HomeMy WebLinkAboutDDW-2024-014166
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-4830
Telephone (801) 536-4200 • Fax (801) 536-4211 • T.D.D. (801) 536-4284
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, Ph.D., P.E.
Director
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
September 20, 2024
Cedar City Corporation
℅ Randall McUne, City Attorney
10 North Main Street
Cedar City, UT 84720
Subject: Stipulated Order to Disinfect Cedar City Waterworks UTAH110002
Dear Randall McUne:
We are writing to provide you, on behalf of Cedar City Corporation, with a draft of the Division’s
proposed Stipulated Order to Disinfect (SOTD) that addresses the drinking water compliance
issues currently affecting the Cedar City Waterworks (System).
The SOTD includes milestones the Supplier responsible for the System must meet to comply with
the applicable regulations. It also references stipulated penalties that will be assessed if the System
does not meet the requirements and/or the deadlines. The SOTD is broken down into the following
key sections:
STATUTORY AND REGULATORY AUTHORITY: This section describes the basis for
the authority of the Director of the Division of Drinking Water to issue the SOTD.
FINDINGS: This section provides basic background information about the System,
including its inventory and legal ownership. It also briefly explains the facts underlying the
Director’s decision to require disinfection.
ORDER: The Order Section states requirements for the System and incorporates the
Stipulated Order to Disinfect Schedule as part of the Order.
GENERAL PROVISIONS: This section outlines conditions agreed to by the System and
the Division of Drinking Water, including potential penalties and system ratings.
COMPLIANCE NOTICE: This section states that compliance with this order is mandatory
and falls under the authority of the Utah Safe Drinking Water Act.
Please carefully review the enclosed SOTD. If it is acceptable, it should be signed by an authorized
person and returned to the Director. Once the Director issues the SOTD, a copy will be returned for
Cedar City Waterworks
Page 2 of 2
September 20, 2024
your records. The effective date is the date of issuance by the Director. Failure to return a signed
copy within 30 days of this letter may result in a unilateral administrative order issued by the
Director to ensure progress toward compliance.
I encourage you to continue to work closely with our Division staff. Your primary contact is Sarah
Page at sepage@utah.gov or 385-272-5778.
Sincerely,
Nathan Lunstad Ph.D., P.E.
Director
Division of Drinking Water
cc: Kim Shelley, Utah Department of Environmental Quality, kshelley@utah.gov
Paul Wright, P.E., Utah Department of Environmental Quality, pwright@utah.gov
Jeremy Roberts, Southwest Utah Health Department, jroberts@swuhealth.org
Bret Randall, Utah Attorney General’s Office. bfrandall@agutah.gov-or-
David McKnight, Utah Attorney General’s Office. dmcknight@agutah.gov
Christopher Brown, Environmental Protection Agency-Region 8, brown.christopher.t@epa.gov
Robbie Dean Mitchell, Cedar City Waterworks, mrobbie@cedarcity.org
EQDWMonitoring, EQDWCOA, EQDWVSA, and EQDWFS
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF DRINKING WATER
In the Matter of:
Cedar City Corporation Public Water
System
Stipulated Order to Disinfect
Docket No.UTAH11002-2024001
This Stipulated Order to Disinfect (“SOTD”)has been issued by the Director of the Utah
Division of Drinking Water (“Director”),under the Director’s legal authorities described below.
This SOTD has been agreed to by Cedar City Corporation,a Utah municipal corporation,in its
capacity as the “Supplier”who is legally responsible for the System.
STATUTORY AND REGULATORY AUTHORITY
1.In 1974,Congress enacted the federal Safe Drinking Water Act,codified at 42 U.S.C.§
300f et seq.,as amended.42 U.S.C.§ 300g-2 allows states to achieve primary enforcement
responsibility after the Environmental Protection Agency (“EPA”)has determined that the
state has adopted and can implement a state program that is no less stringent than the
federal public drinking water program (“Primacy”).
2.The Utah legislature has enacted the Utah Safe Drinking Water Act,codified at Utah Code
§19-4-101 (the “Act”),with the intent of achieving Primacy.
3.Utah Code §19-4-104 authorizes the Utah Drinking Water Board (the “Board”),among
other things,to make rules regulating public water systems in the state of Utah.Utah Code
§19-4-104(1)(c)(vi)charges the Board to “meet the requirements of federal law related or
pertaining to drinking water.”The Board has promulgated the Utah Public Drinking Water
Rules,codified at Utah Administrative Code (“UAC”)R309.
4.In 1980,the EPA Administrator determined,in accordance with 40 C.F.R.§142.11,that
the Utah public drinking water program met the federal requirements for Primacy.See 45
Fed.Reg.6647 (January 29,1980).In accordance with 40 C.F.R.§142.17,the EPA
Administrator has reviewed and continues to review annually,the Utah public drinking
water program to evaluate its continuing compliance with the requirements set forth in 40
C.F.R.Part 142.
5.The Board has defined public water systems under the Utah Public Drinking Water Rules,
UAC R309-110-4.
6.UAC R309-100-7 directs the Director to “assign a rating to each public water supply in
order to provide a concise indication of its condition and performance”in accordance with
R309-400.This rule is generally known as the Improvement Priority System (“IPS”)rating
system.
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7.The IPS rating system “is a point system used by the division to evaluate a public water
system’s performance and compliance with the drinking water rules in Title 309,
Environmental Quality,Drinking Water.”UAC R309-400-3(1).Under the IPS rating
system,each public water system is assigned a rating “to characterize the water system’s
compliance with drinking water rules and overall operation and performance.”UAC
R309-400-3(2).The IPS rating system is used by the Division to assign compliance ratings
to public water systems and to prioritize enforcement action based on points assessed for
noncompliance with drinking water rules.”UAC R309-400-1(1).
8.UAC R309-400-4(1)(a)(ii)directs the Director to establish “the point thresholds for
assigning an Approved or Not Approved rating for each type of water system.”The
Director may issue a “Not Approved”rating for systems exceeding the point threshold.
The thresholds are as follows:(i)for community water systems,150 points;(ii)for
non-transient,non-community water systems,120 points;and (iii)for non-community
water systems,100 points.
9.UAC R309-400-4(4)allows the Director to assess points against public water systems
upon their failure to comply with Division directives and orders.
10.UAC R309-400-5(1)(b)(ii)allows the Director to rate any public water system as “Not
Approved”at any time if an immediate threat to public health exists.
11.UAC R309-400-5(1)(c)provides that a public water system may qualify for a “Corrective
Action”rating for its public water system “based on a current,written agreement with the
division to resolve underlying noncompliance according to a compliance schedule.”
12.Pursuant to Utah Code §19-4-106(d),the Director may enforce rules promulgated by the
Board by issuing orders.See also UAC R309-100-8.
13.Utah Code §19-4-107 provides that upon discovery of any violation of the Act or a rule of
the Board,the Director shall promptly notify the supplier of the violation,state the nature
of the violation and issue an order requiring correction of that violation.
14.Utah Code §19-4-109 provides that any person who violates the Act or a rule or order
made or issued pursuant to the Act may be subject to an administrative penalty of up to
$1,000 per day of violation or a civil penalty of up to $5,000 per day of violation.
FINDINGS
The Director makes the following Findings for purposes of this SOTD:
15.There exists a drinking water system in Iron County,Utah,known as Cedar City
Waterworks (the “System”)that serves a population of approximately 37,760 persons.The
System generally includes eight active wells,one proposed well,four springs,three active
pump stations,one proposed pump station,twelve ten active storage tanks,two proposed
storage tanks,four chlorinators,and an independent distribution system supplying
approximately 10,139 service connections.
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16.The Supplier (defined above)is the owner and/or operator of the System and is therefore
legally responsible for the System and for compliance with applicable laws,rules,and
regulations.
17.The System is a public drinking water system within the meaning of the Utah Safe
Drinking Water Act and the Utah Public Drinking Water Rules.
18.The System qualifies as a community under the Utah Public Drinking Water Rules.The
maximum number of IPS points allowed for this type of system is 150.
19.The Master IPS Report attached hereto as Exhibit A describes several violations and
deficiencies associated with the System,which form the basis of this SOTD (the
“Violations and Deficiencies”).Supplier agrees and stipulates that the information
contained in the attached IPS Report is true and correct as of the date shown on the Master
IPS Report.
20.In August 2021 and June,July,August,and November 2022,Cedar City Waterworks had
several total coliform positive sample results,triggering five Level 2 Assessments.
21.Cedar City Waterworks does not reliably meet bacteriological standards in the distribution
system.Based on your sample history,Cedar City Waterworks is required to provide
continuous secondary disinfection throughout the distribution system.These requirements
were initially detailed in a letter from the Director dated January 31,2023.Cedar City
Waterworks may be subject to additional treatment requirements if water quality sampling
results indicate any of the water system’s sources require primary disinfection.
22.In August of 2024,a total of six samples were taken at Shurtz Canyon Spring (WS001),
four samples were total coliform present and E.coli absent.The other two samples were
total coliform present and E.coli present.With confirmed E.coli primary disinfection is
required at Shurtz Canyon Spring (WS001).
ORDER
Based on the foregoing Findings,the agreement of the Supplier,and good cause appearing,IT IS
HEREBY ORDERED as follows:
23.Attached hereto as the Enforcement Order Schedule –UTAH11002 (“Stipulated Order to
Disinfect Schedule”)listing the violations and deficiencies associated with the System as
well as a description of specific corrective actions and other measures that are required for
the System to comply with the Safe Drinking Water Act and the Board’s rules,including
the dates by which such corrective actions and other measures shall be completed.The
Supplier is hereby ordered to complete all corrective actions and other measures described
in the Stipulated Order to Disinfect Schedule,to the satisfaction of the Director,on or
before the due dates identified in the Stipulated Order to Disinfect Schedule.
24.The Supplier agrees to collect all samples required by the Safe Drinking Water Act and the
Board’s rules and to report the sample results to the Director within the timeframe
mandated by the rule.
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25.Within 60 days after the issuance of this Order,the Supplier shall provide the Division of
Drinking Water with a schedule for the System to address the requirements for secondary
disinfection throughout the entire distribution system.The plan shall include proposed
modifications to the System,estimated costs of modifications,a proposed plan,and a
schedule for project completion.The plan shall also include specific milestone dates and a
final compliance date (to be within six months from the date of DDW approval of the
plan).The Director must approve the schedule before construction or modifications can
begin.
26.Within 60 days after the issuance of this Order,the Supplier shall provide the Division of
Drinking Water with a schedule for the System to address the requirements for primary
disinfection for the Shurtz Canyon Spring (WS001).The plan shall include proposed
modifications to the System,estimated costs of modifications,a proposed plan,and a
schedule for project completion.The plan shall also include specific milestone dates and a
final compliance date (to be within six months from the date of DDW approval of the
plan).The Director must approve the schedule before construction or modifications can
begin.
27.The Supplier agrees to send all reporting and notifications required by this Order in
writing to:
Utah Division of Drinking Water
P.O.Box 144830
Salt Lake City,Utah
84114-4830
Email:eqdwvsa@utah.gov
28.The Distribution System (DS001)is hereby rated “Unapproved”as outlined in
R309-515-6(5),R309-515-7(4),R309-500-9(2)and (3).This is a Significant Deficiency
(S100),and 200 Improvement Priority System points were assessed.
29.The Shurtz Canyon Spring (WS001)is hereby rated “Unapproved”as outlined in
R309-515-6(5),R309-515-7(4),R309-500-9(2),and (3).This is a Significant Deficiency
(S100),and 200 Improvement Priority System points were assessed.
30.The Supplier agrees to install and operate Division-approved permanent disinfection for
the entire distribution system (DS001).The Supplier agrees to complete Division Plan
Approval prior to construction of any disinfection facilities.
31.The Supplier agrees to install and operate Division-approved permanent primary
disinfection for the Shurtz Canyon Spring (WS001).The Supplier agrees to complete
Division Plan Approval prior to construction of any disinfection facilities.
Primary Disinfection Requirements
32.To meet primary disinfection requirements,the Supplier agrees to continuously
maintain a minimum of 0.2 mg/L free chlorine residual at the Point(s)of Entry
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(POE)into the distribution system,continuously demonstrate a CT that achieves
4-log inactivation for viruses at the POE for the Shurtz Canyon Chlorinator
(TP001),demonstrate a detectable chlorine residual in the entire distribution
system,and comply with associated reporting requirements.
33.The Supplier agrees to a Microscopic Particulate Analysis (MPA)test for the Shurtz
Canyon Spring (WS001)taken by an approved Division of Drinking Water representative
following Division-approved MPA protocols.This test will be completed by July 1,2025.
(a)This testing is essential to determine whether the source may be considered
Groundwater Under the Direct Influence of Surface Water (UDI).The MPA
test results will help assess the source's quality and determine whether
primary disinfection is necessary to protect public health.
(b)If needed,the Supplier agrees to subsequent MPA samples at the Shurtz
Canyon Spring (WS001)consistent with the Division of Drinking Water
Vulnerable Source Assessment (VSA)Policy (attached).
34.Chlorine Residual ‒Point(s)of Entry (POE)to Distribution System (EP001)
(a)The Supplier agrees to submit a POE sample location to the Division for
Shurtz Canyon Spring (WS001).
(i)The POE sampling location will be identified as EP001 in the
Division’s database.
(b)Maintain a minimum of 0.2 mg/L residual (measured as free chlorine)at the
POE sampling location.[UAC R309-215-16(3)(b)(iii)(A)(I)and (II)].
(c)The chlorine residual concentration measured at the POE sampling location
shall not exceed the Maximum Residual Disinfectant Level (MRDL)of 4.0
mg/L (measured as free chlorine).[R309-200-5(3)(c)(iv)].
(d)Record and report the lowest daily chlorine residual concentration,
measured as free chlorine,at the chlorinator POE sampling location
(EP001)a minimum of daily.[R309-210-8(3)(a)(ii)]
(i)Our records show that your water system serves XXX people.Be
aware that R309-215-16(3)(b)(iii)(A)(I)requires water systems
serving greater than 3,300 people to continuously monitor the POE
chlorine residuals.Therefore,an online analyzer to continuously
monitor the POE chlorine residuals entering the distribution system
is needed.
35.Primary Disinfection and Reporting Requirements
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(a)The water system must operate a treatment facility capable of providing
sufficient disinfection CT to achieve 4-log10 virus inactivation of the water
from the Shurtz Canyon Chlorinator (TP001).[R309-215-16(1)(a)(iii);
R309-520-6(4)(c)]
(b)The water system must demonstrate sufficient disinfection CT by
monitoring and reporting the actual CT achieved during operation using a
monitoring sheet provided by the Division (Monthly Report for Primary
Disinfection Compliance].The monitoring and reporting will include
chlorine residuals measured at the POE to the distribution system and other
parameters for calculating CT.[R309-520-6(4);R309-215-16(3)(b)(iii)(A)]
(c)The water system must submit Primary Disinfection Reports monthly.The
reports are due to the Division by the 10th day following the end of each
reporting month.[R309-215-10]
36.Chlorine Residual ‒Distribution System (DS001)
(a)This water system must maintain a detectable residual throughout the entire
distribution system.Maintaining the chlorine residual above 0.1 ppm in the
distribution system is recommended.[R309-520-5]
(b)The chlorine residual measured in the distribution system shall not exceed
the maximum residual disinfectant level (MRDL)of 4.0 mg/L (measured as
free chlorine).[R309-200-5(3)(c)(iv)]
(c)Take a minimum of three (3)chlorine residual samples per week at varying
locations throughout its distribution system.[UAC R309-105-10(1)(c)]
(d)Distribution system chlorine residuals must be taken in conjunction with
total coliform sampling.[R309-215-10(3)]
Secondary Disinfection Requirements
37.To meet secondary disinfection requirements,the Supplier agrees to continuously
maintain a minimum of 0.2 mg/L free chlorine residual at the Points of Entry (POE)
into the distribution system and demonstrate a detectable chlorine residual in the
entire distribution system.
38.Chlorine Residual ‒Points of Entry (POE)to Distribution System
a.The POE sampling locations for each of the system’s chlorinators will be identified
in the Division’s database.These specific locations shall be provided to the
Division by the system.
b.Maintain a minimum of 0.2 mg/L residual (measured as free chlorine)at the POE
sampling locations.[UAC R309-215-16(3)(b)(iii)(A)(I)and (II)]
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c.The chlorine residual concentration measured at the POE sampling locations shall
not exceed the Maximum Residual Disinfectant Level (MRDL)of 4.0 mg/L
(measured as free chlorine).[UAC R309-200-5(3)(c)(iv)]
d.Record and report the lowest daily chlorine residual concentration,measured as
free chlorine,at the chlorinator POE sampling locations a minimum of daily.
[R309-215-10(1)]
o Our records show that your water system serves 37,760 people.Please
be aware that R309-215-16(3)(b)(iii)(A)(I)requires water systems
serving greater than 3,300 people to continuously monitor the POE
chlorine residuals.Therefore,an online analyzer to continuously
monitor the POE chlorine residuals entering the distribution system will
be needed at each chlorinator.
39.Chlorine Residual ‒Distribution System (DS001)
a.This water system must maintain a detectable residual throughout the entire
distribution system.Maintaining the chlorine residual above 0.1 ppm in the
distribution system is recommended.[R309-520-5]
b.The chlorine residual measured in the distribution system shall not exceed the
maximum residual disinfectant level (MRDL)of 4.0 mg/L (measured as free
chlorine).[R309-200-5(3)(c)(iv)]
c.Take a minimum of three (3)chlorine residual samples per week at varying
locations throughout its distribution system UAC R309-105-10(1)(c).
d.Distribution system chlorine residuals must be taken in conjunction with total
coliform sampling.[R309-215-10(3)]
40.The Supplier must notify the Division by telephone at (801)560-8456 within eight
hours of the malfunction of any disinfection facility such that a detectable residual
cannot be maintained at all points in the distribution system per R309-105-18(1)(a).
GENERAL PROVISIONS
41.Based on this,the Director hereby determines that the System maintains its rating as
“Approved”status.The “Approved”rating is conditioned upon the Supplier’s adherence to
the requirements of this SOTD,the Act,and the Public Drinking Water Rules.The
Director may re-rate the System as “Not Approved”at any time based on any violation of
this SOTD,the Act,or the Public Drinking Water Rules.
42.Upon satisfactory compliance with the Stipulated Order to Disinfect Schedule
requirements,the Director shall issue a subsequent administrative order closing out this
SOTD as defined in UAC R309-400.Pursuant to such subsequent order,the Director may
also take other appropriate actions or impose appropriate conditions based on the facts
presented.
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43.The Supplier hereby stipulates and agrees to pay,within 30 days of demand by the
Director,administrative penalties in the following amounts arising from any and all
violations of this SOTD,on a per-day,per-violation basis:
Penalty Per Violation Per Day Period of Noncompliance
$250 1st through 14th day
$500 15th through 30th day
$1,000 31st day and beyond
44.In the event of any violation of this SOTD with criminal negligence,within the meaning of
Utah Code §19-4-109(7)(b),the Director reserves the right,in the Director’s sole
discretion,to seek the imposition of fines and civil penalties under that section in addition
to stipulated administrative penalties under this SOTD.
45.Nothing in this SOTD shall be construed as prohibiting,altering,or in any way limiting
the ability of the Director to seek injunctive relief pursuant to Utah Code §19-4-107(2)
arising from violations of this SOTD,the Act,or the Utah Public Drinking Water Rules.
46.This SOTD does not in any way relieve the Supplier from any other obligation imposed
under the Act or any other state,federal,or local law,rule,or regulation.The Director
reserves that this SOTD is without prejudice to all rights against the Supplier that the
Director may have pertaining to matters not addressed in this SOTD,including (a)
violations of this SOTD;(b)future violations of the Act or the Utah Public Drinking Water
Rules;and (c)criminal liability.
47.The Director has the jurisdiction and authority to make the findings set forth in this SOTD
and to otherwise enforce the terms of this SOTD.
48.The date of issuance shall be the date that this SOTD is executed by the Director.
49.As of the date of issuance,this SOTD shall constitute a final administrative order under
the Act and shall operate as a final adjudication upon the merits of the matters addressed
herein.In the Director’s sole discretion,violations of this SOTD may result in the
commencement of an action for civil enforcement in state district court,by the attorney
general,as provided in Utah Code Section 19-4-107.Such actions may seek injunctive or
other relief,including the imposition and collection of civil penalties as allowed by law.
The Supplier agrees that in any enforcement action,it shall not contest the finality or
validity of this SOTD or the Director’s authority to enter it as a final administrative order
under the Act.
50.The dates set forth in the Stipulated Order to Disinfect Schedule may be extended in
writing by the Director,in the Director’s sole discretion,based on the Supplier’s showing
of good cause.Good cause for an extension generally means events outside of the
reasonable control of the Supplier,such as force majeure,inclement weather,contractor or
supplier delays,and similar circumstances.However,the Director expects the Supplier to
employ reasonable means to limit foreseeable causes of delay.The timeliness of the
Supplier’s request for an extension shall constitute an important factor in the Director’s
evaluation.
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51.In partial or full satisfaction of the Stipulated Order to Disinfect Schedule,the Supplier
may (a)obtain a variance or exception as allowed by the Act and the Public Drinking
Water Rules;or (b)propose to the Director an alternate method for compliance with the
Act and the Public Drinking Water Rules.No such alternate means of compliance with the
Enforcement Order Schedule shall be accepted unless approved by the Director in writing.
52.The person signing this SOTD on behalf of the Supplier hereby represents to the Director
that he or she has the full legal authorization to do so and agrees that the Director may rely
on this representation.
COMPLIANCE NOTICE
Compliance with the provisions of this SOTD is mandatory.All violations of the Utah Safe
Drinking Water Act,the Drinking Water Rules,and this SOTD shall be strictly enforced during
the time that this SOTD remains in effect.
IT IS SO ORDERED AND AGREED.
DIVISION OF DRINKING WATER
By:___________________________________
Nathan Lunstad Ph.D.,P.E.
Director
DATE:________________________________
CEDAR CITY CORPORATION
By:___________________________________
Name:_________________________________
Title:__________________________________
DATE:_________________________________
9
Garth O. Green (Nov 12, 2024 14:10 MST)
Garth O. Green
Garth O. Green
Mayor
11/12/2024
Nathan
0n.ta (Nov 1т, 2024 10:тх MST)
11/13/2024
Stipulated Order to Disinfect Schedule UTAH11002
System Name:Cedar City Waterworks
System Number:UTAH11002
Administrative Contact:Robbie Dean Mitchell
Email:mrobbie@cedarcity.org
Phone Number:435-233-0067
Corrective Action Requirements and Due Dates
Date of Issuance:_____________________
Distribution System,DS001
Item #1 Code Facility Deficiency Rule Citation
S001 DS001 Unapproved Source In Service R309-515-6(5),R309-515-7(4),
R309-500-9(2)and (3)
Corrective Action Completion Due Date
Submit documentation of the plan to install secondary
disinfection as required in 25 of this Order.
Within 60 days of the Date of
Issuance of this Order.
Shurtz Canyon Spring,WS001
Item #2 Code Facility Deficiency Rule Citation
S001 WS001 Unapproved Source In Service R309-515-6(5),R309-515-7(4),
R309-500-9(2)and (3)
Corrective Action Completion Due Date
Submit documentation of the plan to install primary
disinfection for the Shurtz Canyon Spring (WS001)as
required in 26 of this Order.
Within 60 days of the Date of
Issuance of this Order.
Item #3 Code Facility Deficiency Rule Citation
S001 WS001 Unapproved Source In Service R309-515-6(5),R309-515-7(4),
R309-500-9(2)and (3)
Corrective Action Completion Due Date
Microscopic Particulate Analysis (MPA)test will be
conducted for the Shurtz Canyon Spring (WS001)as required
in item 33 of this order.
By July 1,2025
1
11/13/2024
Item #4 Code Facility Deficiency Rule Citation
S001 WS001 Unapproved Source In Service R309-515-6(5),R309-515-7(4),
R309-500-9(2)and (3)
Corrective Action Completion Due Date
Submit a Point of Entry Point (POE)sample location for the
Shurtz Canyon Spring (WS001)as required in item 34(a)of
this Order.
Within 60 days of the Date of
Issuance of this Order.
IT IS SO ORDERED AND AGREED.
DIVISION OF DRINKING WATER
By:_____________________________________
Nathan Lunstad P.E.
Director
DATE:__________________________________
CEDAR CITY CORPORATION
By:______________________________________
Name:____________________________________
Title:_____________________________________
DATE:___________________________________
2
Garth O. Green (Nov 12, 2024 14:10 MST)
Garth O. Green
Garth O. Green
Mayor
11/12/2024
Nathan
0n.ta (Nov 1т, 2024 10:тх MST)
11/13/2024