DDW-2024-006070

January 18, 2024
Trevor K Clegg
Kamas City Water System
170 N Main St
Kamas, UT 84036
Subject:Notification for Groundwater Required to Disinfect to Secondary Requirements –
Kamas City Water System, UTAH22007, Distribution System (DS001)
Dear Trevor K Clegg:
The Division of Drinking Water (the Division) records indicate that you are the responsible party for the
Kamas City Water System. The Kamas City Water System water system is a public water system and
thus subject to the Administrative Rules for Public Drinking Water Systems. The Division has
determined that, based on recent water quality samples, Kamas City Water System does not reliably
meet bacteriological standards in the distribution system. Kamas City Water System is now subject to
requirements to provide continuous secondary disinfection throughout the entire distribution system and
meet the following requirements:
●Submit documentation demonstrating achievement of secondary disinfection or apply for plan
approval and obtain an operating permit for modifications to your chlorination facility that
achieves secondary disinfection for the entire distribution system.
●Provide continuous disinfection and demonstrate compliance with secondary disinfection
requirements through ongoing monitoring and reporting.
●Conduct monthly source assessment bacteriological monitoring of the Left Hand Fork Spring
(WS002), Hillside Well (WS003), and Simpson Well (WS004) for assessment purposes.
You must notify the Division in writing, within 30 days of the date of this letter, what action will be
taken to address the low water quality in the distribution system.This correspondence should be
addressed to the Vulnerable Source Assessment Team at [e-mail]. If these steps are not
completed within 30 days from the date of this letter the Division may need to follow up with formal
enforcement actions.
If you cannot complete the above steps within 30 days, the Division encourages you to apply for a
Corrective Action Plan (CAP). The purpose of a CAP is to establish terms, conditions, and timelines for
a water system to come into compliance with the significant deficiencies. A CAP can be granted if there
are no violations associated with the deficiencies. A system can request a temporary CAP extension at
Trevor K Clegg
Page 2 of 4
January 18, 2024
requestcap.utah.gov. Nothing in the Corrective Action Plan prohibits the Division from taking further
enforcement actions if a system fails to comply with the requirements in the Corrective Action Plan. If
you have further questions regarding a CAP, contact Brandi Smith at [phone].
Background
In May of 2023, Kamas City Water System routine testing confirmed Escherichia coli (E. coli)within
the distribution system. Out of a total of 20 distribution system samples, six samples were total
coliform-positive, and two samples tested positive for E. coli. One sample was taken at Hillside Well
(WS003) that was total coliform absent. At the Division’s request, the Kamas City Water System issued
a boil order on May 26, 2023. The boil order was removed on May 29, 2023, following two sets of
repeat samples testing negative for coliform bacteria and the system verified a failed pump in the
chlorinator had been replaced.
On May 31, 2023, Utah Division of Drinking Water Scientist Brian Pattee conducted a Level 2
Assessment in response to the pattern of the positive coliform and E.coli samples. In a report mailed to
the System on August 25, 2023, the Division noted the following conclusions that may have led to the
bacteriological issues in May:
1. The cause of the positive samples is unknown currently, the only source suppling [sic]the system
Well WS003 has a clean bacteriological sample history.
2. The Chlorinator failure at the exact time of this incident could be considered a contributing
factor in the positive samples.
3. Silt and sand build up in storage tanks could be a cause.
4. Cross Connection in the area of the Positive samples is always a possibility, although there were
TC+ samples in other areas of the system.
Coliform bacteria, including E. coli, indicate potential contamination in drinking water. Coliform
bacteria are commonly found in the intestines of warm-blooded animals and suggest the possible
presence of harmful pathogens. Consuming water contaminated with coliform bacteria, particularly E.
coli, can result in various health issues, such as gastrointestinal problems, diarrhea, abdominal cramps,
and nausea. In severe cases, it can lead to more serious conditions like kidney failure or hemolytic
uremic syndrome (HUS), especially among vulnerable populations like the elderly, the young, and those
with compromised immune systems. Disinfection processes, like chlorination, play a crucial role in
protecting public health by removing harmful bacteria, including coliforms and E. coli, ensuring the
safety of drinking water.
The bacteriological results indicate that Kamas City Water System does not reliably meet bacteriological
standards in the distribution system.Based on your sample history, Kamas City Water System is
subject to requirements to provide continuous secondary disinfection of the entire distribution
system and may be subject to additional treatment if further water quality sampling results
indicate that any of Kamas City Water System’s sources require primary disinfection.
Trevor K Clegg
Page 3 of 4
January 18, 2024
For Existing Chlorinators
The Division does not have sufficient information on the existing chlorinator (Hillside Tank Chlorinator,
TP001) to determine if it is designed to meet all requirements for secondary disinfection. Please provide
documentation that the following requirement is met within 120 days to avoid the addition of deficiency
points to Kamas City Water System Water Sytem’s IPS report:
●TD22 – Lacks backup power supply for required disinfection (SIG, 25 points)
Required Actions
The Kamas City Water System is subject to requirements to operate Division-approved
permanent disinfection in the entire distribution system.
The system must comply with the secondary disinfection monitoring and reporting requirements
described in Addendum A.
The water system must complete Division Plan Approval prior to construction of any disinfection
facilities. Until the above actions are taken, the distribution system will be marked as unapproved,
and 200 IPS points will be assessed for an unapproved distribution system.
Kamas City Water System’s distribution system will be marked as unapproved until disinfection is
installed, and 200 IPS points will be assessed for use of an unapproved distribution system.
Community water systems with more than 150 IPS points will be rated as unapproved systems if actions
are not taken to address the IPS points. The 200 IPS points assessed for an unapproved distribution
system puts Kamas City Water System above the threshold. Additionally, failure to correct the
significant deficiency in a timely manner will result in the system being assessed a treatment technique
violation in accordance with R309-215-16(4)(a) and 50 Improvement Priority System (IPS) points to the
System’s IPS Report.
Please note that you must notify the Division in writing within 30 days of the date of this letter
what action will be taken to address the low water quality at this water system. If Kamas City
Water System does not take the steps outlined in this letter, the Director may need to follow up
with formal enforcement actions to protect public health.This correspondence should be addressed
to the Vulnerable Source Assessment Team at [e-mail].
Please contact Sarah Page at [phone] or [e-mail] if you have any questions or need
technical assistance.
Sincerely,
Mark Berger
Rules Section Manager
Trevor K Clegg
Page 4 of 4
January 18, 2024
RTCR/DBP/RulesMngr/VSALead/Eng/Assistant Director/Admin (processing)/Admin (mailing) [Initials]
Enclosures: Addendum A - Secondary Disinfection Monitoring and Reporting Requirements
Operational Report_GWRD Secondary
August 25, 2023 Level 2 Assessment Letter
cc: Nathan Brooks, Summit County Health Department, [e-mail]
Julie Cobleigh, Division of Drinking Water, [e-mail]
Mark Berger, Division of Drinking Water, [e-mail]
VSA Team, Division of Drinking Water, [e-mail]
Sarah Page, Division of Drinking Water, [e-mail]
Sitara Federico, Division of Drinking Water, [e-mail]
Luke Treutel, Division of Drinking Water, [e-mail]
Michael Newberry, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Addendum A - Secondary Disinfection Monitoring and Reporting Requirements
To meet secondary disinfection requirements, Kamas City Water System will be required to continuously
maintain a minimum of 0.2 mg/L free chlorine residual at the Points of Entry (POEs) into the system and
demonstrate a detectable chlorine residual in the distribution system.
Secondary Disinfection Requirements and Reporting
1. Chlorine Residual ‒ Points of Entry (POE) to Distribution System (EP001, EP002, etc.)
a. The POE sampling locations for each chlorinator will be identified in the Division’s database (i.e.
the POE for TP001 would be EP001 and the POE for TP002 would be EP002).
b. Maintain a minimum of 0.2 mg/L residual (measured as free chlorine) at the POE sampling
locations. [R309-215-16(3)(b)(iii)(A)(I) and (II)]
c. The chlorine residual concentration measured at the POE sampling locations shall not exceed the
maximum residual disinfectant level (MRDL) of 4.0 mg/L (measured as free chlorine).
[R309-200-5(3)(c)(iv)]
d. Record and report the lowest daily chlorine residual concentration, measured as free chlorine, at
the chlorinator POE sampling locations a minimum of daily.[R309-210- 8(3)(a)(ii)]
2. Chlorine Residual ‒ Distribution System (DS001)
a. This water system must maintain a detectable residual throughout the distribution system. It
is recommended to maintain the chlorine residual above 0.1 ppm in the distribution system.
[R309-520-5]
b. The chlorine residual measured in the distribution system shall not exceed the maximum residual
disinfectant level (MRDL) of 4.0 mg/L (measured as free chlorine). [R309-200-5(3)(c)(iv)]
c. Take a minimum of three (3) chlorine residual samples per week at varying locations
throughout its distribution system (DS001). [R309-105-10(1)(c)]
d. Distribution system chlorine residuals must be taken in conjunction with total coliform sampling.
[R309-215-10(3)]
Disinfection Report Submission
To demonstrate ongoing compliance with secondary disinfection requirements, the Kamas City Water System
water system must complete monthly operational reports for each active chlorinator using a template approved by
the Division.
1.Operational reports are submitted quarterly. The operational report template has been enclosed with
this letter. The reports are due to the Division by the 10th day following the end of each reporting month
or quarter (i.e., January 10th, April 10th, July 10th and October 10
th for quarterly reports). The reports can
be submitted by hardcopy, fax, or email at [e-mail]. Please contact Luke Treutel at (385)
258-6084 or [e-mail] to schedule training regarding proper reporting.
2. In addition to monthly disinfection reporting, this water system must submit the monthly average of
chlorine residual samples taken in the distribution system. Distribution system chlorine residual
monitoring results are due quarterly by the same compliance dates as the monthly disinfection report and
can be submitted via an online form found at mrdl.utah.gov. Maintain monitoring records for a minimum
of 5 years. [R309-105-17(1)]