DDW-2025-000241

Deidre Beck <[e-mail]>
11099-WS001-PER
17 messages
Bryce Ross <[e-mail]>Wed, Oct 23, 2024 at 11:03 AM
To: Deidre Beck <[e-mail]>
Cc: Curtis Nielson <[e-mail]>
Hey Deidre,

Please see the attached PER for the Foothills Water System. If you have any questions, don’t hesitate to reach out anytime.
I appreciate your time & effort.
Sincerely,
Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient, please
destroy it.

11099-WS001-PER.pdf
2154K
Deidre Beck <[e-mail]>Wed, Oct 23, 2024 at 1:18 PM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>, "J. Paul Wright" <[e-mail]>, Mellissa Noble <[e-mail]>, Noah
Zorsky <[e-mail]>
Received, thank you. I have logged this after-the-fact PER into our queue for review. Source protection staff will reach out with any
questions.
I will ask Jennifer Yee to remove the SP06 deficiency once we can concur with the PER.
[Quoted text hidden]
--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…1/19
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
image001.png
10K
Deidre Beck <[e-mail]>Wed, Nov 6, 2024 at 9:27 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>, "J. Paul Wright" <[e-mail]>, Mellissa Noble <[e-mail]>, Noah
Zorsky <[e-mail]>
Hello,
I have reviewed the PER submitted for this source; however, before the Division can concur, the following items must be
addressed:
Section 2.0 - Delineation Report
It doesn't appear that the hydraulic gradient or direction of groundwater flow were calculated correctly. Using the methodology
explained in the attached document and the well logs for the wells illustrated on the "Water Rights Map" in the appendix, the
gradient appears steeper than what you calculated. I calculated a gradient of 0.104 using the 3 wells you illustrated and the
following info:
WR 75-58: Elevation = 5840', SWL=52' so GW Elevation = 5788'
WR 75-1492: Elevation = 5860', SWL=70' so GW Elevation = 5790'
WR 75-2046: Elevation = 5845', SWL=155' so GW Elevation = 5690'
The Direction of groundwater flow also appears to be incorrect based on the wells used. Based on my calculations, the direction of
groundwater flow is from the southeast to the northeast as shown below, which also matches topography. Given that the
potentiometric surface is usually a subdued expression of topography, the direction of groundwater flow used in the model doesn't
make sense.
Please update the model using values for hydraulic gradient and direction of groundwater flow that can be supported by the data
provided.
Once the model is updated, please update all subsequent sections of the PER.
Section 4.0 - Identification and Assessment of Current Controls
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…2/19
The agricultural land is listed as adequately controlled, but only because ordinances restrict usage within zone one. The remaining
zones must also be considered when assessing the current controls of a potential contamination source (PCS).
The septic systems and residential homes are assessed as not adequately controlled in the table, but strategies to assess them as
adequately controlled are listed on the next page. That is contradictory. The management strategies for not adequately controlled
PCSs should appear in Section 5 of the final DWSP plan.
Land Use Agreements, Letters of Intent, or Zoning Ordinances
The administration and enforcement of the Iron County ordinance is the responsibility and obligation of the owner of the Public
Water System (refer to Section 13.16.080). If the Iron County ordinance is used in lieu of land use agreements, the administrative
contact for the system will need to provide a signed and dated statement indicating the following:
(PWS NAME) hereby acknowledges that Iron County Code Title 13.16: Drinking Water Source Protection will be used to protect
source protection zones one and two of the (SOURCE). Given that protection under the Iron County Code is the responsibility of
the Public Water System (PWS), (PWS NAME) commits to the following:
The PWS will monitor the parcels located within source protection zones one and two.
The PWS will inform any landowner of the source protection delineation and county source protection ordinance should any
development occur on their property.
The PWS will inform Iron County and the Southwest Utah Health Department should any property development appear to violate
Chapter 13.16 of the Iron County Code.
Let me know if you have any questions.
[Quoted text hidden]
GW Direction determination.pdf
161K
Deidre Beck <[e-mail]>Wed, Nov 6, 2024 at 9:38 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>, "J. Paul Wright" <[e-mail]>, Mellissa Noble <[e-mail]>, Noah
Zorsky <[e-mail]>
I meant to say that the flow appears to be from the southeast to the northwest. Also, as you're likely aware, the final DWSP
zones will need to be based on aquifer parameters derived from the results of a 24-hour constant rate test.
[Quoted text hidden]
Bryce Ross <[e-mail]>Thu, Nov 7, 2024 at 12:43 PM
To: Deidre Beck <[e-mail]>
Hey Deidre,

Thanks for your help. The more of these plans I complete, the less I think I know 😊 I’ve been remolding the zones in Whaem but
the 15 year delineation zone is huge after making those changes.

Is this what you would expect? I appreciate your time.

1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…3/19

Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient, please
destroy it.

From: Deidre Beck <[e-mail]>
Sent: Wednesday, November 6, 2024 9:28 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>; J. Paul Wright <[e-mail]>; Mellissa Noble <[e-mail]>; Noah
Zorsky <[e-mail]>
Subject: Re: 11099-WS001-PER

Hello,

I have reviewed the PER submitted for this source; however, before the Division can concur, the following items must be addressed:

1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…4/19
Section 2.0 - Delineation Report

It doesn't appear that the hydraulic gradient or direction of groundwater flow were calculated correctly. Using the methodology
explained in the attached document and the well logs for the wells illustrated on the "Water Rights Map" in the appendix, the
gradient appears steeper than what you calculated. I calculated a gradient of 0.104 using the 3 wells you illustrated and the
following info:

WR 75-58: Elevation = 5840', SWL=52' so GW Elevation = 5788'
WR 75-1492: Elevation = 5860', SWL=70' so GW Elevation = 5790'
WR 75-2046: Elevation = 5845', SWL=155' so GW Elevation = 5690'

The Direction of groundwater flow also appears to be incorrect based on the wells used. Based on my calculations, the direction of
groundwater flow is from the southeast to the northeast as shown below, which also matches topography. Given that the
potentiometric surface is usually a subdued expression of topography, the direction of groundwater flow used in the model doesn't
make sense.

Please update the model using values for hydraulic gradient and direction of groundwater flow that can be supported by the data
provided.

Once the model is updated, please update all subsequent sections of the PER.

Section 4.0 - Identification and Assessment of Current Controls

The agricultural land is listed as adequately controlled, but only because ordinances restrict usage within zone one. The remaining
zones must also be considered when assessing the current controls of a potential contamination source (PCS).

The septic systems and residential homes are assessed as not adequately controlled in the table, but strategies to assess them as
adequately controlled are listed on the next page. That is contradictory. The management strategies for not adequately controlled
PCSs should appear in Section 5 of the final DWSP plan.
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…5/19

Land Use Agreements, Letters of Intent, or Zoning Ordinances

The administration and enforcement of the Iron County ordinance is the responsibility and obligation of the owner of the Public
Water System (refer to Section 13.16.080). If the Iron County ordinance is used in lieu of land use agreements, the administrative
contact for the system will need to provide a signed and dated statement indicating the following:
(PWS NAME) hereby acknowledges that Iron County Code Title 13.16: Drinking Water Source Protection will be used to protect
source protection zones one and two of the (SOURCE). Given that protection under the Iron County Code is the responsibility of the
Public Water System (PWS), (PWS NAME) commits to the following:
The PWS will monitor the parcels located within source protection zones one and two.
The PWS will inform any landowner of the source protection delineation and county source protection ordinance should any
development occur on their property.
The PWS will inform Iron County and the Southwest Utah Health Department should any property development appear to violate
Chapter 13.16 of the Iron County Code.

Let me know if you have any questions.

On Wed, Oct 23, 2024 at 1:18 PM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have logged this after-the-fact PER into our queue for review. Source protection staff will reach out with
any questions.

I will ask Jennifer Yee to remove the SP06 deficiency once we can concur with the PER.

On Wed, Oct 23, 2024 at 11:04 AM Bryce Ross <[e-mail]> wrote:
Hey Deidre,

Please see the attached PER for the Foothills Water System. If you have any questions, don’t hesitate to reach out anytime.
I appreciate your time & effort.
Sincerely,
Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient,
please destroy it.

--
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…6/19
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
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]
Deidre Beck <[e-mail]>Fri, Nov 8, 2024 at 7:40 AM
To: Bryce Ross <[e-mail]>
It's because the calculated hydraulic gradient is so steep. I think the problem is the static water level in WR 75-2046. It's a newer
well and perhaps water levels have declined between when that well was drilled and the other two that you picked. Using
topography, the hydraulic gradient is more like 0.01. I would support your use of that hydraulic gradient. Just be sure to indicate in
the plan that based on static water levels in other wells nearby, it appears water levels have declined over the last few decades, so
it was difficult to establish a hydraulic gradient. Does the system have a way of measuring the current static water level in the well?
I would imagine not.
Try remodeling using 0.01 as the hydraulic gradient and send me another screenshot, particularly of zone 2. You may end up with
septic systems in zone 2, which will be an issue. There is another method that could be used, called the volumetric method, but we
don't typically allow it if there are wells in the area that can be used to establish a gradient.
[Quoted text hidden]
3 attachments
image001.png
2159K
image002.png
10K
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…7/19
image003.png
403K
Bryce Ross <[e-mail]>Fri, Nov 8, 2024 at 9:59 AM
To: Deidre Beck <[e-mail]>
Hey Deidre,

Thank you, I appreciate your time. I’ve recalculated the zones & this is zone 2 (250 Days, Hydraulic Gradient @ 0.01)

Please let me know your thoughts.
Sincerely,

From: Deidre Beck <[e-mail]>
Sent: Friday, November 8, 2024 7:40 AM
To: Bryce Ross <[e-mail]>
Subject: Re: 11099-WS001-PER
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…8/19

It's because the calculated hydraulic gradient is so steep. I think the problem is the static water level in WR 75-2046. It's a newer
well and perhaps water levels have declined between when that well was drilled and the other two that you picked. Using
topography, the hydraulic gradient is more like 0.01. I would support your use of that hydraulic gradient. Just be sure to indicate in
the plan that based on static water levels in other wells nearby, it appears water levels have declined over the last few decades, so
it was difficult to establish a hydraulic gradient. Does the system have a way of measuring the current static water level in the well?
I would imagine not.

Try remodeling using 0.01 as the hydraulic gradient and send me another screenshot, particularly of zone 2. You may end up with
septic systems in zone 2, which will be an issue. There is another method that could be used, called the volumetric method, but we
don't typically allow it if there are wells in the area that can be used to establish a gradient.

On Thu, Nov 7, 2024 at 12:43 PM Bryce Ross <[e-mail]> wrote:
Hey Deidre,

Thanks for your help. The more of these plans I complete, the less I think I know 😊 I’ve been remolding the zones in Whaem
but the 15 year delineation zone is huge after making those changes.

Is this what you would expect? I appreciate your time.

Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient, please
destroy it.

From: Deidre Beck <[e-mail]>
Sent: Wednesday, November 6, 2024 9:28 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>; J. Paul Wright <[e-mail]>; Mellissa Noble <[e-mail]>;
Noah Zorsky <[e-mail]>
Subject: Re: 11099-WS001-PER

Hello,

I have reviewed the PER submitted for this source; however, before the Division can concur, the following items must be
addressed:

Section 2.0 - Delineation Report

It doesn't appear that the hydraulic gradient or direction of groundwater flow were calculated correctly. Using the methodology
explained in the attached document and the well logs for the wells illustrated on the "Water Rights Map" in the appendix, the
gradient appears steeper than what you calculated. I calculated a gradient of 0.104 using the 3 wells you illustrated and the
following info:
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:1813725100514310…9/19

WR 75-58: Elevation = 5840', SWL=52' so GW Elevation = 5788'
WR 75-1492: Elevation = 5860', SWL=70' so GW Elevation = 5790'
WR 75-2046: Elevation = 5845', SWL=155' so GW Elevation = 5690'

The Direction of groundwater flow also appears to be incorrect based on the wells used. Based on my calculations, the direction
of groundwater flow is from the southeast to the northeast as shown below, which also matches topography. Given that the
potentiometric surface is usually a subdued expression of topography, the direction of groundwater flow used in the model
doesn't make sense.

Please update the model using values for hydraulic gradient and direction of groundwater flow that can be supported by the data
provided.
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
Deidre Beck <[e-mail]>Fri, Nov 8, 2024 at 10:02 AM
To: Bryce Ross <[e-mail]>
Does zone 4 run far up into the hills still?
[Quoted text hidden]
image001.png
2443K
Bryce Ross <[e-mail]>Fri, Nov 8, 2024 at 10:09 AM
To: Deidre Beck <[e-mail]>
Yes, it still runs up the hill but not nearly as big as before. This is zone 4 now.

1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…10/19

Thanks again,

Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
[Quoted text hidden]
Deidre Beck <[e-mail]>Tue, Nov 12, 2024 at 12:52 PM
To: Bryce Ross <[e-mail]>
Okay. I think it's reasonable and it's going to change anyways once you remodel using the results of a constant-rate test. Hopefully,
the transmissivity is less so the zones won't be so long.
Please update all of the sections to reflect this delineation, and resubmit.
Thanks,
[Quoted text hidden]
2 attachments
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…11/19
image001.png
511K
image002.png
10K
Bryce Ross <[e-mail]>Fri, Nov 22, 2024 at 11:01 AM
To: Deidre Beck <[e-mail]>
Hey Deidre,

I forgot to include the ownership information in the previous PER, so please disregard the previous attachment. This one should
have everything.

Thanks,
Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient, please
destroy it.

From: Deidre Beck <[e-mail]>
Sent: Wednesday, November 6, 2024 9:28 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>; J. Paul Wright <[e-mail]>; Mellissa Noble <[e-mail]>; Noah
Zorsky <[e-mail]>
Subject: Re: 11099-WS001-PER

Hello,

1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…12/19
I have reviewed the PER submitted for this source; however, before the Division can concur, the following items must be
addressed:

Section 2.0 - Delineation Report

It doesn't appear that the hydraulic gradient or direction of groundwater flow were calculated correctly. Using the methodology
explained in the attached document and the well logs for the wells illustrated on the "Water Rights Map" in the appendix, the
gradient appears steeper than what you calculated. I calculated a gradient of 0.104 using the 3 wells you illustrated and the
following info:

WR 75-58: Elevation = 5840', SWL=52' so GW Elevation = 5788'
WR 75-1492: Elevation = 5860', SWL=70' so GW Elevation = 5790'
WR 75-2046: Elevation = 5845', SWL=155' so GW Elevation = 5690'

The Direction of groundwater flow also appears to be incorrect based on the wells used. Based on my calculations, the direction of
groundwater flow is from the southeast to the northeast as shown below, which also matches topography. Given that the
potentiometric surface is usually a subdued expression of topography, the direction of groundwater flow used in the model doesn't
make sense.

Please update the model using values for hydraulic gradient and direction of groundwater flow that can be supported by the data
provided.

Once the model is updated, please update all subsequent sections of the PER.

Section 4.0 - Identification and Assessment of Current Controls

The agricultural land is listed as adequately controlled, but only because ordinances restrict usage within zone one. The remaining
zones must also be considered when assessing the current controls of a potential contamination source (PCS).
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…13/19

The septic systems and residential homes are assessed as not adequately controlled in the table, but strategies to assess them as
adequately controlled are listed on the next page. That is contradictory. The management strategies for not adequately controlled
PCSs should appear in Section 5 of the final DWSP plan.

Land Use Agreements, Letters of Intent, or Zoning Ordinances

The administration and enforcement of the Iron County ordinance is the responsibility and obligation of the owner of the Public
Water System (refer to Section 13.16.080). If the Iron County ordinance is used in lieu of land use agreements, the administrative
contact for the system will need to provide a signed and dated statement indicating the following:
(PWS NAME) hereby acknowledges that Iron County Code Title 13.16: Drinking Water Source Protection will be used to protect
source protection zones one and two of the (SOURCE). Given that protection under the Iron County Code is the responsibility of
the Public Water System (PWS), (PWS NAME) commits to the following:
The PWS will monitor the parcels located within source protection zones one and two.
The PWS will inform any landowner of the source protection delineation and county source protection ordinance should any
development occur on their property.
The PWS will inform Iron County and the Southwest Utah Health Department should any property development appear to violate
Chapter 13.16 of the Iron County Code.

Let me know if you have any questions.

On Wed, Oct 23, 2024 at 1:18 PM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have logged this after-the-fact PER into our queue for review. Source protection staff will reach out with
any questions.

I will ask Jennifer Yee to remove the SP06 deficiency once we can concur with the PER.

On Wed, Oct 23, 2024 at 11:04 AM Bryce Ross <[e-mail]> wrote:
Hey Deidre,

Please see the attached PER for the Foothills Water System. If you have any questions, don’t hesitate to reach out anytime.
I appreciate your time & effort.
Sincerely,
Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient,
please destroy it.

--
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…14/19
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
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]
11099-WS001 - PER.pdf
14049K
Deidre Beck <[e-mail]>Fri, Nov 22, 2024 at 11:14 AM
To: Bryce Ross <[e-mail]>
Okay. Thanks.
[Quoted text hidden]
2 attachments
image001.png
10K
image002.png
403K
Deidre Beck <[e-mail]>Mon, Dec 2, 2024 at 11:23 AM
To: Bryce Ross <[e-mail]>
Hey Bryce,
I'm not sure why you changed the status of the septic systems and residents to "adequately controlled" in the table. The Division
cannot concur because we don't consider any control type as adequate to control septic systems or residents. The table is
sufficient for the not adequately controlled PCSs. The strategies listed on the subsequent pages are unnecessary in a PER. The
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…15/19
management strategies for not adequately controlled PCSs should appear in Section 5 of the final DWSP plan not the
PER. So just delete the paragraphs on pages 12 and 13 concerning residents and septic system owners. Save it for the DWSP
plan.
Land Use Agreements, Letters of Intent, or Zoning Ordinances
While the language below was added, the administrative contact for the system will need to provide a signed and dated
statement including the language below before the Division can concur with the PER.
(PWS NAME) hereby acknowledges that Iron County Code Title 13.16: Drinking Water Source Protection will be used to protect
source protection zones one and two of the (SOURCE). Given that protection under the Iron County Code is the responsibility of
the Public Water System (PWS), (PWS NAME) commits to the following:
The PWS will monitor the parcels located within source protection zones one and two.
The PWS will inform any landowner of the source protection delineation and county source protection ordinance should any
development occur on their property.
The PWS will inform Iron County and the Southwest Utah Health Department should any property development appear to violate
Chapter 13.16 of the Iron County Code.
Let me know if you have any questions.
[Quoted text hidden]
Bryce Ross <[e-mail]>Tue, Jan 7, 2025 at 3:28 PM
To: Deidre Beck <[e-mail]>
Cc: Curtis Nielson <[e-mail]>
Hi Deidre,

Please see the attached PER. I’ve completed the revisions for the Foothills Water System and added the signed and dated
statement to the appendix. If you have any questions, don’t hesitate to contact me anytime.

I appreciate your time and effort.
Sincerely,

Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient, please
destroy it.

From: Deidre Beck <[e-mail]>
Sent: Monday, December 2, 2024 11:23 AM
To: Bryce Ross <[e-mail]>
Subject: Re: 11099-WS001-PER
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…16/19

Hey Bryce,

I'm not sure why you changed the status of the septic systems and residents to "adequately controlled" in the table. The Division
cannot concur because we don't consider any control type as adequate to control septic systems or residents. The table is
sufficient for the not adequately controlled PCSs. The strategies listed on the subsequent pages are unnecessary in a PER. The
management strategies for not adequately controlled PCSs should appear in Section 5 of the final DWSP plan not the
PER. So just delete the paragraphs on pages 12 and 13 concerning residents and septic system owners. Save it for the DWSP
plan.

Land Use Agreements, Letters of Intent, or Zoning Ordinances

While the language below was added, the administrative contact for the system will need to provide a signed and dated
statement including the language below before the Division can concur with the PER.

(PWS NAME) hereby acknowledges that Iron County Code Title 13.16: Drinking Water Source Protection will be used to protect
source protection zones one and two of the (SOURCE). Given that protection under the Iron County Code is the responsibility of
the Public Water System (PWS), (PWS NAME) commits to the following:
The PWS will monitor the parcels located within source protection zones one and two.
The PWS will inform any landowner of the source protection delineation and county source protection ordinance should any
development occur on their property.
The PWS will inform Iron County and the Southwest Utah Health Department should any property development appear to violate
Chapter 13.16 of the Iron County Code.

Let me know if you have any questions.

On Fri, Nov 22, 2024 at 11:14 AM Deidre Beck <[e-mail]> wrote:
Okay. Thanks.

On Fri, Nov 22, 2024 at 11:02 AM Bryce Ross <[e-mail]> wrote:
Hey Deidre,

I forgot to include the ownership information in the previous PER, so please disregard the previous attachment. This one
should have everything.

Thanks,
Bryce Ross | CAD Designer
Main 435.865.1453 | Cell 435.704.1438
[e-mail] | ensignutah.com
CONFIDENTIALITY NOTICE: The content of this e-mail is confidential and proprietary privileged. If you are not the intended recipient,
please destroy it.

1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…17/19
From: Deidre Beck <[e-mail]>
Sent: Wednesday, November 6, 2024 9:28 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>; J. Paul Wright <[e-mail]>; Mellissa Noble <[e-mail]>;
Noah Zorsky <[e-mail]>
Subject: Re: 11099-WS001-PER

Hello,

I have reviewed the PER submitted for this source; however, before the Division can concur, the following items must be
addressed:

Section 2.0 - Delineation Report

It doesn't appear that the hydraulic gradient or direction of groundwater flow were calculated correctly. Using the methodology
explained in the attached document and the well logs for the wells illustrated on the "Water Rights Map" in the appendix, the
gradient appears steeper than what you calculated. I calculated a gradient of 0.104 using the 3 wells you illustrated and the
following info:

WR 75-58: Elevation = 5840', SWL=52' so GW Elevation = 5788'
WR 75-1492: Elevation = 5860', SWL=70' so GW Elevation = 5790'
WR 75-2046: Elevation = 5845', SWL=155' so GW Elevation = 5690'

The Direction of groundwater flow also appears to be incorrect based on the wells used. Based on my calculations, the
direction of groundwater flow is from the southeast to the northeast as shown below, which also matches topography. Given
that the potentiometric surface is usually a subdued expression of topography, the direction of groundwater flow used in the
model doesn't make sense.

Please update the model using values for hydraulic gradient and direction of groundwater flow that can be supported by the
data provided.
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
[Quoted text hidden]
11099-WS001-PER.pdf
14194K
Deidre Beck <[e-mail]>Wed, Jan 8, 2025 at 10:15 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>, "J. Paul Wright" <[e-mail]>
Received, thank you. I will let you know if I have any other questions/comments.
[Quoted text hidden]
Deidre Beck <[e-mail]>Mon, Jan 13, 2025 at 9:44 AM
To: Bryce Ross <[e-mail]>
Cc: Curtis Nielson <[e-mail]>, "J. Paul Wright" <[e-mail]>, Jennifer Yee <[e-mail]>
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…18/19
Hi Jen,
I am drafting a concurrence letter for the PER for system 11099 source WS001. Please remove the SP06 deficiency from the
system's IPS report.
[Quoted text hidden]
Jennifer Yee <[e-mail]>Mon, Jan 13, 2025 at 9:49 AM
To: Deidre Beck <[e-mail]>
Cc: Bryce Ross <[e-mail]>, Curtis Nielson <[e-mail]>, "J. Paul Wright" <[e-mail]>
I have removed that deficiency and the associated violation.
Thanks,
Jen
Jennifer Yee
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.
[Quoted text hidden]
1/13/25, 10:37 AM State of Utah Mail - 11099-WS001-PER
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1813725100514310377&simpl=msg-f:181372510051431…19/19