DDW-2024-011126

Noah Zorsky <[e-mail]>
Fwd: 03017 source protection plan updates
7 messages
Melissa Noble <[e-mail]>Fri, Feb 2, 2024 at 10:52 AMTo: Noah Zorsky <[e-mail]>
Melissa N Noble, MS, PG | Environmental Scientist III | Source Protection
385.271.7043 (work cell) | 801.536.4200 (office) | 801.536.4311 (fax)
195 North 1950 West, Salt Lake City, UT 84114
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Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
---------- Forwarded message ---------From: Deidre Beck <[e-mail]>Date: Mon, Jan 3, 2022 at 8:34 AM
Subject: Re: 03017 source protection plan updates
To: Tara Bankhead <[e-mail]>
Cc: Rob Stapley <[e-mail]>, Mellissa Copfer <[e-mail]>
Received, thank you. I have added these plan updates to our review queue.
On Thu, Dec 30, 2021 at 4:25 PM Tara Bankhead <[e-mail]> wrote:
Hi Deidre,
Attached are the updated plans for our 3 wells, including the cover letter and sample results. Sources 2 & 3 are combined into one plan so there will only be 2 plan updates
attached. I have included the susceptibility waiver for sources 2 & 3, it is the last page with the plan.
Please let me know if any additional information is needed.
Hope you have a Happy New Year!
Tara
--Tara BankheadProvidence City
Public Works
435.753.0313 office
435.753.2345 fax
--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMArequirements.
Noah Zorsky <[e-mail]>Thu, Mar 14, 2024 at 5:27 PM
To: Rob Stapley <[e-mail]>, Tara Bankhead <[e-mail]>
Cc: Deidre Beck <[e-mail]>, Melissa Noble <[e-mail]>
Hi Tara,
I'm reviewing the updated DWSP plans for Providence City's Dales Well, Alder-west Well, and 400 S Well, received on December 30, 2021. I will need some information before Ican concur.
No implementation documentation was provided showing that Providence City implemented its management strategies for residences on septic. Residences on septic were
inventoried as uncontrolled PCSs. Therefore, the water system agreed to periodically distribute educational material to these property owners. The material should inform
readers of risks and best management practices associated with septic systems and drain fields as they pertain to drinking water. If public education material was distributed
after the submission of the last DWSP update in 2017, please provide a dated copy of the material. If this has not been done, please do so as soon as possible, and provide the
date of distribution and a copy of what was distributed. This can be accomplished by simply including fact sheets on septic as a bill stuffer in the next mailing.
9/19/24, 10:17 AM State of Utah Mail - Fwd: 03017 source protection plan updates
https://mail.google.com/mail/u/0/?ik=d42b33a28c&view=pt&search=all&permthid=thread-f:1789810559849106006&simpl=msg-f:17898105598491060…1/5
Most systems have not been implementing their plans so plan implementation is now enforced since the re-enactment of the IPS rule in January of 2020. Lack of plan
implementation is considered a significant deficiency and could result in 25 Improvement Priority Points being assigned for failure to comply. As a courtesy, I can
provide 90 days from the date of this email to address this issue, before I draft a formal disapproval letter.
Also, could you please review the images below and confirm where each of these three wells are? It seems that the actual well location is off in our GIS database. We'd like tocorrect this to make sure no sewer lines are running within 100 feet of the wells. The red dots represent the current location we have on file. Please describe or mark the imageto show where the actual well locations are.
Feel free to reach out with any questions. Thanks.
400 S Providence Well (WS004) = red dot
Dales Well 110 E 200 S (WS002) = red dot
Alder-West Well (WS002) = red dot
9/19/24, 10:17 AM State of Utah Mail - Fwd: 03017 source protection plan updates
https://mail.google.com/mail/u/0/?ik=d42b33a28c&view=pt&search=all&permthid=thread-f:1789810559849106006&simpl=msg-f:17898105598491060…2/5
Noah Zorsky, PG
Environmental Scientist II | Division of Drinking Water
P: [phone]
drinkingwater.utah.gov
M: [phone]
[e-mail]
drinkingwater.utah.gov
[Quoted text hidden]
Tara Bankhead <[e-mail]>Fri, Mar 15, 2024 at 9:37 AMTo: Noah Zorsky <[e-mail]>Cc: Rob Stapley <[e-mail]>, Deidre Beck <[e-mail]>, Melissa Noble <[e-mail]>
Hi Noah,
Thank you for your email. We'll get you the additional information as soon as possible, and for sure within the 90 day time frame.
Thanks!
Tara
[Quoted text hidden]
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You drown not by falling into a river,but by staying submerged in it. Paulo Coelho
Noah Zorsky <[e-mail]>Wed, Jun 5, 2024 at 8:49 AM
To: Tara Bankhead <[e-mail]>
Cc: Rob Stapley <[e-mail]>, Deidre Beck <[e-mail]>, Melissa Noble <[e-mail]>
Hi Tara,
The 90-day grace period will expire next week. I wanted to send you a reminder so a formal disapproval letter and IPS points can be avoided. Let me know if you have any
questions about the implementation issues discussed in my previous email.
Thanks
9/19/24, 10:17 AM State of Utah Mail - Fwd: 03017 source protection plan updates
https://mail.google.com/mail/u/0/?ik=d42b33a28c&view=pt&search=all&permthid=thread-f:1789810559849106006&simpl=msg-f:17898105598491060…3/5
Noah Zorsky, PG
Environmental Scientist II | Division of Drinking Water
P: [phone]drinkingwater.utah.gov
M: [phone]
[e-mail]
drinkingwater.utah.gov
[Quoted text hidden]
Rob Stapley <[e-mail]>Wed, Jun 12, 2024 at 6:04 PM
To: Noah Zorsky <[e-mail]>
Cc: Tara Bankhead <[e-mail]>, Deidre Beck <[e-mail]>, Melissa Noble <[e-mail]>
Hi Noah,
This response took us an extra minute to dial in the results to you however I believe we have worked towards accomplishing these goals in a good way.
I will attach the last couple of city newsletters with related articles that went out this year (Public works/Sewer)
I scanned screenshots our actual wellhead locations from our GIS which also have our water and sewer mains layer on. P is the pump/well Our GIS is not all to survey gradeyet it is mostly accurate.
I decided to hand deliver and discuss septic tanks and the relationships to groundwater and source protection to the few septic tank residences/addresses that remain. I handed
each a copy of the septic tank diagram during my discussions to help illustrate the educational aspect of this topic.
If any further information is needed please let us know.
Thanks!Rob Stapley
[Quoted text hidden]
--
Rob Stapley
Providence City
Public Works Director
[phone]
3 attachments
Newsletters 2024.pdf2061K
well pump locations.pdf905K
septic diagram.pdf318K
Noah Zorsky <[e-mail]>Thu, Jun 13, 2024 at 11:15 AM
To: Rob Stapley <[e-mail]>
Cc: Tara Bankhead <[e-mail]>, Deidre Beck <[e-mail]>, Melissa Noble <[e-mail]>
9/19/24, 10:17 AM State of Utah Mail - Fwd: 03017 source protection plan updates
https://mail.google.com/mail/u/0/?ik=d42b33a28c&view=pt&search=all&permthid=thread-f:1789810559849106006&simpl=msg-f:17898105598491060…4/5
Received. Thank you. Looks like you implemented public education, so we can consider that as fulfilled.
We'll need to take a closer look at WS004 because it appears there could be sewer lines in zone one. With this well being considered a 'new' source, there could be additional
requirements that may have been missed in prior reviews. I'd like to have this sorted out now so it doesn't come up in future reviews. I will follow up with you next week if more
information or action is needed.
Thanks
Noah Zorsky, PG
Environmental Scientist II | Division of Drinking Water | Source Protection
P: [phone]
drinkingwater.utah.gov
M: [phone]
[e-mail]
drinkingwater.utah.gov
[Quoted text hidden]
Noah Zorsky <[e-mail]>Thu, Sep 19, 2024 at 10:13 AM
To: Rob Stapley <[e-mail]>Cc: Tara Bankhead <[e-mail]>, Deidre Beck <[e-mail]>, Melissa Noble <[e-mail]>
Hi Rob,
Sorry this response took awhile. 400 S street has a sewer line crossing through zone one of the 400 S Providence Well (WS004), I believe you are calling this source Jay's Wellnow. This sewer line within zone one is a violation of our rule R309-600-13(3)a — Unprotected Aquifers - Zone one - all sewer lines and laterals shall be at least 50 feet from the
wellhead or margin of the collection area, and be constructed in accordance to R309-515-6. Unless you can show that this section of sewer was constructed to the special
standards (most lines are not), you will need to request an exception to rule R309-600-13(3) and R309-515-6. You said that Providence City regularly cameras their sewer lines.
You can use this as justification for an exception if you provide evidence that this was completed recently for this portion of sewer line and state that Providence City will continue
to camera this section regularly. Below is some guidance for requesting an exception.
The Director of the Division of Drinking Water may grant exceptions to the requirements of R309-500 through 550. A public water system unable to meet the design,construction, or operational requirements of these rules may request an exception if it can provide an alternative to the rule requirement and show that granting theexception will not jeopardize public health.
To request an exception, prepare a letter that meets these requirements (a Project Notification Form is not required).
1. A written request, preferably on water system letterhead, from the management of the Public Water System to the Director of the Division of Drinking Water
2. Cite the specific rule to which the exception is being requested3. Provide a detailed explanation of why the requirements of the rule cannot be met (include drawings if appropriate)4. Describe what will be done to meet the intent of the rule in place of meeting the requirements of the rule (include drawings if appropriate)5. Provide an alternative to the rule requirements and justification of how it will meet or exceed the public health requirements of the rule that cannot be met
Let us know if you have any questions.
Thanks
Noah Zorsky, PG
Environmental Scientist II | Division of Drinking Water | Source Protection
P: [phone]
drinkingwater.utah.gov
M: [phone]
[e-mail]
drinkingwater.utah.gov
[Quoted text hidden]
03017WS004 sewer in zone 1.pdf1126K
9/19/24, 10:17 AM State of Utah Mail - Fwd: 03017 source protection plan updates
https://mail.google.com/mail/u/0/?ik=d42b33a28c&view=pt&search=all&permthid=thread-f:1789810559849106006&simpl=msg-f:17898105598491060…5/5