DDW-2024-010546

September 3, 2024
Amy Rydalch
Oakley Town Water System
P.O. Box 129
Oakly, Utah 84055
Subject:Operating Permit, Spring Well (WS007);
Concurrence, Preliminary Evaluation Report and Final Drinking Water Source Protection Plan for the Spring Well;
Temporary Exception Granted to Rule R309-600-13(2)(b)(ii);
Oakley City Water System, System #22010, File #14065
This Temporary Exception Expires on December 31, 2028.
Dear Amy Rydalch:The Division of Drinking Water (the Division) received the necessary information for an after-the-fact review (ATF) and Operating Permit issuance for the Spring Well
from your consultant, Michael Maughn on August 13, 2024. The Division issued Plan Approval for drilling this well on February 2, 2002. The Division could not locate a Plan Approval or
Operating Permit for equipping and operating this well. Division staff conducted an onsite inspection of this well on April 16, 2024.
It is our understanding that the Spring Well has been in operation since 2002 but was only recently discovered by the Division as an active source for your system. The Spring Well is
an artesian flowing well drilled to a depth of 500 feet. The well was grouted to 75 feet and received an exception to R309-515-6(6)(i), Well Sealing Techniques and Requirements, on February
2, 2002. The Spring Well is identified as WS007 in the Division’s database.
The Spring Well is currently chlorinated by the Cottonwood Springs Chlorinator (TP003) and then flows to the Spring Tanks #1 and #2 (ST001, ST002). Plan Approval was granted on May
20, 2024, for a new gas chlorinator (TP006) which will replace the existing Cottonwood Springs Chlorinator (File #12649).
We have received the following information for Spring Well (WS007):
Design engineer’s statement of conformance with approval conditions.
Documentation of valid water rights.
Well Driller’s Report
Certification of Surface Seal, dated May 14, 2002, by William Birkes, P.E.
Documentation that the requirements for coverage under the Summit County source protection ordinance have been met.
Satisfactory bacteriological results as evidence of proper disinfection and flushing.
Water quality data — new source chemistry analyses
We have determined that all conditions of operating permit issuance have been met. On this basis, an Operating Permit for the Spring Well (WS007)is hereby issued as constituted by this
letter. You may now place the Spring Well (WS007) in service in your water system.
Please maintain a copy of this letter with your permanent records for future reference.
The Spring Well (WS007) is an artesian well that flows at a rate of 230 gallons per minute (gpm) based on historical data provided by the System. The safe yield of Spring Well (WS007)
is rated at 230 gpm. The safe yield of 230 gpm is the basis for determining the maximum number of connections that Spring Well (WS007) can serve.
Concurrence - Preliminary Evaluation Report and Drinking Water Source Protection Plan
The Division received a combined Preliminary Evaluation Report (PER) and Drinking Water Source Protection (DWSP) plan for the Spring Well from your consultant, Loughlin Water Associates,
LLC on July 30, 2024. The Division requested additional information via email on August 5, 2024. Your consultant provided a request for exception to Rule R309-600-13(2)(b)(ii) on your
behalf on August 23, 2024. Proof that a map of the final source protection zones was provided to Summit County for coverage under their drinking water source protection ordinance was
provided via email on August 26, 2024.
We have completed our review of the combined PER and DWSP plan, stamped and signed by William D. Loughlin, P.G., and dated July 30, 2024, and found that the plan basically complies with
the applicable portions of Utah’s Administrative Rules for Public Water Systems, except for rule R309-600-13(2)(b)(ii). The Division concurs with this plan. We commend you for establishing
a program to protect this source from present and future contamination. This plan must be updated often enough to ensure it reflects current conditions in your protection zones. The
due date for submitting the next updated plan is December 31, 2028.
Please be aware that the source protection zones for this source have now been incorporated into
the Division’s Geographic Information System (GIS) database. In addition, these zones should
now appear on the Utah Environmental Interactive Map, so long as this system is currently
classified as Public in the Division’s database. The Utah Environmental Interactive Map can be
accessed by visiting enviro.deq.utah.gov. We encourage you to visit the map to confirm that the location of this source and the source protection zones are accurate. If you have questions
about the Interactive Map or review of your source protection plan, please contact Deidre Beck, P.G., at [phone] or via email at [e-mail].
Temporary Exception Granted to Rule R309-600-13(2)(b)(ii)
The Division received a request for a temporary exception to Rule R309-600-13(2)(b)(ii) - Protection Areas Delineated using the Preferred Delineation Procedure in Unprotected Aquifers,
from your consultant, Loughlin Water Associates, LLC, in a letter dated August 23, 2024. Rule R309-600-13(2)(b)(ii) indicates that a Public Water System shall not locate a new groundwater
source of drinking water where a pollution source exists within zone two unless the pollution source implements design standards which prevent contaminated discharges to groundwater.
Currently, two septic systems, which are considered pollution sources, are located within zone two. Design standards cannot be implemented that are adequate to prevent contaminated discharges
to groundwater from a conventional onsite wastewater system. The request for exception was based on the following:
Oakley will mail letters more frequently to the owners of the septic systems. Rather than sending them once every 6 years, Oakley will send them annually.
The letter will request that the septic owners follow Summit County Environmental Health Department guidelines for the operation and maintenance of their septic systems and to not dispose
of hazardous chemicals in the septic systems. The letter will also include Fact Sheets concerning the proper operating and maintenance of septic systems.
The system has agreed to increased monitoring of nitrate.
If the increased monitoring of nitrate indicates that concentrations will exceed the primary maximum contaminant level (MCL) of 10 milligrams per liter, the system will implement a two-phased
contingency plan to evaluate potential alternatives and determine a path forward that has been approved by the Division.
On this basis, a temporary exception to R309-600-13(2)(b)(ii) - Protection Areas Delineated using the Preferred Delineation Procedure in Unprotected Aquifers is hereby granted subject

to the following conditions:
This Temporary Exception expires on December 31, 2028, which coincides with the due date of the first updated DWSP plan for this source.
Quarterly nitrate monitoring will be required during operation of the Spring Well. Please see the source chemical monitoring section for your current required sampling. This requirement
will be re-evaluated when the temporary exception is renewed.
You must provide documentation that the measures you have agreed to above have been implemented, i.e., you must provide proof that the septic system owners have received public education
materials on the proper use and maintenance of septic systems at least once per year.
You will be required to re-submit an exception request along with confirmation that all conditions outlined have been fulfilled.
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 drinking water quality
remains protected.
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.
Source Bacteriological Monitoring 
Monthly Escherichia Coli (E. Coli) sampling at Spring Well (WS007) is required, prior to any treatment, for the months the well is in operation or accessible for a minimum of two operating
seasons. This monitoring is required to evaluate the quality of the water coming from Spring Well (WS007) to determine whether primary disinfection treatment is required or not. Additional
monitoring and/or disinfection requirements may be assigned depending on the results of the assessment monitoring.
Monthly Source Assessment Monitoring
The source sampling requirement shall begin no later than September 2024 and extend to cover the duration of at least 18 months, sufficient to span two (spring/summer or peak season)
cycles. 
The sampling location of the source water bacteriological samples needs to be labeled as WS007. 
The source bacteriological sampling is in addition to the monthly total coliform sampling in the distribution system (DS001) that has been in place for your water system. 
In the result of an E. coli positive sample, please contact Sitara Federico at [e-mail] or [phone] within 24 hours of notification.
Source Chemical Monitoring 
Issuance of this Operating Permit changes your water system’s monitoring and reporting
requirements. The monitoring requirements for this well are given below. An updated monitoring schedule can be viewed any time at waterlink.utah.gov under the Water Monitoring section.
Please contact David Kruse at (385)-566-7789 or [e-mail] for questions regarding the source monitoring and reporting requirements for your water system.Facility with new requirementsAnalyte(s)
Required# of samplesSampling FrequencyNext Due DateRule ReferenceWS007 Spring WellRadionuclides1Quarterly10/01/2024-12/31/2024R309-205-7(1)(b)Nitrate1Quarterly10/01/2024-12/31/2024R309-205-5(4)(a)
and R309-600-12(2)(b)(ii)Volatile Organic Contaminants1Yearly01/01/2025-12/31/2025R309-205-6(2)Inorganics & Metals1Every three years01/01/2026-12/31/2028R309-205-5(3)(a)Sulfate, Sodium,
TDS1Every three years01/01/2026-12/31/2028R309-205-5(3)(a)Pesticides1Every three years01/01/2026-12/31/2028R309-205-6(1)(f)The issuance of this Operating Permit resolves your water system’s
deficiency related to having an unapproved source in service and lacking an approved DWSP plan for an active source (S001 and SP07). 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.
If you have any questions regarding this Operating Permit, please contact Julie Cobleigh, P.E., of this office, at [phone], or Michael Newberry, P.E., Permitting and Engineering
Manager, at [phone].
Sincerely,
Russell Seeley, P.E.
Assistant Director
JJC/DLB/mrn/mdbcc: Nathan Brooks, Summit County Health Department, [e-mail] Maughan, Aqua Engineering, [e-mail] Rydalch, Oakley Town Water
System, [e-mail]
Julie Cobleigh, Division of Drinking Water, [e-mail]
Deidre Beck, P.G., Division of Drinking Water, [e-mail]
Sitara Federico, Division of Drinking Water, [e-mail]
David Kruse, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail] 22010 14065 WS007 ATF OP