DDW-2024-013767

December 3, 2024
Michael Waite
Brigham City Water System
PO Box 1005
Brigham City, Utah 84302
Subject:After-the-Fact Plan Approval/Temporary Operating Permit, Bunderson Spring Development (WS023); Brigham City Water System, System #02004, File #13632
This Temporary Operating Permit Expires on March 31, 2028.
Dear Michael Waite:The Division of Drinking Water (the Division) received the plans and specifications for Bunderson Spring Development from your consultant, Kent Jones on February 26,
2024. A request for the Preliminary Evaluation Report was sent on March 13, 2024, but was never received. The project was constructed prior to issuance of the Plan Approval;thus, an
After-the-Fact Plan Approval is now issued with this letter in concurrence with the Temporary Operating Permit. The Division received your request for an Operating Permit from your consultant
on August 26, 2024. Division staff conducted an onsite final inspection of this project on September 3, 2024.
Our understanding of the project was the construction of piping, controls and associated appurtenances required to develop the Bunderson Spring into a culinary water source. The spring
is located on the northeast side of Mantua Reservoir.The Bunderson Spring is identified as WS023 in the Division’s database.
We have received the following information forBunderson Spring Development:
Plans and specifications for spring development.
Evidence of a legal right to divert water from the proposed spring.
Preliminary Evaluation Report and Drinking Water Source Protection Plan.
Proof that a map of the final source protection zones was submitted to Box Elder County.
New source chemical analyses of the spring water.
Record drawings.
Satisfactory bacteriological results as evidence of proper disinfection and flushing.
We have completed our review of the plans and specifications, stamped, and signed by Brett Jones, P.E., and dated February 14, 2024, and found they basically complied with the applicable
portions of Utah’s Administrative Rules for Public Drinking Water Systems in R309. On this basis, the plans for developing Bunderson Spring Developmentwere hereby approved.
The current spring flow is 105 gallons per minute (gpm) based on the data you have gathered. Brigham City Water System is required to measure and record the spring flow data once a month,
for each month the spring is reasonably accessible, for a minimum of three years. The Division will determine the yield of this spring when a minimum of three years of spring flow data
become available. Typically, the spring yield will be the basis for determining the maximum number of connections or population that Bunderson Spring (WS023) can serve.
Condition(s) of Obtaining Permanent Operating Permit & Spring Flow Data Requirement
Brigham City Water System must submit a minimum of three years of monthly spring flow data with a permanent Operating Permit request to the Division and obtain a permanent Operating
Permit for Bunderson Spring (WS023) by March 31, 2028.
The spring flow data submission requirement has been added to the Division’s database as a tracking tool and reminder. Please note that this water system will be assessed 200 deficiency
points if you do not submit the spring flow data and obtain a permanent Operating Permit for the Bunderson Spring (WS023) by March 31, 2028.
New Source Chemical Analysis
A complete New Source Chemical Analysis was received for Bunderson Spring and does not indicate any water quality concerns.
Preliminary Evaluation Report and Drinking Water Source Protection Plan Concurrence
The Division received a combined Preliminary Evaluation Report (PER) and Drinking Water Source Protection (DWSP) plan for this source from your consultant, Emily Thomas with Jones &
Associates Consulting Engineers, on October 7, 2024. The Division requested additional information via email on October 23, 2024. Your consultant provided revisions to the combined plan,
which included proof that a map of the final zones had been submitted to Box Elder County to be covered under its Drinking Water Source Protection ordinance on November 18, 2024.
We have completed our review of this plan and find that it basically complies with the applicable portions of Utah’s Administrative Rules for Public Drinking Water Systems. The Division
concurs with this 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, 2026, and every six years, thereafter.
Please be aware that the source protection zones for this source have now been incorporated into the Division’s Geographic Information System (GIS) database. In addition, these zones
should now appear on the Utah Environmental Interactive Map, so long as this system is currently classified as Public in the Division’s database. The Utah Environmental Interactive Map
can be accessed by visiting enviro.deq.utah.gov. We encourage you to visit the map to confirm that the location of this source and the source protection zones are accurate. If you need
assistance with navigating the map or to report any discrepancies, please call [phone] and ask to speak to source protection staff.
As stated in R309-600: 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 submission. 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: 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.
Please contact Deidre Beck at [phone] or via email at [e-mail] if you have questions about the source protection requirements.
Spring Source Monitoring
1. Bacteriological Source Sampling
a. This system is required to take monthly Escherichia Coli (E. coli) sampling at Bunderson Spring (WS023) (assessment monitoring) during the operating period when the Spring is accessible
and shall continue for a minimum of 12 months of data. This schedule will begin October 2024.
b. This sample is in addition to the monthly distribution system sample (DS001). Please label the source sample as WS023 (for both the facility ID and sample point ID) on all laboratory
forms.

c. Please contact Sitara Federico for any positive samples that may occur at the source at [phone] or [e-mail]. If any sample result comes back as E. coli positive,
please contact the Division within 24 hours of being notified of the result.
2. MPA Test – A Microscopic Particulate Analysis (MPA) test will be conducted by the Division during spring runoff in spring of 2025. This monitoring is required to evaluate the quality
of the water coming from Bunderson Spring (WS023) to better protect public health. Additional monitoring and/or disinfection requirements may be assigned depending on the results of
the assessment monitoring and MPA test.
If you have any questions regarding this After-the-Fact Plan Approval and Temporary Operating Permit, please contact Cameron Draney, P.E., of this office, at [e-mail], or Michael
Newberry, P.E., at [e-mail].
Sincerely,
Russell Seeley, P.E.
Assistant Director
CLD/DLB/mrn/mdb
Enclosures ─ Spring Approval Checklist; Operating Permit Checklistcc:Ben Harker, Bear River Health Department, [e-mail] Jones, Jones and Associates, [e-mail]
Jones, P.E., Jones and Associates, [e-mail] Draney, P.E., Division of Drinking Water, [e-mail] Waite, Brigham City Water System, [e-mail]
Pugsley, Brigham City Water System, [e-mail] Source Assessment Team, Division of Drinking Water, [e-mail]
David Kruse, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Sitara Federico, Division of Drinking Water, [e-mail]
Deidre Beck, P.G., Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
CDraney 02004 13632 PA Bunderson Spring DevelopmentDivision of Drinking WaterChecklist for New or Redeveloped Public Drinking Water Springs
System Name:System Number:Spring Name & Description:1.Approval to Develop (or Redevelop) the Spring
☐Project Notification Form
☐Preliminary Evaluation Report (PER) concurrence (for new springs)
☐Spring location data
☐Documentation of valid water right(s)
☐If available, an engineer’s or geologist’s statement indicating:
☐The historical record of the spring flow variation
☐Expected minimum flow and the time of the year it will occur
☐Expected maximum flow and the time of the year it will occur
☐Expected average flow
☐The behavior of the spring during drought conditions
☐New source chemical analyses of the spring water (for new springs or existing springs that have not been sampled) [R309-515-4(5)]
☐An assessment of whether the spring is “under the direct influence of surface water” [This assessment can be based on an on-site inspection, known geological conditions, or specific
water analysis results such as an MPA.]
☐Detailed plans and specifications for spring developmentor redevelopment2.Operating Permit to Use the Spring Water
☐Information on the rate of flow developed from the spring
☐Historical spring flow data or a minimum of 3 years of spring flow data — for determining the spring yield and issuing an Operating Permit
☐Current spring flow rate — for issuing a temporary Operating Permit (in case of insufficient flow data for determining the spring yield)
☐ Recorded land use agreements, or documentation that the requirements for coverage under the City/County source protection ordinance have been met
☐Design engineer’s certification of rule conformance with plan approval conditions
☐Design engineer’s certification of rule conformance for any deviation from approved plans
☐As-built or record drawings
☐Proof of satisfactory bacteriological quality
☐Water quality data, where appropriate [If the initial new source sampling indicates unsatisfactory turbidity, the spring water must be re-sampled and proven to have turbidity level
below the MCL.]
Utah Division of Drinking Water ― Checklist for Issuing Operating PermitsWater System Name:System Number: Project Description:File Number:
Items 1 through 8 below must be submitted to the Division and found to be acceptable prior to operating permit issuance (unless a water line project meets the requirements of R309-500-7
and is not required to obtain an Operating Permit).
Distribution lines (not including in-line booster pump stations) requiring Plan Approval may be placed into service prior to submitting all of the following items and receipt of Operating
Permit if the water system has received items 1 and 4 below.☐1.Certification of Rule Conformance by a professional engineer (P.E.) that all conditions of Plan Approval were accomplished,
and if applicable, changes made during construction were in conformance with rules R309-500 through 550☐2.As-built or record drawings incorporating all changes to approved plans and
specifications (unless no changes were made to the previously approved plans during construction)☐3.Confirmation that as-built or record drawings have been received by the water system☐4.Satisfactory
bacteriological samples as evidence of proper disinfection and flushing in accordance with the appropriate ANSI/AWWA standards:
☐ANSI/AWWA C651-14 AWWA Standard for Disinfecting Water MainsTwo consecutive sample sets at least 16 hours apart, none positive (every 1200 feet, end-of-line, each branch, etc.)☐ANSI/AWWA
C652-11 AWWA Standard for Disinfection of Water-Storage FacilitiesOne or more samples, none positive☐ANSI/AWWA C653-13 AWWA Standard for Disinfection of Water Treatment PlantsTwo consecutive
samples per unit, none positive, no less than 30 minutes apart☐ANSI/AWWA C654-13 AWWA Standard for Disinfection of WellsTwo consecutive samples, none positive, no less than 30 minutes
apart☐5.Water quality data, where appropriate [For example, water quality data showing MCL compliance; raw and finished water data that demonstrate satisfactory performance of the new
treatment facility.]☐6.If applicable, all other documentation that may have been required during the plan review process☐7.If applicable, confirmation that the water system owner has
received the O&M manual for the new facility☐8.If applicable, location data of new storage tank, treatment facility, or source