Boulder Waterkeeper has collected water samples from Boulder Creek and paid for independent laboratory testing which the environmental advocacy group said has detected a “human waste footprint” to the E.coli presence that those tests revealed.
Notice of those findings was provided by email this week to the University of Colorado Boulder’s Health and Safety Department, the Colorado Department of Public Health and Environment and the Environmental Protection Agency.
The group’s test results, however, are challenged by CU Boulder, which commissioned its own tests on E.Coli creek samples by a third-party lab in 2018. A university spokesman stated in an email Friday its own test result “does not absolutely indicate human sources,” and “found potential human-associated markers for E. coli in raccoon feces collected from storm drains on campus.”
The two collection points for the sampling by Boulder Waterkeeper, conducted on Nov. 17, at what is known as “Outfall C,” just upstream from the Folsom Avenue bridge, and a second outfall at 17th Street, just below the bridge.
Their samples were sent to two labs; one, Microbial Insights of Knoxville, Tenn., uses quantitative polymerase chain reaction analysis (qPCR), a genetic-based molecular method capable of differentiating between human, goose and dog waste resources. Additionally, samples were sent to Colorado Analytical Laboratories in Lakewood, for an E.coli analysis.
The qPCR analysis from Outfall C showed a “human waste footprint” to dry-weather discharges at that site, and an E.coli value of 980 colony forming units per 100 millileters, which is well above the creek’s established water quality standard of 126 cfu/100 ml.
The corresponding analyses at 17th Street did not show a “human waste footprint,” but its E.coli value was 2,420 cfu/100 ml.
The advocates’ report notes that “the E.Coli laboratory holding time of 6 hours was exceeded due to the Sunday (Nov. 17) sampling and the laboratory was closed; therefore, the E.Coli data should be considered semi-quantitative.”
Boulder Waterkeeper spokesman Art Hirsch, a retired environmental engineer who lives in unincorporated Boulder County and authored the letter Wednesday notifying university, state and federal officials of his group’s findings, is pointing his finger at CU Boulder as needing to make changes to its discharge practices.
‘It’s no longer just raccoons’
“It’s directly downstream of the storm sewer systems at the university,” Hirsch said of the contamination. “What it indicates to me is that there is a human source to it. It is either a direct or indirect source of human waste, potentially the sanity sewer systems into the stormwater systems.
“And the issue is that if that is indeed what is happening, that is an illicit discharge. I paraphrase the EPA in saying it should ruled be an illicit discharge. If there is a human footprint. It’s no longer just raccoons.”
Boulder Waterkeeper has been hitting on the theme of Boulder Creek’s health — it will be conducting another community forum on the subject 6 p.m. Monday at Boulder’s Jewish Community Center — and filed an illicit discharge complaint on the issue to CU Boulder on July 24, followed by a similar complaint to CDPHE on Aug. 8 and to the EPA on Sept. 5.
CU Boulder has maintained that it is in compliance with its stormwater discharge permit, known as an MS4 permit. CDPHE has ruled that the discharges are not illicit, and the EPA has deferred on that question to the state, although it noted to Boulder Waterkeeper that if there were indicators of human waste in the dry-weather discharges from the university into the creek — as the advocates’ testing has reportedly found — that might indicate the presence of an illicit discharge.
CU Boulder spokesman Joshua Lindenstein took strong issue with the environmentalists’ report on Friday, and said the university “continues to be proactive” and takes the issue seriously.
“The claims of illicit discharges made in the Boulder Waterkeeper complaints are unfounded, as shown by CDPHE’s previous responses to Boulder Waterkeeper,” Lindenstein stated. “…The limitations of this testing method to distinguish between raccoon and human sources were shared with the Boulder Waterkeeper several months ago through presentation at a water quality forum hosted by them.”
CU doing ‘more than is required’
Hirsch said he rates CU Boulder’s response to date on the creek health issue as “poor.” He is not satisfied with the university’s stance that it is within compliance with its current MS4 permit, or the fact that its permit is currently undergoing revision by the state and that the university is looking to the results of that revision for guidance on how best to proceed going forward. That revision, Hirsch claimed, could take two or three more years.
“They know there is a water quality issue and all they say is they are in compliance with their permit” Hirsch said. “They should have gone outside the parameters of their permit, knowing that they are a major contributor to the pollution of Boulder Creek.”
But Lindenstein defended the university’s record and current practice as it relates to the creek’s health.
“CU Boulder has for years done more than is required under our current MS4 permit as it relates to monitoring for, and mitigating against, E. coli in storm drains that discharge into Boulder Creek,” Lindsentein wrote.
Most recently, he said, CU Boulder Environmental Health and Safety staff over the summer began increasing the frequency of sampling to identify potential issues and determine possible solutions. And this fall, the university augmented its prior efforts related to restricting animal access to the storm drains on campus. These measures, he added, have previously shown positive results in reducing E.coli levels discharged to Boulder Creek.
CU Boulder continually investigates sanitary sewers to determine whether leaks are occurring, he stated, and that “on the rare occasion that leaks have been found, CU Boulder has promptly made repairs to ensure that sanitary systems are not impacting storm lines.”
Due to holiday staffing on Friday, CDPHE was unable to comment on Boulder Waterkeeper’s report.