DDW-2024-014448

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Interim Executive Director

DIVISION OF DRINKING WATER
Ying-Ying Macauley, P.E.
Interim Director

February 3, 2021

Randy Larsen
Cove Waterworks
1290 E 12600 N
Cove, UT 84320

Subject: Temporary Operating Permit, Atkinson Spring (WS001) Rehabilitation and Replacement
Water Line; Temporary Exception to R309-515-7(7)(e), Spring Fencing (WS001); Cove
Waterworks, System #03006, File #11071 & #12085

The Temporary Operating Permit and Temporary Exception both expire on July 31, 2024.

Dear Mr. Larsen:

The Division of Drinking Water (the Division) received your request for an Operating Permit for the
Atkinson Spring Rehabilitation Project (File #11071) and the Replacement Water Line (File #12085) from
your consultant, Chad Brown, P.E., Franson Civil, on June 11, 2020, and January 6, 2021, respectively.
Previously, the Division determined that Atkinson Spring (identified as WS001 in the Division’s database)
was under the direct influence of surface water (UDI) on March 15, 2018, The Division records indicated
that the Cove Waterworks Water System had a history of total coliform positive (TC+) samples. The
Division staff conducted onsite inspections of this spring on March 21, 2017, and January 4, 2018, and
observed several significant physical deficiencies of this spring. A final inspection was conducted by
Division staff, Dani Zebelean, on January 14, 2021.

Our understanding of these two projects is summarized below:

1. Atkinson Spring Rehabilitation (File #11071)
a. This project was the redevelopment of the existing spring collection system.
b. It consisted of clearing the existing spring collection area of overgrown trees and vegetation,
the installation of a new collection system of perforated and non-perforated PVC pipe, gravel
bedding, geomembrane liner, clay cutoff wall, and collection manholes as shown in the design
drawings. The project also included the installation of a new stock tight fence around the
Atkinson Spring.
c. The Division issued Plan Approval for this project on January 30, 2020.

2. Replacement Water Line (File #12085)
a. This project consists of approximately 2,767 feet (DR 32.5) and 5,241 feet (DR 18) of 4-inch
diameter PVC water line, four (4) air vacuum valve stations, one (1) blow off assembly, and
replacement service connections were installed from the spring collection area to the existing
Randy Larsen
Page 2 of 4
February 3, 2021

concrete storage tank downstream of the spring collection zone.
b. The Division issued Plan approval for this project on April 23, 2020.

Temporary Exception to R309-515-7(7)(e), Spring Fencing (WS001)

On May 18, 2020, the Division of Drinking Water (the Division) received your request for an exception to
Rule R309-515-7(7)(e), Spring Fencing for Atkinson Spring (WS001). This rule states “The spring
collection area shall be surrounded by a fence located a distance of 50 feet (preferably 100 feet if
conditions allow) from all collection devices on land at an elevation equal to or higher than the collection
device, and a distance of 15 feet from all collection devices on land at an elevation lower than the
collection device.”

The basis for your request for an exception to R309-515-7(7)(e), Spring Fencing is as follows. One
property owner was resistant to allowing for the required fencing (at the 50-foot distance specified per the
rule) to be installed on his property. Repeated and continuous negotiations over several months between
the water system and the property owner concluded with a compromise for the location of the fence
boundary, which is to surround the spring redevelopment property 25 feet North, 30 feet East of the
northern collection manhole, and 18 feet South and East of the Southern Collection manhole. The property
bordering the fence is not used for agriculture and the owner does not apply any fertilizer to the area.

On this basis, the temporary exception to R309-515-7(7)(e), Spring Fencing is hereby granted for the
Atkinson Spring (WS001) redevelopment subject to the following restrictions:

1. This Temporary Exception expires on July 31, 2024.

2. You are required to re-submit an exception request along with confirmation that all conditions
outlined in this temporary exception have been fulfilled and obtain an exception renewal prior to
July 31, 2024.

a. Temporary exceptions granted by the Division include an expiration date to ensure that the
basis and conditions for granting the exception are verified periodically and that the
drinking water quality remains protected. After receiving your request, the Division will
determine whether this exception can be re-issued.

b. Failure to request the re-evaluation of this exception and obtain an exception renewal by
July 31, 2024, will result in the activation of the deficiency related to not having spring
fencing that does not meet the rule.

3. This Temporary Exception may be rescinded any time if new evidence indicates that the
conditions of this exception are no longer being met or a public health risk exists due to this
exception.

The issuance of this exception temporarily resolves your water system’s deficiency related to SS02. An
updated IPS report is available at https://waterlink.utah.gov. Please contact Jennifer Yee at
[phone] or [e-mail] for questions related to your water system’s IPS report or deficiencies.

Temporary Operating Permit for Atkinson Spring Rehabilitation (File #11071) and Replacement
Water Line Project (File #12085)

Randy Larsen
Page 3 of 4
February 3, 2021

We have received the following information for the Atkinson Spring (WS001) Redevelopment and the
Replacement Water Line Projects:

1. Design engineer’s statement of conformance with approval conditions.
2. Record drawings
3. Satisfactory bacteriological results as evidence of proper disinfection and flushing.
4. New source chemical analysis data has been submitted to the Division for review. No new
treatment is required.
5. The Division protocol requires two consecutive low-risk Microscopic Particulate Analysis (MPA)
samples following redevelopment for this source to be considered not UDI.

We have determined that the conditions of issuing a Temporary Operating Permit have been accomplished.
On this basis, a Temporary Operating Permit for the Atkinson Spring (WS001) Rehabilitation (File
#11071) and Replacement Water Line Project (File #12085) is hereby issued contingent upon your
compliance with all of the following conditions:

1. This Temporary Operating Permit expires on July 31, 2024.

2. Cove Waterworks 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.

a. 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 the Atkinson Spring
(WS001) can serve.

3. Cove Waterworks 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 Atkinson Spring (WS001) and Replacement Water Line by July 31, 2024.

a. The spring flow data submission requirement has been added to the Division’s database as
a tracking tool and reminder.
b. 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 Atkinson
Spring (WS001) and Replacement Water Line by July 31, 2024.

4. Schedule the Microscopic Particulate Analysis (MPA) sampling in the 2021 and 2022 spring
seasons that represent high surface water runoff condition.
a. Since Atkinson Spring (WS001) was declared UDI, two consecutive low-risk Microscopic
Particulate Analysis (MPA) samples following redevelopment are required for this source
to not be considered UDI.
b. The MPA sampling needs to be performed during high flows, two years in a row, to
evaluate whether this spring redevelopment project is successful in eliminating surface
water influence.
c. Please contact Brian Pattee at [phone] or [e-mail] to schedule the MPA
sampling.

Randy Larsen
Page 4 of 4
February 3, 2021

Drinking Water Source Protection Requirement

A revised Drinking Water Source Protection (DWSP) plan must be submitted to the Division within
180 days after the reconstruction or redevelopment of any ground-water source of drinking
water (refer to R306-600-7(2)(f)). The revised plan must address changes in source construction, source
development, hydrogeology, delineation, potential contamination sources, and proposed land management
strategies, as applicable. If redevelopment of the spring(s) did not result in changes that would affect
delineation of the source protection zones, such as increased flow, then send an email to Deidre Beck
at [e-mail] or submit a letter to the Division stating that the zones have not changed as a result of
the redevelopment. The revised plan must be submitted to the Division within 180 days of the date of
this letter.

In addition, please be aware that a surface water DWSP plan may be required if the source does not
receive two consecutive low-risk MPA samples as the source will be considered UDI and the
requirements under R309-600-3(3) and R309-605-8 will apply. If you have questions about the source
protection requirements contact the source protection staff at [phone].

If you have any questions regarding this letter, please contact Dani Zebelean, of this office, at (385) 278-
5110, or Michael Newberry, Engineering Manager, at [phone].

Sincerely,

Ying-Ying Macauley, P.E.
Interim Director

DZ/DLB/mrn/as/mdb
cc: Grant Koford, Environmental Health Director, Bear River Health Department, [e-mail]
Randy Larsen, Cove Waterworks, [e-mail]
Chad H. Brown, P.E., Franson Civil Engineers, [e-mail]
Dani Zebelean, Division of Drinking Water, [e-mail]
Michael Newberry, P.E., Division of Drinking Water, [e-mail]
Nathan Lunstad, P.E., Division of Drinking Water, [e-mail]
Brian Pattee, Division of Drinking Water, [e-mail]
Division of Drinking Water UDI Team, [e-mail]
Emily Frary, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Colt Smith, Division of Drinking Water, [e-mail]
Brandi Smith, Division of Drinking Water, [e-mail]
Nagendra Dev, Division of Drinking Water, [e-mail]
Deidre Beck, Division of Drinking Water, [e-mail]

DDW-2021-000547