DDW-2024-009119

July 22, 2024
Robert Drew Sullivan
Central Culinary Water Association
135 South 300 East
Central, Utah 84722
Subject:TemporaryException Renewal to R309-515-6(6)(b)(vi), Casing Height above Floor, Facility Central Culinary Well (WS002); Central Culinary Water Association, System #27002, File
#12675
This Temporary Exception Expires on December 31, 2027.
Dear Robert Sullivan:
On July 17, 2024, the Division of Drinking Water (the Division) received your request for a renewal of an exception to Rule R309-515-6(6)(b)(vi)regarding casing height above the floor,
for the Central Culinary Well (WS002). According to this rule, the casing height shall “project at least 18 inches above the anticipated final ground surface and at least 12 inches above
the anticipated pump house floor level.”
Background
This well has been in existence since this water system began. The well is located inside a small, enclosed box on a hillside. During the 2021 sanitary survey, it was discovered that
the well casing only projects 8 inches above the enclosed box, with a concrete floor. Paul Wright conducted a site visit on July 12 to assess the situation and take photos.
Exception Renewal Request
The basis for your request for a renewal for an exception to R309-515-6(6)(b)(vi)is that, as stated before, the well casing is only 8 inches above the concrete floor in the well enclosure,
rather than the required 12 inches. However, because the discharge piping comes out of the top of the casing,
to raise the casing 4 inches would also require removing all the discharge piping, raising it up and tearing out the uphill side of the concrete box to reroute the piping. This level
of construction does not seem reasonable for only a small increase in casing height and could only further compromise the enclosure.
The measures that were taken and were previously built into the enclosure to protect public health and safety are as follows, including ongoing measures to protect public health and
safety:
The old wooden enclosure on top of the concrete foundation was rebuilt to seal up any openings.
The enclosure is on the side of a hill where drainage all runs away from it. The risk of any standing water or flooding is extremely unlikely and there was no evidence of this in the
box.
There is a 4-inch drain to daylight that has far more than adequate capacity to drain any water from the box if plumbing or the well were to leak.
The well enclosure has been inspected once a month and after all substantial rainfall.
On this basis, a renewal to the exception to R309-515-6(6)(b)(vi), Casing Height above Floor, is hereby granted for the Central Culinary Well (WS002).
This Temporary Exception expires on December 31, 2027.
You must continue to inspect the well enclosure on at least a monthly basis and after any substantial rainfall to determine that the enclosure is protected. Record these inspections
and conditions found in a log sheet.
You will be required to re-submit an exception request along with confirmation that all conditions outlined in this temporary exception have been fulfilled and obtain an exception renewal
prior to December 31, 2027.
Exceptions granted by the Division include an expiration date to ensure that the basis and conditions for granting the exception are verified periodically and that the drinking water
quality remains protected. After receiving your request, the Division will determine whether this exception can be re-issued.
Failure to request the re-evaluation of this exception and obtain an exception renewal by December 31, 2027, will result in the activation of the deficiency related to the Central Culinary
Well 1.
This Temporary Exception may be rescinded any time if new evidence indicates that the conditions of this exception are no longer being met or a public health risk exists due to this
exception.The issuance of this exception temporarily resolves your water system’s dormant deficiency S003 related to Central Culinary Well 1. An updated IPS report isavailable at https://waterlink.utah.gov.
Please contact Jennifer Yee at [phone] or [e-mail] for questions related to your water system’s IPS report or deficiencies.
Please maintain a copy of this letter with your permanent records for future reference.
If you have any questions regarding this temporary exception, please contact J. Paul Wright, P.E., DEQ Southwest District Office, at 435-986-2590, or Michael Newberry, P.E., Engineering
Manager, at (385) 515‑1464.
Sincerely,
Russell Seeley, P.E.
Assistant Director
JPW/mrn/mdbcc:Jeremy Robert, Southwest Utah Public Health Department, [e-mail]. Paul Wright, P.E., DEQ Southwest District Office, [e-mail] Drew Sullivan,
Central Culinary Water Association, [e-mail] Yee, Division of Drinking Water, [e-mail] Dev, P.E., Division of Drinking Water, [e-mail]
PWright 27002 12675 WS002 EG Renewal