DDW-2024-006083

January 31, 2024
Andrew Clark Beecher
Cinnamon Creek Rec Area
50 E North Temple Street, RM 1205
Natural Resource Services
Salt Lake City, UT 84150
Subject:Notification for Groundwater Required to Disinfect to Primary Requirements –
Cinnamon Creek Rec Area UTAH03105, Spring #2 (Upper) (WS002)
Notification for Groundwater Required to Disinfect to Secondary Requirements –
Cinnamon Creek Rec Area UTAH03105, Spring #1 (Lower) (WS001)
Dear Andrew Clark Beecher:
The Division of Drinking Water (the Division) records indicate that you are the responsible party for the
Cinnamon Creek Rec Area. The Cinnamon Creek Rec Area 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, both Spring #2 (Upper) (WS002) and Spring #1
(Lower) (WS001) are low-quality ground water sources that do not reliably meet bacteriological
standards. Cinnamon Creek Rec Area is now subject to requirement to provide continuous primary and
secondary disinfection at Spring #2 (Upper) (WS002) and continuous secondary disinfection at Spring
#1 (Lower) (WS001) and meet the following requirements:
●Submit documentation for Spring #2 (Upper) (WS002) demonstrating a disinfection CT (CT =
Concentration × Contact Time) that achieves 4-log inactivation for virus through disinfection or
apply for plan approval and obtain an operating permit for modifications to your chlorination
facility that achieves 4-log inactivation for virus.
●Provide continuous disinfection and demonstrate compliance with primary and secondary
disinfection requirements through ongoing monitoring and reporting using a Division-approved
template.
●Continue monthly source assessment bacteriological monitoring of the Spring #1 (Lower)
(WS001) and Spring #2 (Upper) (WS002) 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 at this water source.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.
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF DRINKING WATER
Nathan Lunstad, P.E.
Director
State of Utah
SPENCER J. COX
Gove rnor
DEIDRE HENDERSON
Lieutenant Governor
Andrew Clark Beecher
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January 31, 2024
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
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
On June 18, 2014, the Director issued an operating permit for the Cinnamon Creek water system’s
waterline and improvements to the system's two chlorinators (Spring No 1 Hypchlorinator, TP001; and
Upper Spring Chlorinator, TP002). Because of a pattern of coliform-positive samples at Upper Spring
(WS002), a condition of the 2014 Operating Permit required monthly coliform monitoring of WS002.
The System collected a total of 42 source coliform samples since that requirement. Of those 42 samples,
30 tested positive for coliform, and seven tested positive for Escherichia coli (E. coli). All samples
during September and August 2023 tested positive for E. coli. Additionally, a Microscopic Particulate
Analysis (MPA) test taken September 19, 2023 had a moderate risk, indicating some risk that Spring #2
(Upper) (WS002) is under the direct influence of surface water. Further sampling is required per the
Division’s letter dated October 13, 2023. Finally, of the three samples taken at WS002, two came back
total coliform positive. A detailed sample history is attached to this letter.
Coliform Samples Taken From Upper Springs WS002 Since July 2014
Total Samples Taken Coliform Absent Coliform Positive Coliform and E. coli
positive
45 8 30 7*
*August and September 2023 Samples
Coliform Samples Taken From Upper Springs WS002 Since July 2014
Total Samples Taken Coliform Absent Coliform Positive Coliform and E. coli
positive
3 1 2*0
*August and September 2023
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,
Andrew Clark Beecher
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January 31, 2024
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 Spring #2 (Upper) (WS002) and Spring #1 (Lower) (WS001)
sources are low-quality ground water sources that do not consistently meet standards of bacteriologic
quality. Based on your sample history, Cinnamon Creek Rec Area is subject to requirements to
provide continuous primary and secondary disinfection of the Spring #2 (Upper) (WS002) and
may be subject to additional treatment requirements if further water quality sampling results
indicate that the source is UDI. Additionally, Cinnamon Creek Rec Area is subject to
requirements to provide continuous secondary disinfection of the Spring #1 (Lower) (WS001) and
may be subject to additional treatment requirements if further water quality sampling results
indicate that primary disinfection is required.
Existing Chlorinators
The Division does not have sufficient information on the existing chlorinators (Upper Spring
Chlorinator, TP002 and Springs No 1 Hypochlorinator, TP001) to determine if they are designed to meet
all requirements for primary disinfection. Please provide documentation that the following requirement
is met within 120 days to avoid the addition of deficiency points for each chlorinator to Cinnamon
Creek Rec Area Water Sytem’s IPS report:
●TD25 – Disinfection required, but disinfection is intermittent or not continuous due to lack of
automatic switchover (SIG, 50 points)
●TD22 – Lacks backup power supply for required disinfection (SIG, 25 points)
Required Actions
The Cinnamon Creek Rec Area Water System is subject to requirements to install and operate
Division-approved permanent primary disinfection for Spring #2 (Upper) (WS002) and the entire
distribution system. The water system must also install and operate Division-approved permanent
secondary disinfection for Spring #1 (Lower) (WS001). The system must comply with the primary
and secondary disinfection requirements described in Addendum A. The water system must
complete Division Plan Approval prior to construction of any disinfection facilities.
The water system must also complete the bacteriological source assessment monitoring described
in the “Additional Required Monitoring” section of this letter.
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.
The Division considers Spring #2 (Upper) (WS002) an unapproved source until primary
disinfection is installed and operational. If this chlorination facility does not provide adequate
disinfection, 200 significant deficiency points will be assessed to Cinnamon Creek Rec Area,
Andrew Clark Beecher
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January 31, 2024
UTAH03105 for inadequate disinfection for a groundwater system required to disinfect. 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 source puts Cinnamon
Creek Rec Area 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.
Additional Required Monitoring
Based on the determination that Spring #2 (Upper) (WS002) requires primary disinfection, the following
monitoring is required:
1. Based on the E. Coli positive results, the Division suspects that Spring #2 (Upper) (WS002) may
be under the direct influence of surface water (UDI)
i. An initial MPA sample was collected from Spring #2 (Upper) (WS002) on
September 13, 2023 and scored Moderate, indicating a moderate risk for being
UDI.
1. Please note that the Division protocol requires two consecutive low-risk
MPA samples for this source to be considered not UDI. This source may
be classified as UDI if the results of the follow-up MPA samples indicate
moderate or high risk. Ongoing source assessment monitoring may also be
considered in this determination. The Division can re-evaluate this source
at any time if there are circumstances that affect its susceptibility to
surface water influence. For information about UDI and MPA sampling,
see the attached UDI Definition and Possible Causes.
ii. A moderate risk MPA test result, as obtained on September 13, 2023, requires:
1. further sampling, as described below in bacteriological source sampling
under condition 2 below,
2. a follow up MPA sample taken during spring runoff in 2024.
2. Bacteriological Source Sampling
a. This system is subject to take monthly Escherichia coli (E. coli) samples at Spring #1
(Lower) (WS001 and Spring #2 (Upper) (WS002) (assessment monitoring) during the
operating period and shall continue for a minimum of 18 months.This schedule will
begin April 2024.
b. This sample is in addition to the monthly distribution system sample (DS001). Please
label the source samples as WS001 and WS002 (for both the facility ID and sample point
ID) on all laboratory forms.
c. Please contact Sitara Federico for any positive samples that may occur at the sources at
385-515-1459 or [e-mail]. If any sample result comes back as E. coli positive,
please contact the Division within 24 hours of being notified of the result.
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 Cinnamon
Creek Rec Area 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].
Andrew Clark Beecher
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January 31, 2024
Please contact Sarah Page at [phone] or [e-mail] if you have any questions or need
technical assistance.
Sincerely,
Mark Berger
Rules Section Manager
Enclosures:
Addendum A - Primary and Secondary Disinfection Monitoring and Reporting Requirements
Addendum B - Secondary Disinfection Monitoring and Reporting Requirements
2014 Cinnamon Creek Operating Permit
Bacteriological Summary for Upper Spring WS002
cc: Ben Harker, Bear River Health Department, [e-mail]
Grant Koford, Bear River Health Department, [e-mail]
Hunter Payne, Division of Drinking Water, [e-mail]
Cameron Draney, 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]
Sarah Romero Rivera, Division of Drinking Water, [e-mail]
Addendum A – Primary and Secondary Disinfection Monitoring and Reporting Requirements
Primary Disinfection Requirements and Reporting
1. The chlorinator will be operated continuously to achieve primary disinfection of the water
from Spring #2 (WS002), i.e., a minimum of 4-log10 virus inactivation for groundwater sources.
[R309-215-16(1)(a)(iii); R309-520-6(4)(c)]
2. The chlorinator will provide sufficient disinfection CT and conduct compliance monitoring to
demonstrate treatment effectiveness.
a. Sufficient disinfection CT will be demonstrated by monitoring and reporting the actual
CT achieved during operation using a monitoring sheet that will be provided by the
Division in the future.The monitoring and reporting will include chlorine residuals
measured at the POE to the distribution system and other parameters for calculating CT.
[R309-520-6(4); R309-215-16(3)(b)(iii)(A)]
3.Chlorine Residual ‒ Point of Entry (POE) to Distribution System
a. The POE sampling location(s) will be identified in the Division’s database.
b. Maintain a minimum of 0.2 mg/L residual (measured as free chlorine) at the POE
sampling location. [R309-215-16(3)(b)(iii)(A)(I) and (II)]
c. The chlorine residual concentration measured at the POE sampling location 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 location(s)a minimum of daily. [R309-210-
8(3)(a)(ii)]
o Our records show that your water system serves 50 people. Please be aware
that R309-215-16(3)(b)(iii)(A)(II) requires water systems serving 3,300 people
or fewer to monitor the POE chlorine residuals and take daily grab sample(s).
Alternatively, instead of taking daily grab samples, a groundwater system
serving 3,300 or fewer people may choose to use an online analyzer to
continuously monitor the POE chlorine residuals entering the distribution
system.
Secondary Disinfection Reporting
1. 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) and (4)]
Disinfection Report Submission
To demonstrate ongoing compliance with the primary and secondary disinfection requirements, the
water system must complete monthly disinfection and operational reports for each active chlorinator
using a template approved by the Division.
1.Primary disinfection reports are submitted monthly, and operational reports are submitted
quarterly. The primary disinfection template draft will be sent by email, and the operational
report template may be found here:
https://deq.utah.gov/drinking-water/resources-and-requirements-for-disinfecting-systems.
a. 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].
b. Please contact Luke Treutel at [phone] or [e-mail] to schedule training
regarding disinfection 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)]
Addendum B - Secondary Disinfection Monitoring and Reporting Requirements
Secondary Disinfection Requirements and Reporting
1.Chlorine Residual ‒ Point of Entry (POE) to Distribution System (EP001)
a. The POE sampling location will be identified as EP001 in the Division’s database.
b. Maintain a minimum of 0.2 mg/L residual (measured as free chlorine) at the POE
sampling location. [R309-215-16(3)(b)(iii)(A)(I) and (II)]
c. The chlorine residual concentration measured at the POE sampling location 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 location (EP001)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 Portage Town
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 [phone] 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)]