DDW-2024-009361

DFCM Project No. 22230510
FAI #14-21-0082

May 20, 2024

Mr. David Kruse, Environmental Scientist
Source Water Monitoring Rule Manager
Utah Division of Drinking Water
195 North 1950 West
Salt Lake City, UT 84116

RE: Request for Approval to Use Water That Exceeds MCLGs for TDS and Sulfate.
Division of State Parks
North Eden Campground Phase 3 – Site Improvements
Water System No. UTAH17038

Dear Mr. Kruse,

Bear Lake State Park has recently sampled and has had analyzed water from the new well previously
constructed at the North Eden Campground located on the northeast side of Bear Lake at the Utah-Idaho
border. The sample analyses performed by Chemtech-Ford revealed that the levels of Sulfate and Total
Dissolved Solids (TDS) are below the Utah primary maximum contaminant levels (MCLs) of the
regulatory levels established under Administrative Rule R309 200 5(1)[Table 200-1] but exceed the
secondary maximum contaminant level (MCLGs). The following table presents the Sulfate and TDS
water sample analyses results and respective regulatory levels:

Parameter 4/26/2024 Utah MCL* Utah MCL** EPA MCL**
Sulfate 746 mg/L 1000 mg/L 500 mg/L 250 mg/L
TDS 1360 mg/L 2000 mg/L 1000 mg/L 500 mg/L
* Primary Standard, ** Secondary Standard

According to R309-200, if levels for Sulfate and TDS are greater than 500 mg/L and 1000 mg/L,
respectively, the water supplier must:

1- Satisfactorily demonstrate that no better water is available (Sulfate and TDS).
2- The water shall not be available for human consumption from commercial establishments (Sulfate
only).

Understanding that TDS comprise of inorganic salts, principally calcium, magnesium, potassium,
sodium, bicarbonates, chlorides, and sulfates and some small amounts of organic matter that are dissolved
in water, we reviewed driller reports from existing wells constructed south of and in the general vicinity
of the North Eden Campground well to compare levels of TDS. It was reported that TDS levels ranged
from 400 mg/L to 650 mg/L in similar lithologic structures and alluvial stratification (WR 23-3759, WR
23-3768, WR 23-3980, and WR 23-3076). It was also noted that some wells were constructed into
relatively dry formations and abandoned. The possibility of drilling another well to procure improved
water quality is highly unlikely but it is asserted by the local residents that TDS lowers over time with
use.

Mr. David Kruse
May 20, 2024
Page 2 of 2
FAI #14-18-0177

DFCM Project No. 22230510
FAI #14-21-0082

Connecting North Eden Campground to an existing public water system is impractical and cost
prohibitive as the nearest public entity having the capacity to serve the campground is Laketown, which is
located approximately 12 miles to the south.

Regarding the requirement that water having Sulfate greater than 500 mg/L shall not be available for
human consumption from commercial establishments, whereas, the term “commercial establishment”—
(A) means an establishment used for commercial purposes, such as a bar, restaurant, private office, fitness
club, oil rig, retail store, bank or other financial institution, supermarket, automobile or boat dealership, or
any other establishment with a common business area; and (B) does not include a multi-unit permanent or
temporary dwelling where private home viewing occurs, such as a hotel, dormitory, hospital, apartment,
condominium, or prison, campsites and the dwellings thereon should be considered as a temporary
dwellings meaning a dwelling intended to be used for human habitation for a time period not exceeding
thirty (30) days, and include tents, camping trailers, boats, recreational vehicles, and other similar
vehicles or equipment.

Under these constraints, Bear Lake State Park respectfully requests herewith approval to use water
that exceeds MCLGs for TDS and Sulfate from the North Eden Campground well (WS001) to service the
park tenants through the summer recreation season.

Should you have any questions or would like to discuss this further, please contact me via email at
[e-mail] or by phone at 208-866-1393.

Sincerely,

Eric E. Dursteler, P.E., CFM
A/E Project Manager

Cc: Mark Berger, UDDW, Water Quality / Monitoring Standards Manager
Dani Zebelean, UDDW, Environmental Engineer
Richard Droesbeke, DNR-DWP, BLSP Park Manager
Jamie Harsh, DNR-DSP, Project Manager
Tim Parkinson, UDGO-DFCM, Project Manager