HomeMy WebLinkAbout1.38 EngDesign-G.SanitarySewerPlan FINAL
SANITARY SEWAGE
DISPOSAL PLAN
(SEWAGE MANAGEMENT PLAN )
RIVER EDGE COLORADO
GARFIELD COUNTY, COL ORADO
O W N E R / A P P L I C A N T :
C A R B O N D A L E I N V E S T M E N T S , L L C
7 9 9 9 H W Y 8 2
C A R B O N D A L E C O 8 1 6 2 3
970-456-5 3 2 5
C O N S U L T A N T :
8 1 4 0 P A R T N E R S , L L C
P O B O X 0 4 2 6
E A G L E , C O 8 1 6 3 1
J A N U A R Y 1 4 , 2 0 1 1
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
2
SANITARY SEWAGE DISP OSAL PLAN
(SEWAGE MANAGEMENT P LAN)
RIVER EDGE COLORADO
GARFIELD COUNTY, COL ORADO
TABLE OF CONTENTS
I. INTRODUCTION ........................................................................... 3
A. BASIS .................................................................................................... 3
B. PURPOSE AND SCOPE OF REPORT .......................................................... 3
C. FINDINGS .............................................................................................. 3
II. PROJECT LOCATION AND DESCRIPTION .......................................... 4
A. PROJECT LOCATION ............................................................................... 4
B. PROJECT DES CRIPTION .......................................................................... 4
III. EVIDENCE OF ADEQUATE SEWAGE DISPOSAL .................................. 5
A. ADEQUACY OF TREATMEN T ALTERNATIVES ............................................. 5
1. NEW WWTP ALTERNATIVE ........................................................................ 6
2. RFWSD TREATMENT ALTERNATIVE ............................................................ 9
B. ENTITY THAT OWNS AND OPERATES THE COLLECT ION AND TREATMENT
FACILITIES ...................................................................................................... 11
1. REC TREATMENT ALTERNATIVE................................................................ 11
2. RFWSD TREATMENT ALTERNATIVE .......................................................... 12
C. METHOD OF FINANCING THE COLLECTION AND T REATMENT FACILITIES 12
APPENDICES
APPENDIX A: VICINITY MAP AND PROJECT SITE MAP
APPENDIX B: TREATMENT ALTERNATIVE DESIGN SCHEMATICS
APPENDIX C: PERMITTING ANALYSIS
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
3
I. INTRODUCTION
A. BASIS
This Sanitary Sewage Disposal Plan ("Plan") has been prepared in support of an
application for PUD Plan Review ("Rezoning") and Subdivision Review ("Preliminary
Plan") for the proposed River Edge Colorado ("Project", "REC", or "REC PUD") in
accordance with the requirements of the Garfield County Unified Land Use Resolution of
2008 ("ULUR"), as amended. This Plan specifically addresses the requirements of Section
5-502C.14 of the ULUR, and along with the Sewage Collection Design Report documents
that a sewage collection and treatment system meeting the criteria of Sections 5-
501G.11.d, 501G.11.g, 502C.14 and 7-106.B of the ULUR is available or can be designed
to serve the Project. This Plan is supported by other referenced documents submitted as
part of the REC rezoning and preliminary plan applications including the River Edge
Colorado PUD and Subdivision Drawing Package ("Drawing Package").
This Plan is designed to provide Garfield County with evidence that provision has been
made for adequate treatment service to support the Project, in compliance with State
and County regulations. With respect to collection and transmission of sewage within
the Project, the design of the sewage collection system is documented in the Sewage
Collection Design Report which is included as part of the REC rezoning and preliminary
plan applications. The Sewage Collection Design Report concludes that a sewage
collection system can be designed and constructed to support the development of the
Project in accordance with generally accepted practices.
B. PURPOSE AND SCOPE OF REPORT
The primary purpose of this Plan is to provide evidence that provision has been made
for adequate sanitary sewage treatment to service the Project, in compliance with state
and County regulations. This includes the following:
Evidence that the proposed treatment facilities can and will provide
adequate service for the proposed land use.
A description of the legal entity that will own and operate the collection
and treatment facilities.
A description of the proposed method of financing the collection and
treatment facilities serving the proposed land use.
C. FINDINGS
A preliminary analysis of the sewage treatment system has been completed under the
direction and review of William S. Otero P.E. (Colorado Registration #32163). William S.
Otero P.E. has determined that the Project can be adequately served by a sewage
treatment system, as shown herein and as depicted here and in the sewage collection
system engineering plans shown on the Sewage Collection and Water Supply and
Distribution Plan, SW01-03 Series drawings in the Drawing Package provided herewith,
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
4
which proposed system meets generally accepted engineering standards for the
collection and treatment of sewage, and requirements of the ULUR.
II. PROJECT LOCATION AND DESCRIPTION
A. PROJECT LOCATION
The Project is located along State Highway 82 ("SH 82") between the City of Glenwood
Springs and Town of Carbondale near the junction of County Road 110/113 ("CR 113")
and SH 82. The property is located almost entirely west of the Roaring Fork Transit
Authority ("RFTA") right-of-way and east of the Roaring Fork River and the Roaring Fork
Conservancy ("RFC") Conservation Easement (i.e., Grant of Conservation Easement
dated February 3, 2000, recorded at Reception Number 559036 and survey map,
recorded December 24th, 2008, recorded at Reception Number 760571 in the real
property records of Garfield County, Colorado). The Project straddles Cattle Creek which
is also located within the RFC Conservation Easement. A vicinity map is provided as
Exhibit 1 in Appendix A. The Project covers approximately 160 acres ("Project Site") as
shown and described on the Project Site drawing [Exhibit 2(a-d), Appendix A]. The
Project is proposed by Carbondale Investments, LLC ("CI").
B. PROJECT DESCRIPTION
The Project is a proposal to create a walkable clustered-form of residential development
with neighborhood amenities including naturalized open space and enhanced wildlife
habitat, community recreation, parks, and neighborhood agriculture that is designed to
serve the residents and preserve and provide reference to the rural character and
agricultural roots of the Roaring Fork Valley. The Project aims to have a strong historic
identity back to the days of ‘old Colorado’ when compact neighborhoods formed with a
strong sense of community based on the land and surrounding landscape. The REC
landscape aesthetic will be simple, informal, and place emphasis in the use of plant and
landscape materials local, adaptable and appropriate to the climate and environment of
the area. The Project will include approximately 366 residential units of various sizes
and types including 55 affordable homes and one exclusive executive lot for a custom
home. Housing types will range from attached homes to small single family attached
and detached garden homes, village homes, and larger estate homes. Smaller garden
homes are anticipated to be designed for younger residents that are looking for their
first home in the County, while village homes and estate homes will provide move up
opportunities for growing families. Densities in the Project are proposed at less than 2½
units per acre. Lot sizes will vary from over 1 acre to approximately 5,000 square feet for
single family homes, and 1,700-5000 square feet of lot area for each garden home. Most
of the units back to either proposed active parks or reclaimed open space to help
enhance the connection to the land. The REC layout and design is depicted in the PUD
Plan, PUD01-03 Series and the Preliminary Plan PRPN01-03 Series of the Drawing
Package.
The architectural theme will be complementary to the traditional architecture of the
valley. Generally, exterior materials will include wood, stone, brick, stucco and cement
board siding. Varied roof heights and articulation of the front elevations will be used to
break up the massing and provide street-level appeal. Front porches and covered stoops
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
5
are included on homes to emphasize the entry and connection to the sidewalk and
street. Roofing will include dimensional shingles, metal, or other materials appropriate
to the building style and that roofs will generally be pitched. Gables, wall plane and
roofline articulation, bays, balconies, porches, canopies and arcades will be used in the
design of various buildings. The selection of materials will minimize the exterior
maintenance of the homes to help maintain a quality appearance for the long term.
The street pattern and pedestrian network are designed to facilitate community
interaction. Streets have detached sidewalks with designated cross walks at major
intersections and landscaped areas that create a comfortable environment for walking.
On‐street parking in most areas will further buffer vehicular and pedestrian uses.
Internal circulation is maximized and dead‐end streets are limited. Alleys are used
where appropriate to enhance the streetscape and achieve a mix of housing styles. A
soft trail system is used to connect open spaces and other commo n elements with the
sidewalk network. The homes are placed close to the streets to help define the
streetscape space and provide visual interest to pedestrians. Street trees and plantings
are proposed to enhance the aesthetics of the street.
The community is served with a variety of recreational facilities and a neighborhood
center that could include meeting room(s), fitness room, offices, kitchen, restrooms,
recreational facilities, and limited community service use such as a day care facility,
deli/coffee shop, or health club. Parks will provide informal recreational opportunities
within the community and will likely include tot lots, playfields, and trail system. The
west portion of the property is generally set aside as the naturalized area that buffers
the RFC Conservation Easement along the Roaring Fork River. The soft trails around the
property allow residents to enjoy the river and wetland areas without disrupting the
environment in conformance with the terms of the RFC Conservation Easement. More
than the minimum open space requirements will be met by the project. Nearly 50% of
the Project Site is in some form of open space, common area or park. Finally,
opportunities for productive and edible landscapes, including community gardens and
neighborhood orchards are integrated and dispersed in between the residential land
uses as gathering and focal places for residents connecting REC to its agricultural
heritage.
The combination of trails, recreation areas, and open space system with the ability to
engage in ‘interactive community agriculture’ on a small scale will make REC a very
desirable place to live, filling a unique niche not yet met in Garfield County. This unique
combination will help establish a sense of place, foster community, and engage
residents with their immediate environment. It is intended this overall outdoor focus
will set the tone and become a major driver of the identity of REC.
III. EVIDENCE OF ADEQUATE SEWAGE DISPOSAL
A. ADEQUACY OF TREATMENT A LTERNATIVES
Two primary alternatives (and one hybrid alternative) have been identified for the
treatment of sewage generated by the Project. Treatment capacity to serve the Project
does not currently exist. As a result, the alternatives require the permitting and
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
6
construction of new wastewater treatment capacity. This may take one of three forms:
(1) the design, permitting and construction of a new wastewater treatment plant
("WWTP") on the Project Site, owned and operated by the REC Property Owners
Association ("POA") (i.e., "privately-operated alternative"); (2) the design, permitting
and construction of a new WWTP on the Project Site, owned and operated by the
Roaring Fork Water and Sanitation District ("RFWSD") (i.e., "hybrid alternative"; or (3)
the design, permitting and expansion of the existing RFWSD WWTP (i.e., "RFWSD
alternative"). As discussed below, each of these is a viable alternative provided the
alternative is found by the Colorado Department of Public Health and the Environment
("CDHPE") to meet their permitting criteria. Each alternative could provide adequate
facilities to meet the Project's demands.
1. NEW WWTP ALTERNATIVE (PRIVATELY-OPERATED AND HYBRID)
One option available to service REC with sanitary sewage treatment is the
construction of a new WWTP within the Project Site. The WWTP would be
located on the Project Site on Tract AO which is identified as a Water and
Wastewater Tract as part of the REC rezoning and subdivision application and
proposed to allow such a facility in accordance with the PUD Guide. This site is
alternatively planned for use by the RFWSD to house a required lift station
under the alternative requiring RFWSD WWTP expansion, as discussed below.
As documented in Appendix B, based on the current Roaring Fork River
discharge standards, the treatment process would be expected to follow a fairly
traditional treatment program similar to that utilized by other WWTPs in the
region. WWTPs in the area have been able to consistently meet CDPHE water
quality discharge requirements utilizing these simple technologies, when
properly operated. Appendix B also provides schematics and preliminary
engineering information concerning the WWTP design which documents that a
new treatment plant can be designed and constructed to serve the Project in
accordance with CDPHE plant design guidelines and standards. Discharges
would be consistent with discharges under an expansion of the existing RFWSD
WWTP although the exact location of the discharges from an onsite plant would
likely occur further downstream on the Roaring Fork River, but generally within
the same reach and adjacent to the Project.
Two options exist for the ownership and operation of the new WWTP. Under
one option, CI would be responsible for operating the collection and treatment
facilities necessary to provide sanitary sewer to the Project, including (1) a new
WWTP within Water and Wastewater Utility Tract (Tract AO), and (2) sanitary
sewer collection system meeting applicable CDPHE standards. Alternatively, the
new WWTP and sanitary sewer collection system meeting applicable RFWSD
standards could be operated by the RFWSD as a satellite or secondary system.
The design of the collection facilities located within the Project is discussed in
the Sewage Collection Design Report, and is identical for all practical purposes
under either sewage treatment option.
In approving the siting of a new WWTP, CDPHE considers three primary criteria:
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
7
The local long-range comprehensive plans for the area as they
affect water quality and any approved water quality
management plan for the area;
Whether the proposed domestic wastewater treatment works
can be managed to minimize the potential adverse impact on
water quality and in accordance with the preliminary effluent
limits developed;
The options for consolidation of wastewater treatment works
when feasible with consideration for such issues as water
conservation, water rights utilization, stream flow, water
quality, or economics.
The first criterion involves planning for the service needs of regional areas in
accordance with potential development patterns, densities and types. Based on
the recently updated Garfield County Comprehensive Plan 2030, more growth is
expected to both the north and east of the Project in the form of mixed
residential and commercial development. Sanitary service to these areas can
only be achieved through the formation of a new district or inclusion in the
RFWSD. The extension of sewer mains to connect to REC utilities will be a
challenge from an economic standpoint based on the future development
designations and densities north of REC. This challenge exists whether or not
REC is serviced by the RFWSD or a new independent system. CI is prepared to
make accommodations to serve properties to the north and east of the Project
if future needs arise and the formation of a new district is considered
appropriate by the County and State. As discussed below, the WWTP will likely
be designed utilizing a "modular" treatment technology that would easily
accommodate expansion to service this area in the future. Cleary, any action by
CI that would result in making the area to the north and east of the Project Site
more difficult to service is in neither CI's or the County's interests. CI has already
initiated discussions with other property owners in the area about potential
future connections in an effort to understand the need and determine future
treatment plant capacity and necessary land areas to accommodate such
facilities.
The second criterion involves the ability to design, construct and operate a
WWTP that will meet discharge standards long-term. Proposed as an
independent system, the WWTP serving REC would be constructed, owned and
operated by the POA as a component of the overall infrastructure. Under the
proposed REC PUD, the POA is also responsible for a raw water treatment and
delivery system, roads, parks, recreation center, trails, and may be responsible
for a potable water treatment and delivery system as discussed in the Water
Treatment and Distribution Design Report. As a result, the POA will ultimately
be a relatively robust organization with employees, billing systems,
maintenance facilities, etc. with the long term capability or capacity to operate a
WWTP. The system would include a minimum of 370 residential and commercial
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
8
taps and might be expanded to include additional areas to the north and east as
described above.
With respect to the sanitary system and treatment works, the startup is the
most critical from an operations standpoint. Collection and treatment facilities
are typically designed for some selected buildout condition which may
represent either a final or phased buildout condition. Regardless, the interim
operations must be carefully monitored to ensure discharge requirements are
met since facilities are normally designed and constructed to serve a
substantially larger population than would utilize the system in the early periods
of operation. In addition, until a sufficient number of rate payers are available
within the POA, CI would be responsible to ensure the operation and
maintenance of the collection and disposal facilities are fully funded. While
there may be temporary advantages to consolidation with the RFWSD since REC
would represent only a fraction of the overall flows initially, the operational
disadvantages associated with a new WWTP may be overcome through focused
management of the system and adequate operational funding. Initial WWTP
inefficiencies should be overcome in a short period of time and , in any case,
water quality discharge standards will at all times be met. Based on the WWTP
design requirements, the WWTP would likely be designed using a "modular"
technology to allow the WWTP to be constructed and expanded in accordance
with demand over the development period. No one can accurately determine
exactly what the buildout period will be at REC since this depends on a broad
range of economic variables. By utilizing a "modular" technology, system
efficiencies can be maximized and operational costs minimized to the benefit of
the REC residents. Currently, the buildout of REC is projected to occur over a
period of 6-7 years. This means that even if the WWTP were to be constructed
at full capacity initially, the WWTP would hit the same operational efficiency
levels currently achieved by the RFWSD within 4 years. High efficiencies might
be achievable within 2 years and might be easily maintainable into the future as
the WWTP is expanded to serve the subsequent phases of development by
utilizing a "modular" technology.
Members of CI have direct and substantial experience managing independent
WWTP facilities and site personnel through the start up phases. Further, they
have access to advanced and patented wastewater treatment technologies that
could be utilized at this site under the oversight of highly skilled technical
personnel. In light of the proposed facility design and construction program and
CI member entities' success in the design, construction, startup, operation, and
maintenance of similar facilities in other communities, it is anticipated that the
design, construction and management of a WWTP at REC is fully manageable by
CI and its affiliates and discharge limits can be achieved immediately and into
the future at reasonable cost to the residents at REC. Alternatively, the new
WWTP could be operated by the RFWSD, consistent with their proven ability in
operating facilities.
The last of the three criteria relates to wastewater treatment consolidation
feasibility. Consolidation feasibility means that treatment alternatives have
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
9
been considered in association with the siting of a new WWTP. The "feasibility"
of the alternatives is assessed based upon the alternative's water conservation,
water rights utilization, stream flow, water quality, distance to existing facilities,
and economic benefits and costs. As presented, two treatment alternatives (and
one hybrid alternative), the siting of a new privately-operated WWTP and
operation by the RFWSD are under consideration at the present time. These
alternatives have been determined to be the only treatment alternatives
available to REC. Efforts have been initiated and continue with the RFWSD to
determine the feasibility of serving the Project through the existing RFWSD
operational and management structure and expanded facilities. The approval of
the REC rezoning and subdivision application would help to serve as a basis for
the complete analysis of each alternative as it places a framework around the
development potential of the land being considered for service. The alternatives
under consideration have technical merit, but inadequate data is currently
available to assess the overall impacts and desirability of each alternative.
Appendix C discusses the permitting requirements associated with the system.
Permits would need to be obtained from Garfield County, CDPHE, and the U.S.
Army Corp of Engineers ("USCOE"). The assessment in Appendix C identifies no
specific obstacles to successfully permitting the non-RFWSD WWTP. Any onsite
facilities are reviewed as part of the REC rezoning and subdivision application as
opposed to Location and Extent review.
2. RFWSD TREATMENT ALTERNATIVE
The RFWSD WWTP currently does not have adequate capacity to serve the
entire Project; therefore, an expansion is required. The RFWSD was planning an
expansion of its wastewater treatment plant, to a capacity of 0.321 million
gallons per day. This expansion was originally anticipated to be completed by
approximately June 2010. Due to the slowdown in housing development within
the RFWSD, these expansion plans have been placed on hold. The expansion will
now be done later based on revised estimates of anticipated growth.
The RFWSD treatment alternative could be pursued under the Out-of-District
Sewer Service Agreement, dated May 24, 1994 (recorded on August 19, 1994 in
Book 912 at Page 973, Reception No. 467451) or based on a pre-inclusion
agreement between CI and the district. Under a pre-inclusion agreement, the
RFWSD will include the Project within its boundaries prior to the first final plat
for the Project, and will provide sewer service as set forth therein. Negotiations
have been initiated with the RFWSD and are progressing. The RFWSD is still in
the process of determining its needs with respect to servicing the Project and
which of those needs shall be borne by CI. Based on the general discussions to
date, sanitary sewer and wastewater treatment service will be provided
pursuant to the following general terms and conditions. In general, CI is
responsible for funding and, in some cases, constructing the RFWSD sanitary
sewer facilities necessary to provide sanitary sewer service to the Project and
surrounding service area, including: (a) lift station within Water and Wastewater
Utility Tract (Tract AO) within REC; (b) sewer force main, a minimum 10-inches
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
10
in diameter, from the lift station across the Roaring Fork River to connect to
existing RFWSD WWTP; (c) a 40,000 gallon equalization tank on the RFWSD
property or on Tract AO; and (c) an additional 196,875 gpd of WWTP capacity on
the RFWSD property located south and west of the Project Site. A schematic of
these improvements has been developed by 8140 Partners, LLC and is
presented in Appendix B. Preliminary design information is also provided in
some instances as part of the Sewage Collection Design Report. No schematic
design information or detailed information on the WWTP expansion has been
provided by the RFWSD to date. Therefore, it is impossible to understand the
full extent of the improvements involved. However, the RFWSD Engineer and
Board have pursued pre-inclusion discussions, including discussions with CI
concerning WWTP expansion, which consistently indicate the ability to expand
the WWTP beyond the previously planned expansion.
Within the Project, CI is also responsible for constructing (1) all sanitary sewer
lines to RFWSD standards including any over sizing, as may be specifically
requested by the RFWSD; (2) all sewer facilities necessary for the RFWSD to
provide sanitary sewer service to any unit within a particular subdivision filing,
including, without limitation, additional lift station(s), if necessary; and sanitary
sewer lines and force mains. The design of these facilities located within the
Project is discussed in the Sewage Collection Design Report.
The RFWSD WWTP does have reasonable existing capacity that can be utilized
during the period the WWTP expansion is under design, permitting and
construction. This existing excess capacity should be adequate to meet the CI
projected Project construction schedule and housing absorption rate without
any risk of exceeding plant discharge standards. However, since WWTP capacity
is limited, CI will be required to fund the entire expansion of the WWTP on or
before approval of the first Final Plat. The RFWSD would be solely responsible
for the planning, permitting and construction of such expansion. As stated
previously, CI is responsible for funding 196,875 gpd of plant capacity. Upon
connection to the RFWSD's WWTP and payment of required fees, the Project
would be entitled to receive wastewater treatment service from the existing
WWTP and the future expanded WWTP.
The expansion of the WWTP and lift station and other major transmission lines
must obtain a permit through CDPHE as discussed in Appendix C. The RFWSD
would be responsible for such permitting. RFWSD has not indicated that there
are any known issues that could result in denial of such a permit.
Major wastewater facilities located outside the Project Site boundaries are not
approved as part of the rezoning and subdivision application. Instead, they will
be required to go through Location and Extent review pursuant to C.R.S. § 30-
28-110(1)(a). It is anticipated that Location and Extent review is required for any
of the facilities or facility enhancement/enlargements required by the RFWSD
and designed to serve the Project and surrounding properties some or all of
which may be located outside the Project Site. CI has been advised by Kathy
Eastley, Senior Planner with the Garfield County Building and Planning
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
11
Department that any offsite facilities proposed by the RFWSD should be
reviewed independently of the REC rezoning and subdivision applications since
they represent regional facilities and not facilities solely designed and
implemented for the purpose of serving the Project. Appendix C discusses the
permitting requirements associated with the system. Permits would need to be
obtained from Garfield County, CDPHE, and the USCOE. The assessment in
Appendix D identifies no specific obstacles to successfully permitting the RFWSD
WWTP expansion.
B. ENTITY THAT OWNS AND OPERATES THE COLLE CTION AND TREATMENT
FACILITIES
Two likely potential treatment owner/operator entities have been identified and
evaluated by this Plan. These include the POA and RFWSD. Alternatively, upon proper
application, Garfield County would have the option of approving a new entity under the
special district provisions of Title 32 of the Colorado State Statute, but this has not been
separately evaluated by this Plan. The special district option is viewed as offering some
benefit over the POA option initially, and may offer superior management capabilities
over the long term if the new system were to be expanded to the service properties to
the north and east as described above.
1. PRIVATELY-OPERATED TREATMENT ALTERNATIVE
Under this treatment alternative, the collection and treatment facilities to be
utilized by the Project would be owned and operated by the POA. Under the
proposed REC PUD, the POA is also responsible for a raw water treatment and
delivery system, roads, parks, recreation center, trails, and may be responsible
for a potable water treatment and delivery system as discussed in the Water
Treatment and Distribution Design Report. As a result, the POA will ultimately
be a relatively robust organization with employees, billing systems,
maintenance facilities, etc. with the long term capability and capacity to operate
a WWTP. The system would include a minimum of 370 residential and
commercial taps and might be expanded to include additional areas to the north
and east as described above. Management of the POA would include both full
time and contract staff trained and licensed for the aspect of the system for
which they are responsible. During the WWTP startup period, the POA would be
primarily funded and controlled by CI. Members of CI have direct experience
managing independent WWTP facilities and site personnel through project
startup and beyond. Further, they have access to advanced and patented
wastewater treatment technologies that could be utilized at this site under the
oversight of highly skilled technical personnel. CI member entities' have success
in the design, construction, startup, operation, and maintenance of similar
facilities. As a result, it is anticipated that the design, construction and
management of a WWTP at REC is fully manageable by CI and its affiliates and
ultimately by the structures established under the POA.
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
12
2. RFWSD TREATMENT ALTERNATIVE
Under this treatment alternative, the collection and treatment facilities to be
utilized by the Project are owned and operated by the RFWSD. The RFWSD was
established on May 5, 1994 for the distribution and supply of water for
domestic and other uses, for the collection and treatment of sewage from
district customers, and for the maintenance, repair and replacement of all
mains, hydrants, valves and necessary service facilities owned by the district.
Currently the RFWSD provides water and sewer service to Aspen Glen, Coryell
Ranch, Midland Point, and Iron Bridge developments. The RFWSD operating
budget is funded through service fees and property tax revenue. The mill levy
for 2010 is 3.7905. This is a reduction from last year’s mill levy of 4.111. The
total tax revenue for 2009 was $238,744. The Project Site is located within the
RFWSD Service Plan boundary approved by the Garfield Board of County
Commissioners.
C. METHOD OF FINANCING THE COLLECTION AND T REATMENT FACILITIES
CI is responsible for financing any new WWTP or alternatively any necessary expansions
to the RFWSD WWTP. CI is further responsible for financing and constructing all
components of the wastewater collection facilities including the lift station and
equalization tank. The Project will finance the collection facilities using traditional
financing mechanisms. In the case of the RFWSD WWTP expansion, these improvements
would be made in lieu of tap fees.
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
APPENDIX A: VICINITY MAP AND PROJECT SITE MAP
App. A-1
12/01/10VICINITY MAPExhibit:Date:8140 Partners, LLCTitle:Prepared by:Owner/Developer: Carbondale Investments, LLC7999 HWY 82Carbondale, CO 81623Phone No:970.456.5325App. A-2
Exhibit:Date:8140 Partners, LLCTitle:Prepared by:Owner/Developer: Carbondale Investments, LLC7999 HWY 82Carbondale, CO 81623Phone No:970.456.532512/01/10App. A-3
Exhibit:Date:8140 Partners, LLCTitle:Prepared by:Owner/Developer: Carbondale Investments, LLC7999 HWY 82Carbondale, CO 81623Phone No:970.456.532512/01/10App. A-4
Exhibit:Date:8140 Partners, LLCTitle:Prepared by:Owner/Developer: Carbondale Investments, LLC7999 HWY 82Carbondale, CO 81623Phone No:970.456.532512/01/10App. A-5
Exhibit:Date:8140 Partners, LLCTitle:Prepared by:Owner/Developer: Carbondale Investments, LLC7999 HWY 82Carbondale, CO 81623Phone No:970.456.532512/01/10App. A-6
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
APPENDIX B: TREATMENT ALTERNATIV E DESIGN
SCHEMATICS
INTRODUCTION
The information presented in this Assessment has been prepared by William S. Otero P.E.
(Colorado Registration #32163) to provide evidence that the Project can be adequately
served by either the RFWSD or a privately-operated public sewage treatment works.
SEWAGE TREATMENT PLANT ALTERNATIVES
The provider of sewage service for the Project will ultimately determine what treatment
system is utilized or may be necessary to achieve CDPHE discharge standards. Two
operational alternatives have been identified for the treatment of wastewater at the
estimated flows for the Project (see Table II-1). One alternative is to execute a pre-inclusion
agreement to join the RFWSD and have the District provide service to the Project. Another
alternative is to develop a private wastewater treatment and collection system owned and
operated by the REC Property Owners Association (POA). Both options can adequately serve
the Project and technically meet the required CDPHE discharge standards. At the time this
Report was prepared, discussions were continuing with the RFWSD to determine if the
District could reasonably and cost effectively serve the Project with sewage treatment and
collection. CI will determine how best to serve the Project with these services based on
CDPHE requirements outlined in Site Location and Design Approval Regulations for Domestic
Wastewater Treatment Works (5 CCR 1002-22).
PRIVATELY-OPERATE WASTEWATER TREATMENT ALTERNATIVE
The collection system and wastewater treatment facility under the privately-operated
alternative would consist of newly constructed facility located on the Project Site (see
Attachment A, Exhibit 1) which siting is proposed and will be approved as part of the REC
rezoning and subdivision application. Based on an initial assessment and our review of
available water quality data for the Roaring Fork River, it is expected that the treatment
process could follow a traditional program for wastewater treatment plants (WWTP) in the
region and utilize industry accepted equipment to meet CDPHE established discharge
standards. In general, CI would be responsible for constructing and operating the collection
and treatment facilities necessary to provide sewage collection and treatment service to the
Project (see Table 1 for estimated flows), including (1) a new WWTP and associated building
located within Water and Wastewater Utility Tract (Tract AO or Tract AR), and (2) sewage
collection lines to appropriate County and CDPHE standards. The design of these collection
facilities discussed below.
App. B-1
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
Table 1: Project Wastewater Flows (REC Alternative)
Demand Estimation
Residential Units (EQRs) 366
Persons per EQR 2.70
Population 988
Residential Flow (gpd/EQR) 189
Residential Use (gpcd) 70
Total Residential ADD (gpd) 69,174
Non-Residential Area (sq. ft.) 30,000
Non-Residential Use (EQRs/1,000 sq. ft.) 9
Non-Residential Flow (gpd/EQR) 189
Total Non-Residential ADD (gpd) 1,701
ADQ including loss (gpd) 77,963
Peak Month Factor 1.5
PMQ (gpd) 116,944
Collection System
The onsite collection system has been designed to a preliminary level following RFWSD
standards, with the focus being on presenting the overall layout and general systems
coordination (i.e. relationship to other development features). Under this operational
configuration, the collection system will be owned and operated by the POA and all
collection facilities are located on the Project Site. The connections between the
collection system and the WWTP will occur directly at Tract AO. This connection will
either be through a new lift station transferring peak hour flows (approximately 220
gpm) through a 10-inch (minimum) force main to a new WWTP sited on Tract AR (see
Lift Station Calculations in Attachment A) or the WWTP will be sited in Tract AO (i.e.
direction connection between collection system and treatment facility). Although the
differential between the average and peak flows is expected to be relatively small due
to the system being new and unit occupancy remaining relatively constant (i.e. first
homes), approximately 20,000 gallons of equalization may still be required.
Treatment Process
Attachment A, Exhibit 2 presents a preliminary Process Flow Diagram (PFD) of one
potential process scheme (extended aeration) available for wastewater treatment,
many others exist. In this process, the major components of the treatment train would
be: (1) primary clarification, (2) extended aeration, and (3) secondary clarification at a
flow rate meeting the estimated Peak Month Flow (PMQ) of approximately 80 to 100
gallons per minute (gpm). WWTP equipment technologies vary greatly by vendor and by
process. The final selection of the equipment and treatment train will be based on many
factors, and designed to meet the required CDPHE discharge standards. The following
presents a general description of the extended aeration WWTP process:
App. B-2
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
Preliminary Treatment consists of screening and grit removal. The
screen removes course solids and other non-treatable debris from the
process stream, which are disposed of offsite. The grit chamber
removes grit, which is material with specific gravities substantially
greater than the organic solids (i.e. sand, gravel), prior to entering
primary treatment. The grit is dewatered and also disposed of offsite.
Primary Treatment consists of primary clarification, then extended
aeration followed by secondary clarification. Primary Clarification occurs
in a tank where water is retained long enough that heavy organic solids
can sediment (suspended solids). Efficiently designed and operated
clarifiers can remove from 50 to 70 percent of the suspended solids and
25 to 40 percent of the BOD. The effluent from the primary clarifier is
mixed with activated sludge and in the aeration tank the mixed liquor is
aerated. By aerating the mixed liquor the aerobic processes will be
stimulated and the growth rate of bacteria is increased. This increased
growth rate of bacteria creates flocks and gases. These flocks are
removed by the secondary clarifier.
Secondary Treatment consists of disinfection using chlorine (typically).
Disinfection at the end of the process makes the effluent free of
disease-causing organisms. Effluent from the chlorine contact tank will
then flow through a constructed conveyance channel followed by
wetlands before discharging to either Cattle Creek or the Roaring Fork
River.
Related Secondary Processes consist of sludge digestion and sludge
handling. Sludge from the clarifiers is digested through an aerobic
digester. The digested sludge is then dewatered and either hauled
offsite for disposal per CDPHE 301 Regulations or possibly used in the
creation of compost.
System Operation
Under this privately-operated alternative, it will be very critical that the process selected
be capable of meeting the demands throughout the year with little fluctuation in
discharge quality. In addition, because this WWTP will be the foundation for sewer
service, the plant will need to be fully automated to allow for continuous monitoring
and control. When starting up a new WWTP the most critical phases are those prior to
system build-out. The treatment and collection facilities are typically designed for some
selected build-out condition. Therefore, the interim operations must be carefully
monitored to ensure discharge requirements are met since facilities are normally
designed and constructed to serve a substantially larger population than would utilize
the system in the early periods of operation. In addition, until a sufficient number of
rate payers are available within the POA, CI would be responsible for ensuring the
operation and maintenance of the collection and disposal facilities are fully funded.
App. B-3
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
RFWSD Treatment Plant Description
The RFWSD treatment alternative would require the execution of a pre-inclusion agreement
between CI and the district. Under a Pre-inclusion Agreement, the RFWSD will include the
Project within its boundaries prior to the first final plat for the Project, and will provide
sewer service as set forth therein based on the flows presented in Table 2. Sanitary sewer
and wastewater treatment service will be provided pursuant to the following general terms
and conditions. In general, CI is responsible for funding and, in some cases, constructing the
RFWSD sanitary sewer facilities necessary to provide sanitary sewer service to the Project
and surrounding service area, including: (a) lift station within Water and Wastewater Utility
Tract (Tract AO) within REC; (b) sewer force main, a minimum 10-inches in diameter, from
the lift station across the Roaring Fork River to connect to existing RFWSD WWTP; and (c) an
additional 196,875 gpd of WWTP capacity on the RFWSD property located south and west of
the Project Site. Within the Project, CI is responsible for constructing (1) all sanitary sewer
lines to RFWSD standards including any over sizing, as may be specifically requested by the
RFWSD; (2) all sewer facilities necessary for the RFWSD to provide sanitary sewer service to
any unit within a particular subdivision filing, including, without limitation, additional lift
station(s), if necessary; and sanitary sewer lines and force mains. The design of these
facilities located within the Project is discussed in the Sewage Collection Design Report.
Table 2: Project Wastewater Flows (RFWSD Alternative)
Demand Estimation
Residential Units (EQRs) 366
Persons per EQR 3.50
Population 1,281
Residential Flow (gpd/EQR) 350
Residential Use (gpcd) 100
Total Residential ADD (gpd) 128,100
Non-Residential Area (sq. ft.) 30,000
Non-Residential Use (EQRs/1,000 sq. ft.) 9
Non-Residential Flow (gpd/EQR) 350
Total Non-Residential ADD (gpd) 3,150
ADQ including loss (gpd) 131,250
Peak Month Factor 1.5
PMQ (gpd) 525,000
Collection
The onsite collection system has been designed to a preliminary level following RFWSD
standards, with the focus being on presenting the overall layout and general systems
coordination (i.e. relationship to other development features). Under this operational
configuration, the collection system will be constructed by CI, but owned and operated
by the RFWSD. The connection between the collection system and the WWTP will occur
App. B-4
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
directly at Tract AO (see Attachment B, Exhibit 1). This connection will be through a new
lift station transferring peak hour flows (approximately 370 gpm) across the Roaring
Fork River approximately 2,000 linear feet through a 10-inch (minimum) force main to
an expended WWTP sited on existing RFWSD property (see Lift Station Calculations in
Attachment B). Although the differential between the average and peak flows is
expected to be relatively small due to the system being new and unit occupancy
remaining relatively constant (i.e. first homes), approximately 40,000 gallons of
equalization may still be required. Note, the force main will crossing impact a sensitive
river environment and while impacts are temporary, they can be avoided through the
alternative system.
Treatment Process
The RFWSD WWTP currently does not have adequate capacity to serve the entire
Project; therefore, an expansion is required. The RFWSD was planning an expansion of
its wastewater treatment plant, to a capacity of 0.321 million gallons per day. This
expansion was originally anticipated to be completed by approximately June 2010. Due
to the slowdown in housing development within the RFWSD, these expansion plans
have been placed on hold. The expansion will now be done later based on revised
estimates of anticipated growth. The RFWSD is solely responsible for the planning,
permitting and construction of such expansion. As stated previously, CI is responsible for
funding 196,875 gpd of plant capacity. Upon connection to the RFWSD's WWTP, the
Project would be entitled to receive wastewater treatment service from the expanded
WWTP.
The WWTP currently consists of: pre-treatment facility consisting of bar screening, and
aerated grit chamber and flow measurements, an extended aeration activated sludge
process followed by secondary clarification; sludge from the clarifier is either pumped
back to the aeration basin or pumped directly to an aerobic digester where the digested
sludge is hauled offsite for disposal, clarified wastewater is pumped to a mixed media
filter then to chlorination, finally the effluent flows through a natural wetland prior to
entering the Roaring fork River. It is expected that the expanded WWTP will follow the
same process as presented and coordinated with the existing system.
System Operation
The expanded WWTP will be operated in the same manner as the current plant and
collection facilities. The timing and phasing of the WWTP relative to the overall District
sewage system would be at the sole discretion of the RFWSD.
SITE LOCATION AND DESIGN APPROVAL CONSIDERATIONS
Based on CDPHE requirements for approval of a new WWTP, the following three points are
to be considered, at a minimum:
Consider the local long-range comprehensive plans for the area as they
affect water quality and any approved water quality management plan
for the area;
App. B-5
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
Determine that the proposed domestic wastewater treatment works
can be managed to minimize the potential adverse impact on water
quality and in accordance with the preliminary effluent limits
developed;
Encourage the consolidation of wastewater treatment works whenever
feasible with consideration for such issues as water conservation, water
rights utilization, stream flow, water quality, or economics.
As presented herein and in the main Report, all three of these points have been considered
and each of the two operational alternatives met the requirements of CDPHE for Site
Location and Design Approval Regulations for Domestic Wastewater Treatment Works (5
CCR 1002-22).
App. B-6
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
ATTACHMENT 1 : PRIVATELY-OPERATED ALTERNATIVE
SCHEMATICS
App. B-7
Estimated Flows
Average Flows Peak Flows
375 EQRs 375 EQRs
189 Gallon/EQR 189 Gallon/EQR
77,963 Gallons/Day 77,963 Gallons/Day
3,248 Gallons/Hour 311,850 Gallons/Day
54 Gallons/Minute 12,994 Gallons/Hour
217 Gallons/Minute
Sewage Pump Station Design
220 Q Pump Design Rate
550 Min. Pump Cycle Volume (V) in V=(Time)(Q)/4
10 Time (minutes)
220 Q (assumed)
6Diameter of wet well (assumed 6 to 8)
2.60 H=V/UV ‐ height between high and low levels
550 V
211 UV
423 V(tot)=HxUV
13 Cycle Time (T) =V(tot)/(Qd‐Qi)+V/Qi
5 Cycles per hour
River Edge Colorado
Lift Station Calculations (REC Alternative)
Static Head
5975 Pump Elevation
6040 High Point in force main
65 Approx. Static Head
Equivalent Length
1500 Force main length
20 Fittings
70 Manholes
1590 Total Equivalent Lengths (EQ)
Friction Head Total Dynamic Head
1.47 Hazen‐Williams Eq.66.47 feet
1.4 Velocity in force main (fps)
Design Pump Break Horsepower
10.39 HP =(Q*TDH)/(k*EFF)
3960 k
35% EFF
1/17/2011 1 of 1
River Edge Colorado
Lift station DesignApp. B-8
REC Private Potable Water and
Sewer System Standards
RFWSD Potable Water and Sewer
System Standards
Residential (Units) 366 366
Person per Unit 2.70 3.50
Residential (Population) 988 1,281
Residential Use (gpd/unit) 189 350
Residential Use (gpcd) 70 100
Residential Demand (gpd)69,174 128,100
Commercial (Sq. Ft.)30,000 30,000
Commercial Use (EQRs/1,000 sq.ft.)9 9
Commercial Use (gpd/EQR)189 350
Commercial Demand (gpd)1,701 3,150
Average Flow with I/I (gpd)77,963 131,250
Peak Month Factor 1.5 1.5
Peak Month Flow (gpd)116,944 196,875
Peak Factor 4 4
Peak Flow (gpd)311,850 525,000
Lift Station Capacity
Peak Hour Flow (gpd)311,850 525,000
River Edge Colorado
Project Wastewater Flow Calculations (REC Alternative)
Wastewater Treatment Plant Capacity
Peak Month Flow (Nominal Capacity) (gpd) 116,944 196,875
0
5,000
10,000
15,000
20,000
25,000
0:001:002:003:004:005:006:007:008:009:0010:0011:0012:0013:0014:0015:0016:0017:0018:0019:0020:0021:0022:0023:000:00GallonsHour
Equalization Storage
Hourly Flow
Avg Flow
Net Storage
1/17/2011
River Edge Colorado
Wastewater Flow CalculationsApp. B-9
Exhibit:
Date:
8140 Partners, LLC
Title:
Prepared by:
Owner/Developer:
Carbondale Investments, LLC
7999 HWY 82
Carbondale, CO 81623
Phone No:
970.456.5325
Wastewater Treatment Schematic 01/14/2011
1App. B-10
Wastewater Treatment Plant PFD
River Edge Colorado, Garfield County, Colorado
WASTEWATER TREATMENT PLANT
PROCESS FLOW DIAGRAM (EXHIBIT B)
Inflow from Collection System1
Outflow to Wetlands and Cattle Creek/Roaring Fork River2
Notes:
1. Final plant selection will be based on demand (phased), outflow quality standards and economics (construction and
operations). Many manufacturer specific systems are available for this level of demand (off the shelf), but the overall
processes remains fairly consistent with the graphic presented above.
2. Outflow from the plant will be conveyed to a constructed wetland prior to final discharge to either Cattle Creek or the
Roaring Fork River. Plant selection and management of wetland will be coordinated with CDPHE and RFC.
3. Dewatered sludge will be transported to an offsite disposal facility and/or integrated with onsite compost used in support
of community gardens.
4. Outflow quality testing protocols and standards will be set by CDPHE based on the selected process and the standards
established for the receiving stream (Cattle Creek/Roaring Fork River).
PMQ ‐ 116,944 gpd
Primary Treatment
(Screening and Grit Removal)
Aerobic Digestion
Primary Clarification
Aeration
Secondary Clarification
Disinfection
All Plant Operations
and Treatment Areas
will be housed in
buildings ‐ 70' x 40'
and 140' x 70'
Outflow Quality Testing4
Sludge Handling3
App. B-11
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
ATTACHMENT B: RFWSD ALTERNATIVE SCHEMATICS
App. B-12
Estimated Flows
Average Flows Peak Flows
375 EQRs 375 EQRs
350 Gallon/EQR 350 Gallon/EQR
131,250 Gallons/Day 131,250 Gallons/Day
5,469 Gallons/Hour 525,000 Gallons/Day
91 Gallons/Minute 21,875 Gallons/Hour
365 Gallons/Minute
Sewage Pump Station Design
365 Q Pump Design Rate
913 Min. Pump Cycle Volume (V) in V=(Time)(Q)/4
10 Time (minutes)
365 Q (assumed)
6Diameter of wet well (assumed 6 to 8)
4.32 H=V/UV ‐ height between high and low levels
913 V
211 UV
423 V(tot)=HxUV
12 Cycle Time (T) =V(tot)/(Qd‐Qi)+V/Qi
5 Cycles per hour
Static Head
Lift Station Calculations (RFWSD Alternative)
River Edge Colorado
Static Head
5975 Pump Elevation
5990 High Point in force main
5940 Low Point in Roaring Fork River crossing
5960 RFWSD WWTP Elevation (at MH 173)
50 Approx. Static Head
Equivalent Length
2050 Force main length
20 Fittings
140 Manholes
2210 Total Equivalent Lengths (EQ)
Friction Head Total Dynamic Head
7.37 Hazen‐Williams Eq.57.37 feet
2.33 Velocity in force main (fps)
Design Pump Break Horsepower
15.09 HP =(Q*TDH)/(k*EFF)
3960 k
35% EFF
1/17/2011 1 of 1
River Edge Colorado
Lift station DesignApp. B-13
REC Private Potable Water and
Sewer System Standards
RFWSD Potable Water and Sewer
System Standards
Residential (Units) 366 366
Person per Unit 2.70 3.50
Residential (Population) 988 1,281
Residential Use (gpd/unit) 189 350
Residential Use (gpcd) 70 100
Residential Demand (gpd)69,174 128,100
Commercial (Sq. Ft.)30,000 30,000
Commercial Use (EQRs/1,000 sq.ft.)9 9
Commercial Use (gpd/EQR)189 350
Commercial Demand (gpd)1,701 3,150
Average Flow with I/I (gpd)77,963 131,250
Peak Month Factor 1.5 1.5
Peak Month Flow (gpd)116,944 196,875
Peak Factor 4 4
Peak Flow (gpd)311,850 525,000
Lift Station Capacity
Peak Hour Flow (gpd)311,850 525,000
River Edge Colorado
Project Wastewater Flow Calculations (RFWSD Alternative)
Wastewater Treatment Plant Capacity
Peak Month Flow (Nominal Capacity) (gpd) 116,944 196,875
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
0:001:002:003:004:005:006:007:008:009:0010:0011:0012:0013:0014:0015:0016:0017:0018:0019:0020:0021:0022:0023:000:00GallonsHour
Equalization Storage
Hourly Flow
Avg Flow
Net Storage
1/17/2011
River Edge Colorado
Wastewater Flow CalculationsApp. B-14
Lift Station Schematic01/14/20112Exhibit:Date:8140 Partners, LLCTitle:Prepared by:Owner/Developer: Carbondale Investments, LLC7999 HWY 82Carbondale, CO 81623Phone No:970.456.5325App. B-15
Sanitary Sewage Disposal Plan (Sewage Management Plan)
River Edge Colorado, Garfield County, Colorado
APPENDIX C: PERMITTING ANALYSIS
App. C-1
13738\2\1491515.3
Memorandum
DATE: January 14, 2011
TO: Carbondale Investments, LLC
8140 Partners, LLC
FROM: Wayne F. Forman
RE: River Edge Project: Water and Wastewater Treatment Systems -- Federal and State
Approvals and Permits
I have been engaged by Carbondale Investments, LLC ("CI"), to assist with water rights and land use
matters related to the proposed development of the River Edge Project. I am a shareholder of the law
firm Brownstein Hyatt Farber & Schreck, LLP and have been practicing in the areas of water, land use
and environmental law for more than 25 years. I am familiar with the requirements for obtaining state
approvals for the location and design of domestic wastewater treatment facilities and for public water
supply systems, as well as the requirements for obtaining a permit for the discharge of dredged and fill
material into waters of the United States under Section 404 (33 U.S.C. §1344), and have handled such
matters as part of my law practice. Based on my experience and familiarity with the proposed River
Edge Project, I am not aware of any legal prohibitions to CI pursuing approvals for water and sewer
systems, either as independent systems or as part of the Roaring Fork Water and Sanitation District. I
have summarized the requirements for these processes below.
I. Site Location and Design Approval Requirements for a Domestic Wastewater
Treatment Plant.
Colorado Regulation 22 governs site location and design approval. The Department of Public Health
and Environment's Water Quality Control Commission implements the regulation. The regulation
applies to the construction of domestic wastewater treatment works, including wastewater treatment
plants, with a capacity of 2,000 gallons per day or greater. 5 CCR 1002-22.1(2).
A. Site Location Approval.
Application procedures for the construction of a new domestic wastewater treatment works are
explained in section 22.4 of the regulations. The applicant must submit approved forms and a
comprehensive engineering report to certain local authorities, as well as to the Division. 22.4(1).
The engineering report must address the applicant's ability to manage and operate the facility for the
life of the project, as well as the proposed site location, the service area including existing and projected
populations, anticipated water quality impacts and anticipated effluent quality, loading and capacity,
evidence that the proposed location will not be affected by floodplain or other natural hazards,
App. C-2
2
13738\2\1491515.3
operational staffing needs, legal arrangements showing control of the site, management capabilities,
the financial system developed to provide necessary capital, implementation plans and construction
schedules, and various other related issues. 22.4(1)(b)(i-xiv). Additionally, prior to submitting the
application the applicant must consider how its effluent will affect local water quality, and should discuss
the development of Preliminary Effluent Limits (PELs) with the Division. 22.4(1)(b)(iii).
i. Consolidation Analysis.
A significant aspect of the site approval process is the consolidation analysis. 22.4(1)(b)(v); 22.3(1)(c).
Pursuant to the regulations, the Division is required to "encourage the consolidation of wastewater
treatment works whenever feasible." In making this determination as part of the site location
application, the Division will consider various factors including the economic viability of consolidation.
If it is demonstrated to the satisfaction of the Division that any one of the following would make
consolidation infeasible, no further analysis of consolidation is required.
Water Conservation – If consolidation would impair water conservation efforts of the new or existing
affected treatment works;
Water Rights Utilization – If consolidation would alter the discharge of effluent in a manner that
would impair the water rights of one of the parties to the consolidation;
Stream Flow – If consolidation would alter flows in a stream or stream segment or transfer a
sufficient amount of water to another stream or stream segment so as to result in (1) overwhelming
adverse environmental effects on either stream, or (2) the lowering of the effluent limits of other
treatment works so as to cause the need to install additional, advanced secondary or tertiary
treatment processes;
Water Quality – Where consolidation has the potential to degrade the surface and/or groundwater
quality; or
Economics – Unless one of the above factors results in a determination that consolidation is not
feasible, the applicant must submit a comparative analysis of the cost of consolidating versus the
cost of constructing separate facilities. All costs, including land acquisition, capital construction,
and debt retirement expenses, among others, must be considered. If the cost of consolidation
exceeds the cost of separate plant construction by more than 30%, no further analysis of
consolidation is required.
If, after considering the above factors consolidation is still an option, the Division will also consider the
following factors. If any of these would make consolidation infeasible, no further analysis of
consolidation is required.
Distance – If the distance to the closest existing/ proposed wastewater treatment works is less than
five miles, an analysis of the cost-effectiveness of consolidation must be included. If the distance is
five miles or greater, no further analysis is required.
Threatened or Endangered Species – If threatened/endangered species inhabit or utilize the only
site that could serve as a consolidated treatment works or through which interceptor lines must
pass, no further analysis is required.
Local Plans – If a local water quality management plan anticipates multiple treatment works, then
no further analysis is required.
Service Area – If the service area of a proposed facility is within the service areas of a district or
municipality providing wastewater treatment service, the applicant must explain why the district or
municipality is not the applicant.
B. Design Approval.
The design approval process is detailed in Section 22.11(1) and (2). For new domestic wastewater
treatment plants, design review is a two step process. After receipt of site location approval, the
App. C-3
3
13738\2\1491515.3
applicant must submit a "Process Design Report" (PDR) to the Water Quality Control Division. The
Division will review the Report and will issue a written approval of the PDR once it is determined that
the PDR meets all regulatory requirements.
After receipt of PDR approval, the applicant is required to submit the "Final Design – Plans and
Specifications." The information must be entirely consistent with the PDR. The Division reviews the
Final Design plans and issues written approval of the Design, which represents approval for
construction.
Finally, after the facility is constructed, the applicant's professional engineer must certify at the
completion of construction that the treatment works was constructed according to plans and
specifications as approved by the Division.
II. Discharge Permit Requirements for a Domestic Wastewater Treatment Plant.
Domestic Wastewater Treatment Facilities that discharge to surface water must comply with Colorado
effluent discharge permit and monitoring requirements. The nature of the permit process will depend
on whether the treatment plant discharges to classified or unclassified waters. As part of the
application, the owner must certify to which type of water it will discharge, that the hydraulic design
capacity of the facility is less than one million gallons per day, that no pre-treatment plan is required,
among other things.
The permit contains specific effluent limitations for various pollutants, such as TSS, pH, E/Coli,
phosphorus, and others. Limits are based on statewide limits, but site-specific limitations may be
developed on a case-by-case basis.
The permit also contains monitoring, sampling and reporting requirements.
III. State Requirements for Public Water Supply System.
The Colorado Water Quality Control Division has developed design criteria for public drinking water
facilities.1 The approval of a new facility is based upon the Division's determination that the facility will
be able to meet Colorado's Primary Drinking Water Regulations. 5 CCR 1003-1.
Approval of a Public Water System is not dissimilar from the approval of a wastewater treatment works.
Initially, the party seeking to construct a new system must submit an application to the Division. The
application must be signed by the responsible party, and must be submitted no less than 45 days prior
to the planned construction start date. The Division will approve, conditionally approve, or deny the
application. It may also seek further information.
The application must include, with a professional engineer's seal, a final copy of the technical
specification and blue prints for the facility. Detailed plans must fully comply with the requirements
enumerated in the state's "Design Criteria for Potable Water Systems."
The application must also include a final design report that fully explains the scope of the project, the
raw water's characteristics, and the various alternatives considered. Ultimately, the system must be
constructed in accordance with the approved plans. Any changes that are not deemed "minor" require
the submission of revised plans and specifications that must be approved by the Division. In addition, a
new system must submit a detailed description of the treatment process that will be employed and the
unit's designed loading rates.
1 The Division has published a comprehensive Design Criteria handbook, available online at:
http://www.cdphe.state.co.us/wq/engineering/pdf/DesignCriteriaPotableWaterSystem.pdf
App. C-4
4
13738\2\1491515.3
The County and Local health and planning departments must approve all water treatment facilities. It is
the applicant's responsibility to secure these approvals prior to applying to the Division for an approval
to construct.
Other items that must be addressed or included in the application:
Flood Plain Certificate – waterworks cannot be located within the plain of a 100-year flood event.
All new water systems must submit a 100-year flood plain certification signed by a professional
engineer.
Inventory Form – the form includes information regarding the approximate number of people served
by the system, owner and operator names and information, and types of treatment that will be
used.
Chemical analysis – one copy of a raw water chemical analysis from a certified lab must be
submitted. The test must include results for nitrate, nitrite, sodium, temperature, pH, alkalinity,
calcium, total dissolved solids, and certain organic and inorganic chemicals.
Lead and Copper assessment – new systems must include a chemical analysis for lead and
copper.
Managerial Plan – A comprehensive management plan must be submitted. It must describe all
aspects of how the facility will be run, including such aspects as the facility's sampling and analysis
program, staffing and training needs, safety, and the legal basis for the facility's existence.
Financial Plan – The financial plan must include, at a minimum, the expected costs for operating
the system and the fee structure for at least five years.
The Design Criteria also address requirements relating to the construction of an Infiltration Gallery.
Once the gallery construction is completed, a microscopic particulate analysis will be performed on the
product water. Infiltration galleries determined to be influenced by surface water must meet all surface
water filtration requirements.2
Design requirements pertaining to infiltration galleries include:
Galleries should not be constructed within the 100 year flood plain, or if it is necessary to do so they
should be protected from a 100 year event;
Galleries should not be constructed in close proximity to a waterway to avoid intrusion of surface
water; and
Infiltration lines should be under the control of the water purveyor to prevent entrance to the system
from unauthorized persons.
A number of other requirements are enumerated in the Design Criteria, as well.
2 Colorado's surface water treatment rule applies to all Community Water Systems serving 10,000
people or more. The rule includes a variety of treatment, monitoring, recordkeeping, and public notice
requirements.
App. C-5
5
13738\2\1491515.3
IV. Federal Clean Water Act Permitting Issues.
The federal Clean Water Act forbids the discharge of any dredge or fill material into navigable waters
unless authorized by a permit issued by the United States Army Corps of Engineers pursuant to Section
404 of the Clean Water Act ("404 permit"). The Roaring Fork District has proposed that, as a condition
of inclusion, CI must install a sewer pipe across the Roaring Fork River to the District's existing
wastewater plant and install a water line across the River to connect to the water system within the Iron
Bridge development. Since the construction of pipelines across the River will invariably involve
dredging of, and discharges into, the River, a 404 permit will be required.
The Corps of Engineers is authorized to issue two basic types of 404 permits: a nationwide permit; and
an individual permit. Nationwide permits authorize categories of activities that are recognized to cause
minimal adverse environmental effects. All told, the Corps has issued 50 nationwide permits.
If a party determines its actions fall within the terms of a nationwide permit, generally the party must
notify the Corps District Engineer of its intent to commence construction under the nationwide 404
permit. The District Engineer will review the pre-construction notification to determine if the activity falls
within the permit's terms. The District Engineer, after considering comments from federal and state
agencies, will authorize or deny the project. The District Engineer may also require modifications of the
project or mitigation for the project's impacts.
In the alternative, individual 404 permits are issued for projects that do not fit within nationwide permits
following a case-by-case evaluation of the projects. The individual permitting process is generally
considered to be much more comprehensive, time consuming, and expensive than use of a general
permit. Under the 404(b)(1) Guidelines adopted by the Corps and the EPA, Applicants for an individual
permit must demonstrate that the discharge of dredged or fill material would not significantly degrade
the nation's waters and that there are no practicable alternatives less damaging to the aquatic
environment. Applicants must also describe steps taken to minimize impacts to water bodies and
wetlands and provide appropriate and practicable mitigation, such as restoring or creating wetlands, for
any remaining, unavoidable impacts. The application itself is a voluminous document that includes a
comprehensive project plan for review by the Corps, a purpose and need analysis, an avoidance,
minimization and public interest analysis and a mitigation plan. The cost for compiling this information
is significant. To issue an individual permit, the Corps would have to prepare an Environmental
Assessment, or potentially an Environmental Impact Statement, which would further protract the
permitting process by six months to a number of years.
Following submission to the Corps, an application for an individual permit will be subject to public
comment and a public hearing, and generally entails significant interactions with both the Corps and the
EPA.
In order to avoid the significant delay generally associated with pursuit of an individual 404 permit, CI,
or the Roaring Fork District, would likely pursue the use of nationwide permits 7, 12 or 29 to construct
the pipelines across the River.
Nationwide Permit 7 authorizes discharges of dredged or fill material related to the construction or
modification of outfall structures and associated intake structures where effluent from the outfall is
authorized by a discharge permit. CI may rely upon this permit for its intake structure in the event it
constructs a surface water treatment plant, and for a sewage treatment plant outfall which will be
permitted through the CDPHE.
Nationwide Permit 19 authorizes activities for the construction, maintenance, repair and removal of
utility lines, including water and sewer lines, and associated facilites where the activity does not result in
the loss of greater than ½ acre of waters of the United States. And Nationwide Permit 29 authorizes
discharge of dredged or fill material associated with the construction of residential subdivisions,
App. C-6
6
13738\2\1491515.3
including "attendant features", which may include the construction of utility. To be eligible for permit
coverage, the discharge must not cause the loss of greater than ½ acre of the river, and loss of no
more than 300 linear feet of stream bed.
While these nationwide permits may be available to authorize a pipeline crossing of the River, the fact
that two crossings may be required as a condition of inclusion into the Roaring Fork District could result
in greater than a ½ acre of disturbance in waters of the United States, thus precluding reliance on
Permit 12. Each permit requires that the activity authorized be a "single and complete project," and that
the same nationwide permit cannot be used more than once for the same "single and complete project."
Federal regulations define a "single and complete project" as "the total project proposed or
accomplished by one owner/developer." 33 C.F.R. § 330.2(i). The regulation further explains that "if
construction of a residential development affects several different areas of a [river], the cumulative total
of all filled areas should be the basis for deciding whether or not the project will be covered by the
Nationwide General Permit." Id. Therefore, the impact of both crossings and any other activities in the
River or adjoining wetlands must be considered in the aggregate when determining whether or not a
nationwide permit may be used. To the extent the pipeline crossings result in dredging or discharges
that exceed the nationwide permit acreage limit, the Project will likely have to pursue an individual
permit.
App. C-7
Attachment B RFWSD Will Serve Letter