DDW-2024-011846

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-4830
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper.
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF DRINKING WATER
Nathan Lunstad, P.E.
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
May 15, 2024

Via Email: [e-mail]
Amy Rydalch
Oakley Town Water System
PO Box 129
Oakley, Utah 84055

Subject: System-Specific Minimum Sizing Standards—Final Determination
Oakley Town Water System, System #22010, File #12515

Dear Amy Rydalch:

DETERMINATIONS

Based on the findings set forth below, the Division of Drinking Water (the Division) hereby
establishes the following system-specific minimum sizing standards for Oakley Town Water
System (the System):

Peak Day Source Demand (gallons/day/ERC) – 1,486
Average Annual Demand (gallons/year/ERC) – 392,554
Equalization Storage (gallons/ERC) – 1,075
Fire Storage (gallons) – 120,000

Introduction

Pursuant to Utah Code Section 19-4-114, the Director of the Division (Director) is required to
establish system-specific minimum sizing standards based on, among other factors, water use data
submitted to the Division of Water Rights (DWRi). The Director’s determinations may also be
based on engineering analyses and other evidence if this is available. This final determination
letter is addressed to you in your capacity as the Administrative Contact for the System. The
Director has delegated the responsibility for making system-specific minimum sizing standards
under Utah Code Section 19-4-114 to the Engineering Manager for the Division.

Prior to issuing this final determination letter, the Division analyzed applicable DWRi water use
data and sent a draft summary of the Division’s proposed system-specific minimum sizing
Amy Rydalch
Page 2 of 4
May 15, 2024

standards to the System on April 4, 2024. The Division allowed for 30 days for the System to
review the draft system-specific minimum sizing. A summary of the water use data and
calculations the Division used to make these determinations is attached as part of the
administrative record.

Water Use Data Definitions

As used in this Final Determination, the following terms have the following meanings:
Peak Day Source Demand is the total flow into a public water system to meet the demand of the
water system on the day of the highest water consumption in a calendar year.

Average Annual Demand is the total quantity of drinking water flowing into a public water system
within a calendar year.

Total Equivalent Residential Connections (ERCs) term represents the number of residential
service connections and the number of equivalent residential connections for non-residential
connections (commercial, industrial, institutional connections).

Minimum Equalization Storage requirement is a volume that is equivalent to the amount of water
needed to meet the average day culinary demand for public water systems. Equalized storage per
ERC is calculated by dividing the Average Annual Demand per ERC data by the number of
operational days in a year.

Water System Background Facts

The Oakley Town Water System is located in Summit County and serves approximately 1,200
customers. The system uses a single well, spring, and multiple storage tanks to provide drinking
water to their customers.

System-Specific Minimum Sizing Standards—Background

Under Utah Code Section 19-4-114, the legislature required that the Director establish minimum
sizing standards on a system-specific basis instead of statewide, as the Division has done in the
past. System-specific determinations need to be based on system-specific information. The code
allows the Director to rely on water use data submitted to DWRi. Alternatively, a community
water system may perform and submit an engineering study to the Division if the water system’s
water use data is not representative of future use or the water system does not yet have actual
water use data. In this matter, actual water use data was available through DWRi, and an
engineering study was not submitted to the Division for review. Therefore, the Division has relied
upon DWRi information and other relevant data.

Amy Rydalch
Page 3 of 4
May 15, 2024

Additional System-Specific Basis for Determinations
Fire Storage was set based on the International Fire Code (IFC) for 1000 gpm for two hours for a
total of 120,000 gallons as a default in the absence of confirmation from the local fire authority.
Your system’s fire suppression storage requirement may be different.
Storage Capacity

Based on the System’s storage facilities and the storage minimum sizing requirement established
in this letter, the Director hereby determines that the System is compliant with the minimum
storage capacity requirements.

Source Capacity

The Division has adequate documentation of established safe yields (wells) and yields (springs)
for all the System’s sources. Using total system-wide safe yields and yields and the source
minimum sizing requirement established in this letter indicates that the System is compliant with
minimum source capacity requirements.

Effective Date

The determinations made in this letter are effective immediately and will become final 30 days
from the date of this letter unless the System files a contest as provided below.

Notice of Right to Contest

The Director has determined this determination made under Section 19-3-114 qualifies as a
“permit order” within the meaning of Utah Code Section 19-1-301.5(1)(f). See Utah Code § 19-1-
301.5(1)(e) (defining “permit” to include a “plan” or “other administrative authorization”).

The System may contest any determinations made herein by delivering a notice of contest to the
Director. The notice of contest must be in writing and must be delivered to the Director on or
before 30 days after the date this letter is signed. There is no particular form for the notice of
contest, but it must include the System’s reasons and rationale for the contest. The Director’s
address for purposes of submitting a notice of contest is as follows:

U.S. Mail

Division of Drinking Water
Attention: Director
P.O. Box 144830
Salt Lake City, UT 84114-4830

Amy Rydalch
Page 4 of 4
May 15, 2024

Email

A notice of contest may be submitted to the Director by email, provided, however, that the
Director confirms receipt of the email. The Director’s email address is:
[e-mail]. The email submission must be received by the Director before the
expiration of the contest deadline.

If the System files a timely notice of contest, the Director will evaluate the matter and attempt to
resolve the matter through negotiations. If the Director is not able to resolve the matter, the
Director will issue a final agency action regarding the contest. At that point in the process, the
System shall have the right to seek further internal agency and judicial review pursuant to Utah
Admin. Code R305-7 and Utah Code Section 19-1-301.5.

Right to Request Reconsideration

The Director plans to evaluate the determinations made herein every three years. However, this
requirement is not mandatory. At any time, a water system whose system-specific minimum
sizing standards have been established by the Division under Section 19-4-114 may request
reconsideration of the Director’s determinations by submitting a written request. A request for
reconsideration shall be submitted to the Director in the same manner as a notice of contest
provided above.

Conclusion

If the System management has any questions regarding this letter, please contact Cameron
Draney, P.E., of this office, at [phone], or me at [phone].

Sincerely,

Michael Newberry, P.E.
Permitting and Engineering Support Manager

CLD/mrn/mdb

Enclosures
1. Utah Department of Environmental Quality Division of Drinking Water Minimum Sizing Standards
Summary Report

cc: Nathan Brooks, Summit County Health Department, [e-mail]
Amy Rydalch, Oakley Town Water System, [e-mail]
Cameron Draney, P.E., Division of Drinking Water, [e-mail]
Ted Black, Office of the State Fire Marshal, [e-mail]

DDW-2024-007594
Utah Department of Environmental Quality
Division of Drinking Water
Minimum Sizing Standards
Date Standard Effective: Thu May 09 09:46:31 MDT 2024
Peak Day Source Demand per ERC (gal/day): 1,486
Average Annual Demand per ERC (gal/year): 392,554
Equalization Storage per ERC (gal/day): 1,075
OAKLEY TOWN WATER SYSTEM PWS ID: UTAH22010
Admin Name: AMY RYDALCH
Address:
City, State, Zip: ,
Phone: [phone]
Email: [e-mail]
System Type: Community
Population: 1,200
MINIMUM SIZING STANDARD
MINIMUM SIZING STANDARD CALCULATIONS VARIABILITY
Data from these reporting years: 2021, 2022, 2023
Peak Day Source Demand per ERC (gal/day): 1,486
Average Annual Demand per ERC (gal/year): 392,554
Equalization Storage per ERC (gal): 1,075
x
x
x
(1 + 0.0)
(1 + 0.0)
(1 + 0.0)
=
=
=
1,486
392,554
1,075
DWRi WATER USE DATA REPORTED
Equalization per ERC (gal): 1,075
Existing Storage (gal): 1,550,000
ERCs: 612
Required Storage w/o Fire Flow: 657,900
Required Fire Storage (gal): 120,000
Required Storage w/Fire (gal): 777,900
Storage Deficiency: 0
Storage Deficiency (%): 0.0
No Storage Deficiency
Peak Day Source Demand per ERC (gpm): 1.03
Existing Source Capacity (gpm): 1,026
ERCs: 612
Required Source Capacity (gpm): 630
Source Deficiency: 0
Source Deficiency (%): 0.0
No Source Deficiency
Year Peak
Day
Source
Demand
(gal/day)
Average
Annual
Demand
(gallons)
ERCs Peak
Demand
per ERC
(gal/day)
Avg
Annual
Demand
per ERC
(gal/day)
Equaliza
tion
Storage
per ERC
(gal/day)
OP
Days
2023 902,607 224,641,679.4 608 1,486 369,781 1,013 365
2022 843,954 240,188,030.61 612 1,379 392,554 1,075 365
2021 870,022 221,888,238.45 590 1,476 376,357 1,031 365
Variability:0.037 0.0 0.0 0.0
Year Peak Month Average
(gal/day)
Peak Month Average
per ERD (gal/day)
Ratio of PD/ERC to
Peak Month Avg/ERC
2023 954,638 1,571 0.95
2022 801,067 1,309 1.05
2021 973,099 1,651 0.89
CAPACITY CALCULATIONS FOR STORAGE
CAPACITY CALCULATIONS FOR SOURCES
SYSTEM STORAGE AND SOURCE INVENTORY
Storage ID Storage Name Effective Volume (GAL)
ST001 SPRING TANKS #1 150,000
ST002 SPRING TANK #2 250,000
ST003 HUMBUG TANK 1,000,000
ST004 MAPLE RIDGE STORAGE 150,000
Storage Totals: 1,550,000 GAL
Source ID Source Name Flow Rate (GPM)
WS004 HUMBUG WELL 650
WS001 COTTONWOOD SPRING 376
WS006 CATTAIL WELL
Source Totals: 1,026 GPM