuss on-
going and pending utility management studies. January 21, 1972.
2.	Determine required contract needs to supplement ongoing and
pending studies. March 1, 1972.
3.	Discuss EPA contract scope with Metro Interests and finalize
request for contract proposals. March 15, 1972.
4.	Select contractor. May 15, 1972„
5.	Initiate contract. June 1, 1972.
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6.	Complete study. November 1, 1972.
7.	Present results to Denver Metropolitan interests and negotiate
for adoption of results. December 1, 1972.
Project Manager: Patrick 0. Godsll, Planning Section
3.2.5 Develop program on optimizing water use, emphasizing reduction In
water usage and recycling.
Purpose of the Plan
To decrease water use and Institute an effective reuse program, so as
to decrease future water diversions.
Heed for the Plan
Denver's annual per capita water use 1s about 225 gallons per day.
This Is higher than the national average but 1s not Inconsistent with
other municipalities 1n Region VIII.
About the only large Industrial influence on Denver water usage 1s
the Public Service Company's plant, which uses large quantities of water
for cooling purposes. Therefore, most of the high water use 1s due to
domestic uses, lawn watering and landscape irrigation, especially during
the summer and fall months.
Another important factor is that only 33% of Denver's water connec-
tions are metered. Generally* unmetered accounts show larger water use
than those that are metered because of the lower "flat rate" structure.
The experience has been that once meters are installed the water use goes
down.
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Even 1f metering and water conservation efforts realized significant
decreases in water use, they would rot offset the burgeoning K & I demands
of the projected population and Industrial growth for the Denver-Metro area.
An additional source being extensively studied by the Denver Water Board Is
water reuse. However, based on the Intensive studies being conducted at
Lake Tahoe, Windhoek, South Africa and Dallas, Texas, it will be some time
before reclaimed wastewater 1s used directly for domestic purposes because:
1.	Much better methods for sampling and testing are needed for
virus. Viral diseases such as Infectious hepatitis are quite
serious and the etiological agents of these diseases have been
found 1n highly treated wastewaters.
2.	More research must be done on the buildup of trace organics and
Inorganics, Including carcinogens and toxic synthetics such as
polychlorlnated blphanyls.
3.	The reliability of wastewater reclammation plants to consistently
produce a quality effluent 1s br?1ng questioned due to faulty
maintenance and Improper operation.
In view of these public health considerations, this Agency must take
the stand that the use of reclaimed wastewaters for public water supply
purposes should be deferred until research and development demonstrates that
such use will not endanger the health of the public and adversely affect
the potability of the water supply.
However, domestic use of water (i.e., drinking, bathing, dishwashing)
is actually a small part of a municipality's total water requirement.
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Definite possibilities do exist for the use of reclaimed water by those
Industries which do not require a high quality process water and for such
uses as landscape Irrigation on public parks, golf courses and freeways.
The Denver Water Board has recognized these possibilities and 1s
currently conducting an 1n-depth study of the reuse situation. This study
Involves a wastewater reclarrmatlon pilot plant, an evaluation of where
the reclaimed water could be used and how the public would accept such a
concept.
Approach
Optimizing water use 1n the Denver area will be a laborious task.
First, reliable water use data will have to be gathered 1n order to deter-
mine where the major efforts should be directed. Therefore, enlisting the
support of the water utilities 1s all Important. On the basis of the data,
public information programs could be directed toward saving water by better
lawn watering and 1n-the-home practices. Tips on optimum lawn watering
rates and frequencies will be developed with the assistance of the county
extension service. The beneficial effects upon the lawn from proper
watering (deeper rooting, less Insect Infestation, etc.) should be stressed
in addition to the economical and ecological benefits. Eliminating waste
1n the home 1s much harder to accomplish* but tips could be developed on
how to save water 1n everyday washing, bathing, etc.
The Denver-Metro area has many parks, public golf courses and green
belt areas which require extensive watering during the summer. These are
for the enjoyment of the public and there would certainly be an outcry 1f
they were allowed to burn up. However, water savings could be gained if
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tighter controls were used. Cooperation between the water utility and
the respective city parks department is essential in working out a proper
watering schedule. The approach would be to set up a trial meeting be-
tween the two (with the extension service Involved) to explore the
possibilities of cutting down on water use. If successful, other meetings
could be held.
The Denver metering policy will be reviewed. The Water Board will be
urged to Inaugurate a program to reach near 100% metered connections. (Any
changes which this Agency might recommend 1n the metering practices would
not be binding on the utility since there 1s no legal basis to do this.)
Water reuse 1s being studied for implementation 1n the Denver area
during the 1980's. Any public Information program will be coordinated
with the Denver Water Board. The purpose will be to Illustrate to
Industry and the public why reuse 1s necessary, what types are being
considered and what effect this will have on them.
Milestones
The following milestones are incorporated 1n the plan:
1.	Contact state and local health departments, Denver Regional
Council of Governments and water utilities to explain water
optimization plan. February 5, 1972.
2.	Review detailed water usage data of the various billing cate-
gories, such as single residences, parks, industrial, commercial,
and wholesale accounts. Detailed data would also need to be
reviewed from sewage treatment plants as to input flows to be
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able to determine consumptive and non-consumptive water use when
compared with data obtained from the Denver Water Board. March 1,
1972.
3.	Meet with the Denver Water Board to discuss ways of optimizing
water usage and how an Information program could be mutually
beneficial. Gaining their assistance and support at this stage
Is critical. March 15, 1972.
4.	Develop a public Information program on the basics of reducing
water usage and possible ways of reuse. June 1, 1972.
5.	Continue to coordinate with the Denver Water Board and assist
them with their program of public and Industrial acceptance. To
make available to them any EPA research results relevant to water
reuse.
Unresolved Policy Issues
The Water Supply Branch does not have sufficient staff to accomplish
this mission as higher priorities exist, namely (1) the Interstate carrier
water certification program, (2) the state evaluation program, and (3) the
municipal water supply Inventory. To accomplish this program would mean
minimizing something else, or, conversely, the Water Supply Program needs
more professional staff. A decision needs to be made to resolve this
dilemma.
Project Manager; Albert V. Soukup, Water Supply Branch
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3.3 Process 50 permits.
Purpose of the Plan
This plan 1s to Identify and describe the role and accomplishments
the Permits Branch 1s planning as part of the South Platte River Basin
strategy to reduce the wastes discharged to the South Platte River. Waste
water flows and concentrations will be reduced through the implementation
of the Permit Program by setting special conditions in each permit that
will require Industries to meet water quality standards and to discharge
effluents that have received no less than the equivalent of secondary
treatment. In many cases, Industries will be placed on Implementation
schedules that will extend for one year or more.
Approach
The work will be carried out principally by the Permits Branch of
the Enforcement Division, but with the aid of the Surveillance and Analysis
Division, Management Division (Computer Branch), and A1r and Water Programs
Division (Planning Section). It represents an ongoing effort by the
Processing and the Engineering Sections 1n which all of the work Items
Included 1n the milestones move forward simultaneously.
Inspections In the Denver SMSA will be carried out by the Surveillance
and Analysis Division and coordinated with the Colorado Water Pollution
Control Commission, Denver County Health Department, Tr1-County (Adams,
Arapahoe, and Douglas) Health Department, and the Jefferson County Health
Department. Management Division support 1s planned for such Items as up-
dating and Implementing computer programs, key punching data, etc. Water
quality standards, metropolitan planning outputs, and systems analysis work

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are expected from the A1r and Water Programs Division.
Milestones
The following milestones constitute the Permits Branch's plan of
action that will, 1n effect, reduce the Industrial waste discharges to
the South Platte River and aid 1n upgrading the quality of the water. It
1s estimated that the special conditions incorporated 1n the permits will
effect reductions of BOD discharged to the river of 45,000 lb/day by
December, 1972 and 65.000 lb/day by December, 1976.
1.	Processing of permit applications 1n the Cache La Poudre and
St. Vraln Creek subbaslns completed. January 15, 1972.
2.	Inspections in the Denver SMSA for the purpose of Identifying
uninformed or non-complying Industries completed. March 1, 1972.
3.	Completed applications obtained for all significant Industries.
March 1, 1972.
4.	Requests for state certification completed for all significant
Industries. March 1, 1972.
5.	Interim effluent monitoring plan developed for the major
industries, April 1, 1972; plan finalized on July 1, 1972.
6.	Technical reviews of applications from significant Industries 1n
South Platte River Basin completed; special permit conditions
set to meet water quality standards, secondary levels of treat-
ment, planning and Institutional requirements, and water quality
25

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criteria set forth by the Bureau of Sport Fisheries and Wildlife
and coordinated with state departments of health; recommendations
to Corps of Engineers completed. June 1, 1972.
Unresolved Policy Issues
In a recent court decision, a Federal judge concluded that permits
could not be Issued for Industrial wastes discharged to non-navigable
streams and for discharges to navigable streams, unless an environmental
Impact statement precede Issuance of each permit. Both facets of this
decision could have far-reaching impacts on the South Platte River, a
non-nav1gable stream.
Under existing policy developed between the Administrator and the
House Agriculture Committee, the Permit Program has been constrained with
regards to Its applicability to feed lot operations. Only those feed lots
having more than 1,000 animal units and having man-made point discharges
of wastes presently fall under the Permit Program. The number of animal
units criteria 1n this policy removes about 90% of the Basin's feed lots
from the Refuse Act authority and the point-discharge stipulation removes
most of the remaining large operations that have diffuse discharges and
cause water quality problems 1n the South Platte River Basin.
Project Manager: B. David Clark, Permits Branch
3.4 Sample and monitor industrial outfalls and ambient stream conditions.
Approach
Review water quality data collected along the South Platte River and
Its tributaries to determine existing quality and Identify sources of
26

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contaminants. Field studies will be conducted on reaches of the main stem
and tributaries for which sufficient data are not available. Inspections
of industries will be conducted to ensure full compliance with the Permits
Program. Where necessary, Industrial outfalls will be sampled to determine
quality characteristics and their Impact on receiving waters.
Milestones
1.	Existing water quality of the South Platte River and Its tributaries
will be determined from the Division of Field Investigations report on
the 1971 water quality Investigation 1n the South Platte River Basin,
STORET data, and other pertinent sources. Although all the water para-
meters for which data are available will be sunmarized and displayed 1n
appropriate graphical arrays, the parameters of critical Importance are
total and fecal conform bacteria, dissolved oxygen, biochemical oxygen
demand (BOD), and nutrients. The Surveillance and Analysis Division will
encourage and provide support to other governmental agencies conducting
monitoring activities In the Basin to place their past and any future data
1n the STORET System. February 15, 1972.
Project Leader: Lester D. Sprenger
2.	In accordance with the recommendations of the Permits Branch,
Enforcement Division, Inspections of suspected Industries will be carried
out to determine compliance or the lack thereof. Effluent studies will
be conducted 1n those cases where the company-furnished data on effluent
characteristics are Incomplete or suspect.
27

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This activity was initiated in December, 1971, and will be completed
by February 1, 1972. By January 15, 1972 fifty-eight industries had been
inspected and one field study completed (Allied Chemical's Jamestown Mine-
discharge to Little James Creek).
3.	Coincident with Milestone 1 (above), water quality data will be
reviewed to Identify the areas of the South Platte River and tributary
streams for which the available Information 1s Inadequate. Correspond-
ingly, a field Investigations program will be designed, describing the
time schedule, sampling locations, and the appropriate parameters for
fully describing existing quality and sources of contaminants.
One area of primary concern will be the South Platte River upstream
from Denver. In order to Implement the objective of achieving a 5056
reduction 1n fecal conforms, a field study will be necessary to determine
the primary source--effluents from municipal plants, agriculture, or
unreliable sampling and analysis procedures. March 1, 1972.
Project Leader: John E. Hardaway
4.	Commencing on or about March 1, field studies (1f necessary) will be
started by the Surveillance and Analysis Division to provide the necessary
analytical data. Although it is possible that the Surveillance and Anal-
ysis Division may be able to meet all existing commitments with judicious
scheduling of sample analyses, the need to obtain assistance from one of
the two national enforcement groups (DFI--Cincinnati or Denver) 1n order to
meet all Regional commitments cannot be totally discounted. June 1, 1972.
Project Leader: John R. Tilstra
28

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5.	A comprehensive report will be prepared wherein data obtained from
the Field Investigations program, as well as pre-existing information,
will be formalized 1n appropriate graphical and statistical arrays to
describe the current water quality, sources of contaminants, and the
impact of Industrial and municipal outfalls on receiving waters. July 1,
1972.
Project Leader: John E. Hardaway
6.	The existing monitoring program for the South Platte River Basin
will be upgraded as necessary to determine the success of the South Platte
water quality Improvement strategy. This will be a coordinated and mutu-
ally cooperative study with the State of Colorado.
Incoming data from the developed monitoring program will be received
and pollution alert notices forwarded to the Enforcement Division for
action on follow-up investigations by the Surveillance and Analysis
Division. By January 15, 1972, four such notices 1n the Basin had been
Issued. July 1, 1972.
Project Leader: Lester D. Sprenger
Project Manager: John E. Hardaway, Surveillance and Analysis Division
3.5 Hold Enforcement Conference.
Approach
Reconvene South Platte River Enforcement Conference to present the
report of the 1971-1972 water quality survey and set future goals for
future improvements in water quality.
29

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Milestones
1.	Complete field survey by DFI-DC. January, 1972.
2.	Complete draft of report. March 30, 1972.
3.	Forward final survey report to conferees for review. May 1, 1972.
4.	Publish the public notice for reconvening the conference. May 30, 1972.
5.	Reconvene the conference. June 27, 1972.
6.	Administrator approval of the conferees recommendations. September 1,
1972.
7.	Begin Implementation of the conferees recomnendations. Septen&er 15,
1972.
Project Manager: Thomas T. Rogers, Chief, Enforcement Branch
3.6 Issue 180-day notices.
Approach
The following enforcement actions will result 1n an upgrading of the
water quality 1n the South Platte River below Denver.
Milestones
1.	Issuance of 180-day notice for violation of Nebraska and Colorado
Water Quality Standards to Great Western Sugar Company Refinery, 0v1d,
Colorado. March, 1972.
2.	Meet with company officials. April, 1972.
30

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3.	Convene public hearing in Denver. May, 1972.
4.	Adequate waste treatment facilities 1n operation which reduce BODg
load to South Platte River by 16,000 lb/day. October, 1972.
5.	Water quality 1n the South Platte upgraded to comply with fecal
coHform criteria of 1000/100 ml and D.0. criteria of 5.0 mg/1 in a
30-m1le reach downstream - 0v1d, Colorado. October, 1972.
6.	Issuance of a 180-day notice for violation of Colorado Water Quality
Standards to Great Western Sugar Company Refinery, Greeley, Colorado.
March, 1972.
7.	Meet with company officials. April, 1972.
8.	Convene public hearing 1n Denver. May, 1972.
9.	Adequate waste treatment facilities on line which reduce B0D5 load
to the Cache La Poudre and South Platte Rivers by 17,000 lb/day.
October, 1972.
10.	Reduction of the present hi(jh collform levels 1n the Cache La Poudre
and South Platte Rivers by approximately 50%. October, 1972.
Project Manager; Thomas T. Rogers, Chief, Enforcement Branch
3.7 Develop water quality management plans for the South Platte River
Basin, the Denver SMSA, and the Larimer-Weld Counties regional planning
areas as required by 18CFR601.
31

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Purpose of the Plan
The metropolitan plan for Metro Denver will be completed by the
DRCOG 3(c). A regional plan will be developed for Larimer and Weld
counties under the direction of the Larimer-Weld Counties Planning Com-
mission. The Basin plan will be formulated by the State Department of
Health, Water Pollution Control Division. Regional assistance through
direct personnel and by appropriate planning grants will be utilized.
Approach and Milestones
1.	Assist State and Larimer-Weld Counties Planning Comnlsslon In develop-
ing work plans for achieving basin and regional planning. Underway.
2.	Determine resource requirements needed to assist State and Larimer-
Weld Counties Planning Comnlsslon In developing basin and regional plan.
April 1, 1972.
3.	Commence Intensive assistance to State and Larimer-Weld Counties
Planning Commission 1n support of basin and regional planning efforts.
May 1, 1972.
4.	Complete basin and regional plans. July 1, 1972.
Unresolved Policy Issues and Constraints
State and local planning jurisdictions do not have resources to meet
rigid accomplishment date. At present* EPA does not have adequate re-
sources to assure meeting the rigid accomplishment date.
Project Manager: Patrick J. Godsll, Planning Section
32

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3.8 Supplement DRCOG 3(c) planning activity to achieve allied regional
objectives for the South Platte Basin.
Purpose of the Plan
The planning grant activity now underway for the Denver SMSA 1s
limited 1n Its ability to achieve all Region VIII objectives for the
metropolitan area. Early review indicates that areas of work allied to
the DRCOG 3(c) work program which requires Region VIII supplemental re-
sources Include:
1.	Development of effluent standards for all discharges 1n the
study area.
2.	Establishment of the location and responsible party of all
Industrial discharges within the stucty area.
3.	Development of a waste allocation model for the South Platte
River Basin.
Approachand Milestones
A regional task force will be developed to provide continuous liaison
between Region VIII and DRCOG.
1.	Assign Regional Liaison Officer. January 7, 1972.
(George Hartmann, Planning Section)
2.	Identify Regional Task Force for technical review of DRCOG 3(c)
planning study. January 12, 1972
3.	Convene meeting of task force. January 17, 1972.
33

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4.	Task force meeting with DRC06 3(c) consultant. By January 28,
1972.
5.	Based on task force evaluation of 3(c) study and meeting with
consultant, prepare report on supplemental resources required to
achieve allied Region VIII objectives.
6.	Implement work plan to achieve results of milestone 5. Febru-
ary 15, 1972.
Project Manager: Patrick J. Godsll, Planning Section
3.9 Develop Control Program for 011 and Hazardous Materials.
Purpose of the Plan
To protect the water quality and prevent damage to beneficial uses
1n the South Platte from spills of pollutlonal materials Into the South
Platte and Its tributaries.
Need for the Plan
Spills of pollutlonal materials have been experienced in the past.
These have caused problems at water treatment facilities, have inter-
fered with aesthetic enjoyment of the streams and undoubtedly have had a
detrimental effect on aquatic life. As abatement and control measures
are taken to upgrade municipal and Industrial effluents, periodic spills
could have a more dramatic effect on stream biota and other legitimate
uses and could largely negate the benefits from significant Investments to
Improve effluent quality.
34

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Approach and Milestones
Two approaches are being pursued. The first 1s the development of
a mutual aid group, consisting of Federal, State, and local government
agencies and companies 1n the area. This group will develop plans for
notification and reaction to emergency spills, train personnel, and main-
tain equipment which will be able to respond to spills immediately with
the capability of containing the spilled material. These groups will
develop, within the group or by outside assistance, the capability of
removing the spilled material, or of treating 1t so as to negate its
effect on the environment.
The second approach 1s the development of contingency plans 1n the
South Platte Basin. The procedure to be followed will vary, depending on
whether the potential hazard relates to a discharge for which a Refuse
Act Permit 1s required.
Where a permit 1s required, the application will be reviewed for
Installation of "fall-safe" systems to avoid spills and accidental dis-
charges. Permit conditions wIM be developed requiring adequate controls
where Indicated.
Where hazardous materials are stored, warehoused, or otherwise not
associated with a discharge for which a Refuse Act Permit is required, an
Inventory of the locations and quantitites of such materials will be
developed cooperatively with the State, DRCOG, other governmental entities
and private Industry.
35

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Milestones
The following are milestones in the implementation of the plan:
1.	Development of a Mutual Aid Group or groups.
a.	Primary contact, February 15, 1972.
b.	Formation of group, 1st meeting - May 1, 1972.
c.	Basic development of group, contingency plan, obtalnment of
equipment and training of personnel - May 1, 1973.
2.	Contingency plan from non-d1scharg1ng facilities.
a.	Inventory started, March 1, 1972.
b.	Primary sources contacted, June 1, 1972.
c.	Most, 1f not all, sources contacted, October 1, 1972.
d.	Plans received from primary sources, September 1, 1972.
e.	Investigation of primary sources, December 1, 1972.
f.	Plans received from most or all sources, December 31, 1973.
g.	Investigation of all other sources, March 1, 1973.
Unresolved Policies on Issues
For hazardous materials not associated with a discharge for which a
Refuse Act Permit 1s required, authority to obtain an Inventory of materials
will presumably rest on the basic right of the State to act to protect the
health and welfare of citizens of the state. There may be some question as
to whether a contingency plan can be required under present state legal
authority. If such plans can be requested only on a cooperative basis,
considerable cooperation by Industry can still be expected.
Project Manager: Richard M. Jones, Surveillance and Analysis Division
36

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SECTION 4
SPECIFIC TASKS AND ACCOMPLISHMENT PLANS
FOR AIR QUALITY IMPROVEMENT
4.1 Problems assessment and proposed solutions relating to mobile source
pollutants.
Purpose of the Plan
Improvements in air quality resulting from the Federal Motor Vehicle
Emission and Fuel Standards Program will not be sufficient to obtain
compliance. Changing the mode of commutes, transportation, and emission
controls on existing automobiles may be needed to achieve the standards for
these associated pollutants. It is anticipated that the State Air Pollution
Control Implementation Plan, submitted by January 30, 1972, will need
revisions concerning the aforementioned problems.
Approach and Milestones
a. Problem Assessment.
1.	Report on existing information concerning possible increased suscepti-
bility of people 1n Denver to pollutdnts. It has been stated at various
public meetings and in the newspapers that because of Denver's altitude,
people are more susceptable to pollutants and further, that the Federal
standards are not sufficiently protective of the people's health.
March 1, 1972.
2.	Report on existing information concerning effectiveness of Federal
Motor Vehicle Program as it applies to Denver. Because of Denver's
altitude, effectiveness of controls may differ from that at sea level.
April 1 , 1972.
37

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3.	Report on the reduction in air pollution which can be anticipated
from application of the Federal Emission Standards for Moving Sources.
Estimations 1n the State Plan were made assuming some control achieve-
ments as those obtained at sea level. May 1, 1972.
4.	Report on the reduction in air pollution which might result from a
State Motor Vehicle Inspection emission program. June 1, 1972.
5.	Report on the effectiveness and applicability of various transpor-
tation control options for reducing pollutants in Denver. July 19, 1972.
6.	Complete control strategy as needed for revision of State Air Pollution
Control Implementation Plan. August 1, 1972.
b. Proposed Solutions.
1.	Regularly scheduled meetings (i.e., monthly) with the State Air Pollution
Control Agency and Commission to inform them of EPA activities and to keep
abreast of their activities in the area of mobile source pollution. March-
September 1972.
2.	Regularly scheduled meetings with appropriate State and/or local trans-
portation agencies to inform them of EPA needs and to stimulate their
participation 1n traffic management for air pollution control purposes.
March-September 1972.
3.	Develop and implement a public Information program to focus attention
on automobile pollutants, mass transportation, and public acceptance of
changes in mode of commuting. This activity will include a series of
newspaper articles in the Sunday Environmental Section of the Denver Post,

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radio, and television spot announcements, educational television spot
announcements, educational television programs, and billboard and
"car cards" in buses. April 1972. (See Section 4.3)
4. Impact the state, county, and city legislation changes needed to
Implement control strategies which involve either restriction of use of
the automobile or promotion of mass transit systems. (Continuing.)
Project Manager: Dale Wells, Air Quality Section.
4.2 Problems assessment and proposed solutions relating to particulate
matter.
Purpose of the Plan
Controlling of stationary point source emissions and other conven-
tional control techniques (open burning, etc.) will not result in
achievement of the secondary standards for particulate matter. It is
anticipated that the State A1r Pollution Control Implementation Plan
will need revisions concerning control of particulate matter pollution.
Road dirt and other fugitive dusts are probably causing enough particulate
pollution to make the secondary standard unattainable by conventional
control techniques.
Approach and Milestones
1.	Review and report on adequacy of State Air Pollution Control Imple-
mentation Plan to achieve the secondary standards. March 1, 1972.
2.	In conjunction with the State and local agencies, prepare report on
most probable sources of uncontrollable particulate pollution. April 1, 1972.
39

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3.	Report on identifiable measures which can be implemented to eliminate
these particulates. May 1 , 1972.
4.	Complete control strategies as needed for revision of State Air
Pollution Control Implementation Plan. June 1, 1972.
Project Manager: Fred Longenberger, Air Quality Branch
4.3 Develop public Information program concerning automobile pollutants
and the practicality of alternative transportation systems.
Purpose of the Plan
A totally new public Information program 1s needed to focus attention
on automobile pollutants and mass transportation. The "Life...Pass It On"
campaign has been extremely effective, not only 1n Region VIII, but also
1n other EPA regions as well. However, the "Life...Pass It On" approach
1s positive, non-threatening, and fairly subtle. Because of the severity
of Denver's air pollution problem, a new direction is needed.
Approach
The PIO staff proposes an independent new concept (i.e., theme) to
hang a public information campaign around. We would like to Initiate a
dramatically different approach in headlines, copy, and visuals, and new
avenues of publicity not previously used.
The theme particulars have not been thoroughly worked out yet. But,
we feel the theme should be action oriented, have a sense of urgency about
1t, and be a "hard" rather than "soft" approach. It should also, in this
particular instance, be extremely factual (as opposed to editorial) since

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the statistics concerning Denver's air pollution problem are so strong --
1n the sense that they can "sell" the public on action.
We are thinking in terms of a headline like "GET DENVER OUT OF THE
BIG 6." This headline is filled with impact words, offers an action,
and is easy to build an entire campaign around. This headline is also
easy to attach to subheads to "GET DENVER OUT OF THE BIG 6."
a.	A1r Pollution is darkening out lives.
b.	Take a friend to work today.
c.	Walk for clean a1r.
We have not used newspaper space in any of our previous campaigns:
Now 1s the time. The space can be donated by not only the Post and News,
but also by the many weekly and community papers in the Denver area.
This concept also lends itself well to billboards and "car cards"
space in or on buses and taxis.
Mr. Green and key staff meirtoers should use the dual-fuel car as often
as possible. Excellent press coverage can be achieved with this idea.
A group of :05 and :10 radio messages used as PSA station IDs is
proposed. We are certain to get good mileage out of PSA's with these
lengths.
We are also thinking along the lines of a weekly newspaper column
dealing specifically with Denver air. The column would be run in the
Sunday Environmental section of the Post as well as the smaller weeklies
1n the area. The column would be internally created and submitted to the
papers on a regular basis.
A series of hard news stories would supplement this effort.
41

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The NBC station here has been approached about running an air
pollution segment in their nightly weather broadcasts. This would
involve a stationary camera and time-lapse photography.
The entire campaign would reach its apex with a city-wide eco-day.
EPA would act as coordinator of all the local environmental groups.
Grade, junior, and senior high schools would participate by devoting
fifteen minutes of every class hour to the Denver air problem. Work-
shops, forums, and panel discussions would back up this effort. Various
environment groups could provide speakers.
And, on this particular day, we would put a real push on mass
transportation with newspaper, radio, and TV PSA's exhorting people to
take a friend to work, walk for clean air, ride the bus, or a bike.
Environmental groups would sponsor an open-to-the-public eco-forum,
and some "names" would be attracted enough to participate. Day-long
coverage by the local educational TV station could be arranged. The
public that wished to participate but was unable to attend 1n person,
could sponsor a neighborhood "watch-1n, phone-1n" from their neighborhoods -
several neighbors get together and call 1n questions to the panel.
Eco-day would coincide with the review of the Colorado Implementation
Plan by Air and Water and the Congressional Liaison's efforts to work with
the State legislature concerning new air legislation.
Simultaneously, we would add a new dimension to our newspaper campaign
with a questional're concerning Denver air. A headline like "Who Is
Responsible for Denver's A1r Pollution Problem? A Quiz for the Concerned."
The questional re would be answered by the reader, checked against the

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correct answers given 1n the ad, clipped, and mailed to the State
legislators. This would give an accurate reading of the public atti-
tudes, point out where additional environmental education 1s necessary,
and, most Important, put pressure on the legislature for workable air
ordinances.
A spur campaign aimed directly at business and industry is a
headline like "CLEAN AIR IS GOOD BUSINESS," stressing tax breaks, lower
cost ration, good public relations, and general aesthetics.
This entire campaign would be the first city-wide effort in Denver
dealing strictly with air. We can reach virtually every segment of
the population, and we will be reaching them through a variety of media.
The tremendous momentum built up by this program would, hopefully, result
not only 1n Increased awareness but real affirmative action taken by every
Individual in the community.
4.4 Contact members of state legislature and Impress needs for legislation
relating to transportation sources of air pollution and environmental
legislation.
Approach and Milestones
As a matter of legislative history, the Colorado legislature meets
every year but with different rules. During the general sessions, held
on the odd years, the legislature 1s open for any bill sponsored by one
or more members of the legislature. During the short sessions, held on
the even years, the only items which may be considered by the legislature
are those items which fall 1n categories contained 1n the Governor's Call.

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The Colorado legislature went into session on January 5, 1972
at 10:00 a.m. for the so-called "short session."
The first section of the Governor's Call for the 1972 legislative
session contains thirty-three items specifically requested by the
Governor.
1.	Support the passage by the Colorado legislature of the Colorado
Environmental Policy Act. In connection with this legislation, specific
meetings with the Speaker of the House, Majority Leader of the House,
Majority Whip of the House, Minority Leader of the House, Minority Whip
of the House, Chairman of House Conmittee on Environment, Chairman of
Senate Committee on Environment, Majority Leader in the Senate, and
Minority Leader in the Senate. By March 15, 1972.
2.	Meet and consult with most influential menters of State House and
Senate to obtain sponsorship of proposed legislation for presentation at
the open general session commencing approximately January 9, 1973. To
assist the legislative assistant in the Governor's office 1n preparation
of meaningful and effective legislation in the fields of water, air, and
solid waste abatement. By June 1, 1972.
Project Manager: Dean Norris, Congressional and Intergovernmental
Relations.
44

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APPENDIX A
SUMMARY SCHEDULE

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p
PROJECT AND PROJECT MANAGER
1972
JAN FEB MAR APR MAY JUN JUL AUC SEP OCT NOV DEC
1973 1974
1976
UPGRADE CLASSIFICATION OF THE SOUTH PLATTE
Begin contacc with Interested State agencies
Present position to Colorado Water Pollution Control Commission
State reclassifies river, and standards are adopted
If State of Colorado falls to take action:
Public Notice for convening Standards Conference
Standards Setting Conference
Changes in Standards recommended
Approval of Changes
Implement Changes (fully)
PATRICK J. GODSIL - A&W
1
29
30
15
lxx
12 xx
Begin public Information program to express the need for
upgrading the classification of the South Platte River.
JACK R. HALLOWELL - PAO
29
f ENSURE ADEQUATE PROVISION FOR PRESENT AND FUTURE WATER NEEDS AND WASTE LOADS
to
Survey Waste Water Treatment Plants
Complete 0f
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ENSURE ADEQUATE PROVISION FOR PRESENT AMD FUTURE
WATER NEEDS AND WASTE LOADS - cont'd
Develop Efficient Utility Management Program for the Denver Public
Waste Water System
Meet with Denver Metro and COG Project Manager -
Discuss Utility Studies
Determine contract needs for additional studies
Discuss EPA contract scope with Metro interest -
and Finalize contract proposals
Select contractor
initiate contract
Complete study
Present results to Denver Metro Interests and
Negotiate for adoption of results
PATRICK GODSIL - A&W
Develop Program on Optimizing Water Use
Contact State and Local Agencies
Review Detailed Water Usage Data
Meet with Denver Water Board
>	Develop a Public Information Program on Water Use & Re-Use
w	Continue to coordinate with Denver Water Board
ALBERT V. SOUKUP - A&W
PROCESS FIFTY PERMITS
Processing Permits Applications In the Cache La Poudre and
St. Vrain Creek Sub-basins
Inspect Denver Metro to Identify Uninformed or Non-complying
Industries
Obtain completed applications for all significant industries
Complete requests for State cert, for all significant industries
Develop interim effluent monitoring plan for major industries
Finalize plan for monitoring
Complete Tech review of applications from significant industries
B. DAVID CLARK - ENF
JSIL
JAW FEB MAR APR MAY JUN JUL AUG SEP OCT HOV DEC
1973 1974 1221 liZfi.
21
1
15
15
1
15
-ONGOING-
15
1
1
1
1
1

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SAMPLE AND MONITOR INDUSTRIAL OUTFALLS AND AMBIENT STREAM CONDITIONS
Describe Quality of the South Platte River and Tributaries
Verify Selected Industrial Effluent Data
Review Data to Identify Need for Additional Sampling
Conduct Sampling Program
Analyze Data from Sampling Program
velop Continuous Surveillance Program
hn e: HARDAWAY - S&A
HOLD ENFORCEMENT CONFERENCE
Complete Field Survey By D.F.I., D.C.
Complete Draft of Report
Forward Final Survey Report
Publish Public Notice for Reconvening Corference
Reconvene Conference
Administrator Approval of Conferees Recommendations
Resin Implementation of Recommendations
THOMAS ROGERS - ENF
ISSUE 180-DAY NOTICES
180-Day Notice to Great Western Sugar, Ovid. Colo.
Meet with Great Uestern Sugar officials
Convene Public Hearing
Adequate Waste Treatment Facilities In operation
(to reduce BOD load by 16,000 lbs/day)
Fecal Coliform of 1000/100 ml
Dissolved Oxygen 5.0 mg/1 (in 30 mile reach downstream)
THOMAS ROGERS - ENF
180-Day Notice to Great Western Sugar, Greelev. Colo.
Meet with Great Uestern Officials
Convene Public Hearing
Adequate Waste Treatment Facilities in operation
(to reduce BOD load by 16,000 lbs/day
Reduce Coliform Level in Cache La Poudre and South Platte by
THOMAS ROGERS - ENF
1311.
1071 1974 1975 1976
JAN FEB KAR APR MAY JUN JUL AUG SEP OCT NOV DEC
15
1
30
1
30
27
1
15
X
X
X
X
X
X
X
X

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DEVELOP WATER QUALITY MANAGEMENT PLAN AS REQUIRED BY 18 CFR 601
Assist State and Larimer-Weld Counties Planning Commission
Determine resource requirements needed to assist State and
Larimer-Weld Counties
Begin assistance to State and Larimer -Weld Co. Planning Commission
Complete Basin and Regional Plans
PATRICK G0DS1L - A&W
SUPPLEMENT DEKVER REGIONAL COG 3(C) PLANNING ACTIVITY TO ACHIEVE
REQUIRED OBJECTIVES
Assign Regional Liaison Officer
Identify Regional Task Force for Tech. Review of DR COG Study
Convene Meeting of Task Force
Task Force Meeting with DR COG 3(C) Consultant
Implement Work Plan on Supplemental Resolutions Required to
achieve Allied Reg. 8 Objectives
PATRICK GODSIL - A&W
IMPROVEMENTS IN AIR QUALITY
>
ui	Mobile Sources
Begin review of the Colo. State Air Pollution Control Plan
Report on possible Increased susceptibility of Denver residents
to pollutants because of altitude
Report on effectlveneBss of Federal Motor Vehicle Program as It
applies to Denver
Report on expected reduction In pollution from application of
Federal Emission Standards for moving sources
Report on expected reduction in pollution from State Motor
Vehicle Inspection
Report on the effectiveness and applicability of various
transportation control options
Complete control strategy as needed for revision of State
Air Pollution Control Implementation Plan
Meet with State Agencies to exchange Information
Meet with State and Local Transportation Agencies
Continuing Project: Impact State, County and City legislation
which restricts automobile use and promotes mass transit
DALE WELLS - A&W
	1972	 1973 1973 1973 1976
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
UNDERWAY
x
1
1
7
12
17
26
1
1
1
1
19
1
x
x
	Continuing Project	

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PROBLEMS ASSESSMENT AND PROPOSED SOLUTIONS RELATING TO PARTICULATE MATTER
Review and report on adequacy of State Plan
In conjunction with State and Local agencies, prepare a report on
probable sources of uncontrollable particulate pollution
Report on measures to eliminate these particulates
Complete control strategies for revision of State Plan
NORMAN HUEY - A&W
Public Information program to focus attention on air pollution
caused by mobile sources
JAMES BOWYER - PDS
Impact Colorado legislature concerning legislation affecting
the environment
Meet and consult with members of Colorado legislature to
encourage the presentation of new environmental laws for
the open session
DEAN NORRIS - PDS
DEVELOP CONTROL PROGRAM FOR OIL AND HAZARDOUS MATERIALS
Development of A Mutual Aid Group or groups
Primary contact,
Formation of group, 1st meeting -
Basic development of group, contingency plan,
obtainment of equipment and training of personnel
Contingency Plan from non-discharging facilities.
Inventory started
Primary Sources contacted
Most, if not all, sources contacted
Plans received from primary sources
Investigation of primary sources
Plans received from most or all sources
Investigation of all other sources
RICHARD M. JONES - S&A
1972
1973 1974 1975 1976
U! FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
1
1
15
1
15
5/1
1
12/31
3/0i

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