DDW-2024-011707

STATE OF UTAH

Capacity Development Program

Triennial Report

to the Governor of Utah

for Fiscal Years 2015 - 2017

In Compliance with the Requirements of

the Federal Safe Drinking Water Act

Section 1420(c)(3)

Utah Division of Drinking Water

Salt Lake City, UT

September 2017

i
TABLE OF CONTENTS

Executive Summary

1 INTRODUCTION
1.1 Historical Record of Annual Program Reports to EPA
1.2 Safe Drinking Water Act, State Primacy, and State Capitalization
Grants
1.3 State-Level Capacity Development Programs

2 UTAH'S CAPACITY DEVELOPMENT PROGRAM
2.1 Rule Promulgation
2.1.1 Authority
2.1.2 Most Recent Reporting Period
2.2 Range of Program and Activities
2.2.1 Allocation of Budget Resources
2.2.2 Drinking Water State Revolving Fund (DWSRF)
2.2.3 System Consolidation and Restructuring
2.2.4 Training Efforts (Operator Certification, etc.,) Fiscal Year 2017
2.3 State Capacity Development Program for New Water Systems
2.3.1 Background
2.3.2 Most Recent Reporting Period
2.4 State Capacity Development Program for Existing Water Systems
2.4.1 Background
2.4.2 Most Recent Reporting Period

3 STATE APPROACH TO IDENTIFIED NEEDS AND CONCERNS
3.1 Improvement Priority System (IPS)
3.1.1 Program Description
3.2 Utah Top 25 Significant Noncompliance (SNC) List
3.2.1 Origin of the List
3.2.2 Most Recent Reporting Period
3.3 Utah Rating Change List
3.3.1 Origin of the List
3.3.2 Most Recent Reporting Period
3.4 Review of Implementation of the Program
3.5 Modifications to the Program Strategy
3.6 Availability of the Report to the Public

ii

Executive Summary
The 1996 Amendments to the Federal Safe Drinking Water Act (SDWA) added
provisions for each state to develop a Capacity Development Program (CDP). The
objective of the CDP is to enhance public health protection by helping water systems
develop and maintain the capability. Systems with adequate technical, managerial and
financial (TMF) capacity are able to maintain high rates of compliance with health-based
standards.
Utah Division of Drinking Water Capacity Development program is actively helping to
evaluate Public Water System (PWSs) technical, managerial, and financial capabilities
and to assist these PWSs in improving their overall performance goal. The division has
been showing considerable improvement in the current practices with the implementation
of the Capacity Development program and the sanitary survey process. The Capacity
Development program put every public water system (PWS) in the state on a triennial
sanitary survey schedule. The sanitary survey process provides an evaluation of the
systems’ overall capabilities based on criteria developed by Division of Drinking Water
in conjunction with the Local Health Department. The division’s Capacity Development
and Technical Assistance personnel provide support and guidance as needed where
indicated by this evaluation.
The Capacity Development program has proven successful in its mission to improve the
technical, managerial, and financial capabilities of small PWSs through the sanitary
survey process and various methods of assistance including direct on-site assistance.
Tracking of Notices of Violation (NOVs) to the water systems and the trend of NOVs
issued over the period decreased by 60 percent from fiscal year 2014 to fiscal year 2017,
which highlights the positive impact of the Capacity Development program. These trends
indicate a better understanding of the Capacity Development program requirements and
of the Safe Drinking Water Act in general as PWS operators and managers become better
educated and more aware of pertinent issues.
The Capacity Development program, in conjunction with its partners and stakeholders,
has amicably worked to identify ways of helping PWSs to address technical, managerial,
and financial issues through innovative and improved methods of operation and
management. Over seventy five percent of the 482 PWSs in the state serve communities
with less than 10,000 people; over fifty-five percent serve communities with less than
3,300 – CDP has influenced them with par excellence. Capacity Development personnel
continue to work on guidance documents and other tools for PWSs’ use to improve
performance, achieve compliance, and increase technical, managerial, and financial
capacity.

Triennial Report to the Governor
Capacity Development Program
State of Utah FY17 Page 1
1 INTRODUCTION

1.1 Triennial Program Report to the Governor and Annual Program Report to EPA

Every three years, EPA requires that the states submit State Capacity Development
Program Reports to their Governors. The states are also required to make these reports
available to the public.

Following the Office of Inspector General's Capacity Development Program Evaluation
in 2003, EPA's Office of Water made a commitment to establish consistent reporting
criteria for the required reports. Criteria were compiled to guide and assist the states in
developing their annual program reports. The criteria are also intended to help EPA
Regions maintain uniformity when assessing each State's implementation of its approved
Capacity Development Program. The criteria also act as an aid to the states as they
develop their triennial reports to their Governors.

1.2 Safe Drinking Water Act, State Primacy, and State Capitalization Grants

The Safe Drinking Water Act (SDWA) was established in 1974 with the intention of
assuring safe drinking water in public water systems (PWS's) throughout the United
States. SDWA authorized the Environmental Protection Agency (EPA) to delegate
primary enforcement authority, or primacy, to any individual state deemed sufficiently
capable to administer its state program of Public Water System Supervision (PWSS).
Utah was granted primacy on February 28, 1980.

The initial federal monies under SDWA from EPA to the states aided the states in
regulation of PWS's with respect to EPA-promulgated maximum contaminant levels
(MCL's). Minor amendments to SDWA in 1977, 1979, and 1980, and major amendments
in 1986 and 1996 expanded federal focus from the original chemical contaminants of
interest to additional concerns with drinking water. The 1986 Amendments focused on
disease-causing microbial contaminants in drinking water and established minimum
treatment requirements for all surface waters. They also encouraged EPA to quicken the
pace of MCL promulgation by specific direction to EPA to establish MCL’s and
MCLG’s (maximum contaminant level goals) for 83 specific contaminants including
synthetic chemical contaminants of ground water. The 1986 Amendments also addressed
lead and copper contamination in drinking water at the consumer’s tap, principally as a
result of distribution system and fixture corrosion.

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 2
The 1996 Amendments implemented stronger prevention programs, empowered the
states with greater flexibility, afforded consumers access to better information ("right to
know") in consistent format (Consumer Confidence Reports), and overhauled EPA’s
regulatory development process including how many and which contaminants are to be
selected for regulation. The 1996 Amendments redirected drinking water contamination
prevention efforts to the new programs of source water protection, capacity development,
and operator certification. The 1996 Amendments also establish federal funding for
states and their PWS's through the Drinking Water State Revolving Fund (DWSRF). The
DWSRF assists communities in drinking water treatment and protection in much the
same way that wastewater treatment and clean water have been promoted through the
Clean Water State Revolving Fund (CWSRF).

The 1996 Amendments to SDWA allow the option of designation of portions of a state's
grant monies as set-aside funds for specific priority activities and other administrative
requirements. As much as 10 percent of a state’s capitalization grant may be used for
implementation of source water protection, capacity development, and operator
certification programs, as well as for the state’s overall drinking water program
[§1452(g)]. Up to 15 percent (no more than 10 percent for any one purpose) can be used
for prevention projects in water systems, including source water protection loans,
technical and financial assistance to systems as part of a state capacity development
strategy, source water assessments, and wellhead protection [§1452(k)].

The 1996 Amendments to SDWA make it incumbent upon the states to adopt program
modifications and additions prescribed by EPA. EPA designates these program
requirements for the states as either mandatory or voluntary. Failure of a state to enact a
mandated program by the allotted deadline can result in state forfeiture of primacy for its
own Public Water System Supervision (PWSS) program and loss of the entire program
capitalization grant. Failure to enact a voluntary program calls for loss of only a portion
of the program capitalization grant, typically 20 percent.

Utah and the other states regularly reconcile available resources to EPA compliance
deadlines for both mandatory and voluntary programs. The states’ PWSS programs in
FY17 continued to attend to multiple EPA Rule initiatives including Long-Term 2
Enhanced Surface Water Treatment Rule, Ground Water Rule, and Total Coliform Rule.

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 3

1.3 State-Level Capacity Development Programs

In the time leading up to the 1996 Amendments to SDWA, EPA became aware of
demonstrated success in several states in reliably delivering safe drinking water. These
states had each focused on improvements in the technical, managerial, and financial
capabilities of their PWS's. The 1996 Amendments represent EPA's efforts to build
nationally on this demonstrated success by imposing certain mandates on the states.
Namely, in order to receive the full allotment of funds to which they are entitled under
the DWSRF, states have had to develop:

1. A program to ensure that all new community and new non-transient, non-
community water systems commencing operation after October 1, 1999,
demonstrate sufficient technical, managerial, and financial capacity to comply
with national primary drinking water regulations (NPDWR's); and,
2. A strategy to assist existing PWS’s in acquiring and maintaining technical,
managerial, and financial capacity to comply with SDWA requirements.

EPA's intent is that the states use DWSRF set-aside funds for their capacity development
program and implementation efforts. As intended by the 1996 SDWA Amendments,
“capacity” encompasses the technical, managerial, and financial capabilities of a water
system to achieve, maintain, and plan for compliance with applicable drinking water
standards given the available water resources and the characteristics of the population
served by the water system.

Technical capacity refers to the physical infrastructure of the water system, including but
not limited to the adequacy of source water, infrastructure adequacy (source, treatment,
storage, and distribution), and the ability of system personnel to implement the requisite
technical knowledge. Managerial capacity refers to the management matrix of the water
system, including but not limited to ownership accountability, staffing and organization,
and effective external linkages. Financial capacity refers to the financial resources of the
water system, including but not limited to the revenue sufficiency, credit worthiness, and
fiscal management and controls.

Failure to meet the requirements of the provisions for Capacity Development published
by EPA subjects a state to a 20 percent withholding from its DWSRF allotment. In the
several years since the 1996 Amendments, most states have identified and prioritized
PWS's most in need of assistance in enhancing their technical, managerial, and financial

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 4
capacity. In addition, the states (including Utah) have for a number of years been
targeting deficient PWS's for technical and financial assistance.

The 1996 SDWA Amendments directed EPA to provide guidance to the states in
establishing their capacity development programs. The following documents were
published to meet this requirement.

 Information for States on Implementing the Capacity Development Provisions
of the Safe Drinking Water Act Amendments of 1996. 1998. U.S. Govt. Pub.
EPA 816-R-98-008.
 Handbook for Capacity Development: Developing Water System Capacity Under
the Safe Drinking Water Act as Amended in 1996. 1999. U.S. Govt. Pub. EPA
816-R-99-012
 Developing Water System Managerial Capacity: Training Module. 2002.
Drinking Water Academy and Environmental Protection Agency.

Capacity Development is intended to be a commitment by the states on behalf of their
PWS's to (i) protect public health by ensuring consistent compliance with drinking water
standards, including federal and State regulations and other applicable standards of
performance; (ii) enhance performance beyond compliance through measures that bring
about efficiency, effectiveness, and service excellence; and (iii) promote continuous
improvement through monitoring, assessment, and strategic planning. EPA's policy
position is that all water systems, regardless of size or other characteristics, can benefit
from a program of ongoing capability development. Capable water systems are better
positioned to consistently comply with applicable standards and provide customers with
safe and reliable water service. Furthermore, capable systems also are better positioned
to meet other standards of performance that are generally accepted in the industry or
required by other regulatory agencies – e.g., the aesthetic quality of water (taste, color,
and odor), water pressure, water loss minimization, or other measurable aspects of
performance.

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 5

2 UTAH'S CAPACITY DEVELOPMENT PROGRAM

2.1 Rule Promulgation

2.1.1 Authority

In Utah, the Drinking Water Board operates under authority granted in 1981 by
Section 19-4-104 of the Utah Safe Drinking Water Act. The Utah Drinking Water
Board is an 9-person board appointed by the Governor. The Board is empowered
to adopt rules governing the design, operation, and maintenance of Utah's public
drinking water systems. The Utah Capacity Development Program is codified in
Utah Administrative Code Rule 309-800 Capacity Development Program.

2.1.2 Most Recent Reporting Period

In FY 2017 The Division of Drinking Water did not implement any changes to
R309-800 Capacity Development Program.

2.2 Range of Program and Activities

2.2.1 Allocation of Budget Resources

The State of Utah allocates money to a specific Capacity Development set-aside
fund in accordance with SDWA program guidelines. The State’s fiscal year
begins each calendar year on July 1st and ends on June 30 of the following
calendar year. The Division of Drinking Water began FY17 with $ 18,087 in the
Capacity Development set-aside fund (Unit Code 3823). During the year
$13,698was charged against this fund. An amount of $10,000 was requested for
this set-aside. The Division should have $14,389 for Capacity Development
oversight for FY18.

2.2.2 Drinking Water State Revolving Fund (DWSRF)

The Utah Capacity Development Program’s principal activity is in support of the
federal and State Drinking Water SRF programs. For Fiscal Year 2017, the State
of Utah Drinking Water Board authorized funding for 26 projects through the
SRF programs. Projects authorized in FY 2017 were approximately $ 21,261,273
of which $ 18,711,273 was allocated from the federal SRF program and
$ 2,510,000 was allocated from the State SRF program.

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 6

From the pool of authorized projects, Division Staff closed loans to complete the
funding process for 24 projects totaling approximately $ 8,212,874 of which
$5,103,874 was committed from the federal SRF program and $3,109,000 was
committed from the State SRF program.

2.2.3 System Consolidation and Restructuring

The Division continued work on its initiative to work closely with local and
county planners and the Division of Public Utilities to develop regulatory
guidelines and a cooperative environment whereby new developments are not
approved for construction without the appropriate review and approval of the
drinking water system. Counties continue to investigate adopting ordinances and
developing a relationship with the Division of Drinking Water to assure that new
development or proposed new water systems receive Division approval prior to
county plat approval.

2.2.4 Training Efforts Fiscal Year 2017

A portion of Utah's Capacity Development Program fund is allocated to drinking
water system operator education and certification. SDWIS records for the State
of Utah report 482 community water systems and 71 non-transient non-
community water systems during FY17. Of these systems, 38 community and 5
non-transient non-community systems are reportedly lacking a certified operator.
Collaboration between State Division of Drinking Water staff with the
Intermountain Section of the American Water Works Association and the Rural
Water Association of Utah to provide operator training resources, including pre-
certification training, is an ongoing effort to assure that all water systems in the
state of Utah have access to certified personnel.

Utah had 2449 certified operators in FY17. Operator Certification records show
that 467 written examinations were administered in Utah for all levels of
distribution and treatment operators during FY17. Water distribution is the more
common certification and accounts for approximately 77 percent of the total
number of operator certificates in the State of Utah.

In addition to water system operator training and certification, the Division of
Drinking Water also provides funding (through DWSRF set-aside funds) for

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 7
training and certification for backflow technicians. Division records indicate
there are 771 certified backflow technicians in the State of Utah and that 344
written examinations were administered during FY17.

2.3 State Capacity Development Program for New Water Systems

2.3.1 Background

The State of Utah’s present day efforts in capacity development have their roots
in the area of system viability, namely Rule R309-500-11 Financial Viability,
which became effective in 1998 and encouraged system owners and managers to
develop strategies to recoup the costs of constructing, operating and maintaining
their systems. The rule suggested that capital and operating cost data and/or
estimates be submitted to the Division of Drinking Water for review at the same
time that engineering plans and specifications are submitted for approval.

The Rule was well-intentioned but lacked a regulatory framework for adequate
enforcement and was replaced in 1999 by R309-352 Capacity Development
Program. This rule was renumbered to R309-800 during this fiscal year 2011 to
conform with the new rule numbering convention adopted by the Division of
Drinking Water.

Congress recognized this same circumstance on a national scale and the 1996
SDWA Amendments enacted a provision to move the states to action, namely that
the states must have the legal authority to ensure the technical, managerial, and
financial capabilities of new water systems or risk losing up to 20 percent of their
annual DWSRF capitalization grant.

At the state level, Utah Code 19-4-104(1)(a)(v) was promulgated and specifically
grants authority to the Drinking Water Board to make rules regarding the
Capacity Development Program and it references SDWA Section 1420. Utah’s
resulting Capacity Development Program Rule requires that new water systems
demonstrate they have adequate technical, managerial, and financial capacity
before they may be approved as a public water system (PWS). With its adoption,
and established effective date of September 15, 1999, Rule R309-352 Capacity
Development Program requires both new community and new non-transient non-
community water systems to submit a Capacity Assessment Review, which is to
include a Project Notification Form and a Business Plan (which is to consist of a
Facility Plan, a Management Plan, and a Financial Plan).

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 8

The Facility Plan is intended to provide a description of the scope of the water
services that will be provided by the proposed community or non-transient non-
community water system and must include:

1. A description of the nature and extent of the area to be served and
provisions for extending the water supply system to meet growth;
2. An assessment of current and expected drinking water compliance
based on monitoring data from the proposed water source;
3. A description of the alternatives considered, including
interconnections with other existing water systems, and the
technical, managerial, financial, and operational reasons for the
approach selected; and,
4. An engineering description of the facilities to be constructed,
including the construction phases and future phases as well as
future plans for expansion and an estimate of the full cost of any
required construction, operation, and maintenance.

The Management Plan is intended to describe how the proposed community or
non-transient non-community water system will provide effective system
management and operation. It must include:

1. Documentation that the applicant has water rights, and the legal
right and authority to construct, operate, and maintain the system;
2. An Operating Plan that describes the tasks to be performed in
managing and operating the system including administrative and
management organization charts, plans for staffing the system with
certified operators, and provisions for an operations and
maintenance manual; and,
3. Documentation of management credentials of operations personnel
and documentation of cooperative agreements or service contracts
including demonstration of compliance with the water system
operator certification rule.

The Financial Plan is intended to describe the proposed community or
nontransient noncommunity water system’s revenues, cash flow, income, and debt
(issuing and repayment) for meeting the costs of construction as well as the costs
of operation and maintenance for five years from the date the applicant expects to

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 9
begin system operation.

After the Division deems that the information submitted by the applicant is
complete, the Division conducts a Capacity Assessment Review. The applicant is
notified in writing whether or not the proposed new system has met the Rule
requirements for technical, managerial, and financial capacity. R309-800
Capacity Development Program stipulates that no new community water system,
nor non-transient non-community water system, shall be approved in the absence
of demonstrated adequate capacity.

2.3.2 Most Recent Reporting Period

In any given fiscal year, the Division of Drinking Water receives numerous
inquiries from developers, landowners, and other entities about creation of new
public water systems. In such inquiries, the Division promotes alternatives such
as consolidation with, or annexation by, existing public water systems where such
alternatives are available. R309-800 Capacity Development Program is written in
straightforward language and the Division refers those individuals proposing the
new water system to this Rule to acquaint them with the tasks involved in creating
a new water system.

In an average year 5-10 new water systems are proposed, about half of which are
new community or new non-transient non-community water systems that are
subject to the requirements of R309-800 Capacity Development Program. Staff
typically responds to the initial inquiry and capacity assessment within 30 days.

2.4 State Capacity Development Program for Existing Water Systems

2.4.1 Background

Congress, in the 1996 SDWA Amendments, worked from the premise that
enhancing and ensuring the technical, managerial, and financial capabilities of
small water systems is the best strategy for correcting and preventing
noncompliance with public drinking water system requirements. To this end,
penalties for not implementing strategies “to assist public water systems in
acquiring and maintaining technical, managerial, and financial capacity” (SDWA
Sec. 1420(c)) were included in the legislation to prompt states to adhere to this
philosophy.

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 10
Utah implemented the wishes of Congress on several regulatory fronts. The State
of Utah Administrative Rules for Public Drinking Water Systems Rule 309-705,
Financial Assistance: Federal Drinking Water Project Revolving Loan Program,
has several components that interface with issues of system capacity and systems
with histories of significant noncompliance. The purpose of Rule 309-705,
Financial Assistance: Federal Drinking Water Project Revolving Loan Program
is to establish criteria for financial assistance to public drinking water systems in
accordance with a federal grant established under 42 U.S.C. 300j et seq., federal
Safe Drinking Water Act. The Rule defines an eligible water system as any
community drinking water system, either privately or publicly owned, and
nonprofit noncommunity water systems.

Historically, State financial assistance through Rule 309-705 has been sought by
water systems across the entire compliance spectrum from those systems with
significant compliance issues to those with few if any compliance issues. An
important stipulation of Rule 309-705-4(3)(a) is that no financial assistance is
authorized for any project for a water system in significant noncompliance, as
measured by a not approved rating, unless the project will resolve all outstanding
issues causing the noncompliance. Rule 309-705-5(3) further requires that as part
of the application and project initiation procedures, Division staff will prepare a
capacity development analysis (i.e., capacity assessment) of the applicant water
system. Thus, the elements of the State’s Capacity Development Program for
new community water systems and nontransient noncommunity (NTNC) water
systems (see Section 2.3, State Capacity Development Program for New Systems)
can be used in the analysis of existing water systems.

2.4.2 Most Recent Reporting Period

During FY17, staff completed Capacity Assessments, according to the procedures
outlined in R309-800 Capacity Development Program, for the following DWSRF
applicants:

Winchester Hill W System
Big Plains Water & Sewer SSD
San Juan Spanish Valley SSD
Bridge Hollow Water System
Rocky Ridge

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 11
Fairfield Culinary Water System
Virgin Town Water System
Cedarview Montwell
Hanksville Town Water System
Lizard Bench Water Association
Iron Town Water System
Big Water Town
Community Water Company
Koosharem Town
Holmstead Ranch LLC W System
North Valley Ranch W System
Pleasant View W System
Manila Town W System
Mendon City W System

Capacity assessments for these applicants were conducted according to the
procedures outlined in R309-800 Capacity Development Program. A capacity
assessment report was prepared and submitted to the water system and a copy was
placed in each applicant’s project folder.

3 STATE APPROACH TO IDENTIFIED NEEDS AND CONCERNS

3.1 Improvement Priority System (IPS)

3.1.1 Program Description

The State of Utah employs a system for assessing deficiency points against public
water systems on the basis not only of the monitoring and reporting shortcomings
addressed in the EPA Enforcement Targeting Tool (ETT) but also a spectrum of
other public health concerns. EPA replaced the Significant Non Compliance
(SNC) List with the ETT in 2010. According to information in the quarterly ETT
list submitted to the states: “The purpose of the Enforcement Targeting Tool is to
prioritize public water systems for enforcement response. It assigns points for
each unaddressed violation at a PWS during the last 5 years, which are added to
create a total score for each PWS.”

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 12

Utah public drinking water systems are subject to additional observation and
compliance monitoring than that included on the EPA ETT list alone. The
program is authorized under State of Utah Administrative Rules for Public
Drinking Water Systems Rule 309-400, Improvement Priority System Rule, which
enumerates Improvement Priority System (IPS) deficiency points for
administrative violations, infrastructure construction irregularities, unauthorized
water source or other infrastructure use, and other practices that are inconsistent
with delivery of safe drinking water to public drinking water system users.

IPS points are assigned as a result of deficiencies identified during water system
inspections (i.e., sanitary surveys), for failure to comply with monitoring and
reporting requirements and are typically assigned as soon as the deviations from
these requirements are noted in the State’s data base, or for failure to follow
design and construction rules (such as using an unapproved source, failure to
follow plan approval procedures, or failure to obtain an operating permit). Rule
309-400 requires that a community water system that is assessed more than 150
deficiency points be classified by the Utah Division of Drinking Water as “Not
Approved.”

3.2 Utah Top 25 Significant Noncompliance (SNC) List

3.2.1 Origin of the List

The State of Utah has developed a list of systems with a history of significant
noncompliance in monitoring and reporting as well as physical system
deficiencies in anticipation of using the list as compliance tools. Four times per
year, the State develops a Utah Top [Worst] 25 Significant Noncompliance (SNC)
List. This list is generated before regularly scheduled, quarterly meetings, and is a
tabulation of the worst 25 scores of all public water system IPS scores (i.e., those
water systems with the highest point totals). This list supplements the EPA ETT
List.

It is not unusual for Utah water systems with severe technical, managerial, and
financial challenges to regularly and repeatedly appear on this list. In contrast,
water systems that achieves and maintains sufficient technical, managerial, and
financial capabilities rarely appear on the list for more than one quarter. An
isolated incident, such as failure to complete the design approval process correctly
for new water system infrastructure, or failure to take scheduled water samples,

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 13
occasionally occurs among even the most capable water systems but is generally
resolved as soon as the problem is brought to the attention of a technically,
managerially, and financially capable public water system.

3.2.2 Most Recent Reporting Period

For Fiscal Year 2017, Utah Compliance Assurance Program (CAP) quarterly
meetings were held in August, November, February, and May. Meetings are
normally held within 45 days of the end of the previous quarter.

3.3 Utah Rating Change List

3.3.1 Origin of the List

The utility of the Utah Top [Worst] 25 SNC List has been supplemented by the
State’s generation of an additional quarterly list entitled the Utah [Water System]
Rating Change List. This list identifies water systems whose IPS scores have
fallen below (a good development) or exceeded (a bad development) the critical
150 IPS point threshold between “Approved” and “Not Approved” status. This
list thus serves as a convenient method to identify on a quarterly basis those
systems that either merit a return to “Approved” status or warrant a change to
“Not Approved” status relative to their previous quarter's status.

3.3.2 Most Recent Reporting Period

In any given fiscal year, the four Utah quarterly CAP meetings have the primary
purpose of addressing the EPA ETT List and the Utah Top [Worst] 25 Significant
Noncompliance (SNC) List. A secondary function of the quarterly meetings is
serving as a forum for discussion of public water systems whose ratings warranted
change from approved or not approved. In each case, the meeting’s findings are
officially sent to the affected water systems.

3.4 Review of Implementation of the Program

The Division of Drinking Water does not conduct regularly scheduled reviews of the
implementation of its Capacity Development Program. There is a great deal of flexibility
in program administration under Rule R309-800 Capacity Development Program and
program implementation evolves in response to water system applicant (new systems)
and operator (existing systems) feedback.

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 14
During the previous three years fourteen new public water systems were identified or
organized in the State of Utah. These systems are detailed in the table below.

Retail
PWSID PWS Name EPA
Region State PWS Population
Served
Type
UTAH08048 Lila Canyon Mine 8 UT NTNC 300 FY17
UTAH18177 Utah Data Center 8 UT C 250 FY17
UTAH25179 Rigtrup Egg Farm 8 UT NTNC 35 FY17
UTAH27106 Holmstead Ranch Llc 8 UT NTNC 100 FY16
UTAH27086 North Valley Ranches Sub 8 UT C 30 FY16
UTAH27088 Olympus Academy 8 UT C 84 FY15
UTAH06008 Weber Basin Job Corps 8 UT C 305 FY16
UTAH15043 Houwelings Tomato Plant 8 UT NTNC 50 FY16
UTAH06047 Mida - Falcon Hill (Hafb) 8 UT NTNC 55 FY16
UTAH25077 Riverbend Grove, Inc. 8 UT NTNC 35 FY15
UTAH27104 Snow Canyon State Park 8 UT NTNC 266 FY14
UTAH28028 Caineville SSD 8 UT C 83 FY14
UTAH27105 Camp Kolob- Oak V Girls
Camp 8 UT NTNC 300 FY14
UTAH11094 Beryl Baptist Church 8 UT NTNC 40 FY15
UTAH18173 VA Medical Center SLC 8 UT C 5550 FY15
UTAH25178 Krishna Temple 8 UT NTNC 50 FY15
UTAH02080 Washakie Renewal Energy 8 UT NTNC 45 FY15
UTAH02079 Bear River WCD- Collinston
Water 8 UT C 102 FY15
UTAH22148 Weber River Rec Camp 8 UT NTNC 150 FY15

Triennial Report to the Governor
State of Utah FY17
Capacity Development Program Page 15
According to July 2017 ETT list; these are the projects which show the violations
with their ETT score. Pinnacle Homeowners Association has TCR violation of 13.
Shooting Star RV Resort and Frandsen Scout Reservation has TCR violation of
11. Susent Park has violation of TCR, nitrates and VOC violation at point 12.
Systems in violation of Nitrates above ETT points 11 are Heber City Kingdom
Hall and Lucerne Valley Campground.

3.5 Modifications to the Program Strategy

There were no major modifications to the program strategy during recent reporting years.

3.6 Availability of the Report to the Public

The Division of Drinking Water posts its annual Capacity Development Program Report
to EPA and its Triennial Capacity Development Report to the Governor on its web site at:

https://deq.utah.gov/ProgramsServices/programs/water/capacitydevelopment/index.htm