HomeMy WebLinkAbout2.0 Staff ReportREQUEST:
APPLICANT:
ENGINEERS:
LOCATION:
BOCC 5116104
MB
PROJECT INFORMATION AND STAFF COMMBNTS
Application tor Site Approval for Construction of a
new Domestic Wastewater Treatment Facility at the
RaPids on the Colorado'
The Rapids Development Corporation
Martin/Martin, lnc'
Rapids on the Colorado is located in portions of
il;*"t 4 and5, T 6 S, R 91 W of the P'M' It is
ir"t" pt*,icallv located appr"*iT1t:].Y-'3::
I. SUMMARY OR REQUBST
Rapids Development Corporation is proposing the
construction of a wastewater treatment facility
iJwir"l at the Rapids on the Colorado
subdivision.
The image to the right shows the location of the
G"t ,ibdiririo, ir relation to the Town of New
C"t,f". The subdivision is located in the lower
f,ft-qr'ruarunt of the illustration' Apple Tree
*"Uii" home park is in the center and the Town of
New Castle is in the upper right quadrant of the
picture.
II. DESCRIPTION OF THE PROPOSAL
The Rapids on the colorado is a92.z69acre tract thar was subdivided into 33 single family lots in
1997. Al1 of the lots are served by a central water system "pfti"o
by two (2) on-site water wells and
wastewarer is to be treated by enginee;;';; iuntt' unajiutr' ntra'' No building permits have
been issued for the J"'"fop-"nt since the original platting'
Request: The Rapids Deveropment corporation is requesting Site Apprication approvar to construct a
wastewater Treatment Facility (,.Sequencing Batch Reactor tsBni svstem") to.rreat all wastewater
generated from a proposed Planned U'* il;lop*"nt to'ois rrabo I p"t duy) ' The effluent will
then be discharged into the cororado River. the ,,servi ce ared' wilr consist of the existing
subdivision una u o+- ire tfact southeast of the existing subdivision'
^ I;:'#'iu],;:il;;",*ent racility wourd serve a proposed puD with 121 dwelling units to
be located on the existing ezu"r."ilupi;; ", it'" coto'uao subdivision property and
expandable to the previously noted Oi ui'"tract to the southeast of the subdivision' There
would not be u'y io*"rcial users in the area'
-.
H:t;;|:Jf,TJ"m w,l consist or a Sequen"ilg_11,:h Reacror (sBR) treatment racilitv'
The SBR system will have a plant t;;il;;olis yo," to serve a proposed PUD and has
a flow rate of approximatery +s,ooo [Jrioi. p", o^v !gq9j A, not"d earlier' the effluent will
be discharged inio the cororad" Ririlil;tiro* unJirign ry downstream from the facility'
..
I,TH3L:,iil1s:::.'Jr'j;'J.t,is not locared in the service area of an existing provider or
201 plan. The property is not r*""0"i, ite New castle or Silt 201 planning areas'
D. Hazards
AccordingtothereportcompletedbyZancanella&Associates,theproposedtreatment
facility is not i*o"a in the iden,in"a roo-y"u, noooplain. The Applicant submitted.a
georechnic.r ,rroi""raucted uy.Hr c*r".t, *t i"r, ultimately indicated thar the properry rs
suitable for the proposed devetofment based on geologic conditions and there are no
geologic trazardsihat would p'"'"" the development as proposed'
E. Description of Selected Alternative
The selected alternative is a Sequencing Bath Reactor (SBR) ffeatment facility' The SBR
system has the ability to act u, u"'"qr"ii zattonbasin, aeration basin' and clarifier within a
single reactor. An SRB "un ""u'nl*'
f'o,o a few thousand gallons to-millions of gallons
per day, with a high quality final effluent. The system desigi will be based on a peaking
factor of 2, but .un u..o,,,*oau,"-u pJ"rl'g factoi or + ii noi's exceed the maximum daily
flow. The SBR process was selected as the recommended treatment process based on the
following;
o Small land area required
ital cost and also can be operated with
o Low cost - an SBR facility has the lowest cap
the lowest operation and maintenance cost'
'
o Reliabitity - the system has the ability to continuously operate for extended periods'
under varying conditionJanJ wittr minimal downtime due to major maintenance'
The SBR has the ability to produce "o,,i,t",,iol",llt ",flT1:,der
varying load
conditions.Itincludesequipmentredundancytofacilitateroutinemaintenanceand
capabilitytoopelated,.ing.powerfailureandmajormaintenance.
o Flexibility- the sBR proclr, .un be adjusted to meet a wide variety of influent
compositions and effluent requirements.
"it"
sy*"m offers redundancy' and
"upu'Uitity
to handle peaking flows'
oRegulatoryCompliance_ThesBRwitlmeetCDPHE,sdesignrequirementsandwill
t'Ii,::l,ll?lE;ffi','1ffi:tBRl*,n11'l:"11T,:yi:1,:T::?il:ill"'ffi ?.
can be covered *or"-".onomica11y. a"#"' it " rvtt"* mitigates the potential for
odor.
Expandabitity-thesBRhastheabititytoaccommodateadditionalcapacity
expansions.
F. Treatment Alternatives 1L^- ^6 .ito ,nrl off The appiicant
The Applic*, *rlii"rld several other on-site and off-site alternattves'
reviewedutt"*uti"connection"";';;;il1:1y:ttt*:n:,.n:ilff :;T#:itt':
::l*::*'['*:f:'};I,il:il:::;'i;J
":*"ffiI]"]"
"
I e as'[ o*ow n * u' "*pt
o'e d an d
determined to economically prohibitive'
AfteralengthydiscussionwiththeTownofNewCastle,theapplicantenteredintoa
Memorandum of Understanding wilh;; i"*'' ft'" rt'rOU 'uppottt
the approval of the
proposed ,"*ur";;;;' facility' with a number of stipulations'
Thetreatmentalternatives,ActivatedSludgeandAeratedLagoonSystem,werenot
chosen due to ffeatment limitations, targ"itano urea requirements' and proximity to
residential development, limited maxirrirm BOD removat ano being visually
unaccePtable'
G. Effluent Limitations
Asnoted,theproposedfacilitywilldischargetheeffluentintotheColoradoRiverbelowthe
facility. Th. c;i;*d" River i, thJ;;; iilassified for the following uses:
Cold Water Aquatic Life Class 1
;il la Existing Primary Contact Recreation
Agriculture
Water SuPPtY
To ensure these uses are protected, the colorado Department of Health andEnvironmenthas
estabrished preriminary effluent limits iprr-o foltle propoia facility' The PELs establish
the warer quality l^inJi, ortn" oir"rrurg.'lr. 4e a"ro'udo Ri'"r' which are monitoredby the
colorado ,"p**"r, of puuti. g.ut?t and Environment (CDPHE) for compliance'
II. OPeration & Maintenance
The fac,ity will be operated and mainrained by a State certified operator' Initially' the
Rapids Development corporation *liiu" financially '"'pon'iur"
for,the;-lstruction and
initial start-up of the facility. On"" it'" iu"ility is U"*t' ii i' ptopot"d to turn it over to the
homeowner,s association and ," *;-; rr*iat districiio "oniin,e
the operation of the
facilitY.
I. Facility Cost / Implementation Plan and Schedule
1)
2)
3)
4)
Theproposedfacilityisestimatedtocost$616,140.00.Itwasestimatedinaprevious
application, if,u,,t" *r,.rut op"*li"g "".i;lf \A"Slii+O,
based on a flow of 0'060 MGD'
This would t"q'itt a charge of $:t'ZSltnonthr/tap'
III. STAFF COMMENTS
Statestatutes:C.R.S.25-8-702(2)(a-c),uid.h:...RegulationsforSiteApplicationsfor
Domestic Wastewater Treatmeniw"irtt;:'otnn"' tr" iuiu*titrs bv whi'lhtheWater Quality
Control Division ("Division'1'f'1fi^*i'fo* "'11?fi*" o' Ae'nV I site application for a
wastewater treatment works. The Division i, ,"qoirJJ ro o.i"r** thlleach site rocation is
1) consistent with the rong."r;;;;;r"tr"r.iu",pi"rtitg for tJ1-11it which it is to be
located; 2) thatthe plant * tht;;;;"J J-e, *l']]e ma:naged to minimize the potential
adverse impacts on water quality'; ur,o r) must "ncourage
ttrJ consolidation of wastewater
treatment works whenever feasible'
TheApplicantisrequiredtoobtainarecommendationofapproval,denialorcolnmentoniy
from the Garfield county go*d;Hearth and c"rr;;;;;i of county commissioners and
various other local and regional agencies'
Therefore,GarfieldCounty,sinvolvementintheprocessisto..reviewand
commentupontherelationshifoftheq:ament:v:rkstothelocallong-range
comprehensiveplanfol.h:,"uu,itaffectswaterquality'proposedsitelocation
alternatives including the location with respect to tht nood-ptain' and capacity to
serve the Planned develoPment'"
A. Relationship to the Comprehensive Plan
ThemainmechanismwithwhichtheBoardevaluateswhetherolnotaproposed
wastewater treatment f""ii;yit "rqt+rate
is*tne Comprehensive Plan and whether or
nor the proposal is consistent wittLitre long-range plan oi the a1'a' Garfield county does
nothaveaZOgwater*"r"r"*"rtt1l;it'it'Jc"roradoRiverArea'TheGarfield
county comprehen.ir" illi%iiooo io"ntin".1r'" Rapids on the colorado property
Outlying Residential p"n'iiy' i "t'"11 y't *^a U"i'g *i't'* thlJown of New Castle Two
Mile Sphere of tnfluen..;;;itt"i, g-Nail" A';;;;'ndary' The existing subdivision is
consistent with the recommended density of 2 ac'ld'tt"
section 10.0 urban Area of Influence, defines the rerationship between the county and
Municipallandusepori"i*undaspecificpolicyaddressesthisissue:
Policyl0.lComprehensivePlanZollrngResolutionrevisions,TnneDistrict
Amendments and inairi-ouaii-i""* *itt'in?"nned urban Areas of Influence' will be
consistent with local municipal land use policies'
TheabovepolicygivesrecognitiontotheTownofNewCastleComprehensivePlanand
PROJECT INFORMATION AND STAFF COMMENTS
BOCC 5tr6t04
MB
Application for Site Approval for Construction of a
new Domestic Wastewater Treatment Facility at the
Rapids on the Colorado.
The Rapids Development Corporation
Martin/Martin, Inc.
Rapids on the Colorado is located in portions of
Sections 4 and 5,T 6 S, R 91 W of the P.M. It is
more practically located approximately 2 miles
south and west of New Castle and south of I-70.
REQUEST:
APPLICANT:
ENGINEERS:
LOCATION:
SUMMARY OR REQUEST
Rapids Development Corporation is proposing the
construction of a wastewater treatment facility
("WTft"; at the Rapids on the Colorado
subdivision.
The image to the right shows the location of the
Rapids subdivision in relation to the Town of New
Castle. The subdivision is located in the lower
left quadrant of the illustration. Apple Tree
mobile home park is in the center and the Town of
New Castle is in the upper right quadrant of the
picture.
II.DESCRIPTION OF THE PROPOSAL
The Rapids on the Colorado rs a92.269 acre tract that was subdivided into 33 single family lots in
1997 . All of the lots are served by a central water system supplied by two (2) on-site water wells and
wastewater is to be treated by engineered septic tanks and leach fields. No building permits have
been issued for the development since the original platting.
Request: The Rapids Development Corporation is requesting Site Application approval to construct a
Wastewater Treatment Facility ("Sequencing Batch Reactor (SBR) System") to treat all wastewater
generated from a proposed Planned Unit Development (0.045 MGD / per day).. The effluent will
then be discharged into the Colorado River. The "service atea" will consist of the existing
subdivision and a 64 acre tract southeast of the existing subdivision.
A.Projected Service
Speiifically, the rreatment facility would serve a proposed PUD with 121 dwelling units to
be located on the existing gJacre Rapids on the Colorado subdivision property and
expandable to the previously noted 64 acretract to the southeast of the subdivision' There
would not be any commercial users in the area.
Wastewater Flow
The proposed system will consist of a Sequencing Batch Reactor (SBR) treatment facility.
fhe 3gn sysrem will have a plant capacity of 0.045 MGD to serve a proposed PUD and has
a flow rate of approximately +5,000 gallons per day (gpd). As noted earlier, the effluent will
be discharged into the Coloiado River just below and slightly downstream from the facility.
Water and Sanitation Districts
At present, the proposed property is not located in the service area of an existing provider or
20i plan. The property is not located in the New Castle or Silt 201 planning areas.
Hazards
According to the report completed by Zancanella & Associates, the proposed treatment
facility is not located in rhe identified 100-year floodplain. The Applicant submitted a
geotechnical study conducted by HP Geotech which ultimately indicated that the property is
iuitabte for the proposed development based on geologic conditions and there are no
geologic hazards that would prevent the development as proposed.
Description of Selected Alternative
The selected alternative is a Sequencing Bath Reactor (SBR) treatment facility. The SBR
system has the ability to act as an equal rzation basin, aeration basin, and clarifier within a
single reactor. An SRB can treat flows from a few thousand gallons to millions of gallons
p"iduy, with a high quality final effluent. The system design will be based on a peaking
iu"to, of 2, but .u, u".o*odate a peaking factor of 4 if flows exceed the maximum daily
flow. The SBR process was selected as the recommended treatment process based on the
following;
o Small land area required
o Low cost - an SBR facility has the lowest capital cost and also can be operated with
the lowest operation and maintenance cost.
o Reliability - the system has the ability to continuously operate for extended periods,
under varying conditions and with minimal downtime due to major maintenance.
The SBR tras ttre ability to produce consistent quality effluent under varying load
conditions. It includes equipment redundancy to facilitate routine maintenance and
capability to operate during power failure and major maintenance.
o Flexibility- the SBR process can be adjusted to meet a wide variety of influent
compositions and effluent requirements. The System offers redundancy, and
capability to handle peaking flows.
o Regulatory Compliance - The SBR will meet CDPIIE's design requirements and will
B.
C.
D.
E.
F.
achieve a high qualitY effluent.
o Environmental Concerns - The SBR alternative has a smaller footprint and the SBR
can be covered more economically. Covering the system mitigates the potential for
odor.
o Expandability - the SBR has the ability to accommodate additional capacity
expansions.
Treatment Alternatives
The Applicant considered several other on-site and off-site alternatives. The applicant
reviewed alternative connections to the Apple Tree Mobile Home Park and the Town of Silt
and determined that they were not viable alternatives. Another analysis of the possible
connection to Town of 3ilt, through the new high school east of town was explored and
determined to economically prohibitive.
After a lengthy discussion with the Town of New Castle, the applicant entered into a
Memorandum of Understanding with the Town. The MOU supports the approval of the
proposed Sewage treatment facility, with a number of stipulations.
The treatment alternatives, Activated Sludge and Aerated Lagoon System, were not
chosen due to ffeatment limitations, larger land area requirements, and proximity to
residential development, limited maximum BOD removal and being visually
unacceptable.
Effluent Limitations
As noted, the proposed facility will discharge the effluent into the Colorado River below the
facility. The Colorado River in that area is classified for the following uses:
1) Cold Water Aquatic Life Class 1
2) Class la Existing Primary Contact Recreation
3) Agriculture
4) Water SuPPIY
To ensure these uses are protected, the Colorado Department of Health and Environment has
established preliminary effluent limits (PELs) for the proposed facility. The PELs establish
the water qrutity limits of the discharge into the Colorado River, which are monitored by the
Colorado Department of Public Health and Environment (CDPHE) for compliance.
Operation & Maintenance
The facility will be operated and maintained by a State certified Operator. lnitially, the
Rapids Development Corporation will be financially responsible for the construction and
iniiiat start-up of the faciliiy. once the facility is built, it is proposed to turn it over to the
homeowner's association and to form a special district to continue the operation of the
facility.
Facility Cost / Implementation Plan and Schedule
G.
H.
I.
ilI.
The proposed facility is estimated to cost $616,140.00. It was estimated in a previous
upptlcation, that the annual operating cost will be $72,7 40, based on a flow of 0.060 MGD'
This would require a charge of $31.25lmonth/tap.
STAFF COMMENTS
State Statutes: C.R.S. 25-8-lO2(2) (a-c), and the "Regulations for Site Applications for
Domestic Wastewater Treatment Works", defines the parameters by which the Water Quality
Control Division ("Division") shall review and approve or deny a site application for a
wastewater treatment works. The Division is required to determine that each site location is
1) consistent with the long range, comprehensive planning for the area in which it is to be
located; 2) that the plant on the proposed site will be managed to minimize the potential
adverse impacts on water quality; and 3) must encourage the consolidation of wastewater
treatment works whenever feasible.
The Applicant is required to obtain a recommendation of approval, denial or conlment only
from the Garfield County Board of Health and County Board of County Commissioners and
various other local and regional agencies.
Therefore, Garfield County's involvement in the process is to "review and
comment upon the relationship of the treatment works to the local long-range
compreheniive plan for the area as it affects water quality, proposed site location
alternatives including the location with respect to the flood plain, and capacity to
serve the planned develoPment."
Relationship to the Comprehensive Plan
The main mechanism with which the Board evaluates whether or not a proposed
wastewater treatment facility is appropriate is the Comprehensive Plan and whether or
not the proposal is consistent with the long-range plan of the area. Garfield County does
not have a 208 Water Management Plan for the Colorado River Area. The Garfield
County Comprehensive Plan of 2000 identifies the Rapids on the Colorado property
Outlying Residential Density, 2 acreld.u. and being within the Town of New Castle Two
Mile Sphere of Influence and their 3-Mile Area Boundary. The existing subdivision is
consistent with the recommended density of 2 ac-ld.u..
Section 10.0 Urban Area of Influence, defines the relationship between the County and
Municipal land use policies and a specific policy addresses this issue:
policy 10.1 Comprehensive Plan Zonrng Resolution revisions, Zone District
Amendments and individual projects within defined Urban Areas of lnfluence, will be
consistent with local municipal land use policies.
The above policy gives recognition to the Town of New Castle Comprehensive Plan and
A.
policies. The Town of New castle adopted the 1996 Community Plan Repofi' New
castle for Future Land Use and Growth. This document contained a map that was titled
3-Mile Area plan, Town of New Castle, and Garfield County, Colorado, that identified
proposed land uses for the area within three miles of the Town' The Rapids on the
colorado is labeled as cluster Low Density Residential ( 1 du/ac) for the area between the
South River Road (CR 346) and the river and Agricultural Resource ( 1 du/40 ac') for the
rest of the property on the south side of the county road' The propos ed l2l dwellings
for the 121 acres of land exceeds both the County and the Town's recommended
densities for the area. In the previously noted Memorandum of Understanding' the
Town has made a determination that the proposed development' if it meets all of the
stipulations in the MOU, is "consistent with its Comprehensive Plan, although not in
strict compliance with such Plan as to density'
Another guiding land use policy in the plan (Section 7.0 water and Sewer Services) is:
Objective 7.5 provides the most direct guidance to this issue. It states that Garfield
County will strongly discourage the proliferation of private water and sewer systems'
Since Rapids on the colorado is proposing a private sewer system to serve only their
specific existing needs on their ptip"tty und do"t not contemplate providing service to
surrounding -Jur.. An addendum to-the application refers to a "Regional sanitation
District or other appropriate district" as a future owner. There is limited discussion of
howtoaccommodateAppleTreemobilehomeparkandotherareasandnodiscussionof
orher areas that could be included in a future district boundary'
One of the stipulations in the MoU with the Town of New Castle is an acknowledgement
that the proposed sewage treatment system can be expanded to accommodate Apple Tree
mobile home park and-another nearby 100 acres of land. A1l expansion costs will have
to be paid Uy itre entity wanting to connect to the treatment facility'
B. Demonstrated Need
Theexisting33lotsubdivisionwasapprovedwithengineeredlsDSasthemethodof
treating sewage from the residences o, tt
"
property' The applicant has not demonstrated
that a distinct ,,need,, exists to switch to a new system, other than a desire to develop the
property at a significantly higher density than either the Town or the County proposed
land use densities would support'
B. Future ConnectivitY
Theapplicanthasincludedinthedocumentationsubmittedandanaddendumtothe
application and evaluation of the possible consolidation of the sewage disposal needs of
this development with wastewater treatment facilities in the area. The Town of New
castle is located approximately 1.5 miles upstream and to the northeast of the proposed
development. The proposed project is outside of the Town's projected service area' but
C.
the Town was willing to consider taking the sewage from the applicant's site As a
result of further consideration, the Town-cleclined to provide service, but entered into the
MOU with the applicant regarding the construction of the proposed facility'
Located approximately 0.5 miles upstream of the Rapids on the colorado is the Apple
Tree Mobile Home Park sewage treatment system. The owner has declined to consider
the additional sewage from thJ Rapids development' It should be noted that the recent
addition of the chlorine contact chamber *u, dor" without the approval of the CDPHE'
which may create some problems for them in the future'
Contrary to the statement in the application, the Town of Sitt is located within five (5)
miles of the proposed site. iiris wilt require the Town to provide their own
recommendation io CDPHE regarding the pioposed sewage treatment plant' (See
attached) The applicant has provided to separate analysis of the possibility of connecting
to the Town',s ,"*", system. An analysis pro.lected a cost of $2,1 19,796 to hook into the
system at the location of the new high school site east of town.
As noted previously, the applicant in an addendum notes a possible future "Regional
sanitation District or other appropriate district" as a possible owner of the facility'
There is no discussion of who might be included in this district and how the proposed
treatment facility would be incorporated in a district. Should the facility be available to
other users, a special district or annexation to the Town of New Castle would be an
appropriate method of dealing with the need'
Colorado DePartment of Health
DwainWatson,CDPHE,providedtheappiicantswithsomeinitialcommentsonthe
application, which are summar\zedina memo provided to the applicant' (See responses
& memo attached) The applicant has ."rpond.d to those concerns, but not all of the
responses will be acceptable to GDPHE. The following are issues that Mr' Watson still
has concerns:
1. The applicant is required by State regulations to provide evidence of financial
security for the proposed construction of the facility. No evidence has been
provided, only a statement that security will be provided after sufficient design
information is available.
2. The GDPHE uses 100 gallday/person and 3.5 people per dwelling, for-design flow
rate of 350 gallon, p"rtuy perhousehold. The applicant's engin":l lut assumed
1 00 gal/daylperson, but 2. 5 persons per dwelling, for a total of 250 gall day I dwelling'
This leaves a substantial difference in ttre overall design capacity. The GDPHE
criteria would result in a system of 67,900 gpd , which would require an expansion of
the proposed system. According to otheisections of the application' the proposed
treatment technology can be expanded'
3. The Town of silt is within 5 miles of the proposed treatment facility and will be
required to provide a recommendation to the CDPHE'
4. The Town of Silt does have tap fees of $3700 x 3 for out of Town taps'
Additionally, there is a cost recovery system in effect for lines that hook into the
proposed school site.
5. Apple Tree Mobile Home park could work with the Rapids developer to develop a
facility capable of handling waste for both areas. No real good evaluation of this
alternative was considered.
6. The revised cost estimates do include the provision of a building, but CDPHE had
some questions about the consistency of the costs associated with the proposed
treatment facility and the costs for extending service from the Town of Silt. This
may be a moot issue, given the Town's position regarding the cost of taps outside the
town limits.
The revised application attempted to address a number of these issues. CDPHE has not
seen the recent amended application.
ry. RECOMMENDATION
Staff would like to note that this application has been one of the most frustrating applications to
understand. The application submitted as an amended application included statements from the first
application that are no longer correct and there have been a number of supplements added to the
document since it was submitted.
Based on the current comprehensive plan designations in the County Comprehensive Plan which
acknowledges the Town of New Castle's 3-Mile Area Plan as the guiding land use document and
the Town's determination of the consistency with a number of the Plan's elements; the consideration
of consolidation with a other local service providers and adjoining properties, Staff recommends that
the Garfield County Board of Health and Board of County Commissioners RECOMMEND
AppROVAL of the site application for the Rapids on the Colorado Wastewater Treatment Facility'
It should be noted by the applicant that the recommendation of approval in no way obligates
the County to approve the proposed PUD or any other additional development, nor is the
County bound by any of the .tipolutiors the Memorandum of Understanding with the Town of
New Castle.
Towm of Silt
March 29,2004
colorado Department of Public Health and Environment
Attn: Mr. Dwain Watson
222 S.6th Street, Room 232
Grand Junction, CO 81501
231 No. 7tb Street / P.O. Eor 7O / Silt' CO 81652
Phone: 97C-87€-23,63 / Faz: 97O-876-2937
RECEIVED
APR 0 2 2004
GARFIELD COUNTY
BUILDING & PLANNING
Dear Mr. Watson:
The Town of Silt recently met with Gene Hilton, owner of the "Rapids" Subdivision and
his attorney, Loyal E. Leavenworth. Town staff, Mr. Hilton and Mr' Leavenworth
discussed the Town correspondence to the CDPFIE dated February 27 ' 2004' regarding
the Town's position on Mr. Hilton's proposal to construct a Sequencing Batch Reactor
wastewater treatment facility. Otherit".t of discussion included the following: 1) the
newly decreased density of it e subdivision from 194 to l2l units; 2) increased land
o.r.ug" associated with the development; 3) costs associated with attachment to the
Town of Silt wastewater treatment system; 4) potential attachment to the Town of New
Castle wastewater treatment system;- 5) potential attachment of the Apple Tree Mobile
Home Park to this proposed system; and 6) operation of the proposed wastewater
treatment sYstem.
Atter numerous conversations with Garfield County, Mr. Hilton, Mr' Russ Talbott' and
with the Town of New Castle, the Town was lecl to believe that a lagoon system would be
installed for the "Rapicls" Subdivision or on the Apple Tree Park parcel' to serve both
clevelopments. Lagoon systems typically exceed effluent parameters, and the Town was
concerned that this type of system would aftect the Town of silt domestic water intake'
Additionally, the Town of Silt was opposed to the proposecl density of 194 units' a 588Vo
increase tiom the number of platted unitt (::)' The Town of Silt has long held that
density should appropriately tccur in municipalities, where all services are available'
including police protlction, parks and recreation, water and wastewater service' etc'
However, the Town concecles that this issue is better addressed by the municipality most
aftectecl, in this case the Town of New Castle'
I spoke with Davis Farrar on Monday, March 29,2004, and he informed that the
developer's proposal of 121 units now conforms to the maximum clensity in the Town of
New Castle Comprehensive Plan Land Use Designation, with one unit per acre' He
indicated that Mr. Hilton h:.is had initial discussions with tl-re Town of New Castle
regarding density, location of trail, open space and clustering of units.
Ihe Town of Silt would recommend that the Town of New Castle and this developer
negotiate and reach mutual terms for wastewater treatment, before any approval by
Garfield County for increased density, and before CDPHE's approval of the system' It is
the Town's understanding that a licensed wastewatel operator must opelate the
wastewater plant.
The Town of silt appreciates the opportunity to comment on this project, as the project is
within 2.9 miies from the Town of Sitt boundaries. Should you have any questions'
please do not hesitate to call Monday through Friday, from 8 a.m' to 5 p'm'
Sincerely,
@"6Mjrt"t,ufu,cl--
Janet G. Steinbach
Community DeveloPment Director
CC: Board of Trustees; Richard J. Aluise, Town Administrator; Mark Bean' Director of
Building and Planning, Garfield County; file
iij ii E c ri Eneu r sr-H'^'h6
cElvtsruiifJlxi:# "
APR 1 4 2004
BfiSl,f&?33Hm"
t3'2oo4
LOYAL E. LEAVENWORTH
SANDER N. KARP
DAVID H. McCONAUGHY
JAMES S. NEU
SUSAN W. LAATSCH
NICOLE D. GARRIMONE
ANNA S.ITENBERG
MICHAELJ. SAWYER
TERESA L. HOCK
EDWARD B. OLSZEWSKI
Steve RippY, Town Administrator
Town of New Castle
P.O. Box 90
New Castle, CO 81647
LEAVENWORTH & KARP, P.C.
ATTORNEYS AT LAW
101 I GRAND AVENUE
P. O. DRAWER 2O3O
GLENWOOD SPRINGS, COLORADO 8I602
TelePhone: (97 0) 9 45'2261
DENVER OFFICE:*
WAZEE EXCHANGE BUILDING
19OO WAZEE STREET, STE. 203
DENVER, COLORADO 80202
TelePhone: (303) 825-3995
Facsimile: (303) 825-3997
*(Please direct all correspondence
lo our Glenwood SPrings Ollice)
Re:
VIA FACSIMILE
Davis Farrar
WesternSloPe Consulting
165 Basalt Mountain Drive
Carbondale, CO 81623
Dear Steve and Davis:
At your request, the consulting engineer for The Rapids on the colorado wastewater Treatment
Facility Site Application has analyzed thJcost of extending service for The Rapids Development to the
Town ofNew castle,s treatment plant. Enclosed is a letter analyzing those costs. As you can tg:, tlt t::t
of an extension to New castle is approximately $2.2 million, *ir"."ut a facility can be built at The Rapids
for $.66 million. we did not analyze the cost of going to the intersection (to connect to the fuverside PUD
line to be constructrJj Lr.uure tire breakeu.n ioin(given Jhe cost of a line in the county road versus a
river crossing) is approximately .4 of a mile, and ttre aaaitional distance to the intersection is well over
a mile. In other words, it is cheaper to go under the river than continue up to the intersection'
The site application review is tentatively scheduled before the Board of County Commissioners
for Monday, April lg,2oo4. we would very rnuch like to retain that schedule. could you please send
a letter to ihe County at your earliest convenience?
Very tmlY Yours,
LEAVENWORTH & KARP, P.C.
Loyalfi.. {,eavenworthl)
I have also asked the engineer to confirm that there is additional land at the site, and the proposed
plant is capable or r*funrion, tI serve additional users' That letter will be forthcoming shortly'
If you have any further questions, or desire additional information, please feel free to contact me'
LEL:bsl
Enclosure
Mark Bean, w/enc.
Gene Hilton, w/enc.
lrUm4\Cliots\tupids-l4o71l3l65\lippy'Feil'l'rPd
MARTIN / MARTI N
Eon srLTlNtr ENETNEERS
P -02Apr- L?-04
APR. 12
1 1 :34A
2(rlJ4 1:14PM l\]lARTIN & lltARTIN N0 5996 P, 1
Mr. Lec Leavenwsrh, AnoIneY
Lcavcnworth & KarP, P'C'
10tl Grand Awnuc
P.O. Drawcr 2030'C]""*".a
SPrings, Colondo 81602
Re: Thc BaPids on thc Colorado WWTF
Dear Mr. Leavctrwoflh: --
AstcquestcdbyGerreHittoD,isthcopinionofcotsforthc.,lriousscenariosforsewagetrestmcnt
f; # aborrc referenccd Projcct'
constnrctiog a sewsgc Iifl at thc ycs; cnd oj rirc Rapids dcvelopnrcnt urd puruping the sewage to
Nar castrc,s warncat plmt, inctuding oo. i*L-.f,**.y otrc 021) tryfecs is s2'200'755 (sce
cnclqsed shea).
'
rhc cs,irorrcd *"':'*.#;;HH"fi, .:ffi,l5iffiHf:::,tiillfiJ"
ttrc S,t
TrrTt,as sub'mitcr
MARTIN/MARflN,slatcstopmiong|goststoconstnrc-ti4luPmfortheRapidsatthe;;";d;;, i, *timatcJ to ue ffot'lgz as shown in &c addcodum
Assho\firaboYc,itismorcccouomioalfortheRepi&toconstrrctrhcirournwsstcwttEr
reatmart Plmt
SincaelY'
fi'J."e,le
nogh g- Srnades, P'E'
PrincrPal
Anachment
RHS-njt
i:
t z.tt ljcir CCLtar av?tuc
i
,,O.!or 151soo o Lr(Ewtroo'colot^oe tO2l5 r SA3'4!1'3toO
P-03
. APt.L2-O4 11:34A
Gomparison of Waste Water Treatment Alternatives For 121 Units At
The Rapids on the Colorado Subdivision
Cost of Taos & Line Extension From Rapids to Silt
Tap Fees $3700 PerTap X 3 Outside Torn Limits X 121 Units
River Crossing42S Feet X $200/Foot
Pump Station Due To Line Under River
Pipeline Cost 3.75 Miles X 5,280 X $35 / Foot Due to Water lssues
Cost Recovary Scfrool 3.50 Miles X 5,280 X $35 I Foolx 112
Generator Back-uP to Porver Pump Station ln Emergencies
cost of Easements Not Considered Due to High cost of Alternative
Gost of Taos & Line Extension From Raoids to New'Castle
Tap Fees $5,OOO Per Tap Outside Tovn Limits X 121 Units $
Locate 8898 Feet of Line in CR 335 X $67 Ft
Lines (Duplicate) Located on th€ Rapids Subdivision 4,800 X $32
River Crossing 400 Feet X $35o/Foot
Lift Station and Controls
Electrical
Buitding Over WWTF Facilities
Generator Back-Up to Power Pump Station ln Emergencies
lnterstate 70 Bore
Engineering
Cost of Waete llYater Treatment Facilitv at Raoids
Headrorks
Sequencing Batcfi Reaclor
Sequencing Batctr Reactor Basin
U ltraviolet Disinfec{ion
Sludge Holding
Standby G€nerator
Outfall Structure
Blowers,and Building
Builcting Covering Plant
Site Work
Yard Piping
Electrical / lnstrumentation
OutfatlLine
Contingencies
s 1,343,100
85,000
100,000
693,000
323,400
uo,To
3 2,GO4,5oo
I 2,200,785
-
3 681,392
-
605,000
596,166
153,500
140,000
150,0@
1E,000
75,000
50,0(D
290,000
123.000
28,000
138,000
126,000
26,000
38,000
35,000
6,000
24,M
120,000
19,000
18,000
32,000
4,500
47,492
WWTF Comparisons NC Silt RDC
ffil
*l
.rsd I4l
&t4il
P -04Aor-L?-o4 1I:34A
zffi
-ruFE
tEAViN\i!0RlH & KARP
LEA1IEIYIilORTII & KARP, P.C.
ATTORNEYS AT LAW
To:
Fax:
I0lI GBANDAVEIIUE DENVEROFFICE;r
p. o. pnewm'1oso wAfr'E EXCHANOE BUILDING
GI.El.IwooD sPRrNGs-oLoRADO EI6O2 l9o0 wAzEE STREET' STE 203-- la"ptone; (9?ir) 945'2261 DENvER' coLoRADo 80202
;;;i:ra'trh!'g#xl
FACSnflLE TRANSMITTAL S*ET
Date: April 14,2004
N0,63i D 1 i Il, tl )
APR. 14, 2004 1 :48P[4
LOYAIE. LEAVENV/ORTH
SA}IDERN, KARP
DAv[DIr. McCONAUG]fY
JAMES S. NEU
JrJUE C. BERQUIST-I{EATH
SUSAN W.I.AATSCH
NICOLE D. GARRMONE
ANNA S, ITENEERG
MICHAEL
'.
SAWYER
TERESAI., HOCK
EDWABDE. OISZEWSKI
To:
Fax:
With co to: MarkBean
Fax: 184'3470
With cc to: Gene Hiltou
Fax: (303) 798-1750
From: Lee Leavenworth
Nnnrber of pages to be taasmitted:
David Fanar
963-71'72
With cc to: Roger Smades, P.E.
Fax (303)43I-4028
Steve Rippy
984-2716
3 (including cover page)
Documeot Description: Letter re: site Locatiou Application of Rapids Development
CorPoration
REMARKS:
NOTE: If you encounter any diffrculty in receiviug the total number of pages indicated
above, PLEASE CAI1 (970t945-2261 AS SOON AS POSSIBLE.
Breoda
Operator
X ORIGINAI SENT BY U.S. MAIL
-
ORIGINAL NOT SENT
TIIIS FACSIMTI.E TR.A.NSMISSION IS STRICTLY CONF'IDENTIAL AIYD IS INIENDED ONLY FOR TIiE
TNDmDUAT,ORf,NTffyNA]IEDABOYE. TYOUBAYEBECIIyf,DTHISFACSIMIIJEIRAI{SMISSION
rN ERf,o& pLEAsE uoinv tros oFFIcE rIV(MEDTATEI.Y AND RETURNTTTE TRrr.NsMIssIoNTo Us
ATTIIE ABOVE ADDRESS' THANKYOU.
tu6cohAl{LBumFdlFrI6e-xss16il'dd+'
APR. 14, 2004 i:49PMl
LoYA! E I,EAVENII|ORTI{
SANDERN.KARP
DAVIDH. MCCONAUGHY
JAME$S. NEU
ruLIE C- BERQIff ST.ITEATII
SUS.{\ W.IAATSCIT
MCOLE D. GARRIMOI.E
A}INA &ITEI{BERG
IVIICHAELJ. SAW]TER
TERESAL HOCI(
EDWARDB. OLSZEUISKI
Stcve Rippn Town Administator
Toum, ofNery Castle
P.O, Box 90
Nw Castle, CO 81647
LEL:bsl
Enclozureco: MarkBean,w/euc-
Gcnetliltor, Venc.
Roger Smades, P-E., w/out euc-
llo0f, tl.ilnedaDtffi mur>ho{-X
TEAViN\/il0RT11 & KARP
LEAI{EI{\ilORIH & I(ARP, P-C-
ATTORI\TEYS AI LAW
IOII GRA}IDAVENUE
P, O. DRAWER2O3O
GLENII/OOD SPRINGS, COLORADD t1602
Tdcphon* (970) 945'226 I
Fs€skttilc: (9?0) 945-7336
tel@lklavtrrm'com
N0.611 P, ?i3
DE}IVEROFFICEA
WAZT D(CI{ANGE BUILDING
I9OO WAZEE STREET, STE. 203
DENVER, COLORADO 80202
Teleptooe (303) 825-3995
Prcsirnile (303) 825'3997
'(Plcoe dhect all corraTonden*
to ozr Glennd Springs OIFcc)
April 14,2004
VIA FACSIMILE
DavisFarrar
Western Slope Consulting
165 Bssalt Moutain Drive
Grboodale CO 81623
Rq ThFRapids.pn-tbe ColoradoSiteAPolication
Dear Ste\re and Davis:
As promisedinmy letterofApnl 13,2004, errclosdistheeogineer's letterco_nfinuingthere
is additional land atthcsiic, andthcpioposedplantis cspable oforpansioato se,rvsadditioualusers'
Ifyouhave aoyfigtherquestions, ordesire additioualinformation, pleascfeel fieetoconEct
l:le.
VerytulYYours,
LEAVENWORTII & KARP, P.C.
nt+
LrydffL"aveoworth
a.o,APR. 11.-2014r-1j19-!|1 LEAVENi/i0RTH & KARP' .'
ApL tJ. 2004 !:22pM UARTIiJ & MAf,TIlr
N0,631 P, 3i3
t{0. 6045 P. I /1
P.02
!(r, LGa Lcntasorth) Atto[rtay
Lcrvcrr*orth &, Krrp, P.C.
10lt &rndAvstuc
P.O. Dnn*2030
Glcasood SPriPSe, Colordo t1.602
R* thc Rapida o thc Coloado WWIF
PGar!,G Eerytnwor&
As rcqucsrOdUy both yomclf ed Crcm Hiltoq I hlYc EYiID'cd &c pwel of land tbrt ir
dcsig'tlaafcil"n oeooalfilslllntTt iu adc lo dcGrrtine if tbr poposcd frsility cottd bc
cxgruilodin lhc firtEc-
ThcCrictinf sicllill rccourorlec &rm6ri6oftcpropcrod SBS,ftcility iuqrderto ucrt
51ti3brd f,rtrc ttguc, grovirbd drr! fi&E Erbilii, mi olLcr irnn couU bc ntolwd pnic to
u cryrudor qlilgplrcc otroptltics osild by tlE B+iilr D6.cl6Doctt Comproy-
tf yorr bvc roy otbct jtcstiour, d:rse cutrctrc il 303431{100.
e, Gcncllt'lton
BES.ajt
lz.t9 yat? goL"^r avtrut. F"o-aol llltig9. L.r3regD. solea.oo tlo3r3 r 3ot.art.6loo
MAR.TIN / MA.RTIN
COIvSULYIi,{ CNBINtEIs
Sbcacly,
ttB ]2004 \:?lPtt MARTIN & iViARTIl']
-- N0 433l.-P, I /?4
PRELIMn.{ARy Errr,unxr Ln urs
TEE COLORADO RNMN
Tm R.qrms DE\TELoPMENT ConronlnoN W'WTF
I. Introduction
The preliminary effluent limits (PEIs) evaluation of the Colorado River near The Rapids
Development Corporation Wastewater Treatrneut Facility flMWTF)was developed fortheColorado
Deparurrent ofPublic HealthandEnvironment (CDPI{E) WaterQualityControlDivision(W@D).
The evaluation was conducted to facilitate issuance of PELs for The Rapids Developmalt
Corporation WWTF for polluuns for.urd to bc of concern
Figure 1 on the fol.lowing page contaim a rBBp of the shrdy area evaluated as part of this PEL.
Thc Rapids Development Corporation W-WTF will discharge to the Colorado River. The Rapids
Development Corporation is planning a new residential developrnent west of the Town of New
Castle uasred The Rapids ou the Colorado. A mechauicd WWTF'rith a design flow of0.060 MGD
wiil serve this development.
The ratio of the low flow of the Coiorado River to The Rapids Development Corporation WWTF
design flow is 11,747:1. Because of the large flow in the Cotorado Rivm, aearby upsteam and
dowisueam facilities would have little if any impact on the assimilative capacities available to The
Rapids Development Corporation WWTF. Analyscs thus indicate that assimilative capacities are
very luge.
Irufofmation used io this asses$nort includes data gathered from The Rapids Development
qorpor"tior" the WQCD, &e U.S. EnvironmeDtal Protection Agency (EPA), the U.S' Geological
S*uey (USGS), and the U.S. Census Bnreau TIGER Mapping Service. The data used in the
assessment consist ofthe best information available at the time ofpreparation of this PELs analpis.
Table I
Assessmeut Su
Name ofFacility The Rapids Developmsnt Corporation W'WTF
CDPS Number CO.PEL
WBID - Steun
Segmeut
Lower Colorado River Basin, Low€r Colorado River Sub-basin,
SEeam Segment 0t: Mainstem of Colorado River frorn the confluence
with the Roaring Fork River to irnrnediatelybelow the coulluence
with Parachute Creek.
COLCLCOI
Classifications Cold Water Aquatic Life Class 1
Class la Existing Primary Contact Recreation
Agriculture
Water Supply
Desimation Undesimated
Page 1 of14
ItB 3 20()4 5:22PM MART]N & MiARTIl\l N0 413?P, Bi24
The Raoids Development Corp. WWTF Preliminary EfiIuent Limib PEl-Garfield Couaty
Figure A-1
Study.{'rea
Toumof Nerv
wwrT, co-0040479
Inter$ate -----+
usGS 09085100, 12
rniles upsreaurRivcrbend
Subdivisiqn
WWTT,
Tbe Rapids
Developmeut
Cqreoration WWIF
t€GETO
- ffflI[ondrocean H ill i:lll 3#e source: us census riger
- gg7E31 Sl Other Park Mapping Service
-
Express$Ey ilEfSchool
-
Highnay f__l City
-
Qsfa1gstsp
-Countyf Strean .o.o ,o.E ,1.0 ,1 .LJz.orll
Sca I e t : 56483 iffi.3T1Tri5rz-Tr2.S.,s.otu,
ilrverteE-lwe scrlr dcpendo 0n nonrtDr nttoluElol
II. Weter QualitY
The Rapids Development Colporation WWTF wrll discharge to the Water Body ldentification
$fBIDi steam segmenr COLCLCOI, which means the Lower Colorado River Basir, Lower
tolor.io River Sub-basin, Steam Segmeut 01. This segment is composed of the'Maiustem of
Colorado River from the confluence with the Roaring Fork River to immediately below the
confluence with Parachute Creek-" Steam segment COLCLCO1 is classified for Cold Water
Aquatic Life Class l, Class la Existing Primary Contact Recreation, Agricultnre, and Water SupPly.
Numeric standards are developed on a basin-specific basis and are adopted for particr:Iar stream
segmenrs by rhe Water Qualiq'Contol Commission. To simplify the listing of the segment-spe cific
stindards, many of the aquatic life srandards are contarned in a table at the begiruung of each chapter
of the regulations, The staDdards in Table 2 have been assigned to stream segrneat COLCLC0I in
acoordance with &e Clossifications and Numeric Standards for Lower Colorado River Basin,
Talboa
Emerprises,
Inc. WVTF
Page 2 of 14
FEB 1.2004 5:22PM MART]l{ & MIARTiN N0 4312 P, 9/24
TheRapidsDevelopment Corp. WWTF PreliminaryEIIIumt Limits PEl-Garfield Corurty
effective January 20, 2004. Because this WWTF has not yet bem coosttrcted, this soou to be
effectiveversion of the Classi-flcations and Srurdards documeot is being followed'
Standards for metals arc generally shorrm in the regulations as Table Value Standards (fVS)' and
these oftea must be de,rived from equations that tlepe,nd on tht receiving stream hardness or qpecies
of fish preseot, The Classificatiou and Nruneric Standards documents for each basin include a
qpecification for appropriate hardness values to be used. Specifically, the regulations state that:
The hardness velues used in calculating the apprcpriate mehl smndard should be based
on the lower 95% confidEnce limit of the meau hardness value at the periodic low flow
criteria as determined tom a regression analysis of site-specific data Where
insuff,cient site-specific data exists to define the mern bardness value at the periodic
low flow cnteria, representativeregional data shall be used to perform the regression
Table 2
In-strerrn Standards for Stream Seg-eq! t9lrel,C0l
,_ P,nytya *!_par*Ai,
Oi$olucd O*vgeo (DO) -- 6 mgll,
o4.=6.5'9su
Fecsl Coliform :200 coloniaVlO0 ml
th-ionized ammonia asute: TVS
Ul_i9ni4ed amgroEia ehmic = 0'02 mln
Chlorine acute = 0.019-nog/l -Cblori+c cbronic = 0.01I mg/t
Free Cwnidc acute = 0.005 merl
.. Sulfide chronic = 0.002 etll
Boroo cbrooic = 0.75 mrttll
Nitnte - 0.05 ursn
Nitrate - l0 mg4
Ctlc,ridc chrS4& =2!q_sE
Sulfate chrooic - 250 me/l
Metak
Total Recoverablc Arecoic acutc : 50 ucn
Orrrot""O Cadmrrm acrrte for trout aud.Ditsolved Cadmium th,rgris: TVS
Total Recovcrlblc Tri*lent Chtmdum "cutc = 50 u/l
Digsglvcd Hexavateot Ctroqfum aolte and ch{gnig = lyS
- Dissolvcd.g.gp]rraorteaadchr@lc:TvS -. . Dlssolved lrofl chronig= 300 us/l .
Total Recov*Eblc lrm cbroqic - 1000ug/l
Dissolned Lead acute aod chronic 'lru!
Dissolvcd M"oglsesg-chroaic = 50 og[
nissolved Melsl4glg-Ccrtrc - ryg
TCqIM
-
Dissol rcd.Nc&el rcute snd cb@ic: TvS -Dissolved Seleuium actrrc snd chrouic = TvS
ffiolt.a Srlver acute sud Dissolvcd Silver ghtmic fsE-q'q -T\NS--.:' -
Dissolved Zinc aorte aud chroic : TvS -
Page 3 of t4
,1 ',.
Table 3
TVS-Bcsed Metals Water Quality Standards For The Rapids Developmeut Corp WWTF
Based on the Table Value Standards Contained in the Colorado Departnent of Public Health
and Esyrrorunsnt Water Quality Control Cornurission Reggiatror 37 ,-
Calculated Using the Following Value for Hardoess as CaCOr: 193 mg4
Parametet
In-Stream Waler
Ouality Standard Formula Used
Cadrnium, Dissolved Trout 7.5 ue/1 -- (l. t 2t(Hhrrdnesr))'3.828)l
I . I 366/4.04 I tdlh(hrrdncit)l [, -
Ctronic 3.5 ug/l lt.lol d7o.04r B4hg*a,*;1, @ 7852(ln(hl&cs)!2-?l 5)l
Hexavalent Chromiurn,
Dissolved
Acute 16 ug/l Nun*ric End.tdr povidcd, fonrula aot rmlicablc
Chronic l1 u/l Nu,rEie tandrr& pmndcd, fomh not rpglicrblc
Coppo, Disolved Acute 25 u,g[e (0.94220r{hsdnrs)}1.7a08)
Ch,ronic 16 ug/l , (0.t5450r{tnrduss)}1.7428)
Lead, Dissolved
Acute 131 ug/t1.4620!{-lr5?1zh(trr&.r)lic
(l'27!0n(}nrerc)}l'16)I
C'hronic 5.1 u/l (t J73{'lnftrr&rerD4.7 05)l
ll ,4620r{. I 4r? I 2br(hsdncrs)[c '
Manganese
Acutc 3717 u,sJl , (0f 13 I ftr(lnrenss)P6.4676)
C'luonic 2054 us/l e
(0333 I 0n0rdlcs)F5.8741 )
Nickel, Dissolved
Acute 817 ue/l , (o.M60n(hr&6l)Irz.2s 3)
Cfuonic 9t u/l , (0.E1(ln(hudna)F0'0554)
Seleniurr, Dissolved
Acute 18 ue/l Nunrric rundror prwided, frmrla not rppliceblc
Clnonic 4.6 us/l Nurrrric Elrdsdt providad, fcrmtlr nor rpplicrblc
Silver, Dissolved
Acute 6-3 \el,7r, (1,22(h(hrtu))6.s2)
Trout 0.23 us/), ( I 72(ln(hrtdacas} I 0.5t )
Zinc, Dissolved
Acute 205 lusl €
(0,t{73 ['n(ht&cr)F0.861 8)
Ctuonic 206 ue/l e
(0.81?3(hOrydBas))+o.t699)
FtB I ?004 5:21PM MARTlN & IVIARTiN N0 4332 P,1l.i24
The R-aoids Develooment Com, WWTF Preliminary Effluent Limits PEl-Garfteld County
---- - 5 I .
-
I
analysis, Where a re$ession analysis is not appropriate, a site-specific method should
be used,
Hardness data for the Colorado River near the proposed point of discharge of The Ralds
Development Corporation WWTF were insufficiemt to conduct a regressiou analysis based on the
low flow, Therefore, the WQCD's altemative approach to calculating hardness was used, which
involves computitrg a mean har&tess.
The mean hudness was computed to bet93 mfl based on sampling data from WQCD Water Quality
Starioa 000047 located on rhe Colorado River upsteara of The Rapids Development Corporation
WWTF. This harduess value and the formulas contained in the TVS were used to calculate the in'
streern water quality sturdards f616etals, with thE results shown in Table 3'
Page 4 of 14
I
[/]ARTIN & MIARTiN
i\]n /?11t\v.'1))L P, 11/24F!B 1 2004 5:21PM
the Rapids Dwelgpment Corp. YIWTF Preliminary Effluept Limits PELGaffield. County
Ambient'W'ater Oq ality
The WQCD evaluates ambimt water qualitybase d on a variety of statistical mahods as prescribedin
Sectioo rl.8(zXaXi) and 3i.8(2)(bXiXB) of the Colorado Department of Public Health and
Environment Water Anfity Control Commission Regulation No. 31. Ambient water quality is,
evaluated in this PELs analysis for use in determiniDg assimilative capacities and in cornpleting
anti de gradation rwiews for po llutants of concem.
To conduct an usessmant of tbe ambient water quality upstream of The Rapids Developmart
Corporation W-WTF, data were gathered from WQCD wata quaiity stalion 000047 loeated
approximately 3 miles upstean &om &e proposed facility. Data were available for a period of
record from October 1 995 through December i 999. A sunrmary of these data is presented in Table
4.
Table 4
Ambient Water Qualltv for the Colorado River
Parameler
15th.
Percentile
5Dth
Percenttle
85rh
Percentile Mean ffofes
Iernp ('C)50 1.9 7.7 l5 8.2 20
DO fms/l)48 9.2 1l l3 l1 7
pH (su)4',1 8,7 E,4 E,6 t.3 6.5-9
Fecal Colifo,ra (#/I00
ml)44 23 93 20
I
I
Har&ress (mE/l
CaCf)1)16 120 205 240 193 NA
Ai, Trec (ue,4)I 0 0 0.02?NA 1
Cd. Drs (uen)49 0 0 c 0 3.6
C\r. Dis (usn)49 U U 0 0.42 l6
Fe, Dis (urll)9 5.0 2',7 36 29 300
e, ftoc (ug/l)49 5l r20 126 562 1000
Pb, Dis (ue/l)49 c 0 0,073 5,1
Ma, Dis (uil)49 6.0 9.0 l1 E.9 50
He. Trcc (up/l)20 C U 0 0 NA 2
Se, Die (usn)a8 0 0 1.0 0.34 4.6
Ag, Dis (ugfl)34 0 0 0 0 0.23 2
Za, Dis (uell)q9 0 0 22 9.9 206
Sulfrtc (m/l)49 43 120 87 250
Nitile+Nirrite (men)49 0 0 0,10 0.039 NA 2
NHr Tot (ms/:).t,U U U 0,0080 NA a
l,IIIr_ Unionizcd (n/t)25 0 0030 0.005c 0.010 0.0062 0.02
TSS (men)26 0 0 59 30 NA .,
Notc l: Ihc cllcuhtcd rmn ir lIrc torrrtjc.nrtn, Noc het fr n*rtrnnatica nrpccs, thc nluc of srp ,ras urcd vbat &grE ua, no daiccEb&
Etmw[bacausc 2€ro cttrottc urcd to ulmlets ftt gcornruic.
Noa 2: Vlhan setrPlc rsrilo *uc bslgw dcrcction lqwls, he vrlue of lao yas ured h lcrqdarpc vi{t tltc CO WQCD'; lnndrrd 4poech fo
iurErnriatigfl and rvcreghr ourfficr
Page 5 of 14
Nimbbr
oJ .:
Samflbi,
C )
F EB. 3 ?004 5:23PM MARTlN & IVIARiiN t\io 4332 P, 1)i24
. WWTF Preliminary Effluent Limits PEL-Carfield
III. Water Quantity
The Colorado Regulations speciff the use of low flow oonditions whEn estabiishing water quality
basedefflueut limitations, specifically the acute and chrouic low flows. The acute lsw flow, referrC
to as 1E3, represents the one-day low flow reeurring ia a three-year interval. The chronic low flow,
30E3, represents the 30-day avgrage low flow recurring in a tlrree-year inteu-val.
Low Flow Analvsis
To determin€the low flows availableto TheRapidsDevelopmurt CorporationWWTF,USGS gage
station 09085100 (Colorado Rjver below Glenwood Springs, CO) was used. This gage station
proYiales a conservative enalysis cf the low flcws available to The Rapids Development Corporation
IVU/TF because additional srean'Is add flow to the Colorado River beiow the location of the gage
station A coruervative analpis is aciequate for tiris WQA because the process required to add the
ad<iitional flows to reflect the ach:al low flow available to the facility would be resource mtensive
and would not change the outcome of this aoalpis.
Daiiy flows from the USGS Gage Station 09085100 (Colorado Riverbelow Gtenwood Springs, CO)
were obtained arrd the annual iE3 aud 30E3 low flows were caleulaled using U.S, Environncental
Protection Aggncy (EfA) DFTOW sohryare. The output &om DFI-OW provides calculated acute
and cluonic low flows for each month. r', . i
Flow data from October l, 1992 througb Septernbcr 30. 2002, were available fromthe gage station,
Ttre gage station and time frames wae deemed the most aseuate and representative cfcr:rreoi flows
and were tterelbre used in this anaiysis. '
Based on the low flow analysis described previously, tJte upstearn low florvs available to The Rapids
Development colporation wwTF were salculated and are pr*ented io Table 5.
Trbie 5
Low Flows for the Colorado River ar The Rapids Development Coruoration WWTF.
LUW T'U'J
tcFl
'A'nnaaI ,Fcb Msr
. ,-,, ,)
-, t,ilpr May Itn f,al aug Qen Dec
IE3
Acutc E15 r'.]5 879 875 1r09 l75t 1597 t4l l 1250 t08 I r021 8?5 69E'
3iFS
Clrouic 1046 I 046 1046 t046 I 109 I 870 1597 1467 1250 1250 1347 1050 1050
Duing the rnonths of April, June, and August, the acute low flow calculated by DFLOlil exceeded
the cluonic low flow. In accordance with WQCD standard procedures, the aoute low flow was thus
set equal to the chronic low flow for these montbs,
Pagc 6 of14
F EB, 3. ?004 5:24PM IV]ARIIN & NlART]N N0. 433?P, 13/?4
The-Rapids DEvelopment Corp._WWTF Preliminary Effluenl-Limits PELGarfield County
ff. Technical Analysis
In-supam background data and ldw flows evaluated in Sections II and III are ultimatel-v used to
determine the assimilative capacity of the Colorado River aear The B"apids Dorelopment Corporadon
WWTF for pollutants of concern. For all parameters exc+t aurn:onie" it is the T,VQCD's apprcach to
conduct i technical analysis of sueam assimilation capacity using the lowest of the monthly low
flowt (refened to as the arnual low flow) as calculated in the low flow uralysis. For ammonia, it is
the standard procedure of the WQCD to detcnrrine assimilative capacities for each month using the
monthly low flows calculated in the Iow flow aoalysis, as the regtrlations allow the use of sea-sonal
flows when establishing assimilative capacities.
The WQCD's standard analysis consists of steady-state, mass-balance calculations for most
pollurants and modeling for pollutants such as amrnonia. The mass-balance equation is used by the
WQCD to calculate the maximrun allowable concentatioa ofpollutants irt the efiluent and eccounts
for the upskeam conceirEation of a pollutant at the existing qualiry, critical low flow (minimal
dilution), eflluent flow and the water quality standard. The mass-balance equation is expressed as:
t2 MrQr- MrQr
Qz
Where,
Q; rUpstream low flow (lE3 or 30E3)
Qt = Average daiJ,y eflluent flow (desigp capacity)
JDownsteaxn flow (fu + Q)
Mr - hr-steam background pollutant concentrations at the oristing quality
M2:5"1"t rated maximum allowable effluer:t pollutant concentration
Mi = Marimum allowable in-sEeam pollutant concenEation (water qualip standards)
Theupskeambackgroundpollutant concsntrationsused inthe mass-balance equation willvarybased
on the regulatory definition of existing &lbient water quatity. For most pollutaats, existing quality is
determined to be the 85fr percentile. For metals in lbe total recoverable form, existing qualily is
determined to be the 506 percentile. For pathogens zuch as fecal coliform, existing quality is
determined to be the geometric meau.
Ior non-conservative parametcrs and ammoni4 &e mass-balance equation is not as applicable aud
thus other approaches are considercd where appropriate, Note that conservative poltutants are
pollutants that are modeled as if rnass is conserved and there is no degadation, wherea-e non-
conservative pollutants degrade and sometimes are created within a receiving stream depending on
steam conditious. A more detailed discussion of the technical analysis for these puam'eten is
provided in tbe pages that follow,
Pollujants of Concern
The following pollutants were identified by &e WQCD as pollutants of concern for this facility:
r BODs
r TSS
r Percent remoYal
PugeT otl4
itB, l.2004 5 24PM IV]ARTIN & lVlARTIN N0, 4132 P, 14/24
The Rapid-s Development C.-oip. \trWTF Preliminary Eflluent LimiE P.El--Garfield County
r Oil ar.vd C:reasc.pH
.DO
. Fecal Coliform
. Total Residual Chlorine
. Ammonia.
There are no in-sheam water quality standards for BOD:, TSS, pe,rcent removal, and oil and gease
for the the Colorado River. Thus, assimilative capacities were not determined for these paraureters
in this section md an urtidegradation review for these parameters was not conducted rn Section V.
The evaluation of applicable limitations for these pollutaats can be found in Section VI, Regulatory
Analysis.
During assessment ofthe facility, nearby facilities, and receiving steam water quality, no additional
parameters were identified as pollutants of concero. It should be noted that cyanide and rnetals arc
not erraluated as put of PELs development because it is the VfQCD's approach to €nsure conuol of
cyanide and metals through a pretreatmenl progran, if necessary, rather than through wastewater
teatmeut at tlre applicaot's facility.
During assessmeflt of the facility, nearby facilities, and receiviug steamwater quality, no additionai
pArameters were identified as pollutants of concern' i ,'
' i.:l
Tbq Bgpids Development Coroo.ration IV'WTF: The Rapids Development Corporarion WWTF
will be located in thc SW 1/4, Section 4, T6S, R91W; Latitude 39" 33'04" Nofih, longitude L07o 34'
11" West; approximately 2 miles west ofNew Castle, CO, in Garfield County. Theproposed design
capaclty of the faciliry is 0.060 MGD (0.093 cfs). Wastewater treakrent is proposed to be
accomplisbed using a mechanical wast€Nilatsr treatlcnt process. The technical analyses that follow
include assessments of the assimilative capacity based on this design capacity,
Nearbv Sources
An assessmeot ofnearby facilities bssed on EPA's Permit Compliance Sy$err (PCS) database found
63 dischugsrs in the Garfield Couoty area, Sweral facilities conducted consEuction-relaled
operations (e.g., sand and gravel mining or oonshrction den*,atering) and thus had no pollutants of
cotrce6 in oommon with The Rapids Developmeot Corporation WWIF. Other facilities were
located more than twentymiles from The Rapids Development Corporation WWTF and thus were
not considered.
. The Town ofNew Castle WWTF (CO-0040479), which discharges to the Colorado River
approximately 2.5 miles upsream tom The Rapids Development Corporation WWTF. This
W'UITF has a design capacity of 0.20 MGD.
r Taibott Enterprises,lnc- WWTF (CO-0035815), which discharges to tbe Colorado River
approximately 1.5 miles upsteam from TheRapids Development Corporztion W'WTF' This
WWTF has a design capacityof 0.15 MGD.
r Rivilbild Subdivision W'til/TF (COG-584006), which discharges to the Colorado River
approximately 3.5 miles upsteam from The Rapids Development Corporation WWTF. This
IV'UITF has a design capacity of 0.0247 MGD.
Page E of 14
FtB. 3,2004 5:25PlV]MIARTiN & IIART]N N0,4332-P, 15/24
TheRapids Developqg$ Corp. WYTF freliminaryEf{Iuent Liquts PEl-Garfield County
. Town of Silt Ww13 (COG584046), which discbarges to the Colorado f,iver approximately
6,5 miles downstream,
The unbient water quality background concentations used in the mass-balance equatiou account for
pollutants of concern coatributedby these upstearn sources, and thus it was not uecessaryto model
the upskearn dischargers together with The Rapids Development Corporation WWTF when
determining the available assimilative capacities in the Coiorado R.iver. Due to the distance
traveled,thesignificantdiiutionofthereceivingskeam,and therelativelysrnallcontibutionsbythe
faciiities of concero" modeling downsteam facilities in conjunction with The Rapids Development
Corporation WWTF was not necessary.
Based on rvailable inforrnation, thetre is no indication that non-point sources were a significaot
source of pollutants of concem. Thus, non-point sources were not considered il this assessmeol.
pE The pH of a stream measures the intensity of the acidity or alkaliniry of the sueam. When pH
falls ouiside of the neutzl range, it can be harmfrrl to aquatic life. To determine assirnilative
capacities of a sbeam for pH, the buffering capacity of the receiving streen and its interactionwith
the discharge contributions would need to be assessed in a complex evaluation.
fui evaluation of pH data availablc for the Colorado RivEr near the proposed The Rapids
Developrnmt Corporation TV'WIE forurd ttrat the 15u percentile value was well above the minimr:m
in-skeam water quality standard and the 85s perceoiile value was well below the ma,rimun in-
stream watsr quality sta:rdard. Because onJy limited data are available and because arnbi€,Dt water
quality data indicate that no fiuther controls are needed to meet in-steam pII standards, a complex
evaluation of the assimilative capacity for pH is not warranted for this facility.
DO:, The availabiiity of dissolved oxygen in receiving streams is critical for aquatic life.
Decorrposition of organic matter and nitification withia receiving steams are geaerally the causes
of the depletion of DO from receiving waters.
For a lon-consavative paf,ameter like DO, a simple mass balance cannot be used to detcmrinc
assimilative capacity. tlstead, backgrourad DO, steam flow, 5-daybiochemical oxygen demand and
amrnqnia loading s8eam dimensions, temp€rature, and estimates of effluent DO may be
incorporated into models such as the Skeeter-Phelps DO model or STREAMDO to simulate the
impact of WWTF discharges.
' An evaluation of DO data available for the Colorado River near the proposed The Rapids
Developmart Corporation WWTF found that the l5s perceotile value was well above theminimum
in-sneaar water qual-ity standard. Because only limited data are available and because ambisut water
qualtty data indicate that no fiuther conEols are needed to meet in-steam standards for DO,
modeling was not conducted as part of this evaluation and no frrther discussion of DO is provided.
SlgiUg: The mass-balance equation was used to determine the assimilative capacity for chiorine,
Th* ,r. no point 6oruces discharging total residual cNorine within one mile of The Rapids
Development Corporation I\IWTF. Because chlorine is rapidly oxidized, in-steam levels ofresidud
Page 9 of i4
tiB, 3,2004 5:25PMl IV]ARTIN & M]ARi]N -N0. 433 2-P, 16/24
The lapids Development Corp..WlMTF Preiiminary Fffluenl Limils -
pEl-Garfield County.
chiorine are detected only for a short distance below a source. A"rnbient chlorine was thercfore
assumed to be zero.
Using the mass-baiance equation provided in the beginning of Section IV, the acute aud chronic low
flows set out in Section [, the chlori:re background concentation ofzero as discussed above, and
the in-sksam standards for chlorine shown in Section tr, assirulative eapacitres for chloriue were
calculaled. The data used and the resulting calculations of the allowable discharge concentration,
M2, $e set forth below.
Parameter Q r Gfs)Q t kfs)Q t (cfs)M 1 fug/l)lt[1 fug/l)LI j (ms/l)
Acute Chlorine E75 0.093 875.093 0 0.019 179
Ckordc Chlorine 1046 0.093 1046,093 0 0.011 124
Fecal ColiforE: Thsre are no point souces discharging fecal coliform within one mile of The
Rapids Development Corporatiou WWTF. Thus, fecal coliform assimilative capacities were
evaluated separately.
It is the standard approach of the WQCD to perform a mass-balance check to determine if fecal
colifonn slandards are exceeded WQCD procedure specifies that checks are conducted using only
the clrronic low flow a6 set out in Seqtion III. Using the rnass-balance equation provided in the
beginning of Section [V, tle backgound concentration contained in Section II, and the in-sEeaul
standards for fecal coliform shciwn in Section II, checki for fecal co]iform were conducted. The datr
used and the resulting calcutations of the allowable distharge concentatio\Mz,arcset forthbelow.'
Amnonia: Ammouia is present in the aqueous mvironme,nt in both iouized and wr-ionized forms.
h is the un-ionized form wNch is toxic and which is addressed by water quality standards. The
proportion of total ammonia present in un-ionized form in the receiving steam is a function of the
cqmhined upstearr and effluent ammonia concerrtations, and the pH and temp€ranrc oftho effluent
and receivirrg steam, combined.
The Coloradti Ammonia Model (CAM) is a software program designed to project the downstreao
effects of ammoaia and the aononia assimilative capacities available to each discharger based on
upsteam water quality and effluent discharges. To develop data for tho CAM, an in-stream water
quality shrdy must be conducted of the upsteam receiving water conditions, particularly tbe pH and
conpsponding temperah[e, ove( a period of at least one ]€ar.
There were no da'.a available for the Colorado Rivq near The Rapids Development Corporation
WWTI tlat could be used as adequate input data for tbe CAI\,l. Therefore, the WQCD standard
procedu{p is to rely on default values for the allowable ckonic concentrations of in-steam total
Paramder Q t kfs)Q t ("fs)I s (cfs)M r (#/100
nt)
M 3 ff/100
nl)
M 2 (#/ta?
mI)
FecdColifomr LA46 0.093 1046.093 20 200 2,024716
Pagc l0 of 14
FiB, 3,2004 1.25PMl IV]ARTIN & IIIART]N N0, 4332-P, 11/24
ERapids Development Corp. WWTF Pretiminary Effluert LimiL ' PEL-Gar4eld County
ammonia, which are provided in the Colarado Totdl lulaximum Daily Load, and Wasteload Alloeation
Guidance and tlre CDPS Summary of Rationale General Permitfor Domestic Wast*,'ater Tleatment
Facititia that Discharge to Receiving Waters with a Chronic Low FIow: Design Ftow Ratio of
1 00: I or Greater. NotE that acute vaJues are not provided in these souces and thus are not evaluated
as pafi of this assessmeut.
Using the mass-balance equation provided in the beginning of Section IV, the acute and cbrooic low
flows sct out in Secfon III, the arnmonia existing quality cortcentratioo showu in Section II, and the
in-shsem standards forxrd in tke Colorado Total Maximum Daily Load andWasteload Allocation
fuidance and the CDPS Summary of Rationale General Permitfor Domestic Waslewato Treatment
Facilities that Discharge to Reieiving Waters with a Chronic Low Flow: Design FIow Ratio of
100; l or Greater for M3, assimilative capacilics for cbronio total ammonia were calculated. The
dala psed ad the resulting calculations ofthe allowable discharge concenfra$on, M2, are contairred
in Table 6.
Based on the analysis, the assimilative capacity of the receiviug water is large errough to allocate a
total amflonia effluerrt concentration of 30 mgA'
V. Antidegradation R.eview
As set out in The Bwic Standards and Methodologies of Surface Wdter, Sectiort 31.8(2)(b), an
urtidegfadation alalyris is required excspt in cases whcf,e the recciving water is designated as "us€
hoteciefl." Note that "LIse hotecled" watErs are waters'lhat the Commission has determined do
Table 6
Ammonia Assimilative Capacities for the Colorado River
at The Rapids Development Corporation W'WTtr'
Design of 0,06 MGD (0.09i cfs)
Parameter 9t (cfs)8z kfs)'8 t'kls)'M1 Mj .Mt
NH3, Tot (mg1l) Jan I046 0.093 I 0461093 0.0080 0.70 7;784
NH3, Tot (mgil) Feb 1046 0.093 1046.093 0.0080 0.60 6,659
NHr, Tot (mgA) Mr 104(0.093 1046.093 0.0080 0.40 4,409
NH3, Tot (mgn) Apr 1r09 0.093 I109,093 0.008c 0.40 4.67s
NH3, Tot (mgn) May 1870 0,093 r870.093 0.008c 0.30 s.872
NH3, Tot (mg/l) Jun 1597 0,09 159?.093 0.008c 0.30 5,015
NH3, Tot (mgA) Jul r467 0,093 t46"t.093 0.008(0.30 4,606
NH3, Tot (rngfl) Aug l25C 0.093 1250,093 0.0080 0.30 3,925
MI,,Tot (mdl) S.p 17.5C 0,093 1250.093 0.0080 0.30 3,925
NH;, Tot (mg/l) Oct 1341 0.093 1347,093 0.0080 0.30 4,230
NH3, Tot (men) Nov l 050 0,093 1050.093 0,008c 0.30 3,297
NIIr, Tot (mg/l) Dec 1050 0.093 1050,093 0.0080 0.50 51555
Page ll of[4
FiB, 3,2004 5:26PVl M]ARTIN & M]ARTIN N0,4332 -P, t8/24
T1," Rapids D"relgpment C.grp. ttrIWTF Preliminary Efllucnt Limits pEl-_Garfield county.
not warrant the special protection provided by the outstanding waters desigrratiou or tle
antidegradatioo' review process" as set out in section 3l.S(2Xb). ThJantidegradation sectson oftheregulatiou bccame effective in December 2000, aad therefore antidegradaliou considerations areapplicable to this PEIs analysis.
According to the C/sr.tificatiom and Numeic Standards for Lower Colorado River Basin,steam
segmmt COLCLC01 is Undesignated, Thus, an antidegradatios review maybe conducted for this
ssgment if new or increased impacts are found to occur. However, the ratio of the flow of the
Colorado River to The Raprds Development Corporation WUJ'TF 4esign flow is 11247:l at low
flowq. Section 3 I '8 (3Xc) specifies that the discharge ofpollutants shoulinot be coruidercd to result
in significant degadation of the reviewable waters if the flow rate is greater than 100:l dilution arlow flow" Thus, condition 31.8(3)(c) of the regulations is met and no firrther anridegradation
evnluation is necessary.
YI. Regulatory Analysis
Re gulation 62, the Regulations for Effluent Limitattons, includes eflluent lirnitaions that apply to all
discharges of wastewater to State waters, wlfi the exception of storm water and agriculhral retrrrn
flows. These regulatiorrs are applicable to the discharge tom the proposed The Rapids Development
corporation wwrF. Table 7 coutains.a sumrtrary of these limitatiors.
' Table 7
Spe.cific Limitations for the Discharge of Wastes
Parameter
:
7.Day Average l0-Daglverage. ,,' :,:,fnslanlaneow
Moxitttym.
BODs 45 mpll 30 men NA
TSS, mechanical plant 45 me/l 30 me/l NA
TSS' aerarcd lagoon 110 mell 75 mcft NA
TSS, non-aerated lagoou 160 msJl 105 ms/l NA
BODs Percent Rerroval 85%
TSS Percent Removal Es%
Total Residual CNorine 0.5 mcll
PH 6.0-9.0 su ranse
Oil md Grease 70me[
Note that the TSS limitatiorts shoryn above vary based on the tlpe ofwastewater treahenl processes
used at the facility, The Regz/ations for Eflluent Limitations waivc the E5 percemt rernoval
requilements for TSS where waste stabilization ponds, both aerated and non-aerated, are used as the
principal process for teating domestic wastes,
Section 62'4(l) ofthe.Re6alationsfor Efiluent Limitatiorrs also indicatesthatnumeric limjtations for
fecal colform shall be determhed. The State has develbp ed the Procedure for Selection of Fecal .
ColifoaLimitations Permit Conditioru that specifies a 30-dayavoage limit of 6,000 colorues per
100 EI lnd a 7-day averzge limit of 12,000 colonies per 100 ml whan the ratio of the receiving
steam #ow to desigr flovr is greater than ten to one. T\e Procedarefor Selection ofFecal Coltform
Page l2 of 14
FEB, 3,2004 (26PIV] [4ARTIN & M]ARIIN N0, 4332-P, 19i24
The Rapids De.relopment Corp. \IIWJF Pr.liminaryEffluent Limits pEl-Garfield Counry
Limitations Pumil Condillons also specifies that tbe ?-dry avtl,nge limit must be calculated as two
times the 30-day average limit.
YII. PreliminarT Effluent Limits
The potential PEls reflected in Table 8 irrclude the considqation of rhe following:
' Assimilative capacities as discussed in the technical analysis contained rn-section IVo Effluent limits prescribed by the regulations based on the regulatory analpis provid.ed in
Section VI .
A determination ofwbjchPEls ultimately applywillbe dependent ondecisions madebyTheRapids
Dev elopment Corporatiou WWTF.
BODs(men)45 (7-dsy svaage), 30 (30-dayevcrage)
BODs(% remoral)85 (3Gdayaverage)
TSS, Ecchauical plant (mp/)-. 45 (7-day avcrage), 30 (30.day averrgc)
TSS, mechanical plant (% remowl)85 (30-&yavmage)
Oil and Greasc (m/l)l0 (marimun) I
pH G.u-)6. 5-9. 0 (minimr:m-maximum)
Fccal Coliform (#/100 ml). 12000 (7-day gykage), 6000 (30_d;; avnadi
I'lote that limitations for ammonia were not necessary for this facility because the assimilative
capesity of ttre receiving water, as discussed in SeEtion IV, is large eaough to establish totalarrnonia effluent concenbations at 30 mgil. Because teated sauilary seiage effluent is uot
expected to have a total asmonia concentation greater than 30 mfi, no .ddition.l allocatious were
detsrmined as per WQCD procedrue.
\,-IfI. References
Procedurefor Selection of Fecal Colform Limitations Permit Conditions,CDpllE, WeCD,
ApiI7,1976.
Colorgdo Total Moximun Ddily Load and Wasteload Allocatiorr Cruidance, CDPIIE, WeCD,
November 1991.
Classificatiow and Numeic Smndards for Lower Colorado River Basin, Regulation No, jZ,
CDPHE, WQCC, Effec(ve January 20, 2004,
\he Basic Standards and Methodotogies for Surface Wat*, Regulationrl, CDPHE, WeCC,
Effective October 30, 2001
Page 13 of14
Ft8,3,2004 5:26PM]NlARTIN & MART]N -N0. 4332-P, ?0i24--
Th".RrPids D"r.lopm"nt Cutp.\{WTF PreliminaryEfflu"or Limitr pEl-Garfield CoW
C-DPS Suntmary of Rationale General Permitfor Domestic Wastewater Treatment Facilities thatDischarge to Receiving Waters with a Chronic Low Flow: Design Flow Ratio of lA0: I oy Greeter,
0DPS Permit coc-584000, statewide, cDpHE, wQcD, septanbqr 14, 1994.
Antidegrn.dation Significance Determinationfor New or Increased Wmer euality Impacts,
Pracedural Gutddnce. CDPHE, WQCD, December 2001.
It'{emorandum Re: First Update to Guidance version 1.0, CDpIrE, weCD, April23, 2002.
a
,,
;,
Page 14 of 14
Exhibit B
t[8. 3.2004 5:27Plv][/]ARTIN & 1\,lARTIN N0.4332 ?, 2t/24
ilorv Edith
LoQon \^'.'q-
.t:
t=\+-
'-eav
,r<zhil.7th t-# -J '.--*\$l
t.ool) x . edit;r," _ I-/'
.
i*n^*
I
,ACE I)t{
,;!/
"# -..''.,e /
.h?' J,''
Stote of Colorodo
lFru D?sctf{bls:
PAB,SNG,[ orsltalt
P^n/Cil! rrceg
i""fi"l,',-#;lt::ir?Jr str//' '( s.otto6 . ... tb, str/( o( s.ofloa r. l.rru, o s.,,o-t *^ifiT-.;il?E.rrirgf .t.*o Southroriionrr o( rtd 3req.n a: ur!!. N (, !o, 0rSulJu I .!a .lcq &r er.r{t Uo,cv1lrd cour, orr .il r,.^,.- '1,'-'--:1 1;.."1i,.l-,.a4 l*ot.d ,5 rl"ttYrot.l'il?1'rt',Y,9'iig1.if;il.":,u"3",^:L:ij #:i,.i..il .iy-li!. t i"r.y,o-.l.il?1.,fi,,y,n h,h.. :,.,#l,v['t l'r*,""i.'. r,*""":"'s .x,i l"iil*;L1;.]{rj*i:L',i],i i:Iiri! ii.i itrl_;::y ,, ,,,
[!I."0;??,.n,"'
* l::i;i::i 1,.",.].;:]"1,n;i"S.?*:i,{,? i,:.li:iF"i!,:1i ffi} r.f;,";"it'.1:"i iI ij ,:I '-*li ?,1i,i!ii; ijj;j;'*::::'i"*"."i,,ifi f!il",i:liJ?"*',:."' ;'.H: i::.*:;ir""*1.lt"Hr,i":'"i:'^:{X'.jgii,:":-"rir; -iF:]*?'ffr i;'..'i0,.:l',"' ,H'i.',-,L1f[.",::"'.':iH#;;1 H"a$;.ii;1i."-:i".:.."tt"Ji*-m-.:*.i:J',..i st__i...i:LjT 1"":.;:...,.jU: ;1,:.-ii: ,d.rr{ Dr brucE ,, .da ,.F.t tNDni.rr, tu'!r-..-,., o. c6ur, "":' ",:: i*tl;.-'lil."::'f .ilI.'"r';'.3:t-'? #"::'::fL"; *t;i":lii;'"'
i'':
I,:
$
d.rv Dr '.ucE ,i .rr'r.*Ji t.':.i.]i"-ri :;l:I."::,f *t.'"r';,.3:T"_'? #"*:f #v,'!il;I;:"t"i.::yu'.ytrn:1i,.$i;-:i:i]={if l5e,-'-s.'_'1"r:! !i*y -11^d 1". -'ii,,a."-"*I;. -ff!:r[-.',Ui-,'"Ti.,l.,:'$ Ji....ffi1, t*1#.iT,S,;',.:1. g:'."f :i:,f;: *.ry,.-{n: nt- {. 1,;,r:1 lj." **. d.ess', rr
,6f Nd c.t-rr{. n**. i r-io ii; I
s r. u' zi' r act.u ii.e o-.i".-{.Duus. rr.t
T.,,-_11 y11. o e.o. s F go, m. i rJir,-.:r,?,.*f T:":"^:*-$:I- j+._;;,';;;"i:"J'.::f H',o"r
EZisi4 .:[Iu9i"Et
ZSEi'
EEEiEFrrtEiizz*!i
EE5ii
oo_<t(E O-;oEl
d$^o ir+sdr
5'EpL' LI
--P: iTH V. -F OY
A EU)(Eg
OA.
F
.o. AC{a-rUlL,ll-ti:.e, Itrt't-rALlly1,00t ... r^l!f, nlrld^?loH
.(, ufd lrtul.o. EXlStIilC ructlI-of,r I
gr.:lt.e. ml[
ucLE- P^Ltlt utfrl3
.eec t.u./.crc rfFsrfi
.3ol rcr,/D.U. olrsttr
^J*/RD L.t
?urrQo lNrFkr(-o,-x' s r r.. .r. : r:i.r" ,r."i-o'. ffi;:-" ,,ffo],ffi,.}T; X;t;:ii:r.Jr.ri F,6. rcm 0i DIcoNac: rrrc arre,ui- r.";#;;;i;Trj uh.. Eor e, r.!..
i\
LOt IINE
:=-.
\ -, .'/--.
/C \
( 'r-
' 'r / tI.,
I ../.',..4sat- /.-z-
..-'12
:i .tnt' /9
d:" \ \'\
,,b'1 / t.-..-_..
t-\ --.-
=.q,/. l.'!
1'"-'o"',)jt:-\ o'rrt sPicE
'l.tlr./
)t-,,::*
ItrU
: "=.t 00'
uqJltTlt{ c80s3 Ltr:GtNeER0{6, INC
iil'5u;r'i."^,."". rfff*Clrorood SDrugr. CO Cf60tFh: t?0-0{5.5S.{ fit. 9ZO.gas 5S5g
tB, 3.2004 5:27PMl IY]ARTIN & [/lARTIN
0IYHERz/nFpuc,lN?:
SAPlrs USt EL0p[$rT COXpO-lATroNr UPIDS ON Iu! cOLoRADo
Bo.rtolNEns AESCCIrIIONzl08 t. ARrP^{OE 0nIY8uTrLEmN, co 60120-3008
ENGINEER:
MINEEAI OTINERS:
0rar E. HJltoo & ysr? J, ltiltoqzro? L rrrpuoD onivruTTl8tot{, c0 0orzo-3oo!
Fedcrd laed Ernkf,iclltA, XX
N0,43t2 P, ??/)4
-Dirieie ond ClYde Atcc
RAP/D
FO/,ID
-/' +
'a+/' {1
---]-=--
.\-,1
Roy R.
Rokich
SUBVEIOR;
fiELEd 8ctar, Fls{77! Q1q5b, Bo.d ?1,slr... cc !1562Ph,/fu: e70!zl2ga?
UINERAL LESSEES:
CTLPNO
la00 t?Ur Strid. Sr ?70Dtrtcr. C0 60202
PATRIC|A
MUSICIl
rRp &
CHARLOTTf
J, /SNMER)
,aro
',\n\\
I
)
*lff;ffi ffi'I*HtE;ffi*ffi ffi ffi,,^1.=#fiffi:$*ffiffiffiii;fl**
/.,
/.
',7,t I
,*,..
.-/ t'
f>"",...,,',
:l-..','1
-\,-' .'. !...-
-:/
z -;';i: .)Y
./,"/' -/' jr \/../,.. ."./,.-.
.raa/ -.'./ U'/
" ,oU,|,/|)
/ , t,, Jr.., .-'/ t,,.':..
(,' ,rl/L\\, I
.N.''u !
7
., './
.\ \./t
I
.r/.dyw.,=.,,,'
YARTTN/MARTIN
egNtuLtlNo ENEtritEEna
FfB 3, 20C4 5:28PMl MARIIN & MIART]N
CallFrom: Dwain watson,CDpHE Grand Junctien DateTo: Jeremy Montrose
CopyTo; RogerSmades
N0. 4332-P, 23121
Exhibit C
TELEPHONE CONTVERSATTON RECORD
Paec I of2
Jaouary 24, 2004 Rcv
3:a5EarnEpmTime:
Pro.;ectNo.: 164j4.C.01
Project Titlc: Rapids on rhe Colorado
Discusslon:
Dwain had the following preliminary comments regarding thc site Applicariorr subrnrtted to hjm earrier rhis week.l'
ffilT;HH:'#Iscnd him the PELs which I had received from the p.'Tnirs unit rhis week. J faxed
: iffii:i:f*ff,H.Y,ff: slrows the floodplain boundarv ctearrv arong with rhe precise tocation orrhe3
3ffiffi::t1';1il;t"tdt certiffing that the Rapids Deveropment corporation has the necessary firnds
5' He asked how close the nearest residence will be locatod to thc teatnenr facility, and reminded me thatthers is a I00' setback requirement a=suming rn" rnr *"rrln, r..ir;ry wil ile,l"oroi"a in , building. Ifthe facirity is nor encrosed in q buildrng, *e"seruacilrq*#"", is r000,.6' since the setback requirement is t" gi.t ro, , non-in.i"."o r".iliry, the owaer w1l armosr definitely nced::ffHrTt facility' Therefore, the-costs associared with these added buildin*s musr be added to rhe cost
8, He stated rhat we should be using l5O gpan"p rather thsn 250 gpd,9' He informed me that Stlt's new i"*a*y lies within tl,r"e rfies of thc Rapids site, and therefore Silt musrprovide review corffnenE on the Site Application.
10. He thcn informed me thar full iufrastmctrue and tbe Silt town boundary have been cxpanded to withjn tbreemiles orthe RapiG sitc' rhe new Gorfieldg"*,y.",en il;;iil;;rurd i;;i',ijJ;e is on tbe southside of the south I'70 frontage road a,d on tr,. notru tl?.llti. ri"., at Davis point wiich ries atapproxinately betweea sections l0 and I l. That ,""*-rrrr, rrl would like ro see the option ofconsolidalion wilh silt examined more thoroughly. m;;;,i"g sewff ting at Davis poinr is I5,,, whichwill easily accept our flows. The design capac-iry-of o" iir, pi*, is 0.750 MGD, and they are onlyopcrating at approximatelv 0.160 MG6, so *,.; ri g,ir. fficity as *"t!. o*oi, ,t* gur" some newnumbers to bc used in this consolidation option, whichie r.J, "* mucb more appropriate costinforrn'ation' He stated that the force oraincan [. ir.t"rr"a ro, sts-zolroor, ."a-fli 5irr,s tap fees are only$3000/tap' This dramadcally dccreases the cc,st urro.o,"a *i'rn tu, consolidatron .ption, but &ere is theadded cost of constructing tire river cmssing.
I I' tft firther statcd that we ihourd work harder to convince Tarbon to coordinate with us for the deveropmentof this lift station to tic in to silt. He starcd ttrat ttrey are on u "ompri-oc schedule, and rhe re-tining of thelagoons is likely going to be far more expensive than the Talbon's elpecl, Therefore, they may be moreamenable to consolidation once they reaiize the exteni;f ,rrui"orr, TLe Iift .tntion on our property wouldpossibly be able to take raviry flow from Talbon ana ttre up fees to silt would probably be bargained
llr'"1#f,ff:li:fl?:,gt:,T,11*ss rEsponsc ro the cqD,sry is rcceived wirhin 7 deys frorr dsrc rbove.
Retucd 024f
12499 lYcst Celfax r p,O, Box l5l j00
Qivit Dcprrtmrnr Fax: 303-41 l.rl02g .
r Lakcwood,Colorado602tj r Telephonc:r0rffi
strucnrrl Dqrrrncnt Frx: 303411{865 - ur*oins Dcprrtmcnr Fu; }01-456.gg23
Application.
FIB, 3,2014 5:|9Pttt il]ARTIN & IllARTIN N0, 43i2--P, 14/24----
TELEPHONE COFTYERSATION RECORD
pageZ
down i{, between botb entities, fhcy were offering Silt over 500 taps. Anoth* benefit to this option is thatit would take both the Rapids and npple rr* rrfii"niori oirt, sewage business complctcry.
In summary Dwain feels that we have more work to do prior to thc site-Ap being eonsidered comptete. Sohopefully we can sir down and discuss a, these it"m, .rl*n * r"riiir. on Monday.
JJM
Revised 1t26104 per rhe following;
lll?,Jr';Jl1:ff1#ffi"#l* :"*H,TI.1yJ: *'north side orlnterstate 70, builhe 15, interceptor is
Addition:
li1"r:.'*'"THi',,l.i,Ti',:'.T#Jr'iJ"',:ffi':""1i:'i:1ffi:*$ no, *o praced on hord, which is partiaily why
ilrt"ilLt*:r:i,.Ti,r1i:,*,T1*s t€rsponsc lo thc contrary is rcccived wirhin 7 davs from datc rbove,
I2499WcsCol&xrP.o-Boxl5t500rLakewood,ColoradoE02l5
Civil Dcpanmenr Far:303-a3l^a029 r Stnrctunl Depanmenr Fsx: 30343t-6g68 r Mrkctintl Deparlmenr Fax: 1034j6.9923
R!v&d 024t
//-.V . A. .2< !, -, _
A-* /"-u,.
,J{ y'n-n-/'* Z."Z-_ /_u_ z.t:_tt_--(c.(. Z-_-, ./-_, Z__Aor-.-.,_*T ,4 -., '- . V I
F-L', 4z-.*<- -A"- *7r.e<z_t--<_<- zz<-r=-___4t_<__ y
::' '{'"' ( /'t-a*'-<^(:'< -z z-- .a z;-,-*-L .__ ,/<--4_< __i.
l<-/ ?- Lt-'a-'--44' a-z---*, z-fu- *-- y--^ .t
'* fr-Lt'-="-'- Z.--ru .z; -L---- - ./ -T
3-: a4-;-/'u-4- aa,-,,--{ z.* a--+.**a*
-
R.HCFirVffi&
AUG 0 8 2005
GAi:lr i
":. r"i_,,i..,_r Nl"\
BUtLiltNG il plr\itNiilcl
MARK BEAN
CITY PLANNER
GLENWOOD SPRINGS, CO.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
SUBJECT: project no. 16454.C.01
WASTEWATER TREATMENT FACILITY
THE RAPIDS ON THE COLORADO
First of all it is very upsetting to hear about a system such as this being put in yourhome area with virtually no notte. The only way we found out about this wastewatertreatment facility was by accident.
As an adjacent land owner, I'm very much against this system being put in. It willcause loss of enjoyment o{*y property,.ross of"valre," -v property, odor probrems,and it will further reduce_the qualiiy oith" water in the river. There are six of thesesystems above us on the colorado River now; Glenwood springs, west GlenwoodCanyon Creek' New Castle, River Bend and Apple Tree that dump into the ColoradoRiver, and the moss and argae is so thick nsrrinj l*;; il;up in it.The quality of the water has been reduced.
This system is not needed as the housing sites are to use septic systemsapproved on each site.
This housing development was approved-for 33 housing sites only. The countydisapproved putting more housing siies here because it woild be tooiongesiive and theinfrastructure and facilities couldiot handle any more. To have the housing developerask for a 588%o increase of housing sites is totaliy ridiculous. Nothing has changedin the area to let this increase "o*i about.
If greed is going to run our county and state, we are really in trouble.
Thank you
Kenneth Collins
3839 County Road 335
New Castle, CO. 91647
970-984-2241
-
Ron and Karen Nadon
267s cR335
New Castle , CO 91647
970-984-2569
Fax:970-994-2667
August 4,2005
Dear Sir,
It has come to our attention that Mr. Hilton has requested a permit to construct a
sewer plant on a piece of properfy about a quarter mile east of our house. we,re asking
that you deny his application for the following reasons:
o Presently, Mr. Hilton has been approved by the county to subdivide the
property into 38 lots, three of which wilr be used as open space. The
county authorized the construction of leach fields with septic tanks. The
number of dwelrings was based on several mitigating factors, county
regulations (Agricultual Rural Residentiar Deveropment codes) which
designate I dwelling per 2 acres, road conditions to and from the
development (the road is narow and not adequate to handle more traffrc
than that from the 35 dweilings), availabre water, and trre impact on the
local Bald Eagle population and deer and elk population. when the
county planning committee considered all these factors, they fert these
issues necessitated limiting the number of dwellings to the 35. Mr. Hilton
doesn't need a sewer plant for r94 dweilings when he is autho ized,to
build only 38 homes.
BS,CENP:
AUG t 2 Luu''
sfis"frE?8'1HN'I'I
-
' In addition, sewer prants work best when working at full capacity. To
build a plant that would service 194 homes, when the county has only
approved 35 homes would mean the plant would not be working at its
best.
o There are existing homes adjacent to the subdivision (one that will border
the proposed sewer plant). The smell from the plant will affect the quality
of life for those residents and for us since we live close enough to also
smell the plant' In addition the plant will adversely affect the value of the
property.
o Historically sewer plants have been difficult to keep in compliance. we
don't need another plant dumping into the colorado River especially since
there is one a mere two miles up river.
o we have lived on the river for 25 years. In that time we have noticed that
the river is changing; the amount of moss has increased dramatically.
we're concerned that yet another sewer plant dumping into the river will
adversely affect an important water supply that is already over stressed.
o Mr' Hilton demonstrated time and again an unwillingness to comply with
regulations in his dealings with the county. we,re concerned that he will
follow this pattem with the sewer plant.
we're asking that you wourd prease deny Mr. Hilton,s request for a permit to
build the sewer plant' He doesn't need the plant. He's already authorized to build leach
fields for 35 homes that the county approved of according to what the area can support.
H
Please feel free to contact us if you have any questions or if we can clariff
anything.
Sincerely,
Vr''lYladn*
lfuiyM,.,
Ron and Karen Nadon
\^a\rk ,
W{ ,r^,\ e}Qes 0F lhrr latp,^ Lffi r4/ck- -f cu\o\{p\ oQ}ubtc- l\e*tua5vrovvrro,r!4 [,^l d o0 ca,*tr/r4lecb.
Wr-
, c,s wA^Jdt yor\ f kh^^/ _tftd,- wL,LoM b \A,tr $t\:: \op6*t , Wdrz nat
1*lq fitA,l \,n +\\\^ br 0rymry tM (tqh+1b [uvatry hrs y.uw!, \ruru. M,\ {,,4_hu h- rotruru\
' ib cDr^tty rlur{h +fi"
HfT ,; h#,_ ryvne,^^l#
"" hhJ
FEB 11 2004 7:]5PM
LOYAL E, LEAVENWOR,TI{
SANDER, N. KARP
DAVID H. McCONAUGHY
JAMES S, NEU
JULjE C, BERQUTST-HEATH
SUSAN W- I.AATSCH
NICOLE D. OARRIMONE
,{NNA S, ITENBERC
MICHAEL J. SAWYER
TERESA L. HOCK
EDWARD B, OLSZEWSKI
Io:
Fax:
With cc to:
Fa:<:
From:
LEAVENllORTH & l(ARP
LEAVENWORTH & KARP, P.C.
A.TTORIYEYS AT LAW
NO 3BO t. l/ I
DENVEROFFICE:'
WAZEE EXCHANGE BU1LDING
I 9OO W
^ZEE
SIREET, STE. 203
DENVER, COLORADO EO2O2
Telephona (303) E25.3995
Facsimile; (301) 825-3997
'(Please dtrect all corretporrd€ttce
to ovr Glanwad Syrings OJfice)
Date: February 11,2004
IOI I GRAND AVENUE
P, O. DRAWER 2O3O
GLENWOOD SPRINCS, COLORADO EI602
Telephone; (970) 945-2261
Facsirnile; (970) 94s-7336
Iel@lklawfirm.com
;Ft I 200\
FACSIMILE TRANSIIdITTAI, SEEET
Mark Bea.n
384-3470
Dwain Watson
(97O) 248-7198
Lee Leavenworth
Number of pages to be transrrutted: 2 (including cover page)
Document Description: Letter re: Site Location Application of Rapids Development
Corporation
REMARKS:
NOTE:Ifyou encounter any difficulty in receivrng the total nurnber of pages ind,icated
above, PLEASE CAIL {970) 945-2261 AS SOON AS POSSIBLE.
Brende
Operator
_._ ORIGINAL SENT BY U.S. MAIL L ORIGINAL NOT SENT
THIS $ACSIMILE TRA}.TSMISSION IS STRICILY CONFIDENTIAL AND Is INTENDED oI\ILY FoR TIIEINDIVIDUAL ORENTITY NAMED ABOVE. IF YOU HAVE RECEIVED TEIS tr'ACSIMILE T|IAT]*SMISSION
IN ERnoR, PLEASE NOTIFT THIS OFfICE IMMEDIATELY AND RETIIRI{ fHE TRANSMISSION TO USAT TIIE ABOVE ADDRJSSS. THAM( YOU.
I C&{ElioyEtrol.0r\.erpop,-W.sl.r4d