DDW-2024-014449

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
Department of
Environmental Quality

Alan Matheson
Executive Director

DIVISION OF DRINKING WATER
Marie E. Owens, P.E.
Director

GARY R. HERBERT
Governor

SPENCER J. COX
Lieutenant Governor
State of Utah

March 15, 2018

Randy Gene Larsen
Cove Waterworks Water System
1290 E 12600 North
Cove, Utah 84320

Subject: Atkins Spring (WS001) Under the Direct Influence of Surface Water (UDI); Cove
Waterworks, System #03006, File #11071

Dear Mr. Larsen:

The Division of Drinking Water (“the Division”) has determined that Atkins Spring (identified as
WS001 in the Division’s database) is under the direct influence of surface water (UDI). The
Division is designating the source as UDI based on these concerns:

• The Division records indicate that Cove Waterworks Water System has a history of total
coliform positive (TC+) samples. The water system does not have a chlorinator, and has
only one source supplying the distribution system and positive total coliform (TC+)
samples have been collected at the first connection and/or throughout the distribution
system in March 2002, June 2002, March 2004, April 2004, May 2004, June 2004, April
2005, May 2005, Oct 2006, May 2008, June 2008, July 2008, June 2009, July 2009, Oct
2010, April 2013, Oct 2013, April 2014, May 2014, June 2014, July 2014, Oct 2014, April
2016, Feb 2017, and March 2017). In addition, the system had a boil order June 2014 due
to positive E coli (EC+).

• 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:

1. There is an abundance of deep rooted vegetation growing within the spring
collection area. This physical evidence likely caused surface water to infiltrate the
spring collection piping and resulted in a conduit for surface water intrusion.
2. There is no evidence of the required spring liner. We have not found any records
indicating a liner was installed at the time of spring construction.
3. A 6-inch vertical PVC pipe with a screw on cap protrudes from the spring
collection area from an unknown depth. This pipe was installed by a private owner,
who has 16% water rights to the Atkins Spring, without plan approval from the
Randy Gene Larsen
Page 2 of 4
March 15, 2018

Division. The water system has no knowledge how the pipe was cut into the
collection area. This vertical pipe may create another path for surface water
intrusion.
4. Above the spring is a natural drainage channel, which is 6 to 8 feet deep in some
locations. This channel appears to direct all the run off from the mountains above
the spring, directly into the spring collection area.
5. Animal droppings were found on the spring collection area, which were likely from
deer. The spring collection area is only partially surrounded by a barbed wire fence
that is less the 50 feet from the collection area. The east and south side of the
collection area is adjacent to an animal grazing pasture, divided by a barbed wire
fence, where more animal droppings were found. The grazing pasture is uphill
from the spring collection area where potential surface water runoff is unimpeded
from flowing onto the collection area steeped with animal manure.

As of the date of this letter, Atkins Spring (WS001) is classified as being under the direct
influence (UDI) of surface water. For more details about this designation, what it means, and its
consequences see the attached UDI Definition and Possible Causes.

This water system is required to take the following actions within the following time frames due
to this drinking water source being classified as UDI and posing significant risks to public health.

Required Immediate Actions

You must take the following actions immediately:

1. Notify your water users per the attached public notice protocol.
2. Enact one of the following temporary measures (until a permanent solution is
implemented):

a. Turn the source out of the drinking water system.
b. Issue a boil order or supply bottled water to your customers.
c. Install and operate disinfection facilities to achieve 3-log inactivation of
Giardia lamblia per federal Surface Water Treatment Rule (40 CFR §141.72).

If this water system currently does not have the ability to achieve the treatment
goal of 3-log Giardia lamblia inactivation, this option would require submittal
of plans and specifications of a proposed disinfection facility to the Division for
review and approval. The design must be signed and stamped by a professional
engineer. The proposed design must identify the degree of disinfection in terms
of disinfection CT (Disinfectant Residual Concentration in ppm × Contact
Time in minutes) and inactivation log credit.

For example, to achieve 3-log inactivation of Giardia cysts at free chlorine
residual of 0.5 ppm, water pH of 7 and temperature at 0.5 oC, the required
Randy Gene Larsen
Page 3 of 4
March 15, 2018

disinfection CT is 210, which would require at least 420 minutes of contact
time. Such significant contact time sometimes cannot be achieved with a water
system’s existing configuration. In such case, a water system may need to make
costly modifications in order to achieve the required 3-log Giardia inactivation.
Please note that modifications to existing drinking water facilities also need to
go through the Division’s engineering review process. The implementation
time of this temporary option (Option c) may be similar to that of a permanent
solution.

Please contact Gary Kobzeff at [phone] for questions related to
technical assistance and engineering review.

Required Actions within 30 Days

Notify the Division in writing within 30 days of the date of this letter what your decisions
are regarding this water source.

If an acceptable course of action is not agreed upon by April 30, 2018, the Atkins Spring
will become an unapproved source of drinking water. Subsequently, this water system
would be assessed 200 deficiency points for using an unapproved source, and this water
system’s rating will become “Not Approved.”

If your decision is to continue using Atkins Spring (WS001) for drinking water, you will be
required to immediately comply with the following requirements:

1. Begin collecting water samples from this source prior to any treatment for E. coli
analysis. The E. coli sampling shall be done either once a month for two years or once
every two weeks for one year. A total of twenty four (24) E. coli samples are required
per the federal Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR).
These samples will be used to determine the bin classification of the source water and
the degree of required treatment for Cryptosporidium.
2. Take monthly bacteriological samples from a representative site in the distribution
system.
3. Take nitrate samples on a quarterly basis from this source.
4. Submit monthly disinfection reports to the Division.
5. You may also be required to monitor for disinfection by-products (DBPs). Please
contact Randi Ryan at [phone] or [e-mail] for DBPs questions.

Required Actions within 18 Months

Within 18 months of the date of this letter, you must implement one of the following
permanent solutions:

Randy Gene Larsen
Page 4 of 4
March 15, 2018

1. Abandon Atkins Spring (WS001) as a drinking water source permanently by
physically disconnecting it from your water system.
2. Have installed and be operating an approved surface water treatment facility that
successfully treats this source and meets the surface water treatment requirements.
3. Complete remediation of the source to eliminate the surface water influence. In some
cases, geological conditions might make it impossible to exclude surface water
influence and the expense of the remediation could be futile. We recommend that you
consult with a hydrogeologist first before pursuing this option.

Options 2 and 3 must go through the Division’s Plan Approval process including issuance of
an Operating Permit.

If this source’s UDI designation changes your water system’s monitoring requirement, the staff of
the Rules Sections will follow up to provide an updated monitoring schedule to you. Please
contact Rachael Cassady at [phone] or [e-mail] for questions related to
monitoring and reporting requirements for your water system.

We appreciate your immediate attention to this matter and your cooperation in protection public
health. Please notify the Division in writing, within 30 days of the date of this letter, what
your decisions are regarding this source. If you have questions or need further assistance
regarding this letter, please call Gary Kobzeff at (801)-536-0099 or Bernie Clark at (801) 536-
0092.

Sincerely,

Ying-Ying Macauley, P.E.
Engineering Manager/Assistant Director

GK/ym/hb

Enclosures ─ UDI Public Notice Template & UDI Definition and Possible Causes

cc: Grant Koford, Bear River Health Department, [e-mail]
Gary Kobzeff, Division of Drinking Water, [e-mail]
Division of Drinking Water UDI Team, [e-mail]
Rachael Cassady, Division of Drinking Water, [e-mail]
Emily Frary, Division of Drinking Water, [e-mail]
Randi Ryan, Division of Drinking Water, [e-mail]
Janet Lee, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]

DDW-2018-002225.docx

Instructions for Notice for a UDI Source as Tier 1

Template on Reverse

The Division of Drinking Water has designated a source used by this water system is under the direct influence
of surface water. Continued use of this source has a significant potential to have serious adverse effects on
human health as a result of short-term exposure (R309-220-5(1)(h):. In such cases, you must issue a notice
within the next 24 hours. You should also coordinate with your local health department. You must use one or
more of the following methods to deliver the notice to consumers (R309-220-5(3)):

Radio
Television
Hand or direct delivery
Posting in conspicuous locations

You may need to use additional methods (e.g., newspaper, delivery of multiple copies to hospitals, clinics, or
apartment buildings), since notice must be provided in a manner reasonably calculated to reach all persons
served. If you post or hand deliver, print your notice on letterhead, if you have it.

The notice on the reverse is appropriate for hand delivery or a newspaper notice. However, you may wish to
modify it before using it for a radio or TV notice or posting. If you modify the notice, you must leave the health
effects language in italics unchanged. This language is mandatory (R309-220-8(4)).

Population Served

Make sure it is clear who is served by your water system--you may need to list the areas you serve.

Corrective Action

In your notice, describe corrective actions you are taking. Listed below are some steps commonly taken by water
systems with a source determined to be under the influence of surface water. Use one or more of the following
actions, if appropriate, or develop your own:

We have taken the source which is under the direct influence of surface water out of service until
appropriate treatment can be installed.
We have abandoned the source which is under the direct influence of surface water.
We have installed and are operating disinfection facilities to achieve 3-log inactivation of Giardia lamblia.

Source of the Problem

If you know why the turbidity is high, explain it in your notice. For instance, unusual conditions, such as heavy
rains and flooding, can overburden the water plant, and treated water may therefore not meet the standards. In
addition, run-off from parts of the watershed could contain increased concentrations of sediment and animal
waste.

After Issuing the Notice

Send a copy of each type of notice and a certification that you have met public notice requirements to the
Division of Drinking Water (PO Box 144830, SLC, UT 84414-4830) within ten days after you issue the notice
(R309-105-16(3)). It is a good idea to issue a problem corrected notice when the violation is resolved.

It recommended that you notify health professionals in the area of the violation. People may call their doctors
with questions about how the violation may affect their health, and the doctors should have the information they
need to respond appropriately. In addition, health professionals, including dentists, use tap water during their
procedures and need to know of potential microbiological contamination so they can use bottled water.

DRINKING WATER WARNING

[system] has a source designated as Under the Direct Influence of Surface
Water

BOIL YOUR WATER BEFORE USING

The Division of Drinking Water has designated a source used by this water system is
under the direct influence of surface water. Continued use of this source has a
significant potential to have serious adverse effects on human health as a result of short-
term exposure. Because of the surface water influence to your source, there is an
increased chance that the water may contain disease-causing organisms.

What should I do?

$ DO NOT DRINK THE WATER WITHOUT BOILING IT FIRST. Bring all water to a boil, let it
boil for one minute, and let it cool before using, or use bottled water. Boiled or bottled water
should be used for drinking, making ice, washing dishes, brushing teeth, and food preparation
until further notice.

$ Sources under the direct influence of surface water may contain disease-causing organisms.
These organisms include bacteria, viruses, and parasites, which can cause symptoms such
as nausea, cramps, diarrhea, and associated headaches. People with severely compromised
immune systems, infants, and some elderly may be at increased risk. These people should
seek advice about drinking water from their health care providers.

$ The symptoms above are not caused only by organisms in drinking water. If you experience
any of these symptoms and they persist, you may want to seek medical advice.

What happened? What is being done?

[Describe the system future plan for the source, corrective action, and when the system expects
to return to compliance.]

We will inform you when you no longer need to boil your water.

For more information, please contact [name of contact] at [phone number] or [mailing
address]. General guidelines on ways to lessen the risk of infection by microbes are
available from the EPA Safe Drinking Water Hotline at 1(800) 426-4791.

Please share this information with all the other people who drink this water, especially
those who may not have received this notice directly (for example, people in
apartments, nursing homes, schools, and businesses). You can do this by posting
this notice in a public place or distributing copies by hand or mail.

This notice is being sent to you by [system].

Water System ID#: ___________. Date distributed: ___________.

UDI Definition and Possible Causes

A groundwater source that is Under the Direct Influence of surface water (UDI) is
vulnerable to contamination by pathogens found in surface water. This vulnerability could
be because the sub-surface formation is not sufficiently filtering water as the water
percolates through the formation or because the groundwater collection infrastructure is
poorly constructed and allows surface water to directly contaminate the groundwater.
The Division of Drinking Water’s protocol determines and classifies a groundwater
source as UDI based on one or more of the following factors:

1. Physical evidence of source deficiencies that allow, or have the potential to allow,
surface water contamination of the source
2. MPA sampling results indicating surface water influence:
a. One high-risk MPA sample result
b. Two consecutive moderate-risk MPA sample results
c. Inconclusive MPA sample results, such as alternating low-risk and
moderate-risk results, along with other water quality data or observations of
the source that indicate potential contamination by surface water
3. Water quality data indicating contamination by surface water, e.g., E. coli positive
source sample results not caused by physical deficiencies, detection of
Cryptosporidium or Giardia in the source water.

An MPA test (Item #2) consists of running the source water through a spiral-wound filter
for a period of the time. Particles collected by the filter are extracted in a laboratory,
examined under a microscope, and identified. Particles that are expected to be found
only above ground or in surface water indicate a risk of surface water contamination.
Such indicators include chlorophyll-bearing algae, parts of flying insects, plant debris,
Cryptosporidium, Giardia lamblia, etc. Some of these indicators are not pathogens, but
their presence in the source water means it is susceptible to contamination by pathogens
found in surface water.

An MPA sample is rated as having a low, moderate, or high risk of UDI if the score is 0-9,
10–19, or 20 and above, respectively. When basing the classification of a groundwater
source on MPA results, the Division protocol classifies a source as UDI if any MPA
sample is high risk or if any two MPA samples are moderate risk or above.

The path that surface water takes as it flows to a groundwater source can and usually
does vary with season and hydrogeological conditions. It is common for the flow path to
be directly influenced by surface water under some conditions (such as during a high
surface runoff during spring), but not to be directly influenced under others. So, a
surface-water-influenced water source may have MPA sample results of various risk
levels, depending on the timing of the sampling. A true groundwater source that is not
under the direct influence of surface water will always have only low-risk MPA results.