colorado DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 
Water Quality Control Commission
5 CCR 1002-41
REGULATION NO. 41 
The basic standards for ground water
. . . .
41.5	GROUND WATER QUALITY STANDARDS
The water quality standards specified in subsection B below are deemed necessary and appropriate to protect ground water uses as specified in section 41.4, and shall be adopted to protect such classified uses. The standards specified in subsections A and C apply to all State ground waters, unless alternative site-specific standards have been adopted for a specified area pursuant to subsection D below.
. . . .
C.	Statewide Standards
. . . .
3.	Interim Organic Pollutant Standards:
Note that all standards in table A are being adopted as “interim standards.” These interim standards will remain in effect until alternative permanent standards are adopted by the Commission in revisions to this regulation or site-specific standards determinations. Although fully effective with respect to current regulatory applications, these interim standards shall not be considered final or permanent standards subject to restrictions such as antibacksliding or downgrading.
TABLE A
GROUND WATER ORGANIC CHEMICAL STANDARDS
(in micrograms per liter)	
Parameter	CAS No.	STANDARD1	
Acenaphthene	83-32-9	420	
Acetochlor	34256-82-1	140	
Acetone	67-64-1	6300	
Acrolein	107-02-8	3.5	
AcrylamideC,8	79-06-1	0.022	
AcrylonitrileC	107-13-1	0.065	
Alachlor	15972-60-8	2.0M	
Aldicarb	116-06-3	7.0M	
Aldicarb Sulfone	1646-88-4	7.0M	
Aldicarb Sulfoxide	1646-87-3	7.0M	
AldrinC	309-00-2	0.0021	
AnilineC	62-53-3	6.1	
Anthracene (PAH)	120-12-7	2100	
AramiteC	140-57-8	1.4	
Atrazine	1912-24-9	3.0M	
AzobenzeneC 	103-33-3	0.32	
BenzeneC,2	71-43-2	5.0M	
BenzidineC	92-87-5	0.00015	
Benzo(a)anthracene (PAH)C	56-55-3	0.0048	
Benzo(a)pyrene (PAH)C, 6	50-32-8	0.0048 to 0.2M	
Benzo(b)fluoranthene (PAH)C	205-99-2	0.0048	
Benzo(k)fluoranthene (PAH)C	207-08-9	0.0048	
BenzotrichlorideC	98-07-7	0.0027	
Benzyl chlorideC	100-44-7	0.21	
Bis(chloromethyl)ether (BCME)C	542-88-1	0.00016	
BromateC	15541-45-4	0.05	
Bromobenzene	108-86-1	56	
Bromodichloromethane (THM)C, 7	75-27-4	0.56 	
Bromoform (THM)C, 7 	75-25-2	4	
Butyl benzyl phthalate	85-68-7	1,400	
Carbofuran6	1563-66-2	35 to 40M  	
Carbon tetrachlorideC, 6	56-23-5	0.5 to 5M	
ChlordaneC, 6 	57-74-9	0.10 to 2M	
Chlordecone C	143-50-0	.0035	
Chlorethyl ether (BIS-2)C	111-44-4	0.032	
4-Chloro-3-methylphenol	59-50-7	210	
Chlorobenzene	108-90-7	100M	
Chloroform (THM)C, 7	67-66-3	3.5	
Chloroisopropyl ether (BIS-2)	108-60-1	280	
Chloronapthalene	91-58-7	560	
Chlorophenol, 2-	95-57-8	35	
Chlorphrifos	2921-88-2	21	
Chrysene (PAH)C	218-01-9	0.0048	
Dalapon	75-99-0	200M	
DDDC	72-54-8	0.15	
DDEC	72-55-9	0.1	
DDTC	50-29-3	0.1	
Di(2-ethylhexyl)adipate	103-23-1	400M	
Dibenzo(a,h)anthracene (PAH)C	53-70-3	0.0048	
1,2-Dibromo-3-Chloropropane (DBCP)	96-12-8	0.2M	
Dibromochloromethane (THM)3, 7	124-48-1	14	
Dibromoethane 1,2C	106-93-4	0.018	
Dicamba	1918-00-9	210	
Dichloroacetic acidC	79-43-6	0.7	
Dichlorobenzene 1,2	95-50-1	600M	
Dichlorobenzene 1,3	541-73-1	94	
Dichlorobenzene 1,4	106-46-7	75M	
Dichloroethane 1,2C, 6	107-06-2	0.38 to 5M	
Dichloroethylene 1,1	75-35-4	7M	
Dichloroethylene 1,2-cis6	156-59-2	14 to 70M	
Dichloroethylene 1,2-trans6	156-60-5	140 or 100M 	
Dichloromethane (methylene chloride) C,6,8	75-09-2	5.6 or 5M	
Dichlorophenol 2,4	120-83-2	21	
Dichlorophenoxyacetic acid (2,4-D)	94-75-7	70M	
Dichloropropane 1,2C, 6	78-87-5	0.52 to 5M	
DichlorvosC	62-73-7	0.12	
DiclorobenzidineC	91-94-1	0.078	
DieldrinC	60-57-1	0.002	
Diethyl phthalate	84-66-2	5,600	
Diisopropylmethylphosphonate (DIMP)4	1445-75-6	8	
Dimethylphenol 2,4	105-67-9	140	
Di-n-butyl phthalate	84-74-2	700	
Dinitro-o-cresol 4,6	534-52-1	0.27	
Dinitrophenol 2,4	51-28-5	14	
Dinitrotoluene 2,4C	121-14-2	0.11	
Dinoseb	88-85-7	7M	
Dioxane 1,4-C	123-91-1	0.35	
Dioxin (2,3,7,8 TCDD)C, 6		1746-01-6	2.2x10-7 to 3.0x10-5, M	
Diphenylhydrazine 1,2C	122-66-7	0.044	
Diquat6	85-00-7	15 to 20M 	
Endosulfan	115-29-7	42	
Endosulfan sulfate	1031-07-8	42	
Endosulfan, alpha	959-98-8	42	
Endosulfan, beta	33213-65-9	42	
Endothall	145-73-3	100M	
Endrin	72-20-8	2M	
Endrin aldehyde	7421-93-4	2.1	
EpichlorohydrinC	106-89-8 	3.5	
Ethylbenzene	100-41-4	700M	
Ethylene DibromideC, 6
(1,2-dibromoehtane)	106-93-4	0.02 to 0.05M	
Ethylene glycol monobutyl ether (EGBE) (2-Butoxyethanol)	111-76-2	700	
Ethylhexyl phthalate (BIS-2)C, 6(DEHP)	117-81-7	2.5 to 6M	
Fluoranthene (PAH)	206-44-0	280	
Fluorene (PAH)	86-73-7	280	
FolpetC	133-07-3	10	
FurmecycloxC	60568-05-0	1.2	
Glyphosate	1071-83-6	700M	
HeptachlorC, 6	76-44-8	0.008 to 0.4M	
Heptachlor epoxideC, 6	1024-57-3	0.004 to 0.2M	
HexachlorobenzeneC, 6	118-74-1	0.022 to 1.0M 	
Hexachlorobutadiene	87-68-3	0.45	
Hexachlorocyclohexane, AlphaC	319-84-6	0.0056	
Hexachlorocyclohexane, Gamma (Lindane)	58-89-9	0.2M	
Hexachlorocyclopentadiene6 50M	77-47-4	42 to 50M	
Hexachlorodibenzo-p-dioxin (1,2,3,7,8,9-hcdd)C	19408-74-3	5.60E-06	
HexachloroethaneC	67-72-1	0.88	
Hexanone 2	591-78-6	35	
Hydrazine/Hydrazine sulfateC	302-01-2	0.012	
Indeno (1,2,3-cd) pyrene (PAH)C	193-39-5	0.0048	
Isophorone3	78-59-1	140	
Malathion	121-75-5	140	
Methoxychlor6	72-43-5	35 to 40M	
Methylene bis(N,N'-dimethyl)aniline 4,4'C	101-61-1	0.76	
Metribuzin	21087-64-9	180	
Mirex	2385-85-5	1.4	
Naphthalene (PAH)	91-20-3	140	
Nitrobenzene	98-95-3	14	
Nitrophenol 4	100-02-7	56	
Nitrosodimethylamine NC(NDMA)	62-75-9	0.00069	
Nitrosodiphenylamine NC	86-30-6	7.1	
N-NitrosodiethanolamineC	1116-54-7	0.013	
N-Nitrosodi-n-propylamineC	621-64-7	0.005	
N-Nitroso-N-MethylethylamineC	10595-95-6	0.0016	
Oxamyl (vydate)6	23135-22-0	175 to 200M	
PCBsC, 5, 6	1336-36-3	0.0175 to 0.5M	
Pentachlorobenzene	608-93-5	5.6	
PentachlorophenolC, 6	87-86-5	0.088 to 1.0M	
Perchlorate	7790-98-9	4.9	
Phenol	108-95-2	2,100	
Picloram	1918-02-1	490	
Prometon	1610-18-0	100	
Propylene oxideC	75-56-9	0.15	
Pyrene (PAH)	129-00-0	210	
QuinolineC	91-22-5	0.012	
Simazine	122-34-9	4M	
Styrene	100-42-5	100M	
Tetrachlorobenzene 1,2,4,5	95-94-3	2.1	
Tetrachloroethane 1,1,2,2	79-34-5	0.18	
Tetrachloroethylene (PCE)6	127-18-4	17 or 5M 	
Toluene6	108-88-3	560 to 1,000M	
Total Trihalomethanes (TTHMs)7	N/A	80M	
ToxapheneC, 6	8001-35-2	0.032 to 3M	
Trichlorobenzene 1,2,4	120-82-1	70M	
Trichloroacetic acidC	76-03-9	0.52	
Trichloroethane 1,1,1 (1,1,1-TCA)6	71-55-6	14,000 or 200M 	
Trichloroethane 1,1,23, 6
(1,1,2-TCA)	79-00-5	2.8 to 5M	
Trichloroethylene (TCE)	79-01-6	5M	
Trichloropropane 1,2,3C,8	96-18-4	3.7E-4	
Trichlorophenol 2,4,5	95-95-4	700	
Trichlorophenol 2,4,6C	88-06-2	3.2	
Trichlorophenoxyproprionic acid (2,4,5-tp) (Silvex)	93-72-1	50M 	
Vinyl ChlorideC, 6	75-01-4	0.023 to2M 	
Xylenes (total)6	1330-20-7	1,400 to 10,000M	
Notes and Abbreviations:
1	All standards are chronic or 30-day standards.  They are based on information contained in EPA's Integrated Risk Information System (IRIS) and/or EPA lifetime health advisories for drinking water using a 10-6 incremental risk factor unless otherwise noted.
2	The standard for Benzene has been established at the MCL (q.v. 41.17)
3	Standards for Group C compounds that have both published toxicity and carcinogenic risk data are calculated based on toxicity data and then adjusted downward using an uncertainty factor of 10.  
4	The Diisopropylmethylphosphonate (DIMP) standard was adopted in 1993 (q.v. 41.16)
5	PCBs are a class of chemicals that include aroclors, 1242, 1254, 1221, 1232, 1248, 1260, and 1016, CAS numbers 53469-21-9, 11097-69-1, 11104-28-2, 11141-16-5, 12672-29-6, 11096-82-5, and 12674-11-2 respectively.  The human-health criteria apply to total PCBs, i.e. the sum of all congener or all isomer analyses.
6	Whenever a range of standards is listed and referenced to this footnote, the first number in the range is a strictly health-based value, based on the Commission’s established methodology for human health-based standards.  The second number in the range is a maximum contaminant level, established under the federal Safe Drinking Water Act has been determined to be an acceptable level of this chemical in public water supplies, taking treatability and laboratory detection limits into account.  The Commission intends that control requirements for this chemical be implemented to attain a level of ambient water quality that is at least equal to the first number in the range except as follows:
	Where ground water quality exceeds the first number in the range due to a release of contaminants that occurred prior to September 14, 2004, (regardless of the date of discovery or subsequent migration of such contaminants) clean-up levels for the entire contaminant plume shall be no more restrictive than the second number in the range or the ground water quality resulting from such release, whichever is more protective.
	Wherever the Commission has adopted alternative, site-specific standards for the chemical, the site-specific standards shall apply instead of these statewide standards.
	When the first number in the range is higher than the maximum contaminant level, the implementing agency must establish the protection level, either the first number in the range or the second number in the range, that is determined by the implementing agency to be consistent with the current and reasonably anticipated future uses of the ground water.
The Commission does not intend the adoption of this range of standards to result in changes to clean-up requirements previously established by an implementing agency, unless such change is mandated by the implementing agency pursuant to its independent statutory authority.
7	For aquifer storage and recovery facilities, if the source of this chemical in ground water is potable water provided by a drinking water system with a Colorado PWSID that meets all applicable federal Safe Drinking Water Act and corresponding State requirements at the time that it is utilized for aquifer storage and recovery or artificial recharge, then the separate total trihalomethane standard will apply to the ground water in question, rather than the individual standards for bromodichloromethane, bromoform, chloroform, and/or dibromochloromethane.  For any parameter for which there is a Maximum Containment Level (MCL) established by the Safe Drinking Water Act, as identified in Table A with Footnote “M”, the MCL shall apply as the standard for groundwater when potable water is used for ASR or artificial recharge. 
8	Mutagenic compound, age dependent factors were used in calculating standard.
N/A – not applicable
C	Carcinogens classified by the EPA as A, B1, or B2.
M	Drinking water MCL.
CAS No. - Chemical Abstracts Service Registry Number
THM - Halomethanes
4.	Whenever the practical quantitation limit, or PQL, for a pollutant is higher (less stringent) than a standard listed in subsection 2 or 3 above, the PQL shall be used in regulating specific activities.  These PQL's shall be approved by the Water Quality Control Division unless an alternate PQL has been established by the applicable implementing agency.
. . . .
41.8	SEVERABILITY
The provisions of these regulations are severable, and if any provisions or the application of the provisions to any circumstances is held invalid, the application of such provision to other circumstances, and the remainder of these regulations, shall not be affected thereby.
TABLE 1
Domestic Water Supply – Human Health Standards	
Parameter	Standard1	
Biological	 	 	 	
 	Total Coliforms 
(30 day average)	2.2 a	org/100 ml	
	Total Coliforms
(max in 30 days)	23	org/100 ml	
Inorganic	 	 	 	
Antimony	(Sb)d, M	0.006	mg/l	
Asbestos	M	7,000,000	fibers/Liter	
Arsenic	(As)d, M	0.01	mg/l	
Barium	(Ba)d, M	2.0	mg/l	
Beryllium	(Be)d, M	0.004	mg/l	
Cadmium	(Cd)d, M	0.005	mg/l	
Chromium	(Cr)c, d, M	0.1	mg/l	
Cyanide [Free]	(CN)M	0.2	mg/l	
Fluoride	(F)d, M	4.0	mg/l	
Lead	(Pb)d	0.05	mg/l	
Mercury (inorganic)	(Hg)d,M	0.002	mg/l	
Molybdenum	(Mo) d	0.21	mg/l		
Nickel	(Ni)d	0.1	mg/l	
Nitrate	(NO3)d, M	10.0	mg/l as N	
Nitrite	(NO2)d, M	1.0	mg/l as N	
Total Nitrate+Nitrite	(NO2+NO3-N)d, f	10.0	mg/l as N	
Selenium	(Se)d, M	0.05	mg/l	
Silver	(Ag)d	0.05	mg/l	
Thallium	(Tl)d, M	0.002	mg/l	
Uranium	(U) d, 2	0.0168 to 0.03M	mg/l	
Radiologicalb, d	 	 	 	

 Gross Alpha Particle Activityi, M
	15	pCi/l	
 Beta and Photon Emitterse	4	mrem/year	
. . . .
1 	Chronic or 30-day standard based on information contained in EPA's Integrated Risk Information System (IRIS) using a 10-6 incremental risk factor.
2 	Whenever a range of standards is listed and referenced to this footnote, the first number in the range is a strictly health-based value, based on the Commission’s established methodology for human health-based standards.  The second number in the range is a maximum contaminant level, established under the federal Safe Drinking Water Act that has been determined to be an acceptable level of this chemical in public water supplies, taking treatability and laboratory detection limits into account.  The Commission intends that control requirements for this chemical be implemented to attain a level of ambient water quality that is at least equal to the first number in the range except as follows:
	Where ground water quality exceeds the first number in the range due to a release of contaminants that occurred prior to September 15, 2012, (regardless of the date of discovery or subsequent migration of such contaminants) clean-up levels for the entire contaminant plume shall be no more restrictive than the second number in the range or the ground water quality resulting from such release, whichever is more protective.
	Wherever the Commission has adopted alternative, site-specific standards for the chemical, the site-specific standards shall apply instead of these statewide standards.
The Commission does not intend the adoption of this range of standards to result in changes to clean-up requirements previously established by an implementing agency, unless such change is mandated by the implementing agency pursuant to its independent statutory authority.
a 	.  When the Membrane Filter Technique is used for analysis, the average of all samples taken within thirty days must be less than 1 organism per 100 milliliters of sample.  When the Multiple Tube Fermentation Method is used for analysis, the limit is less than 2.2 org/100 ml.
b	If the identity and concentration of each radionuclide in a mixture are known, the limiting value would be derived as follows:  Determine, for each radionuclide in the mixture, the ratio between the quantity present in the mixture and the limit specified.  The sum of such ratios for all radionuclides in the mixture shall not exceed "1" (i.e. unity).  A radionuclide may be considered as not present in a mixture if the ratio of the concentration to the limit does not exceed 1/10 and the sum of such ratios for all radionuclides considered as not present in the mixture does not exceed 1/4. 
c	The chromium standard is based on the total concentration of both trivalent and hexavalent forms of dissolved chromium.
d	Measured as dissolved concentration.  The sample water shall be filtered through a 0.45 micron membrane filter prior to preservation.  The total concentration (not filtered) may be required on a case-by-case basis if deemed necessary to characterize the pollution caused by the activity.
e	If two or more radionuclides are present, the sum of their annual dose equivalent to the total body or to any organ shall not exceed 4 mrem per year.  Except for Tritium and Strontium 90 the concentration of man-made radionuclides causing 4 mrem total body or organ dose equivalents shall be calculated on the basis of a 2 liter per day drinking water intake using the 168-hour data listed in "Maximum Permissible Body Burden and Maximum Permissible Concentration of Radionuclides in Air or Water for Occupational Exposure," NBS Handbook 69, as amended, August 1963, US Department of Commerce.
f	These more stringent levels are necessary to protect livestock watering.  Levels for parameters without this footnote are set to protect irrigated crops at the same level.  Where a party can demonstrate that a livestock watering use of ground water is not reasonably expected, the applicable standard for lead is 5.0 mg/l.
g	This level is set to protect the following plants in ascending order of sensitivity:  Pecan, Black Walnut, Persian (English) Walnut, Jerusalem Artichoke, Navy Bean, American Elm, Plum, Pear, Apple, Grape (Sultanina and Malaga), Kadota Fig, Persimmon, Cherry, Peach, Apricot, Thornless Blackberry, Orange, Avocado, Grapefruit, Lemon.  Where a party can demonstrate that a crop watering use of ground water is not reasonably expected, the applicable standard for boron is 5.0 mg/l.
h	This level protects all crops, except citrus which do not grow in Colorado and therefore a more stringent level of protection is not required.
i	The Gross Alpha Activity standard excludes alpha activity due to Radon and Uranium.
j This standard is only appropriate where irrigation water is applied to soils with pH values lower than 6.0.
M	Drinking water MCL.
41.9	Reserved.
. . . 
41.27	STATEMENT OF BASIS, SPECIFIC STATUTORY AUTHORITY AND PURPOSE; AUGUST 13, 2012 RULEMAKING; FINAL ACTION SEPTEMBER 11, 2012; EFFECTIVE JANUARY 31, 2013
The provisions of sections 25-8-202(1)(b); 25-8-204; 25-8-402, C.R.S., provide the specific statutory authority for adoption.  The Commission also adopted, in compliance with section 24-4-103(4) C.R.S., the following statement of basis and purpose.
BASIS AND PURPOSE
1.	Statewide Standards - Interim Organic Pollutant Standards
In this rulemaking, the Commission adopted revised and new organic chemical standards in section 41.5(C)(3). In an effort to keep ground water and surface water organic chemical standards consistent, the changes to section 41.5(C)(3) were considered during the same hearing that addressed changes to the statewide surface water organic chemical standards in Regulation No. 31 (Basic Standards and Methodologies for Surface Water).  
In adopting these new and revised organic chemical standards, the Commission continued to rely on its past policy decisions and precedence documented in Commission Policy 96-2. Additionally, as per Departmental policy, the Commission has relied on the United States Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS) as its first tier source of toxicological data. Review of the IRIS data that had been updated since the last revisions to 41.5(C)(3) indicated that the water quality standards for acrylamide, carbon tetrachloride, 1,2-cis dichloroethylene,1,2-trans dichloroethylene, 1,4-dioxane, hexachloroethane, nitrobenzene, pentachlorophenol, tetrachloroethylene (PCE), and 1,1,1-trichloroethane, needed to be revised. This review also identified new compounds in the IRIS data that the Commission elected to adopt as water quality standards, these were: acetone, bromobenzene, chlordecone, 1,2-dibromoethane, dichloromethane, ethylene glycol monobutyl ether (EGBE) (2-Butoxyethanol), 2-hexanone, perchlorate,  trichloroacetic acid, 1,2,3-trichloropropane. 
The compounds acylamide, dichloromethane, and 1,2,3-trichloropropane are mutagenic compounds, and the resulting standards were calculated following EPA guidance on calculating drinking water supply standards for mutagenic compounds. Footnote 8 was added to indicate that these compounds were calculated using age dependent factors.
The EPA IRIS updates also included instances where the updated human health criteria is less stringent than the maximum contaminant level (MCL) promulgated under the federal Safe Drinking Water Act.  In these instances, the Commission adopted two values shown as a range, with the updated human health criteria being the first number in the range and the federal MCL being the second number in the range. In such cases, the implementing agency must establish the protection level that is determined by the agency to be consistent with the current and future uses of the ground water. The compounds that have a range with the human health criteria being higher than the MCL are 1,2-trans dichloroethylene, tetrachloroethylene (PCE), and 1,1,1 trichloroethane (1,1,1-TCA). Footnote 6 to Table A was amended to clarify the standards implementation intent of the Commission when a human health based standard is a higher numeric value than the maximum contaminant level in a range between the human health based standard and the maximum contaminant level. 
The Commission also corrected several typographical errors and added common synonyms for some of the organic chemicals.  
The Commission heard testimony from several parties asserting that the revised standard adopted for 1,4 dioxane may not be attainable with economical treatment technologies and in some instances may be difficult to measure using current laboratory analytical techniques. Such technical and economic issues are often addressed by EPA in establishing a Maximum Contaminant Level (MCL) under the Safe Drinking Water Act, and the Commission has in the past established a range for a particular chemical, with the health-based standard being the minimum and the MCL the maximum, since EPA has determined that MCLs represent an acceptable level to provide in public drinking water.  However, no MCL has been developed for 1,4 dioxane. The Commission therefore did not adopt a range and instead set the statewide standard for 1,4 dioxane at a level to protect human health, based on the currently available scientific information and applying the Commission’s established risk-based policy approach.  The Commission believes that the concerns raised are better addressed with respect to site-specific implementation issues and notes that there may be a need for site-specific standards for 1,4-dioxane and other regulated organic chemicals to address site-specific economic and/or technical treatment capabilities.  The Division concurred with the parties’ testimony regarding these concerns and expressed willingness to work with parties who propose site-specific solutions to the Commission.
2.	Table Value Criteria – Tables 1 through 4
The Commission revised the Table 1 standard for molybdenum from 35 ug/l to 210 ug/l in an effort to keep the surface and ground water standards consistent.  The Division presented evidence during the hearing that the total recoverable form of molybdenum can be translated to the dissolved form in a 1:1 ratio. 
The Commission revised Table 1 standard for uranium to be a hyphenated value. The Commission retained the 30 μg/L value, the maximum contaminant level (MCL) from EPA’s 2000 radionuclides rule under the Safe Drinking Water Act, and added a value of 16.8 μg/L. The 16.8 μg/L value is derived from use of the reference dose and relative source contribution from the 2000 radionuclides rule in Equation 1-1 of Policy 96-2. This equation and the resulting value are based purely upon the protection of human-health and do not take treatment or economic considerations into account as does the MCL. Footnote 2 to Tables 1- 4 will be applied to the revised uranium value.
PARTIES TO THE RULEMAKING
1.	Climax Molybdenum Company
2.	Metro Wastewater Reclamation District
3.	Lowry Environmental Protection/Cleanup Trust Fund
4.	South Adams County Water and Sanitation District
5.	Brown Group Retail, Inc.
6.	International Risk Group, LLC
7.	Environmental Protection Agency
8.	City of Boulder