DDW-2024-012712

Noah Zorsky <[e-mail]>
Erda Acres Water Co #23053 updated DWSP plan review
4 messages
Noah Zorsky <[e-mail]>Tue, May 28, 2024 at 4:06 PM
To: Megan Jensen <[e-mail]>, [e-mail]
Cc: Deidre Beck <[e-mail]>
Hi Megan and Alan,
I’m reviewing the updated DWSP plan for Erda Acres Water Co’s Nelson Well (WS002) and Campbell Well (WS003), received on
December 15, 2022. In section 7 of the update, it’s mentioned that two properties adjacent to the well lot have changed ownership.
You mention that although land uses have not changed, the number of animals has increased and additional facilities for the
animals have been built. From what I can tell, this is describing the properties south of the Campbell Well, one of which has obvious
equestrian use, seen on aerial imagery. Portions of this property and its animal enclosures appear to lie within zone one of the
Campbell Well. This is an issue because rule R309-600-13(2)(b)(i) states that a Public Water System shall not locate a new ground-
water source where an uncontrolled potential contamination source (PCS) or a pollution source exists within zone one. The animals
located within zone one may constitute a pollution source. It should also be noted that land use agreements (LUAs) from these
adjacent properties agreed not to locate any PCSs within zone one but this appears to have happened anyway. Attached are the
recorded LUAs for your reference.
After reviewing the original 1999 DWSP plan, and all preceding updates, it does not appear that livestock was ever inventoried as a
PCS. Since the livestock has never been inventoried or assessed, we need additional information before we can concur with the
plan update.
1. Please review the screenshot and confirm where the Campbell Well is located. Describe or mark the location so that we can
update the location of the source and identify the most accurate extent of zone one (red boundary).
2. In the 2022 update, you state that these adjacent landowners have horses and goats and the number of animals has
increased since previous ownership.
a. What types of animals are being stabled, fed or maintained within zone 1 and how many of each? (i.e # goats, #
horses, etc). We need exact numbers so that we can assess whether or not these animals meet the definition of a
pollution source.
b. Are these animals stabled, fed, or maintained for a total of 45 days out of a 12 month period within zone 1?
3. While describing the landowner’s animal enclosures in section 7, you state that “their management practices are good”. We
need more detail. Please add livestock to Section 3 of the plan update and add an assessment of the current controls in
place in Section 4. Please be sure to address all topics necessary to assess the livestock as adequately controlled.
4. You state that a berm would be built as a physical barrier between the well lots and the adjacent properties. Has this been
done? Can you provide evidence that this was completed?
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
23053 LUAs 1996.pdf
1781K
Alan Clark <[e-mail]>Thu, Jul 18, 2024 at 8:09 AM
To: Noah Zorsky <[e-mail]>
Cc: Megan Jensen <[e-mail]>, Deidre Beck <[e-mail]>, Alan Clark <[e-mail]>
Hi Noah:
Sorry I have not responded sooner. I left for Maine on the day you sent your email and am here for the summer. The email also
went to my personal email rather than my water company one and I lost track of it while driving across country. I put my Erda Acres
email address in the cc above, I will not be back to Utah until the second week of September. All of my files for the Source Protection
Plan are in Utah but I will do my best to answer your questions.
1. On the screen shot you sent it looks like the dot for the wellhead location is about 3 feet west of the actual location. It is a little blurry
but you can make it out just to the right. So, the zone will not move much. You did not send me a screen shot for the Nelson Well. I
would need that from you to check the location.
2. For the Campbell Well:
a. There are 3 horses that spend some time in zone 1 but their area of confinement extends well outside zone 1. There are 2-3
goats but they seem to be moved around more and I do not see them every time I am there.
b. The horses are there over 45 days a year and the goats probably are.
For the Nelson Well:
a. There are 5 horses that spend some time in zone 1, 3 probably all of the confinement. There are 2 goats that spend part of their
time in zone 1 but their area of confinement is much larger than the zone.
b. I am unsure about the goats due to the large size of their confinement area but the horses are definitely in the zone for over 45
days.
3. I will not be able to update the plan adequately as you requested until I return to Utah in September. I hope that timeline works for
you.
4. As I stated in the plan, we would not establish the berm until we heard from you regarding approval of the update. We redid a
drainage ditch on the Nelson Well lot and stored the material we excavated there that will be used to do the berm. As far as
management of the horses, Nelson Well would be our first priority for completing the berm since the horses are closer to the well head
and the manure not managed as well but this is partly mitigated by the well head being inside our well building with a concrete pad
surrounding it.
Let me know if you have other questions.
Regards,
Alan
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Noah Zorsky <[e-mail]>Thu, Jul 25, 2024 at 10:56 AM
To: Alan Clark <[e-mail]>
Cc: Megan Jensen <[e-mail]>, Deidre Beck <[e-mail]>, Alan Clark <[e-mail]>
Hi Alan,
Thanks for the information. I've included a screenshot of the Nelson Well for your reference. Let me know if this changes your
estimates.
Based on the information you provided, the livestock in zone one for the Campbell Well and the Nelson Well do not meet the definition
of a pollution source, however, livestock is still considered a potential contamination source. As stated, please update the plan to
include livestock in section three and address this PCS in all subsequent sections. Since uncontrolled PCSs cannot be located within
zone one, argue why the livestock should be considered adequately controlled. I've added a note that the revised update will be
submitted by October.
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
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Alan Clark <[e-mail]>Wed, Jul 31, 2024 at 2:06 PM
To: Noah Zorsky <[e-mail]>
Cc: Alan Clark <[e-mail]>, Megan Jensen <[e-mail]>, Deidre Beck <[e-mail]>
Noah:
Based on the screen shot, I would lower my estimates of horses in Nelson Well Zone 1 to 4 horses that spend at least some time in
Zone 1 and 2 them probably all of their confinement. Once I get back to Utah I will make the additions you are requesting.but we also
have a Sanitary Survey due at the end of September so it may be mid-October before I can get the revised plan to you.
Thanks,
Alan
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