HomeMy WebLinkAboutNew Design Request from Public Health 05.26.2026Garfield County Public Health Department – working to promote health and prevent disease
Public Health
195 West 14th Street 2014 Blake Avenue
Rifle, CO 81650 Glenwood Springs, CO 81601
(970) 625-5200 (970) 945-6614
Aspen Waldorf Foundation May 26, 2026
16543 Highway 82
Carbondale, CO 81623
c/o Josh Ervin and Brie Fitzsimmons
Subject: OWTS Not in Compliance
Waldorf School on the Roaring Fork
16549 Highway 82
Carbondale, CO 81623
Josh and Brie,
This letter is to inform you that Garfield County Public Health (GCPH) has determined that your OWTS
located at 16543 Highway 82 near Carbondale is not adequate to treat the wastewater generated by
the Waldorf School on the Roaring Fork.
GCPH provided correspondence and permit conditions to allow the like-for-like replacement of the
failing septic tanks at the campus on June 18, 2025, with subsequent agreement to the conditions by
the Waldorf School in a letter dated June 20, 2025. The two letters are included as Attachments A and
B for your review. All conditions must be met prior to GCPH issuing a final acceptance letter for the
permit.
Testing of the effluent conducted on April 21, 2026, showed concentrations of 221 mg/L BOD5 and 47
mg/L TSS in the effluent discharging to the Soil Treatment Area (STA). The limits to classify the effluent
as Treatment Level 1 (TL1) strength are a BOD5 concentration less than 180 mg/L and a TSS
concentration less than 80 mg/L, according to Table 7-2 of the Garfield County OWTS Regulation.
Therefore, this system is not adequate to treat the wastewater produced by the Waldorf School and is
not in compliance with the Garfield County OWTS Regulation. As required by the permit conditions
agreed upon, Waldorf shall provide the following to our office by June 30, 2026:
Condition #3: Waldorf School on the Roaring Fork shall submit a new design to treat the
wastewater to TL1 concentrations for BOD5 and TSS prior to discharging to the existing STA.
Condition #4: Waldorf School on the Roaring Fork shall submit an inspection report for the
existing OWTS.
Garfield County Public Health Department – working to promote health and prevent disease
The existing permit will expire on June 26, 2026, and will need to be renewed. Depending on the
proposed design to bring this OWTS into compliance, additional permit fees may be required. Please
contact our OWTS email at owts@garfieldcountyco.gov or our OWTS phone line at (970) 945-6614
extension 8150 to discuss permit renewal instructions, if you have questions, or to discuss this letter.
Sincerely,
Edward R. White, P.E.
Environmental Health Specialist III
Garfield County Public Health
cc: Jannette Whitcomb, REHS, Garfield County Environmental Health Manager
Teresa Bianco, Garfield County community Development Permit Technician
Brooke Winschell, Garfield County Community Development Technician
Garfield County Public Health Department – working to promote health and prevent disease
ATTACHMENT A
Garfield County Public Health Department – working to promote health and prevent disease
Public Health
195 West 14th Street 2014 Blake Avenue
Rifle, CO 81650 Glenwood Springs, CO 81601
(970) 625-5200 (970) 945-6614
Aspen Waldorf Foundation June 18, 2025
16543 Highway 82
Carbondale, CO 81623
c/o Josh Ervin and Dana Ellis, AIA
via email: josh@waldorfschoolrf.com; dana@outpoststudioco.com
On May 28, 2025, Garfield County Public Health (GCPH) received correspondence regarding the Onsite
Wastewater Treatment System (OWTS) minor repair permit application for the Waldorf School on the Roaring
Fork located at 16543 Highway 82 near Carbondale in Garfield County, Colorado from Dana Ellis of the Outpost
Studio, LLC. Dana explained that the wastewater flows for the current OWTS were designed to factor in the
flexible use of a school community. Various programs at the school contribute to a fluctuating school population,
which is rarely fully occupied. Water meter readings for 2024 indicate an average water usage of 891 gallons per
day (gpd) and a maximum water usage of 1,118 gpd. The school has operated under a maximum water usage of
1,508 gpd, which corresponds to the current OWTS design flow and tank sizing.
GCPH has reviewed your proposed plan to use Section 43.6.A.4.a.(2) of the Garfield County OWTS Regulation
utilizing water meter readings rather than wastewater flows provided in Table 6-2. The current plan provides the
water usage but is missing the wastewater strength parameters required to use Section 43.6.A.4.a.(2). Strength of
the wastewater is an important component to ensure that at least Treatment Level 1 (TL1) effluent is exiting the
final septic tank in the system before application to the Soil Treatment Area (STA), as required in Garfield
County OWTS Regulations Section 43.6.B.2. Section 43.6.A.4.a.(2)(ii) defines the parameters that shall be
included to determine if the wastewater is classified as high strength. Testing of the effluent should occur during
full occupancy periods, to capture the “worst case scenario”, so during the school year.
The Waldorf School proposes replacing the existing septic tanks which currently present a safety hazard in the
play yard with similar sized tanks as the first step in the total evaluation of the OWTS and provide the required
wastewater testing at a later date. Given this piece of the calculation needs to be when school is in session, GCPH
is willing to issue a minor repair permit for the tank replacement and approve of the septic tank “like-for-like”
permit, with the following conditions:
1. Water use shall continue to be metered. Notification shall be provided to GCPH if usage exceeds 1,500
gallons per day.
2. Testing of the wastewater effluent shall occur during a day of full occupancy and results shall be provided
to GCPH for review. The proposed sampling day shall occur no later than October 1, 2025.
a. Testing shall include BOD5 and Total Suspended Solids for evaluation for high strength
wastewater.
b. Sample location shall be the outlet of the final septic tank before application to the STA.
3. If the test results indicate the wastewater is high strength, a new design to treat the wastewater to TL1
levels shall be designed and the Waldorf School shall apply for an appropriate OWTS permit for the
design.
4. An inspection of the entire OWTS (including the STA) by a qualified OWTS professional (as defined
below) is required as part of a minor repair permit process. A report of the inspection will need to be
submitted to GCPH.
Garfield County Public Health Department – working to promote health and prevent disease
a. A “qualified OWTS professional” for the purposes of providing an inspection report on the
current condition of an existing OWTS is defined as an individual that meets the following
requirements:
i. A NAWT certified OWTS inspector; or
ii. A professional engineer licensed in the state of Colorado with OWTS experience; or
iii. An individual with previous OWTS experience who can evaluate the condition of an
OWTS, can determine if the system is in good working order and is functioning as
intended, and can provide documentation indicating how the assessment of the OWTS
was conducted.
b. The minimum requirements for an OWTS inspection report are:
i. Size of the existing septic tank;
ii. Size of the existing Soil Treatment Area (STA, commonly known as a leachfield);
iii. Distribution media of the STA (chambers, rock and pipe, unlined sand filter, etc.);
iv. Condition of all existing OWTS components;
v. Site plan showing locations of all OWTS components relative to building(s) on the
property;
vi. Description of how the determination of the condition of OWTS components was made.
The Waldorf School shall provide a letter on school letterhead indicating that they agree to these conditions and
the OWTS inspection report prior to GCPH issuing a permit. All conditions shall be met prior to GCPH issuing a
final acceptance letter for the permit. If these conditions are not met, GCPH will pursue compliance through the
Notice of Violation process. Contact me with questions.
Sincerely,
Edward R. White, P.E.
Environmental Health Specialist III
Garfield County Public Health
cc: Jannette Whitcomb, REHS, Garfield County Environmental Health Manager
Teresa Bianco, Garfield County community Development Permit Technician
Brooke Winschell, Garfield County Community Development Technician
Graham Jackson, Garfield County Assistant County Attorney
Garfield County Public Health Department – working to promote health and prevent disease
ATTACHMENT B
• 16543 Highway 82 Carbondale, CO 81623 • 970-963 -1960 (phone) • 970-963-1066 (fax) •
• www.waldorfschoolrf .org • email: info@waldorfschoolrf.org •
Garfield County Public Health June 20, 2025
2014 Blake Ave
Glenwood Springs, CO 81601
Dear Edward White,
We, Waldorf School on the Roaring Fork, accept your terms and conditions for a minor
repair permit to replace our septic tank “like-for-like” outlined as follows:
1. We will continue to meter our water use and notify GCPH if usage exceeds 1,500
gallons per day.
2. We are scheduling testing of the wastewater effluent for a date in September
2025 when we are at full occupancy. Testing will include BOD5 and Total
Suspended Solids. The results will be provided to GCPH.
3. If test results indicate the wastewater is high strength, we will determine how to
treat the wastewater to TL1 levels and apply for an appropriate OWTS permit for
the design.
4. We have a qualified OWTS professional that will conduct an inspection on the
entire OWTS (including STA) and supply a report to GCPH.
The “like-for-like” septic tank replacement is scheduled for June 30th. We have
designated this week when our campus is closed to allow for this work to be completed
safely. Our OWTS professional will be onsite during install as well.
We appreciate your willingness to work with us and approving a minor repair permit to
replace our septic tank “like-for-like”.
Sincerely,
Brie Fitzsimmons
Business Administrator
Waldorf School on the Roaring Fork