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HomeMy WebLinkAbout3.0 Staff ReportDirector Decision 10/22/14 Up Dated 2/2/15 FDPA-8060 GH PROJECT INFORMATION AND STAFF COMMENTS TYPE OF REVIEW APPLICANT (OWNER) REPRESENTATIVE LOCATION Administrative Review for a Flood Plain Development Permit Peter Langegger, Turtle Tracks Riverfront Resort LLC Gamba & Associates Inc. The property is located approximately 3/4 mile south of the Town of Silt at 361 County Road 311. The property is also known by Assessor's Parcel No. 2179- 104-00-516. PROPERTY SIZE 6.79 Acres ZONING Rural I. DESCRIPTION OF THE PROPOSAL The Applicant is requesting approval to construct improvements within the 100 year flood plain, including a restroom and shower facility (bath house) along with an Individual Sanitary Disposal System (ISDS). The bathhouse structure is anticipated to be approximately 600 sq.ft. in size and will include laundry facilities, storage, and fish cleaning facilities. The Applicant received approval in April 2014 for an amendment to an existing resort Special Use Permit for the proposed improvements. A condition of approval for said amendment was obtaining approval of a Flood Plain Development pursuant to the Land Use and Development Code. A copy of the resolution of approval for the approved amendment is attached. The Application proposes elevation of the bath house facility to 1 foot above the 100 year flood plain in accordance with the County's regulations. The ISDS is proposed to be engineered and flood proofed to avoid any infiltration in the event of a flood. The Applicant and former owner of the property have previously submitted ISDS applications to the Garfield County Building Department. No other alterations or improvements to the flood plain are proposed. The Application represents that no areas of wetlands have been 1 identified on the portion of the site proposed for the improvements and a previous wetlands study on the site supports this representation. No hydrologic condition has been identified that required determination or permitting by the Army Corp of Engineers and no development is proposed within the floodway. The site is generally level and lies just west of County Road 311 and south of and adjacent to a channel of the Colorado River. Vegetation in the area of the site proposed for development is generally native grasses and pasture, although the site has previously been disturbed in anticipation of installation of septic tanks for the proposed system. The overall site is improved with a resort development including cabins, teepee camping areas, residences, driveways, and parking areas. VICINITY MAP Il, 41 0 • if gglj 1 P177PFP-r If�o-':,`r:,P, II. AUTHORITY A. The Land Use and Development Code Section 3-301 contains regulations and standards specific to development within a 100 year flood plain. Section 4-109 contains provisions related to the review process (Administrative) and the review criteria for development within a 100 year flood plain and permitting requirements. B. Section 4-203(0) contains a description of the requirements associated with a Floodplain Analysis. Table 4-201 contains submittal requirements for Development in a 100 Year Flood Plain. C. The Application is also subject to compliance with all building code requirements, zoning provisions (setbacks, building height), and stream setback provisions contained in Article 7 of the Land Use and Development Code. VIEW OF THE EXISTING RESORT AND BATH HOUSE AND ISDS LOCATION III. STAFF ANALYSIS Referral — Public Comments 1. The Applicant has provided evidence of proper mailing of public notice for the Director's Decision in compliance with the Land Use and Development Code provisions. No public comments on the request have been received. Referral Comments received from various agencies and are attached and summarized as follows: a. County Consulting Engineer, Mountain Cross Engineering: Commented that the Applicant should explain the reasoning for having the infiltrator elevation at the Base Flood Elevation (BFE) as opposed to having the infiltrator elevation above the BFE. After review of the Applicant's additional submittals and responses to referral comments (dated 12/19/14 and 1/13/15)) the engineer commented that his questions had been addressed and the responses adequately addressed concerns. b. Garfield County Road and Bridge: Commented on the need for a driveway access permit to meet current standards. c. Garfield County Environmental Health provided comments summarized as follows: • Supported water quality testing to ensure the system is working properly. • Requested clarification on some of the site plan elements. • Hazardous materials such as paint or oils should be stored to minimize the risk of entering the river during a flood. • Noted that vehicles parked in the flood plain could pose a risk. d. Town of Silt: Town of Silt: Provided detailed comments and analysis of the proposal focused primarily on the waste water disposal system. Their comments are summarized as follows: • Recommended that the system be designed according to the new OWTS regulations. • Expressed concerns about ground water levels and separation from the infiltrator mound system. Requested use of 100 year floodplain elevation as the effective groundwater elevation. • Recommended use of advanced treatment at a level of TL2N or greater. • Noted potential for wetlands issues including setbacks. • Noted that the system would be used for a commercial business and expressed reservations about use by campers or transient users. The Town also was referred Applicant responses to concerns and the Town provided additional comments in an email dated 1/6/15 which is also attached. e. Other referral agencies receiving the application but not providing comments included Colorado Parks and Wildlife and the U.S. Army Corp of Engineers. AERIAL PHOTOGRAPH Town of Silt Water Facility Section 4-109 (C) Review Criteria 2. The following comments address the review criteria contained in Section 4-109 (C) (1 — 10). Staff analyses are shown in bold. 1. The danger to life and property due to flooding or erosion damage; The Application represents elevation of the structure, engineered foundations, engineering for the ISDS and protection of both the foundation and ISDS mound system from erosion address this criteria. 2. The susceptibility of the proposed facility and its contents to flood damage and the effect of such damage on the individual owner; a. Elevation of the proposed structure and flood proofing of the ISDS will mitigate potential flood impacts and avoid damage to the improvements. Flood proofing utility installations including domestic water systems are also proposed. b. The Application was submitted prior to the County adopting the new On-site Waste Water Treatment System Regulations (OWTS). Therefore the ISDS regulations in place at the time of application are the regulations applicable to the request. This determination was made at the time of Application by Andy Schwaller, Chief Building Official. However, staff has requested that the Applicant address any differences in the code standards and demonstrate that the design is consistent with the new regulations. The Applicant has provided responses which have been reviewed by the County's Consulting Engineer and found to be acceptable. 3. The danger that materials may be swept onto other lands to the injury of others; Contents of the proposed structure will be enclosed within the building. Other improvements are largely below grade utility installations. Protection of the foundation and mound system from scour or erosion will help to preclude any soil/sediment or other materials from being swept onto other properties. 4. The compatibility of the proposed use with existing and anticipated development; a. The proposed uses are consistent with and part of the approved resort Special Use Permit as amended. Compliance with all previous conditions of approval shall be required. b. The Applicant's proposal complies with Section 7-203 A. Minimum Setback of 35 ft. from the ordinary high water mark. c. Pursuant to Section 7-204 Drainage and Erosion, the Applicant shall provide an engineered drainage plan at the time of building permit submittal that addresses storm water, impervious surfaces and best management practices to avoid any impacts to the adjacent water body. d. The proposed structure and ISDS system is located to comply with all required setbacks from wetlands, streams, and irrigation ditches. The ISDS system and mound leach field is 59 ft. from the nearest irrigation ditch, 79 ft. from the nearest pond, and 136 ft. or more from the Last Chance Ditch. e. The Applicant has also provided operations guidelines for the facility that address proper maintenance, care for the leach field, septic tank pumping and inspections. Site Plan Excerpt & Flood Plain Designations y L �— — — — — _ �1 / - •• I f z J may'`/ • Lt .77' — 7' 7 `� I�� y 1�:�1, / /7/1 1 1 / C 1 77 • �7 IL r ' 0 L= 7-/ t - -1 iLT :1>F FE7Fr,1 JJ l 4STFXV AND 7+17F. Par,, f C4r4tth .fall',F -k rAM PAW SfS11CN fF.J CJ+& SrrEM bL E. IMO WGUGM Or fel Qul . "14/1rlornuou+GNP • • • • • • • 5. The safety of access to the property in times of flood for ordinary and emergency vehicles; a. Access to the property is not proposed to be changed. Pursuant to the conditions of approval for the Amended Special Use Permit an updated driveway access permit is required. b. The Applicant has proposed operational limitation and closure of the proposed facility and ISDS in the event of a flood. The closure procedures are intended to provide additional protection for water quality and for public safety of customers of the resort. 6. The costs of providing governmental services during and after flood conditions, including maintenance and repair of streets and bridges, and public utilities and facilities such as sewer, gas, electrical, and water systems; a. The proposed improvements are planned to meet flood elevation requirements and include flood proofing for utility infrastructure. The proposed design should reduce the potential of flood impacts to trigger governmental services during and after flooding. b. The Applicant has provided additional application submittals and responses to referral comments that address a variety of concerns related to the flood proofing of the ISDS and protection against water quality concerns during flooding events. The supplemental materials are attached and dated 12/19/14 and 1/13/15. They include operations guidelines for the ISDS including shut down of the facility in the time of flooding events. The materials also address ground water determinations and separation from the mound system. c. The Applicant has provided engineered plans for the ISDS including flood proofing details. The Applicant has also committed to leak testing the existing septic tanks on site to further protect from potential water quality impacts. 7. The expected heights, velocity, duration, rate of rise, and sediment transport of the flood waters and the effects of wave action, if applicable, expected at the site; The technical evaluations prepared by the Applicant's Engineer address characteristics of the shallow flooding anticipated on the site. The shallow depth and slower velocities should limit impacts. The Application includes stabilization and protection of foundations and the mound leach field from flood impacts or erosion. 8. The necessity to the facility of a waterfront location, where applicable; The Applicant's proposal is part of an approved resort development and will maintain compliance with river setback requirements. 9. The availability of alternative locations, not subject to flooding or erosion damage, for the proposed use; and The Application represents that there are no locations on the property outside the 100 year flood plain. 10. The relationship of the proposed use to the Comprehensive Plan for that area. a. The Applicant's site is located within the Urban Growth Area for the Town of Silt with a Flood Plain overlay. The Application was referred to the Town and their comments noted in the Staff Report and addressed by supplemental Application submittals and conditions of approval. The Town's Comprehensive Plan Future Land Use Map designates the site as Recreation Commercial. b. Excerpts from the Garfield County Comprehensive Plan that address flood plain issues are noted below: Section 8 Natural Resources Goal #2: Preserve natural drainage patterns so the cumulative impact of public and private land use activities will not cause storm drainage and floodwater patterns to exceed the capacity of natural or constructed drainage ways, or to subject other areas to an increased potential for damage due to flooding, erosion or sedimentation or result in pollution to streams, rivers or other natural bodies of water. Section 8 Natural Resources Policies #2: Garfield County will encourage the protection of watersheds, flood plains, and riparian areas. EXCERPT FROM ENGINEERING PLANS (Complete set is attached) FNOY]'VIEY CHCS$ SE: On OF MOU`A LEA> EIE.A IV. SUPPLEMENTAL ANALYSIS — ENGINEERING & DESIGN A summary of key engineering issues is noted as follows: a. Engineering for both the structure's foundation and for the ISDS reflect design considerations appropriate to mitigate for the location within the 100 year flood plain. The plans include requiring an engineered foundation, elevation to 1 foot above the 100 year flood elevation, separation from ground water, monitoring pipes/wells, topsoil cover, erosion control, and flood proofing details. b. The Engineer's Report includes two specific options for protection of the ISDS mound system from erosion or scour during flooding events. The systems include use of an erosion control fabric and re -vegetation or use of a gravel/cobble placement and re -vegetation. c. The Engineer's Report indicates that all utility equipment in the proposed building shall be above the finished floor elevation (1 ft. above the 100 year flood elevation). d. The Engineer's Report indicates that all system components constructed below the 100 year flood elevation shall be constructed to be water -tight and protected from flotation. V. SUGGESTED FINDINGS The following suggested findings support an approval of the requested Flood Plain Development Permit 1. That proper public notice was provided as required for the Director's Decision. 2. Consideration of the Application was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were given the opportunity to provide input prior to the Director's Decision. 3. That for the above stated and other reasons the proposed Langegger, Turtle Tracks Riverfront Resort Flood Plain Development Permit is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. VI. RECOMMENDATION Staff supports a Director Decision approving the Langegger, Turtle Tracks Riverfront Resort Application for a Flood Plain Development Permit based on a the above suggested findings and subject to the following conditions: 1. That all representations contained in the Application and in the supplemental submittals including but not limited to reports dated 12/19/14 and 1/13/15 shall be considered conditions of approval. Said representations include but are not limited to technical flood plain evaluations, minimum elevations for the proposed structure, flood proofing and protection details for the ISDS, and the Operation and Maintenance Guide for the ISDS. 2. A post construction elevation certificate shall be provided to the County confirming compliance with the elevation requirements for the proposed structure, a minimum of one foot above the base flood elevation. 3. As part of the building permit submittals the Applicant shall provide a grading and drainage plan addressing storm water drainage adjacent to the new structure addressing water quality and including run-off from any impervious surfaces. 4. An engineered foundation shall be required for the proposed structure based on a site specific geotechnical evaluation and shall be designed to support the structure under saturated soil conditions. 5. The Applicant shall comply with all representations regarding the ISDS and said system shall be designed by a licensed professional engineer. The system shall be designed to meet all flood proofing standards including ensuring that all facilities below the 100 year flood elevation are water tight. Completion of leak testing for the septic tanks shall be required as a condition of the ISDS permit. Erosion protection as represented in the Application shall be required for the ISDS mound leach field system. 6. The operations guidelines for the resort shall require that in the case of an imminent flooding event on the site, the restroom/shower facility shall be closed and use of the ISDS prohibited until such time as the flood event and flood waters have receded from the site and the facility found to be in good operating condition pursuant to an inspection by a licensed professional engineer or other qualified professional. 7. The Applicant shall re -vegetate disturbed areas utilizing a seed mix and plant types approved by the County Vegetation Manager. The Applicant shall comply with the County weed control regulations including noxious weed management on the site. 8. All new construction on the site shall be subject to obtaining appropriate building permits, ISDS Permits, and grading permits. Compliance with all zoning requirements including building height shall be demonstrated at the time of building permit application. 9. All utilities below grade including electric installations shall be flood proofed to avoid any impacts from flood waters. 10. Prior to construction or grading on the site the Applicant shall obtain an updated driveway access permit for the site from the Garfield County Road and Bridge Department. The Applicant shall comply with any conditions of approval and required improvements. 11. The Applicant shall comply with Section 7-203 Protection of Waterbodies including but not limited to Section 7-203(C) which prohibits removal of existing native vegetation within the 35 foot setback. 12. The Applicant shall maintain compliance with all conditions of approval for the Special Use Permit for the resort including those conditions in Resolution No. 2014-16. ADDITIONAL VIEWS OF THE BATH HOUSE AND ISDS LOCATION October 17, 2014 Mr. Glenn Hartman Garfield County Planning 108 8th Street, Suite 401 Glenwood Springs, CO 81601 RE: Review of Turtle Tracks Resort: FDPA-8060 Dear Glenn: MOUNTAIN CROSS ENGINEERING, INC. Civil and Environmental Consulting and Design This office has performed a review of the documents provided for the Flood Plain Development Permit Application of the Turtle Tracks Resort. The submittal was found to be thorough and well organized. The review generated the following comment: • The Applicant proposes the bottom of the Septic System infiltrators to be at the Base Flood Elevation (BFE). This arrangement would potentially not allow infiltration during flooding events. The Applicant should explain the reasoning for having the infiltrator elevation at the BFE opposed to having the infiltrator elevation above the BFE. Feel free to call if you have any questions or comments. Sincerely, Mou ain Cross Engieerijig, Inc. J�� Chris Hale, PE 8261/2 Grand Avenue, Glenwood Springs, CO 81601 P: 970.945.5544 F: 970.945.5558 www.mountaincross-eng.com Glenn Hartmann From: Dan Goin Sent: Monday, October 13, 2014 11:38 AM To: Glenn Hartmann Subject: Turtle Tracks Resort Glenn, We still have the same problems with this as when Toler was working on it. There is not a current driveway permit on file, and the driveway does not meet current specifications. They have added some material to make the drop off not so steep, but still does not meet the current specifications. Thanks Dan 1 195 W. 14`h Street Rifle, CO 81650 (970) 625-5200 Garfield County Community Development 108 8th Street Glenwood Springs, CO 81601 Attn: Glenn Hartmann Public Health 2014 Blake Avenue Glenwood Springs, CO 81601 (970) 945-6614 October 17, 2014 Hello Glenn, I have reviewed the application for the Turtle Tracks Resort — Langegger Flood Plain Permit and have a few comments: 1. The sewage treatment system seems to be designed properly to withstand the occurrence of a 100 year flood, so I have no issues there. However, due to the system's close proximity to the Colorado River and its location in the river's alluvium, I recommend regular testing of water quality for E. Coli and nitrates in nearby wells. This will ensure that the system is working properly. 2. Since not every structure is labeled on the site plan, I would like to see some sort of Legend that indicates what the different shapes and textures represent. 3. Residents of the property, either temporary or permanent, should pay close attention to where hazardous materials such as paint and motor oil are stored to reduce their potential to enter the river in the event of the flood. Vehicles parked in the floodplain could also pose a risk to the water supply. Thank you, Ic7,7l Morgan Hill Environmental Health Specialist III Garfield County Public Health 195 W. 14th Street Rifle, CO 81650 (970) 665-6383 Garfield County Public Health Department — working to promote health and prevent disease 231 N. 7th Street, P.O. Box 70, Silt, Colorado 81652 (970) 876-2353 Office (970) 876-2937 Fax October 17, 2014 Garfield County Community Development Attn: Mr. Glenn Hartmann 108 8th Street, Suite 401 Glenwood Springs, CO 81601 Re: Referral for Turtle Tracks Resort ISDS within 100 -year floodplain Dear Mr. Hartmann: On October 7, 2014, the Town of Silt reviewed the Turtle Tracks Resort Floodplain Development Permit at its regularly scheduled Planning & Zoning Commission Meeting. The Town of Silt believes that installing an Individual Sewage Disposal System (ISDS) within the floodplain of the Colorado River and upstream of the Town water supply is concerning. As you may be aware, the Colorado Department of Public Health and Environment (CDPHE) replaced ISDS regulations with new Onsite Waste Water Treatment (OWTS) regulations (Regulation # 43) on June 30, 2013. The CDPHE then allotted counties one year to provide their own more stringent regulations or adopt the CDPHE's. The Garfield County Board of County Commissioners (BOCC), sitting as the Board of Health, passed Resolution No. 14-22 on April 14, 2014, which essentially adopted CDPHE Regulation # 43 with an effective date of June 30, 2014. According to the application, the DFE (Design Flood Elevation) is approximately 2.2 feet above the existing ground. The greatest concern is that the applicant is proposing an ISDS (disposal) under the older regulations and not the OWTS (treatment) under the current regulations in an area that has high groundwater that surfaces in early sunnner, is subject to flooding, and may receive concentrated waste (BODS, TSS and nitrogen) or non-residential waste by transient users. There is also a concern that the leach field is located on top of or within 50' of a jurisdictional wetlands. Regulation #43.8.J states: New OWTS and replacement OWTS installed in a 100-yearfloodplain shall meet or exceed the requirements of the Federal Emergency Management Agency and the local emergency agency. Repairs of an existing system shall meet the 231 N. 7th Street, P.O. Box 70, Silt, Colorado 81652 (970) 876-2353 Office (970) 876-2937 Fax requirements as feasible. The system as approved by a local public health agency shall be designed to minimize or eliminate infiltration offloodwaters into the system and discharge from the system into the floodwaters. NFIP Unit 5, NFIP Floodplain Management Requirements states: Water and Sewer Systems 44 CFR 60.3(a)(6) [The community must] Require within flood -prone areas (i) new and replacement sewage systems to be designed to minimize or eliminate infiltration of flood waters into the systems and discharges from the systems into flood waters and (ii) onsite waste disposal systems to be located to avoid impairment to them or contamination from them during flooding The objection of these requirements is to ensure that a building that is protected from flood damage can still be used after the flood recedes. In most instances, these criteria can be met through careful system design. Manholes should be raised above the 100 -year flood level or equipped with seals to prevent leakage. Pumping stations should have electrical panels elevation above the BFE On-site waste disposal systems should be located to ensure they will not release contamination in a flood and can be used after flood waters recede. The first objective should be to locate the system outside the flood hazard area, if that is feasible. A couple of major differences between the ISDS regulations and the OWTS regulations that affect this site and are of concern to the Town are: Vertical setback from groundwater: ISDS = 4', OWTS = 4' (Treatment Level TL1) or 3' with pressure dosing (TL1) or 2' with advanced treatment (TL2N or greater). Setback from wetlands: ISDS = N/A, OWTS = 50 (wetland grasses and shallow groundwater on the site). Given the proximity and upstream location of this system to the Town's only water supply, the Town of Silt would suggest that the system be designed according to the current OWTS regulations (not the outdated ISDS regulations) with the consideration of the 100 -year floodplain elevation as the effective groundwater elevation and with advanced treatment at a level of TL2N or greater. At a minimum, advanced treatment TL2N should be mandated for the site. These precautions should ensure that the groundwater is not contaminated by effluent under daily use and that the river does not received the contaminated soils of the mound when the site does flood. 231 N. 7th Street, P.O. Box 70, Silt, Colorado 81652 (970) 876-2353 Office (970) 876-2937 Fax hanks for your consideration. (/?' Sincerely, til Mark Rinehart, Planning & Zoning Corrunission Chairman CC: Planning & Zoning Commission; Janet Aluise, Community Development Director; Jack Castle, Utilities Director; Pamela Woods, Town Administrator, Gerry Pace, Public Works Director; file Glenn Hartmann From: Janet Aluise [jaluise@townofsilt.org] Sent: Tuesday, January 06, 2015 8:44 AM To: Glenn Hartmann Subject: Turtle Tracks ISDS Hello Glenn: The Town, after a thorough review of the comments from Gamba and Assoc. regarding the Turtle Tracks Flood Plain Development permit and ISDS: (Town's comments are in italics and highlight) • Questions and concerns regarding compliance with Regulation 43.8.J: o The system as designed is in full compliance with regulation 43.8.J. ■ Regulation 43.8.1.1 states, "New OWTS and replacement OWTS installed in a 100 -year floodplain shall meet or exceed the requirements of the Federal Emergency Management Agency and the local emergency agency... The system as approved by a local public health agency shall be designed to minimize or eliminate infiltration of floodwaters into the system and discharge from the system into the floodwaters." For reference, the subject site appears to be located in Zone A. ISDS (OWTS) absorption field components include the distribution layer and the treatment soils located beneath the distribution layer as evidenced by the CDPHE requirements to maintain minimum vertical separations between the infiltrative surface (bottom of Infiltrators) and restrictive layers or groundwater (CDPHE Regulation #43, Table 7-2) . FEMA publication Protecting Building Utilities From Flood Damage (FEMA P-348, Edition 1/November 1999) Section 3.4.2.1 NFIP Requirements states, "Component Protection refers to the implementation of design techniques that protect a component or group of components located below the DFE from flood damage by preventing floodwater from entering or accumulating within the system components." This publication also requires that the tank be watertight if installed below the DFE, including walls, wall penetrations, tank access covers and tank inspection pipes and indicates that leach fields located in Zone A should be protected from erosion and scour. The design does not provide evidence of such protections or the prevention of floodwater from entering or accumulating within the treatment layer component of the ISDS (OWTS) or the discharge of untreated effluent into the floodwaters. • Questions and concerns regarding compliance with FEMA Floodplain Management Requirements [44 CFR 60.3(a)(6)]: o The system as designed is in full compliance with the FEMA regulations as stated in 44 CFR 60.3(a)(6). ■ 44 CFR 60.3(a)(6) states, "(6) Require within flood -prone areas (i) new and replacement sanitary sewage systems to be designed to minimize or eliminate infiltration of flood waters into the systems and discharges from the systems into flood waters and (11) onsite waste disposal systems to be located to avoid impairment to them or contamination from them during flooding." 1 The design is not in compliance because it permits the infiltration of floodwaters into the treatment layer component of the ISDS (OWTS) and does not protect the leach field from erosion and scour which would permit contamination from the system during flooding. • Compliance with OWTS regulations vs. ISDS regulations: o The system as designed provides a minimum vertical separation of 4 -feet from the normal groundwater level which is in compliance with the OWTS regulations. • The Regulation 43 definition for Ground Water Surface states, "'Ground water surface' means the uppermost limit of an unconfined aquifer at atmospheric pressure." The Town would contend that this definition does not include the term 'normal' as used by the Applicant's engineer and that 'uppermost limit' includes the 100 -year flood elevation since the subject site is located well within a documented flood prone area. Please also know that the Town has a photograph which indicates that the 'normal' seasonal ground water level exists just above the ground surface in the vicinity of the proposed ISDS (OWTS). The drawings provided for comment do not include a section of the ISDS (OWTS) absorption field to confirm the 4 -foot separation claimed. o The system as designed provides a minimum setback of approximately 79 -feet from wetlands, which complies with the minimum 50 -ft setback as required by the OWTS regulations. ■ The Town has photographs which indicate a significant presence of wetland vegetation in the immediate vicinity of the proposed ISDS (OWTS). The documents and plans received for comment do not include any USACE approved wetland delineations. The statement by the Applicant's engineer that the design provides a minimum setback of approximately 79 feet from wetlands appears to suggest that wetlands only exist along the edges of the pond to the south when compared to the drawings received for review. The Town believes that there is sufficient reason to require that the wetlands be mapped and approved by the USACE as evidence that system is in conformance of Regulation #43. o System should be designed to advanced treatment level TL2N: ■ The system as designed is in complete conformance with the current OWTS regulations adopted by the CDPHE and all Garfield County regulations based on the level of treatment proposed. There are no state of Colorado or Garfield County regulations which would require that this system be designed to provide for a higher level of treatment. • The suggestion that the system be designed to advanced treatment level TL2N is proposed so that the Applicant's engineer could effectively reduce the required vertical separation between the bottom of the Infiltrators to the appropriately defined 'ground water surface' down from 4 -feet to 2 -feet. A treatment level of TL2N would also reduce the contamination level of the effluent entering the absorption field to level which is acceptable to the Town for an ISDS (OWTS) which is located in close proximity to the Town's only potable water supply source. In addition to these response comments, it has also come to the Town's attention that this /505 (OWTS) system is for a non-residential use and is subject to additional requirements according to CDPHE Regulation #43 Section 43.7.K.1 including: b. Receive only such biodegradable wastes for treatment and distribution as are compatible with those biological treatment processes as occur within the septic tank, any additional treatment unit and the soil treatment area; and c. Receive authorization by rule or a class V underground injection permit from the United States Environmental Protection Agency (EPA) before an application for an OWTS permit is approved if the system may receive non-residential wastewater or is otherwise covered by the EPA underground injection control program. Based on the documents received for comment, the Town has no assurances that the ISDS (OWTS) will comply with 43.7.k.1.b. The Town would contend that it is not uncommon for transient users/campers to unlawfully discard non 2 biodegradable and harmful/hazardous contaminants into sanitary facilities. A basic TL1 treatment level ISDS (OWTS) will essential discharge these contaminants directly into soils and groundwater located upstream of the Town's potable water supply source. Therefore advanced treatment should be implemented to provide at least some protections. Effluent should also be tested for contaminants on a routine basis with results reported to the County and Town. Testing procedures and scheduling should be incorporated into the Operation and Maintenance Guide for proper compliance.. Please also provide evidence that Section 43.7.K.1.c has been complied with prior to issuance of any permits. Janet Aluise Community Development Director Town of Silt 231 N. 7th Street P.O. Box 70 Silt, CO 81652 (970) 876-2353 Ext. 1o8 (office) (97o) 876-2937 (fax) jaluiseOtownofsilt.org janet@townofsilt.org http://www.townofsilt.org This electronic mail message, including all attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information or otherwise may be protected from disclosure. Any unauthorized review, use, disclosure, distribution or actions which rely on the contents of this information is prohibited. If you are not the intended recipient, please contact the sender and delete the message and any attachment(s) from your system. Thank you. 3 VIII !or11r,'frivA m+KUIra Ir.,110. ii , 1111 Reception#: 847974 04,0712014 04 07 42 PM Jean Albe 1 co 1 of 6 Rec Fee $0 00 Doc Fee 0 00 GARFIELD COUNTY CO STATE OF COLORADO ) )ss County of Garfield ) At a regular meeting of the Board of County Commissioners for Garfield County, Colorado, held in the Commissioners' Meeting Room, Garfield County Administration Building in Glenwood Springs on Monday, the 17`h day of March A.D. 2014, there were present: John Martin Mike Samson Tom Jankovsky Frank Hutfless Jean Alberico Andrew Gorgey , Commissioner Chairman , Commissioner , Commissioner , County Attorney , Clerk of the Board , County Manager when the following proceedings, among others were had and done, to -wit: RESOLUTION NO. G.210/4 4 ` Ra A RESOLUTION OF APPROVAL FOR AN AMENDED LAND USE CHANGE PERMIT, SPECIAL USE PERMIT FOR A RESORT ON A 6.87 ACRE PROPERTY OWNED BY PETER LANGEGGER, LOCATED AT 361 COUNTY ROAD 311, IN SECTION 10, TOWNSHIP 6 SOUTH, RANGE 92 WEST OF THE 6TH P.M., GARFIELD COUNTY PARCEL NO. 2179-104-00-516 Recitals A. The Board of County Commissioners of Garfield County, Colorado, (Board) received a request for an Amended Land Use Change Permit — Special Use Permit to allow modifications to an existing Special Use Permit for a Resort, as further described in Exhibit A, Site Plan. (File No. SUAA-7776) B. The Project is located on a 6.87 acre parcel of land owned by Peter Langegger. The ownership of this property is described in a warranty deed found at Reception Number 846099 in the records of the Garfield County Clerk and Recorder. The Application was originally submitted by Thom and Camille Toler and subsequently assigned to Peter Langegger. The Project is also known as the Ruby River Ranch Resort. C. The subject property is located within unincorporated Garfield County in the Rural (R) zone district, approximately '/2 mile south of the Town of Silt. 1 • UH[KirYkliOti.laVoillke tRIVAl«Ch0,1iiii1111i Reception4: 847974 0410717014 04 07.42 PM Jean Alberico 2 of 6 Rec Fee $0 00 Doc Fee 0 00 GARFIELD COUNTY CO D. The Application was reviewed by the Board of County Commissioners in accordance with the provision of the original Special Use Permit approval, Resolution No. 2004-112, and consistent with the Land Use and Development Code for an Amendment to an Approved Land Use Change Permit Special Use Permit. E. The Board is authorized to approve, deny or approve with conditions an Amendment to an Approved Land Use Change Permit application resulting in issuance of an Amended Land Use Change Permit pursuant to the Land Use and Development Code, as amended. F. The Board of County Commissioners opened a public hearing on the 17th day of March, 2014 for consideration of whether the proposed Amended Land Use Change Permit should be granted or denied, during which hearing the public and interested persons were given the opportunity to express their opinions regarding the request. G. The Board of County Commissioners closed the public hearing on the 17th day of March, 2014 to make a final decision. H. The Board on the basis of substantial competent evidence produced at the aforementioned hearing, has made the following determinations of fact: 1. That proper public notice was provided as required for the hearing before the Board of County Commissioners. 2. The hearing before the Board of County Commissioners was extensive and complete, that all pertinent facts, matters and issues were submitted and that all interested parties were heard at that meeting. 3. That for the above stated and other reasons the proposed Amendment to the Langegger Ruby River Ranch Resort Special Use Permit is in the best interest of the health, safety, convenience, order, prosperity and welfare of the citizens of Garfield County. 4. That with the adoption of conditions, the application is in general conformance with the 2030 Comprehensive Plan, as amended. 5. That with the adoptions of conditions the application has adequately met the requirements of the Garfield County Land Use and Development Code, as amended. RESOLUTION NOW THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Garfield County, Colorado, that: A. The forgoing Recitals are incorporated by this reference as part of the resolution. 2 . 1111 FrarYi4VtnJillt ii11tiif ,iw/,?NEIilr1Ihinaki,11111 Reception#: 847974 04/07/2014 04 07:42 PM Jean Rlberico 3 of 6 Rec Fee $0 00 Doc Fee.0 00 GARFIELD COUNTY CO B. The Land Use Change Permit for an Amendment to the Langegger Ruby River Ranch Resort Special Use Permit is hereby approved subject to compliance with the following conditions: 1. That all representations made by the Applicant in the application shall be conditions of approval, unless specifically altered by the Board of County Commissioners. 2. That the operation of the Resort facility shall be done in accordance with all applicable Federal, State, and local regulations governing the operation of this type of facility including but not limited to Army Corp of Engineers Permitting and storage requirements for potentially hazardous or polluting materials. 3. Prior to the issuance of the Land Use Change Permit, the Applicant shall provide documentation that all required amended well permits have been issued by the Division of Water Resources adequate to demonstrate a legal supply of water for the facility. The well permits shall include use of the wells for the bath house facility and the Applicant shall keep current all contracts with the West Divide Water Conservancy required for the issuance of the amended well permits. 4. Prior to issuance of the Land Use Change Permit, the Applicant shall complete a 4 hour pump test and required water quality testing in accordance with the Land Use and Development Code. The reports shall be accompanied by analysis by a qualified professional indicating that the well production is adequate to serve the proposed use and that the water quality is safe for human consumption meeting applicable CDPHE standards or provide for acceptable treatment options in order to achieve compliance. 5. Prior to the issuance of the Land Use Change Permit, the Applicant shall obtain a flood plain development permit for the proposed bath house facility and supporting infrastructure. The Applicant shall comply with all conditions of said permitting including flood proofing and elevation as may be required. 6. Prior to the issuance of the Land Use Change Permit, the Applicant shall obtain a County Driveway Access Permit and comply with any required improvements. 7. The Applicant shall provide evidence that the pedestrian access bridge westerly landing on the camping area/island is located within the Applicant's property, will be relocated to the Applicant's property within the same general area of the site subject to compliance with all County Flood Plain and Army Corp of Engineering regulations, or provide other evidence acceptable to the County that encroachment issues have been addressed by easements, use agreements, or property acquisitions/boundary line adjustments. 3 UIlf 1i!'1Ci!tilYiliki SP!, 11 II 1 Receptiont4: 847974 04/07/2014 04 07 42 PM Jean Rlberico 4 of 5 Rec Fee $0 00 Doc Fee 0 00 GARFIELD COUNTY CO 8. Waivers from Land Use and Development Code requirements for Landscaping Plans and Traffic Studies are approved pursuant to the approval criteria contained in Section 4-118. 9. All previous conditions of approval contained in Resolution 2004-112 shall remain in effect with the exception of Condition #8 which shall be deleted. 10. In accordance with Resolution No. 2004-112 Condition #7, the Applicant shall maintain all emergency vehicle access driveways at a minimum width of 20 ft. and shall provide an emergency vehicle turnaround in the vicinity of the fishing pond. 11. Construction of the proposed facility and any related site disturbance shall be properly designed for drainage and restored with native vegetation and seed mixes as part of the Building Permit process for the facility. 12. The Applicant shall complete all remaining engineering required for the septic system and obtain all required County permits for said system. 13. All potential hazardous materials or materials with potential for impacts on water quality shall be properly stored and contained within the building. Dated this I day of ATTEST: , A.D. 20 I . Y BOARD OF GARFIELD k of the Board Upon motion duly made and secon • ed the fo egoing ' soon was a• • pted by the following vote: COMMISSIONER CHAIR JOHN F. MARTIN COMMISSIONER MIKE SAMSON COMMISSIONER TOM JANKOVSKY , Aye , Aye , Aye 4 - u111tordrubvimli 111 Reception*: 847974 04/07/2014 04 07 42 PM Jean Rlberico 5 of 5 Rec Fee $0 00 Doc Fee 0 00 GARFIELD COUNTY CO STATE OF COLORADO )ss County of Garfield I, , County Clerk and ex -officio Clerk of the Board of County Commissioners, in and for the County and State aforesaid, do hereby certify that the annexed and foregoing Resolution is truly copied from the Records of the Proceeding of the Board of County Commissioners for said Garfield County, now in my office. IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of said County, at Glenwood Springs, this day of , A.D. 20 County Clerk and ex -officio Clerk of the Board of County Commissioners 5 Mill FIF.IrtilliYAMI,I 1111 Reception#: 847974 04/07/2014 04 07-42 PM Jean Rlberica 6 of 6 Rec Fee $0 00 Doc Fee 0 00 GARFIELD COUNTY CO EXHIBIT A — SITE PLAN 6 110'"F-- a�Zil r • Proposed Location of Combined Bathhouse Building WASIK op PAWL Pupae • • u 0.1.930.0 PC MAO ti r r r 6 G A M B A & ASSOCIATES CONSULTING ENGINEERS & LAND SURVEYORS WWW. IM[t RIMp.COM PHONE: 970/945-2550 Fax: 970/945-1410 • 113 NINTH STREET, SUITE 214 P.O. Box 1458 GLENWOOD SPRINGS, COLORADO 81602-1458 December 19, 2014 Glen Hartmann Garfield County Planning 108 8th Street - Suite 401 Glenwood Springs, CO 81601 RE: Response to Review Comments in regard to the Flood Plain Development Permit and ISDS Permit for the Turtle Tracks Resort near Silt, Colorado Dear Glen: In accordance with your request, following are our responses to the review comments that you received in regard to the Flood Plain Development Permit and ISDS Permit for the Turtle Tracks Resort near Silt, Colorado. Response to Chris Hale's Comments: • Bottom of Infiltrators at the base flood elevation vs. 1 -ft above the BFE: o This is not an issue for two reasons: 1. During a 100 -year flood event the bathroom facility which is served by the proposed ISDS will be surrounded by 2 to 3 feet of floodwaters and will not be in use. Therefore there will be no effluent directed to the ISDS 2. In the unlikely event that someone did happen to use the bathroom facility under these circumstances, the effluent would percolate laterally through the sides of the infiltrators and in doing so would have to travel laterally through a minimum of 6 -feet (2 -feet of topsoil at 3 to 1 slope = 6 -feet) of topsoil before discharging to the floodwaters 3. Finally, if these are not satisfactory, then a restriction can be placed on the bathroom facility that it shall not be used during a 100 -year flood event. Response to Dan Goin Comments: • We believe that this comment is in regard to a prior application by this property owner for the development of the resort and is addressed by a condition of approval for that application. This particular application is entirely related to the development of the proposed restroom facility and the associated ISDS. In any case, if the driveway needs to be regraded to meet a certain specification, then that can be accomplished. Response to Morgan Hill Comments: • Regular Water quality testing due to proximity to Colorado River: o The leach field is over 320 -feet from the actual normal bank of the Colorado River and 161 feet from the bank of the Last chance ditch. Both of these distances exceed the minimum allowable distances established by either Garco or CDPHE, and neither Garco nor CDPHE require regular testing of water quality. We do not believe that such testing is required by any regulation and therefore should not be required. • A legend and additional labels have been provided on the attached Site plan. • The applicant understands that hazardous materials and/or vehicles parked in floodplain can pose a risk to the water supply and intends to avoid and/or minimize these occurrences. Response to Town of Silt Comments: • Questions and concerns regarding compliance with Regulation 43.8.J: o The system as designed is in full compliance with regulation 43.8.J. • Questions and concerns regarding compliance with FEMA Floodplain Management Requirements [44 CFR 60.3(a)(6)]: o The system as designed is in full compliance with the FEMA regulations as stated in 44 CFR 60.3(a)(6). • Compliance with OWTS regulations vs. ISDS regulations: o The system as designed provides a minimum vertical separation of 4 -feet from the normal groundwater level which is in compliance with the OWTS regulations. o The system as designed provides a minimum setback of approximately 79 -feet from wetlands, which complies with the minimum 50 -ft setback as required by the OWTS regulations. • System should be designed to advanced treatment level TL2N: o The system as designed is in complete conformance with the current OWTS regulations adopted by the CDPHE and all Garfield County regulations based on the level of treatment proposed. There are no state of Colorado or Garfield County regulations which would require that this system be designed to provide for a higher level of treatment. Please contact us if you have any questions, or need additional information. Sincerely, Gamba & Associates, Inc. A•Ap Michael Gamba, P.E. & P.L.S. 28036 1:\GVWF\14115\ISDS\Response to Referral Comments - 20141219.doc Glenn Hartmann From: Mike Gamba [mgamba@gambaengineering.com] Sent: Friday, December 19, 2014 4:14 PM To: Glenn Hartmann Cc: bkelly@gambaengineering.com Subject: RE: Langegger Flood Plain Development Permit Attachments: Flood Plain Development Site Plan - 20141219 -Site Map.pdf; ISDS - Operation and Maintenance Guidelines.pdf; Response to Referral Comments - 20141219.pdf Glenn, With respect to the Langegger Flood Plain Development Permit, in response to your request, attached please find the following: • Revised Site Plan with labels and legend per comments from Morgan Hill • ISDS Operation and Maintenance Guidelines for the proposed system • Responses to the referral comments. Please contact us if you have any questions or need additional information. Sincerely, Gamba & Associates, Inc. Michael Gamba, P.E. & P.L.S. 113 Ninth Street - Suite 214 Post Office Box 1458 Glenwood Springs, Colorado 81602 Phone: (970) 945-2550 Fax: (970) 945-1410 mgamba[lagambaengineering.com Original Message From: Glenn Hartmann [mailto:ghartmannOgarfield-county.com] Sent: Wednesday, October 22, 2014 9:48 AM To: Mike Gamba Subject: Langegger Flood Plain Development Permit Hi Mike: Attached are the referral comments we have received to date. I will call to discuss a couple of questions as we finalize the Director's Decision. I am working with our Chief Building Official, Andy Schwaller on the Town of Silt, ISDS comments. Thanks. Sincerely, Glenn Hartmann Community Development Department 1 TURTLE TRACKS RESORT, LLC Silt, Colorado INDIVIDUAL SEWAGE DISPOSAL SYSTEM OPERATION and MAINTENANCE GUIDE Owner: Peter Langegger 361 Divide Creek Road (C.R. 311) Silt, CO 81652 Prepared By: Gamba & Associates, Inc. 113 9th Street, Suite 214 Glenwood Springs, Colorado 81601 (970) 945-2550 G A M B A & ASSOCIATES CONSULTING ENGINEERS & LAND SURVEYORS W W W.OAMSASNOINS[RIMO.COM Michael I. Gamba, P.E. 28036 December 19, 2014 INDIVIDUAL SEWAGE DISPOSAL SYSTEM OPERATION AND MAINTENANCE The following tips and suggestions are intended to increase the useful life of your engineered sewage disposal system and to prevent disposal system failure due to neglect and abuse. MINIMIZE THE LIQUIDS Practicing water conservation practices can minimize wastewater that enters the system. The less wastewater you produce, the less wastewater there will be to treat and dispose. 1. Repair leaky fixtures. Check the toilet by dropping food -coloring dye in the tank and see if it shows up in the bowl prior to flushing. 2. Wash clothes only when you have a full load. 3. Take short showers instead of baths. Don't turn on the shower all the way and turn it off while lathering. 4. Install and use water saving fixtures and devices in your bathrooms, laundry rooms and kitchens. 5. Do not let the water run while washing, shaving, brushing teeth, rinsing vegetables, dishes, etc. Use a stoppered basin where possible. 6. Provide adequate drainage around the engineered system area to divert surface runoff from higher ground during storms or winter snowmelt. MINIMIZE THE SOLIDS Septic systems are "anaerobic" treatment systems. Digestion of solid materials is very slow and requires air or "aerobic" conditions to "disappear". The less material you put into the system, the less often it will require pumping. A good rule to follow is: "Don't use your septic system for anything that can be disposed of in some other way" 1. Avoid using a garbage disposal. Throw out scraps and other garbage with the trash. ISDS Operation and Maintenance Page 2 of 5 2. Collect grease in a container rather than pouring it down the sink. 3. Minimize the disposal of paper products into the system. Nondegradable items such as disposable diapers, sanitary napkins, condoms, tissues, cigarette butts and paper towels are especially harmful to the system. 4. Only three things should go into the septic tank: Human Wastes; Toilet Paper; and Water. 5. Ordinary household chemicals (bleaches, detergents & soaps) will not hurt the bacteria in your system when not used in excessive amounts. 6. DO NOT DISPOSE GASOLINE, OILS, ANTIFREEZE, PAINTS, THINNERS OR OTHER TOXIC LIQUIDS INTO YOUR SYSTEM. SEPTIC TANK ADDITIVES Advertised chemical additives, bacteria, enzymes, etc. do not help solids breakdown in the septic tank and should not be used to reduce the need for pumping the septic tank. CARE OF LEACH FIELD The leach field is an important part of your septic system. Here are a few things you should do to maintain it: 1. Don't drive or park vehicles on any part of your septic system. Doing so can compact the soil in your leach field or damage pipes, tank, or other septic system components. 2. Keep roof drains, basement sump pump drains, and other rainwater or surface water drainage systems away from the leach field. Flooding the leach field with excessive water slows down or stops treatment processes and can cause plumbing fixtures to back up. ISDS Operation and Maintenance Page 3 of 5 REGULAR INSPECTIONS Septic Tank: To inspect the septic tank, remove the manhole cover at the inlet end of the tank. Use a shovel to push the scum layer away from the side of the tank and estimate its thickness. If the scum layer is 12" thick or more arrange to have the septic tank pumped immediately. Replace the cover and wash off the shovel and your hands. For an average septic tank, the pumping interval is usually between 2 and 4 years. Annual inspection of the septic tank should become part of your overall resort maintenance routine. Dosing Tank or Pump Station: To inspect the dosing tank, follow the same instructions for the septic tank. However, there should not be a scum layer or sediments inside the tank. Check to see if the water level markings are consistent on the side of the tank. Variability indicates that the siphon or effluent pump is not operating properly. If the water level is near the top of the markings, wait for the siphon or pump to operate and watch for problems. The siphon has an overflow pipe in which the effluent will flow out of the tank by gravity. Should this be occurring, have the tank pumped and check the siphon openings to see if they are plugged. Filter Mound or Trench: Check the observation tubes regularly. Standing water near the same elevation as the natural soil surface (or higher) may be an indication of an operational problem. Look for seepage or excessive wetness near the base of the filter mound or trench area. Lush green grass over the leach field, even during dry weather is often an indication that an excessive amount of liquid from the system is moving up through the soil, instead of downward, as it should. While some upward movement of liquid from the absorption field is good, too much could indicate problems with the system. SUMMARY A general inspection of the septic tank, dosing tank (or pump station), filter mound or trench area should be made each year. These inspections are best made during the wet season of the year. If these items are not routinely inspected, solids can carry over into the ISDS Operation and Maintenance Page 4 of 5 disposal areas from the septic tank and clog the system resulting in system failure and health hazard risk. Pumping during high water months may cause the septic tank to float out of the ground. Due to the tanks being subject to buoyancy, they should be strapped down with buoyancy counteracting blocks. ISDS Operation and Maintenance Page 5 of 5 G A M B A 6 ASSOCIATES CONSULTING ENGINEERS & LAND SURVEYORS www. 1wcc Riwo.Cew PHONE: 970/945-2550 Fax: 970/945-1410 • 113 NINTH STREET, SUITE 214 P.O. Box 1458 GLENWOOD SPRINGS, COLORADO 81602-1458 January 13, 2015 Glen Hartmann Garfield County Planning 108 8th Street - Suite 401 Glenwood Springs, CO 81601 RE: Response to Issues Identified in Meeting with Glenn Hartmann, Andy Schwaller and Chris Hale on January 9, 2015 Dear Glen: In accordance with your request, following are our responses to the issues identified in our meeting with you, Andy Schwaller and Chris Hale on January 9th, 2015. 1. How was the groundwater elevation determined? The groundwater elevation was determined by observing both the static water level and the highwater mark within the existing septic tank excavation and measuring the vertical difference between these levels and known elevations such as the top of the septic tank lid. Based on the local elevation datum the elevation of the top of the septic tank lid was surveyed to be 5425.70. The vertical difference from the highwater line to the top of the septic tank was measured to be approximately 0.9 feet. On this basis, the elevation of the groundwater would calculate to be 5424.80. We conservatively identified the groundwater level to be 5425.00 feet above sea level based on the local elevation datum. 2. Why were percolation tests not performed within the in-situ soils underlying the proposed mound system? When designing a mound type leach field, the engineer must evaluate the soil or surficial conditions that exist below the proposed mound system in order to determine if conditions exist which could present a limiting condition with respect to the percolation of the treated effluent into the insitu materials below the mound. In this case, the in- situ materials consist of silty soils which are typical of this area. Our experience in other locations with these similar soils indicates that these soils can present percolation rates ranging from a low of approximately 40 minutes per inch to a high of approximately 10 minutes per inch. The design of the proposed mound system provides for the importation of Class 6 aggregate base course with a percolation rate of 20 minutes per inch. The minimum area of the Infiltrator bed is calculated to be 1371.33 sq. ft. based on the 20 minute per inch percolation rate. The horizontal area of the base of the mound is approximately 4292 sq. ft., which is more than three times larger than the area of the Infiltrator bed. In order for the in-situ soils to present a limiting condition for this mound system, the percolation rate of the soils would need to be equal to or slower than 190 minutes per inch. Based on our experience with similar soils in this general area, we have never measured a percolation rate slower than 40 minutes per inch and therefore did not believe that performing a percolation test for this system was necessary. 3. It has been suggested by the Town of Silt that for the purpose of determining the design constraints related to groundwater elevations and floodwater elevations, the OWTS regulations do not distinguish between the two. Therefore, what is the official regulatory difference between groundwater and floodwater? In regard to this question we were able to contact Chuck Cousino of the Colorado Department of Public Health and Environment (CDPHE). Mr. Cousino is the CDPHE official responsible for administering and interpreting regulations related to Onsite Wastewater Treatment Systems with capacities less than 2000 gallons per day. It is Mr. Cousino's position that there is in fact a definite regulatory difference between the groundwater elevation and the floodwater elevation. Specifically, Mr. Cousino agreed with our design that the bottom of the Infiltrator units must be a minimum of 3 -feet vertically above the groundwater elevation, and that the bottom of the Infiltrator units can be installed at an elevation equal to or greater than the Base Flood Elevation (100 -year flood elevation). Mr. Cousino further stated that this position is also in conformance with the applicable FEMA regulations related to OWTS. 4. We were asked to depict the groundwater elevation on the ISDS plans. We have provided a revised set of ISDS plans to Garfield County which depict the groundwater elevation as determined in Item No. 1 above. 5. We were asked to confirm the size of the septic tank. We have surveyed measurements of the existing septic tank which has been placed inside an excavation on the site and which is intended to be used for this ISDS. Based on the physical dimensions of this tank, we have determined the tank volume to be 2000 gallons. 6. We were asked to confirm that a leak test of the existing tank will be performed prior to approval of the system. We propose to observe and certify a leak test to be performed on the existing septic tank prior to the acceptance of this tank for use in this ISDS. 7. What is the CDPHE interpretation of Regulation 43.8.K.1.c? During our discussion with Mr. Cousino he explained that this requirement only applies to non-domestic type septage. In other words, if a commercial OWTS were to receive wastewater effluent that was equivalent to standard domestic wastewater, then this regulation does not apply. As we discussed during our meeting, this system is designed to receive wastewater from toilets, showers, sinks and a laundry washing machine serving 10 individual tent campsites. This was explained to Mr. Cousino and he indicated that in his opinion this wastewater would be considered to be standard domestic wastewater and therefore this regulation was not applicable. 8. Provide ISDS Plan digitally to Garfield County. As stated above, we have provided a digital copy of the revised ISDS plans to Garfield County. We believe that this letter responds to the issues identified during our meeting. If you have any questions, or need additional information, please contact us. Sincerely, Gamba & Associates, Inc. Michael Gamba, P.E. & P.L.S. 28036 I:\GVWF\14115\ISDS\20150109 Response\Response to Referral Comments - 20150113.doc Glenn Hartmann From: Chris Hale [chris@mountaincross-eng.com] Sent: Tuesday, December 30, 2014 2:14 PM To: Glenn Hartmann Subject: RE: Langegger Flood Plain Development Permit Glenn: I have reviewed the additional information provided. It is our opinion that the response adequately addresses our concerns. No additional comments were generated. Happy New Year. Sincerely, Mountain Cross Engineering, Inc. Chris Hale, P.E. 826 1/2 Grand Avenue Glenwood Springs, CO 81601 Ph: 970.945.5544 Fx: 970.945.5558 From: Glenn Hartmann [mailto:ghartmann@garfield-county.coml Sent: Monday, December 22, 2014 9:51 AM To: Chris Hale; Andy Schwaller; Tamra Allen Subject: FW: Langegger Flood Plain Development Permit Hi Chris, Andy, and Tamra: Thanks for fielding referrals and previous questions from me on this Flood Plain Permit Application. Attached is the Applicant's response to referral comments from Chris and the Town of Silt. Especially in light of the extensive comments from the Town of Silt and their request for enhanced treatment I want to make sure the Applicant's responses are adequate. Please call to discuss the additional information. If you feel that meeting briefly would be helpful just let me know. Thanks. Glenn. Glenn Hartmann Community Development Department From: Mike Gamba [mailto:mgamba©gambaengineering.com] Sent: Friday, December 19, 2014 4:14 PM To: Glenn Hartmann Cc: bkelly@gambaengineering.com Subject: RE: Langegger Flood Plain Development Permit Glenn, With respect to the Langegger Flood Plain Development Permit, in response to your request, attached please find the following: 1 • Revised Site Plan with labels and legend per comments from Morgan Hill • ISDS Operation and Maintenance Guidelines for the proposed system • Responses to the referral comments. Please contact us if you have any questions or need additional information. Sincerely, Gamba & Associates, Inc. Michael Gamba, P.E. & P.L.S. 113 Ninth Street - Suite 214 Post Office Box 1458 Glenwood Springs, Colorado 81602 Phone: (970) 945-2550 Fax: (970) 945-1410 mgambaOgambaengineering.com Glenn Hartmann From: Chris Hale [chris@mountaincross-eng.com] Sent: Thursday, January 15, 2015 9:36 AM To: Glenn Hartmann; Andy Schwaller Subject: RE: Turtle Tracks ISDS Glenn: I have reviewed the additional information provided. The review addressed our previous comments and no additional comments were generated. Sincerely, Mountain Cross Engineering, Inc. Chris Hale, P.E. 826 1/2 Grand Avenue Glenwood Springs, CO 81601 Ph: 970.945.5544 Fx: 970.945.5558 From: Mike Gamba[mailto:mgamba@gambaengineering.com] Sent: Wednesday, January 14, 2015 8:46 AM To: Glenn Hartmann; Andy Schwaller; Chris Hale Subject: RE: Turtle Tracks ISDS Glenn, Andy & Chris: Per our discussion on January 9`h, attached is a response to the issues identified during our meeting. Please contact us if you have any questions, or need additional information. Sincerely, Gamba & Associates, Inc. Michael Gamba, P.E. & P.L.S. 113 Ninth Street - Suite 214 Post Office Box 1458 Glenwood Springs, Colorado 81602 Phone: (970) 945-2550 Fax: (970) 945-1410 mgamba@gambaengineering.com From: Mike Gamba Sent: Friday, January 09, 2015 3:54 PM To: 'Glenn Hartmann'; Andy Schwaller; Chris Hale Cc: Tamra Allen; Britt Kelly (bkelly(agambaengineering.com) Subject: RE: Turtle Tracks ISDS Glenn, Andy and Chris: Per our discussion this morning, attached is a digital copy of the proposed ISDS plans with the delineation of the mean high groundwater level. We are also in the process of preparing a brief report covering the topics discussed in our meeting this morning. We expect to have that completed by Tuesday, January 13th Please contact us if you have any questions, or need additional information. Sincerely, Gamba & Associates, Inc. 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