DDW-2024-010550

September 3, 2024
Randell Gary Obray
Cove Special Service District
1105 South Sevier Highway
Joseph, Utah 84739
Subject:Concurrence, Updated Drinking Water Source Protection Plan for Cove Well #1; Cove Special Service District; Water System #21046, Source No. WS001
Dear Randell Gary Obray:
The Division of Drinking Water (the Division) received the updated Drinking Water Source Protection (DWSP) plan for Cove Well #1 from you on December 28, 2022.
We have completed our review of the updated DWSP plan and find that the plan basically complies with the applicable portions of Utah’s Administrative Rules for Public Drinking Water
Systems. The Division concurs with this updated 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 that it reflects current conditions in your protection zones.
The due date for submitting the next updated plan is December 31, 2028.
Protected Aquifer Conditions
Your updated DWSP plan suggested that Cove Well #1 should be granted susceptibility waivers. You reasoned that the well is eligible for these waivers because the original DWSP plan stated
this source met DDW requirements for protected aquifer conditions. Division staff reviewed the information in the original plan and determined that there was no evidence to support a
laterally continuous clay layer throughout zone two. Therefore, the requirements of R309-600-9(7) have not been met. Furthermore, Division staff reviewed several drilling logs of wells
nearby and determined that there is no evidence that a protective clay layer(s) extends zone two. Based on this information, Cove Well #1 does not meet the requirements for protected
aquifer conditions.RemindersAs stated in R309-600 and 605: Implementing DWSP Plans - Each Public Water System (PWS) shall begin implementing each of its DWSP Plans in accordance with
the implementation schedule within 180 days after submittal if the plan is not disapproved. Be prepared to describe these efforts in your next update, which should include documentation
of how the land management strategies identified for existing and future potential contamination sources were implemented. Your updated plan will be disapproved, and 25 Improvement Priority
System (IPS) points will be assigned for failure to comply with this requirement.As stated in R309-600 and 605: Recordkeeping - As a DWSP Plan is executed, the PWS shall document any
land management strategies that are implemented. Please provide actual copies of memoranda of understanding, public education programs, bill stuffers, newsletters, or other correspondence
documenting the implementation of each land management strategy as it occurs, in this section of your updated plan.
Monitoring Reduction Waivers
You requested susceptibility waivers for volatile organic contaminants (VOCs) and/or pesticides. Cove Well #1 is not eligible for susceptibility waivers, because the requirements of
R309-600-16(4) have not been met. Your source was previously granted reliably and consistently waivers which are currently in place. Your monitoring schedule remains the same. Please
contact Noah Zorsky, P.G., at [phone] or via email at [e-mail] if you have questions or concerns about the review of your DWSP plan. Contact David Kruse at [phone]
or via email at [e-mail] if you have any questions about your monitoring schedule. To help us serve you more efficiently, please use the water system number (21046) in your correspondence.
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
NAZ/mrn/mdbcc:Eric Larsen, Central Utah Health Department, [e-mail] Obray, Cove Special Service District, [e-mail] Zorsky, P.G., Division
of Drinking Water, [e-mail]
John Chartier, P.E., DEQ District Engineer, [e-mail]
NZorsky 21046 WS001 Update Concur