DDW-2024-014125

Danielle Zebelean <[e-mail]>
Re: Pending Violations #22022
9 messages
DDW IPS <[e-mail]>Wed, Jun
To: Scott McGee <[e-mail]>Cc: [e-mail], Colt Smith <[e-mail]>, Julie Cobleigh <[e-mail]>, Danielle Zebelean <[e-mail]>
I've forwarded your email to Colt so it's at the top of his inbox. I also have a meeting with him this morning so I'll make sure to bring your system up so we can work with you on that extension.any violations as you have reached out to us and hopefully we can get that compliance agreement in place quickly.
The first two deficiencies you have questions on will require answers from our permitting section. Julie Cobleigh or Dani Zebelean will most likely be working with you on those deficiencies. I'v
this email and added their contact information below if you would like to reach out to them now.
Julie Cobleigh385-214-9770
[e-mail]
Dani Zebelean385-278-5110
[e-mail]
For the two deficiencies you mentioned were corrected, do you have any photos of the corrections? Pictures of the screen installed and of the receipt or bottle of the new drinking water gradehypochlorite. As soon as we have those photos we can hopefully approve the corrections we can get those ones resolved.
Thanks, and please never hesitate to reach out to me.
Jen
On Wed, Jun 12, 2024 at 8:10 AM Scott McGee <[e-mail]> wrote:
Hi Jennifer and Rocky,
I have reached out to Colt Smith via phone and email relating to our PWS and I have not heard anything back. We are committed to correcting these issues and getting the system up to stafew questions that I was hoping he could help us with. I was also hoping that we could have a small extension, as curing some of the deficiencies will take time to put in place. Can you plea
moving this forward?
The email I sent Colt is below:
Hi Colt,
I was given your contact information to reach out to regarding the water system for Escape RV Resorts Knotty Pine. We are coming up on a due date for curing some deficiencies and I wancould speak about getting that extended.
We are fully committed to fixing all outstanding issues. I just had a few questions regarding the deficiencies that I was hoping you could answer.
I apologize if these are very basic. I am new to the company as of October 2023, and our company is also new to the management of Knotty Pine RV Resort (though the onsite managers h
for 4 years).
My questions regarding the attached report are:
Unapproved facility in use- How do we update the system inventory with our current chlorinator, or find a list of acceptable chlorinators per the Utah DDW?
System Lacks 20% storage capacity: I have been told that the storage tank was abandoned over 5 years ago. Will the state of Utah allow us to install an emergency generator sa variable speed well pump and not the storage tank? I feel that if we were required to get the storage tank back online, the process for making sure it is ready is not something we
Using unapproved chemical or process: We have switched to drinking water grade sodium hypochlorite. Please let me know if there's something else we need to do here? Well casing terminates less than 18 inches above ground: We will get this fixed quickly.
Storage Vent Lacks #14 screen: According to onsite operator, this is fixed.
Please let me know if we can extend our date to cure. We are committed to making sure everything is functioning per code. I look forward to hearing back from you. Thanks.
On Tue, May 21, 2024 at 7:42 AM Tracy Bringhurst <[e-mail]> wrote:Scott, I thought you would want to see this. I do not know where this is coming from. We have been here for almost 6 years and this is the first time I have seen these types of problems.
Tracy
---------- Forwarded message ---------
From: DDW IPS <[e-mail]>Date: Mon, May 20, 2024 at 1:49 PM
Subject: Pending Violations #22022To: <[e-mail]>
I am writing to address the outstanding significant deficiencies identified during the sanitary survey conducted at Escape RV Resort - Knotty Pine on October 17, 2
Upon review, it has come to my attention that five significant deficiencies were noted during the survey mentioned above, yet I cannot find records indicating thewithin the allotted timeframe of 120 days.
DS001 UTAH22022 DISTRIBUTION SYSTEM A 195 Hide Details ( 6 )
Code Description Severity Comments Determined
Date Pending
G001 UNAPPROVED FACILITY
IN SERVICE SIG There is a chlorinator on the system that is not listed on the
system inventory report.10/17/2023 0
12/9/24, 6:03 PM State of Utah Mail - Re: Pending Violations #22022
https://mail.google.com/mail/u/0/?ik=82c167e5f1&view=pt&search=all&permthid=thread-f:1801666121172249658&simpl=msg-f:180166612117224965…1/5
Code Description Severity Comments Determined
Date Pending
V034
SYSTEM LACKS MORE
THAN 20% OF REQUIRED
STORAGE CAPACITY
(FIRE DEMAND NOT
INCLUDED)
SIG
They have a 41500 gallon storage tank, but it is not currently in
use. The operator is not sure why or when they stopped using it,
but it is not currently in use.
10/17/2023 0
G006
USING UNAPPROVED
TREATMENT PROCESS
OR CHEMICAL
SIG
This system has a chlorinator that did not show up on the
inventory report, and I do not believe that they received ddw
approval for it. They are also using pool and spa chlorine and not
culinary drinking water chlorine.
10/17/2023 0
ST001 KNOTTY PINES TANK A 25 Hide Details ( 1 )
Code Description Severity Comments Determined
Date Pending
V007 STORAGE TANK VENT
LACKS NO. 14 SCREEN SIG air vent missing screen.10/17/2023 0
WS001 KNOTTY PINE WELL A 35 Hide Details ( 3 )
Code Description Severity Comments Determined
Date Pending
S003
WELL CASING
TERMINATES LESS THAN
12 INCHES ABOVE
FLOOR OR LESS THAN 18
INCHES ABOVE GROUND
SURFACE
SIG Well casing does not extend 18" above surrounding ground.10/17/2023 0
If these deficiencies have been corrected, I kindly request that you provide detailed information regarding the actions taken to address them, accompanied by anyevidence available for verification purposes.
However, if the matter remains unresolved and additional time is required, we encourage you to initiate discussions regarding a formal compliance agreement withFor further assistance in this regard, please reach out to Colt Smith at [e-mail] or via phone at 385-515-1529.
Please be advised that violations for the outstanding significant deficiencies are scheduled to be assessed on June 6, 2024. To prevent any adverse impact on theincluding an additional 50 points for each violation, I urge you to contact me before the specified date.
Your prompt attention to this matter is greatly appreciated.
Thanks,Jen-
--
Jennifer Yee
IPS Rule Manager
Environmental Scientist | Division of Drinking Water
M: [phone]
drinkingwater.utah.gov
[phone]
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
12/9/24, 6:03 PM State of Utah Mail - Re: Pending Violations #22022
https://mail.google.com/mail/u/0/?ik=82c167e5f1&view=pt&search=all&permthid=thread-f:1801666121172249658&simpl=msg-f:180166612117224965…2/5
--
Best,
Tracy BringhurstKnotty Pine RV Resort
5175 E State Hwy 35,
Kamas, UT 84036
[e-mail]
--Scott McGeeVice President Operations
832.845.4164Roamamerica.com
--
Jennifer Yee
IPS Rule Manager
Environmental Scientist | Division of Drinking Water
M: [phone]
drinkingwater.utah.gov
[phone]
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Scott McGee <[e-mail]>Wed, Jun 12, 2024 at 8:59 AMTo: Danielle Zebelean <[e-mail]>, Julie Cobleigh <[e-mail]>
Hi Julie and Dani,
I was hoping you could answer a couple questions I had related to our PWS and deficiencies.
Unapproved facility in use- How do we update the system inventory with our current chlorinator, or find a list of acceptable chlorinators per the UtahDDW?System Lacks 20% storage capacity: I have been told that the storage tank was abandoned over 5 years ago. Will the state of Utah allow us to install anemergency generator since we are using a variable speed well pump and not the storage tank? I feel that if we were required to get the storage tank backonline, the process for making sure it is ready is not something we can do quickly.
Scott McGeeVice President of Operations
832.845.4164www.roamamerica.com
[Quoted text hidden]
Danielle Zebelean <[e-mail]>Wed, Jun 12, 2024 at 9:54 AM
To: Scott McGee <[e-mail]>Cc: Julie Cobleigh <[e-mail]>, Jennifer Yee <[e-mail]>, Colt Smith <[e-mail]>
Hi Scott,
Please see my answers in purple. Sorry as I did not do the Sanitary Survey my answers may be a bit vague, but I am happy to have follow up conversations to figure this out with you.
Unapproved facility in use- How do we update the system inventory with our current chlorinator, or find a list of acceptable chlorinators per the UtahDDW? This depends on what type of chlorinator you installed. Liquid sodium hypochlorite is an approved chemical to dose with. However, there areother details we need to verify, could be done with photos or a site visit such as: Being able to track how much of the chemical you are using and knowing how much you are dosing. You could have a peristaltic pump already onsite. Verify where the chlorine is being dosed. Making sure you can still collect water samples before and after dosingHaving the chlorine stored in a building/shelter that is protected from the elements. Approximately when and why the chlorinator was installedThis is not a comprehensive list just listing off what I can to respond to you. I would like to schedule a followup meeting, preferably a site visit, or Ican do a virtual meeting, to talk with you about this as it will come with additional monitoring and reporting requirements and source water sampling.
12/9/24, 6:03 PM State of Utah Mail - Re: Pending Violations #22022
https://mail.google.com/mail/u/0/?ik=82c167e5f1&view=pt&search=all&permthid=thread-f:1801666121172249658&simpl=msg-f:180166612117224965…3/5
System Lacks 20% storage capacity: I have been told that the storage tank was abandoned over 5 years ago. Will the state of Utah allow us to install an
emergency generator since we are using a variable speed well pump and not the storage tank? I feel that if we were required to get the storage tank back online,
the process for making sure it is ready is not something we can do quickly. This is interesting since your storage tank is still marked as active in our database.
Rocky did put in the notes that the tank was inactive and empty but it looks like we didn't catch that to update our system. Since you are a transient system we
can issue a temporary exception to your storage deficiency to allow you time to get the tank back up and running. This is dependent on how much your well
produces and how much you need. Which I assume if you've been running this way for 5 years will be sufficient.
From Rocky's notes the operator didn't know why the tank was abandoned but thought it had to do with transitioning from a seasonal system to a year-round
system and there might have been concerns about freezing since the water lines are not deep. So this may need to be evaluated if the tank is to be re-
activated.
You're welcome to call me at my phone number below to discuss further questions over the phone or respond to this email.
Dani Zebelean, P.E.
Environmental Engineer III | Division of Drinking Water
M: [phone]
Hours: M - Th 7 am to 5 pm
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]
Danielle Zebelean <[e-mail]>Wed, Jun 12, 2024 at 10:57 AM
To: Rebecca Yoo <[e-mail]>
Here is the email I sent this morning. Dani Zebelean, P.E.
Environmental Engineer III | Division of Drinking Water
M: [phone]
Hours: M - Th 7 am to 5 pm
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]
Danielle Zebelean <[e-mail]>Fri, Oct 11, 2024 at 9:40 AM
To: Scott McGee <[e-mail]>Cc: Julie Cobleigh <[e-mail]>, Jennifer Yee <[e-mail]>, Colt Smith <[e-mail]>
Hi Scott,
Following up on this thread as I see you've entered into the CA/EO. The email above addressed how we could resolve the V034, G001, and G006 violations. I would need further detailson your well casing in order to give you guidance on how to resolve the S003 on your well casing.
Let me know if you would like to set up a virtual meeting or site visit to see how we can address these concerns and get you back into compliance!
Thanks!
Dani Zebelean, P.E.
Environmental Engineer III | Division of Drinking Water
M: [phone]
Hours: M - Th 7 am to 5 pm
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]
Danielle Zebelean <[e-mail]>Wed, Nov 13, 2024 at 8:49 AM
To: Scott McGee <[e-mail]>Cc: Jennifer Yee <[e-mail]>, Colt Smith <[e-mail]>
Hi Scott,
Thank you for taking my phone call this morning. To follow up on the storage tank exception in order to approve the exception we will need to see that the water demands on your systemare less than what your well can produce. You can do this with metered water data or go through our demand calculations table in R309-510, Table 510-2.
Your well has a 35 gallon per minute or 50,400 gal per day safe yield (what we use to signify reliably what the well can produce). So long as the calculations come in under that we will be
able to grant your exception. It would also be a good idea to have access to a generator however we have not required this for similar exceptions.
Please submit your findings in a memo letter. Instructions for exception submittals can be found here: https://deq.utah.gov/drinking-water/exceptions-to-rule-requirements. The rulerequirement to cite is R309-510-8, Storage Sizing.
Let me know if you have follow up questions.
12/9/24, 6:03 PM State of Utah Mail - Re: Pending Violations #22022
https://mail.google.com/mail/u/0/?ik=82c167e5f1&view=pt&search=all&permthid=thread-f:1801666121172249658&simpl=msg-f:180166612117224965…4/5
Thanks!
Dani Zebelean, P.E.
Environmental Engineer III | Division of Drinking Water
M: [phone]
Hours: M - Th 7 am to 5 pm
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]
R309-510.pdf
111K
Scott McGee <[e-mail]>Wed, Nov 13, 2024 at 9:00 AM
To: Danielle Zebelean <[e-mail]>Cc: Jennifer Yee <[e-mail]>, Colt Smith <[e-mail]>
Hi Dani,
Thank you for the call and the information. Regarding R309-510, table 510-2, would it be best to use "Rooming House, per person"? or perhaps "Boarding Houses- Nonresident"? I'm notseeing anything more similar to campground operations. Would love your thoughts on this. Thanks.
[Quoted text hidden]
Danielle Zebelean <[e-mail]>Wed, Nov 13, 2024 at 10:30 AMTo: Scott McGee <[e-mail]>
Cc: Jennifer Yee <[e-mail]>, Colt Smith <[e-mail]>
My apologies Scott. Wrong table. Table 510-1 has the modern recreation campgrounds.
Dani Zebelean, P.E.
Environmental Engineer III | Division of Drinking Water
M: [phone]
Hours: M - Th 7 am to 5 pm
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]
Scott McGee <[e-mail]>Wed, Nov 13, 2024 at 10:32 AMTo: Danielle Zebelean <[e-mail]>
Cc: Jennifer Yee <[e-mail]>, Colt Smith <[e-mail]>
Thank you. I'll put together the data for calculating demand and will submit it to you all soon. I appreciate the assistance.
[Quoted text hidden]
12/9/24, 6:03 PM State of Utah Mail - Re: Pending Violations #22022
https://mail.google.com/mail/u/0/?ik=82c167e5f1&view=pt&search=all&permthid=thread-f:1801666121172249658&simpl=msg-f:180166612117224965…5/5