DDW-2025-000841

Deidre Beck <[e-mail]>
Fwd: UTAH22159
17 messages
Danielle Zebelean <[e-mail]>Wed, Apr 10, 2024 at 11:14 AM
To: Deidre Beck <[e-mail]>, Melissa Noble <[e-mail]>, Noah Zorsky <[e-mail]>
Hello Source Protection Folks.
I received this engineering evaluation for Wilderness Acres #22159 I am not sure if it also has anything useful for your
review, but I am sending it along anyways.
Will you need to receive and accept the DWSP before the after the fact operating permit it sent out?
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.
---------- Forwarded message ---------
From: <[e-mail]>
Date: Mon, Apr 8, 2024 at 11:18 AM
Subject: UTAH22159
To: <[e-mail]>
Cc: Brad Rawson <[e-mail]>, <[e-mail]>
Dani-

Please find the attached EER as ordered for Wilderness Acres No. 20, UTAH22159. I’ve also included plans for a new
water tank to provide additional information about the system.

-Jacqelyn Lewis, P.E.
Project Engineer
309-271-9981

1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…1/11

2 attachments
WA20 EER_STAMPED 4-8-24.pdf
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WA20_STAMPED SET_4-8-24.pdf
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Deidre Beck <[e-mail]>Wed, Apr 10, 2024 at 11:20 AM
To: Danielle Zebelean <[e-mail]>
Cc: Melissa Noble <[e-mail]>, Noah Zorsky <[e-mail]>
Yes, we need both a PER and DWSP plan submitted and concurred with before the OP is issued. They can be combined
into one report. They'll also need to submit the final zones to Summit County to be covered under their ordinance before
the ATF OP is issued.
[Quoted text hidden]
--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
[Quoted text hidden]
Danielle Zebelean <[e-mail]>Mon, Jun 3, 2024 at 7:28 AM
To: [e-mail]
Cc: Brad Rawson <[e-mail]>, [e-mail], Deidre Beck <[e-mail]>
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…2/11
Hi Jacqelyn,
Sorry for the long delay on this project. I need some more information for you before issuing an operating permit.
Do you have the well log from when the well was drilled? Do you know approximately when the well was drilled?
Do you know the flow from the well pump and approximately when it was installed?
Does Wilderness Acres have the means to measure the water levels in their well currently?
Finally, we need a Preliminary Evaluation Report (PER) and Drinking Water Source Protection Plan (DWSP) for
the well. More information can be found here:https://deq.utah.gov/drinking-water/about-source-protection-program.
You can also reach out to Deidre Beck with any questions at [e-mail] or [phone].
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]
[e-mail] <[e-mail]>Thu, Jun 13, 2024 at 6:01 AM
To: Danielle Zebelean <[e-mail]>, [e-mail]
Cc: Brad Rawson <[e-mail]>, Deidre Beck <[e-mail]>
Dani,
I have attached the PER and DWSP.
We don’t have the well log and don’t know the drilled date.
The current well pump was installed in 2006 and delivers 10 gpm.
The well does not indicate current water levels.

Jared Oldroyd, P.E.
JWO Engineering, PLLC
801-828-7805
[Quoted text hidden]
2 attachments
WA20 EER_STAMPED 4-8-24.pdf
2440K
WA20 Drinking Water Source Protection Plan.docx
6030K
Deidre Beck <[e-mail]>Thu, Jun 13, 2024 at 10:05 AM
To: [e-mail]
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…3/11
Cc: Danielle Zebelean <[e-mail]>, [e-mail], Brad Rawson <[e-mail]>
Hi Jared,
I glanced at the PER. The Division will be unable to concur. The optional two-mile radius delineation procedure can't be
used for a well that is classified as a "new ground-water source". The definition for a "new ground-water source" is not
based on when a well was drilled, it is based on when the Division received plans and specifications for drilling the well,
which we obviously didn't receive prior to 1993. So source protection zones 2-4 will need to be established in some other
manner and the information below provided:
(iv) Aquifer Data for New Wells - A summary report including the calculated hydraulic conductivity of the aquifer,
transmissivity, hydraulic gradient, direction of ground-water flow, estimated effective porosity, and saturated thickness of
the producing aquifer(s). The PWS shall obtain the hydraulic conductivity of the aquifer from a constant-rate aquifer test
and provide the data as described in R309-515-6(10)(b). Estimated effective porosity must be between 1% and 30%.
Clay layers shall not be included in calculations of aquifer thickness or estimated effective porosity. This report shall
include graphs, data, or printouts showing the interpretation of the aquifer test.
Exceptions to the rules can be requested but some attempts should be made to comply. The volumetric method may be
an option. When there is a lack of hydrogeologic data for an aquifer near a proposed well, the Volumetric Method (EPA,
1993 (report attached)) can be used to model groundwater flow to the well and to delineate the zone two, zone three, and
zone four source protection boundaries. This method assumes a flat hydraulic gradient and radial flow to the well, and is
based on the following equation:
where:
Fs is the factor of safety (not required, but more conservative, generally, on the order of 10-15% (1.10-1.15);
R is the radius of each zone in feet;
Q is the pumping rate of the well in cubic feet per day (ft3/day);
t is the time-of-travel in days;
n is the effective porosity of the aquifer; and
B is the saturated thickness of the aquifer in feet.
The zones will be concentric circles around the source. The downside would be if potential contamination sources end up
being located within zone two that violate R309-600-13. The PER cannot be approved if there are sewer lines or septic
systems (or other pollution sources) in zone two unless exceptions are granted to rule, so that will need to be considered
when deciding which method to use.
Also, please be aware that the Summit County ordinance cannot be used to assess conventional septic systems as
adequately controlled. We do not consider any control type sufficient to assess septic systems as adequately controlled
because they have no controls on their ongoing maintenance and directly discharge contaminants to the ground.
Once you have addressed the Delineation Report, please update all subsequent sections of the report. It doesn't look like
all sections of a full DWSP Plan were addressed, only the sections required for a PER. Please add the remaining sections
to the next submission.
Let me know if you have any questions.
[Quoted text hidden]
--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…4/11
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00001OZC_GuidelinesDelineationWellheadAreas.pdf
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Danielle Zebelean <[e-mail]>Mon, Jul 1, 2024 at 5:12 PM
To: [e-mail]
Cc: [e-mail], Brad Rawson <[e-mail]>, Deidre Beck <[e-mail]>
Thank you Jared,
We do need to know approximately how deep the well is, and the depth to which it was sealed. Is that something you
think Wilderness Acres can find?
Also can you send specifications on the current well that is installed and it's operating point?
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]
[e-mail] <[e-mail]>Tue, Jul 9, 2024 at 2:56 PM
To: Danielle Zebelean <[e-mail]>
Cc: [e-mail], Brad Rawson <[e-mail]>, Deidre Beck <[e-mail]>
Danielle,
The attached revised DSWP has the available information on the well. The well is reportedly grouted but I
did not find information on the depth of the seal.

Brad, is there anything else you can find on the well construction that might show the depth of the grout
seal?
Let me know if there are more comments on the DWSP or if it is ready to finalize and stamp.
Thank you,

Jared Oldroyd, P.E.
JWO Engineering, PLLC
801-828-7805
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…5/11

From: Danielle Zebelean <[e-mail]>
Sent: Monday, July 1, 2024 5:12 PM
To: [e-mail]
Cc: [e-mail]; Brad Rawson <[e-mail]>; Deidre Beck <[e-mail]>
Subject: Re: UTAH22159

Thank you Jared,

We do need to know approximately how deep the well is, and the depth to which it was sealed. Is that something you
think Wilderness Acres can find?

Also can you send specifications on the current well that is installed and it's operating point?

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.

On Thu, Jun 13, 2024 at 10:06 AM Deidre Beck <[e-mail]> wrote:
Hi Jared,
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…6/11

I glanced at the PER. The Division will be unable to concur. The optional two-mile radius delineation procedure can't be
used for a well that is classified as a "new ground-water source". The definition for a "new ground-water source" is not
based on when a well was drilled, it is based on when the Division received plans and specifications for drilling the well,
which we obviously didn't receive prior to 1993. So source protection zones 2-4 will need to be established in some
other manner and the information below provided:

(iv) Aquifer Data for New Wells - A summary report including the calculated hydraulic conductivity of the aquifer,
transmissivity, hydraulic gradient, direction of ground-water flow, estimated effective porosity, and saturated thickness
of the producing aquifer(s). The PWS shall obtain the hydraulic conductivity of the aquifer from a constant-rate aquifer
test and provide the data as described in R309-515-6(10)(b). Estimated effective porosity must be between 1% and
30%. Clay layers shall not be included in calculations of aquifer thickness or estimated effective porosity. This report
shall include graphs, data, or printouts showing the interpretation of the aquifer test.

Exceptions to the rules can be requested but some attempts should be made to comply. The volumetric method may
be an option. When there is a lack of hydrogeologic data for an aquifer near a proposed well, the Volumetric Method
(EPA, 1993 (report attached)) can be used to model groundwater flow to the well and to delineate the zone two, zone
three, and zone four source protection boundaries. This method assumes a flat hydraulic gradient and radial flow to the
well, and is based on the following equation:
[Quoted text hidden]
WA20 DWSP 7-9-24 .pdf
2439K
Deidre Beck <[e-mail]>Wed, Jul 10, 2024 at 1:29 PM
To: [e-mail]
Cc: Danielle Zebelean <[e-mail]>, [e-mail], Brad Rawson <[e-mail]>
Hello Jared,
I have reviewed the PER/DWSP plan for this source; however, before the Division can concur, the following items
must be addressed and the plan re-submitted for review:
The Delineation Report needs to be stamped/signed by a licensed geologist or engineer.
Section 2.0 - Delineation Report
A description of the soils was provided. The soil description does not meet the intent of rule R309-600-9(6)(a)(i). A
description of the geologic features and aquifer characteristics observed in the well or in the area of the
protection zones needs to be provided. Water Rights has many well logs with information about other sources. I've
attached 3 that I found within a few thousand feet of this source. There may be others.
The report must provide a calculated hydraulic conductivity and transmissivity. Based on rule, the system is
required to obtain the hydraulic conductivity of the aquifer from a constant-rate aquifer test and provide the data as
described in R309-515-6(10)(b). It doesn't appear that a 24-hour constant-rate test has been conducted. Either a 24-hour
test needs to be conducted or the system needs to request an exception to R309-600-9(6)(a)(iv) - Aquifer Data for New
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…7/11
Wells. If an exception is requested, the system still needs to derive the hydraulic conductivity using another appropriate
method, such as data from a nearby well in the same aquifer, specific capacity of the well, or published hydrogeologic
report(s).
I provided the volumetric method as one possible option for delineating the zones if no other wells existed in the area that
could be used to establish the hydraulic gradient. I assumed there were no wells nearby given the information provided in
the first version of the report. It seems there are multiple wells completed in the same aquifer as the Wilderness Acres
Well that could be used to establish a hydraulic gradient and direction of groundwater flow. Therefore, the volumetric
method cannot be used. Please calculate the hydraulic gradient and direction of groundwater flow and use an
appropriate hydrogeologic method for delineation of the source protection zones. Generally, WHPA or WhAEM are
used to delineate groundwater protection zones. If the well is completed in bedrock, then typically WHPA or WhAEM are
used in conjunction with hydrogeologic mapping. The hydrogeologic method or groundwater model must be reasonably
applicable for the aquifer setting. Please re-delineate the zones using an appropriate hydrogeologic method or
groundwater model. For wells, the hydrogeologic method or groundwater model must include the effects of drawdown,
including increased hydraulic gradient near the well, and interference from other wells.
I recommend that you revise the Delineation Report and submit it for review and concurrence before making
changes to the remaining sections of the plan to avoid unnecessary work. Based on a cursory review of the
remaining sections, I have the following review comments:
Section 3
You cannot eliminate residential pesticide sources as a hazard due to negligible quantities without knowing exactly how
much is being stored or used by each resident. Also, the statement that residents would not want to contaminate their
drinking water is insufficient to classify the residential areas as adequately controlled using negligible quantities. We
typically do not consider residents as adequately controlled PCSs.
Section 4
An assessment should be completed for all PCSs, not just those in zones 1 and 2. To assess a hazard as adequately
controlled using one of the four control types, all steps must be completed for the specific control type.
(a) Regulatory Controls - Identify the enforcement agency and verify that the hazard is being regulated by them; cite and
quote applicable references in the regulation, rule or ordinance which pertain to controlling the hazard; explain how the
regulatory control prevents groundwater contamination; assess the hazard; and set a date to reassess the hazard.
(b) Best Management and Pollution Prevention Practice Controls - List the specific best management and pollution
prevention practices which have been implemented by potential contamination source management to control the hazard
and how that they are willing to continue the use of these practices; explain how these practices prevent groundwater
contamination; assess the hazard; and set a date to reassess the hazard.
(c) Physical Controls - Describe the physical controls which have been constructed to control the hazard; explain how
these controls prevent contamination; assess the hazard; and set a date to reassess the hazard.
(d) Negligible Quantity Control - Identify the quantity of the hazard that is being used, disposed, stored, manufactured, or
transported; explain why this amount should be considered a negligible quantity; assess the hazard; and set a date to
reassess the hazard.
If a control type is not identified or the steps aren't followed, the PCS will be considered not adequately controlled. You
must assess the roads in Zone 1 as adequately controlled using one of the four control types and follow all steps or I will
be unable to concur with the plan.
Section 5
Again, this section should not only reference zones 1 and 2. Any PCS in any zone that is assessed as not adequately
controlled must have land management strategies planned. For septic system owners, PWSs typically send out public
education materials concerning best management practices. Please identify what information will be sent and how
frequently it will be sent. The system should know exactly what strategies need to be implemented and how frequently
they need to be implemented. At least once every update cycle is the minimum requirement.
Please let me know if you have any questions.
Deidre
[Quoted text hidden]
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
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3 attachments
21-1752_432338.pdf
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21-1461_74209079.pdf
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21-1669_28881.pdf
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Danielle Zebelean <[e-mail]>Wed, Jul 17, 2024 at 12:01 PM
To: Deidre Beck <[e-mail]>
Cc: Brad Rawson <[e-mail]>, [e-mail], [e-mail]
Hi Jared,
I’m waiting to hear back from some of my other coworkers on what to do about the unknown grout depth. This may result
in increased sampling of the well or there may be a way to figure it out I’m not aware of.
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]>Mon, Jul 22, 2024 at 7:00 AM
To: [e-mail]
Cc: Brad Rawson <[e-mail]>, [e-mail], Deidre Beck <[e-mail]>
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:1795968743355732…9/11
Hi Jared,
I heard back from my coworkers about the unknown grout depth. They are ok proceeding with some additional monitoring
of the water once the final OP goes out. So now all that is left is wrapping up the drinking water source protection plan!
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]
[e-mail] <[e-mail]>Tue, Jul 30, 2024 at 9:37 AM
To: Deidre Beck <[e-mail]>
Deidre,
Can I set up a meeting with you to discuss this? I have discussed it with a hydrogeologist and want to
discuss it with you before proceeding.
[Quoted text hidden]
Deidre Beck <[e-mail]>Tue, Jul 30, 2024 at 1:52 PM
To: [e-mail]
Yes, we can set up a meeting to discuss this. Tomorrow will probably be tough, but I could do it anytime on Thursday or
Friday morning.
[Quoted text hidden]
[e-mail] <[e-mail]>Tue, Jul 30, 2024 at 3:13 PM
To: Deidre Beck <[e-mail]>
How about Thursday morning at 10:30?
[Quoted text hidden]
Deidre Beck <[e-mail]>Tue, Jul 30, 2024 at 3:23 PM
To: [e-mail]
That works for me.
[Quoted text hidden]
[e-mail] <[e-mail]>Tue, Jul 30, 2024 at 3:38 PM
To: Deidre Beck <[e-mail]>
Thank you. I’ll see you then.
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1795968743355732462&simpl=msg-f:179596874335573…10/11
[Quoted text hidden]
Deidre Beck <[e-mail]>Tue, Jul 30, 2024 at 3:49 PM
To: [e-mail]
Are you going to send me a meeting invite? Or do I need to set one up? Or did you just mean a phone call?
[Quoted text hidden]
[e-mail] <[e-mail]>Tue, Jul 30, 2024 at 4:15 PM
To: Deidre Beck <[e-mail]>
I’ll send a meeting invite.
[Quoted text hidden]
1/27/25, 9:06 AM State of Utah Mail - Fwd: UTAH22159
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Deidre Beck <[e-mail]>
Wilderness Acres Hydraulic Grade
10 messages
[e-mail] <[e-mail]>Mon, Aug 5, 2024 at 7:21 PM
To: Deidre Beck <[e-mail]>
Diedre,
Here are the details from my calculations

Well Ground Elevation Depth to water Water Elevation
Wilderness Acres 8230 90 8140
21-1669 8224 90 8134
21-1577 8220 90 8130

Distance WA to 1669 994’ WA to 1577 809’ 1669 to 1577 1022’

8134 hydraulic contour is 323 feet from 1577 towards WA
Flow is NE towards 1577 from WA.

Jared Oldroyd, P.E.
JWO Engineering, PLLC
801-828-7805

Deidre Beck <[e-mail]>Tue, Aug 6, 2024 at 7:19 AM
To: [e-mail]
Okay. I'll check it, but can you also send the well logs when you have a chance.
[Quoted text hidden]
--
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.
[e-mail] <[e-mail]>Tue, Aug 6, 2024 at 10:57 AM
To: Deidre Beck <[e-mail]>
1/27/25, 9:07 AM State of Utah Mail - Wilderness Acres Hydraulic Grade
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1806599237931148908&simpl=msg-f:180659923793114890…1/5
Deidre,

1669 is attached and 1577 is cut and pasted above.
[Quoted text hidden]
21-1669_28881.pdf
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Deidre Beck <[e-mail]>Tue, Aug 6, 2024 at 11:07 AM
To: [e-mail]
1/27/25, 9:07 AM State of Utah Mail - Wilderness Acres Hydraulic Grade
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1806599237931148908&simpl=msg-f:180659923793114890…2/5
Okay, thanks. I think your calculations make sense. I also checked the gradient in the region based on topography and it was very close to what you calculated.
I have a meeting scheduled tomorrow morning with my manager and Dani Zebelean concerning the source and the exceptions that will likely be required. I will
send an email after that meeting to let you know how best to move forward.
[Quoted text hidden]
Deidre Beck <[e-mail]>Tue, Aug 13, 2024 at 8:03 AM
To: [e-mail]
Cc: Danielle Zebelean <[e-mail]>
Hi Jared,
Dani and I met with our supervisor to discuss the Wilderness Acres 20 Property Owners Well. The next logical step is to have the system request exceptions to
the rules we know will be required so that we can meet with the Assistant Director for preliminary approval. We don’t want to work off of the assumption that theAssistant Director will grant exceptions, and find out that he is not comfortable doing so as it may cause unintended work for you and the system. To request
exceptions, prepare a letter that meets these requirements (a Project Notification Form is not required).
A written request, preferably on water system letterhead, from the management of the Public Water System to the Director of the Division of Drinking
Water.
Cite the specific rules to which the exceptions are being requested.
Provide a detailed explanation of why the requirements of the rule cannot be met (include drawings if appropriate).
Describe what will be done to meet the intent of the rule in place of meeting the requirements of the rule (include drawings if appropriate).
Provide an alternative to the rule requirements and justification of how it will meet or exceed the public health requirements of the rule that cannot be
met.
You don’t need a separate letter for each rule exception. They can all be included in one letter, just be sure to address each rule separately. Dani will be
providing a separate email with references to the engineering rules that need exceptions.
For the source protection requirements, I’ve reviewed the delineation information submitted to date and have the following comments. I’ve referenced in bold
the rules that will or may need exceptions requested.
Section 2.4 - Hydrogeologic Methods and Calculations
The volumetric method can be used when the direction of groundwater flow and magnitude of the hydraulic gradient are unknown. Given the sheer number of
wells completed in the same aquifer and to a similar depth in this region, I’m unsure the volumetric method is the right approach without a few tweaks
(discussed below). I’m willing to allow the use of the volumetric method given that many of the values that would be used as inputs into a program like WhAEM
will also be approximations. If you want to continue with the volumetric method, I think you should review the attached document so you’re aware of its
limitations. Discussion of the volumetric method begins on page 19 (page 27 of the PDF).
I think the saturated thickness needs to be more conservative. It was estimated to be 40 feet based on the highest water reading and the reported well depth.Usually the saturated thickness is based on the open interval of the well, i.e., the length of the screened or perforated zones. Because the system doesn’t have
a well log, there is a huge degree of uncertainty in this value. It also has a huge impact on the volumetric equation. The lower the value, the larger the zones.
I’m not convinced that 40 feet is the saturated thickness that should be used. In looking at other well logs in the area, besides the ones you already provided, itseems that a thickness of 20 - 25 feet may be more representative. Most of the wells in the region have approximately 15 - 30 feet of perforations, not 40 feet.
Please revise the calculations using a more conservative value for the saturated aquifer thickness. This will result in larger zones.
Please be aware that if zone two encroaches on a parcel with a resident on a septic system, then the system will need to request an exception to R306-600-
13(2)(b)(ii) - Protection Areas Delineated using the Preferred Delineation Procedure in Unprotected Aquifers. This rule states that a Public Water System
cannot locate a new groundwater source where an uncontrolled pollution source exists within zone two unless the pollution source implements design
standards which prevent contaminated discharges to groundwater. By design, septic systems discharge contaminants to the ground and conventional onsitewastewater systems do not have sufficient design standards to classify them as “controlled”. As an FYI - the report states that Summit County has the authority
to not allow construction of onsite wastewater systems in zone one. They also have authority to not allow construction in zone two for a source developed in an
unprotected aquifer. As such, if zone two ends up encroaching on an undeveloped lot and a septic permit application is submitted, the local health department
will likely disapprove it. This is for your information and the system’s consideration.
As discussed in our meeting last week, the hydraulic conductivity (and transmissivity) are supposed to be calculated based on the results of a 24-hour constant-
rate test. It sounds like a 24-hour constant-rate test is not possible due to the inability of the current pump to stress the aquifer (insufficient drawdown in the
well). As such, the transmissivity and hydraulic conductivity will need to be based on another appropriate method, such as data from a nearby well in the same
aquifer, specific capacity of the well (or a nearby well), published hydrogeologic studies of the same aquifer, or local or regional groundwater models.These data
are required, even if the volumetric method is used to delineate the drinking water source protection zones. The system will need to request an exception toRule R309-600-9(6)(a)(iv) - Aquifer Data for New Wells due to this issue.
Please contact me with any questions.
Deidre
[Quoted text hidden]
work_whaem_june2018 (1).pdf
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Danielle Zebelean <[e-mail]>Wed, Aug 21, 2024 at 9:04 AM
To: Deidre Beck <[e-mail]>
Cc: [e-mail]
Hi Jared,
Sorry for the delay in following up with the engineering rules. After re-revewing what was submitted the only rule I can see so far that needs an exception is the
grout seal depth. R309-515-6(6)(i) Well Sealing Techniques and Requirements. This rule states that a well must have annular space sealed with grout to at
least a depth of 100 feet below the ground surface.
1/27/25, 9:07 AM State of Utah Mail - Wilderness Acres Hydraulic Grade
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1806599237931148908&simpl=msg-f:180659923793114890…3/5
Julie Cobleigh is doing the site inspection and so she might have others that she finds that will need exceptions. I've asked her to let me know if she does find
anything else.
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]
Brad Rawson <[e-mail]>Sat, Nov 23, 2024 at 8:34 AM
To: Danielle Zebelean <[e-mail]>, Julie Cobleigh <[e-mail]>, Deidre Beck <[e-mail]>
Cc: [e-mail], Marty & Joan Verhoef <[e-mail]>, Chet Cragun <[e-mail]>
Deidre, it has been several weeks since you notified Jared Oldroyd that the next step for Wilderness Acres 20 Property Owners Association would be to preparea letter seeking exceptions from a few of the rules. We have researched rules along with our current system and have attached our formal request for these
exceptions.
Please forward this to any individual you feel necessary. I look forward to further communication with you as we continue to make improvements to our water
system
Sincerely,
Brad J. Rawson
President Wilderness Acres 20 [e-mail]
Office- 801-523-2366
Cell- 801-608-5233
On Tue, Sep 3, 2024 at 11:07 AM Brad Rawson <[e-mail]> wrote:
Jared, let's talk about what needs to be done for this grout sealing rule. I will be having a meeting with the Board and Water committee tomorrow so I wouldlike to be able to report to them.
Thanks,
Brad J. Rawson
Mountainview Steel Detailing
[e-mail]
Office- 801-523-2366
Cell- 801-608-5233
On Thu, Aug 22, 2024 at 2:26 PM <[e-mail]> wrote:
Brad,
I was in a training session for part of this week so apologies for taking so long to get back to your email. I’ll call you tomorrow to discusshow to move forward.

Thank you,
[Quoted text hidden]
WILDERNESS ACRES 20 EXCEPTION REQUEST.pdf
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Julie Cobleigh <[e-mail]>Tue, Nov 26, 2024 at 10:02 AM
To: Brad Rawson <[e-mail]>
Cc: Danielle Zebelean <[e-mail]>, Deidre Beck <[e-mail]>, [e-mail], Marty & Joan Verhoef <[e-mail]>,Chet Cragun <[e-mail]>
Thank you, Brad. We will review this exception request as part of the New PWS review project (File # 13801) and get back to you if we have any questions.
Best,
Julie
1/27/25, 9:07 AM State of Utah Mail - Wilderness Acres Hydraulic Grade
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1806599237931148908&simpl=msg-f:180659923793114890…4/5
Julie Cobleigh, P.E.
Engineer | Permitting
P: [phone]
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRA
[Quoted text hidden]
Deidre Beck <[e-mail]>Wed, Dec 11, 2024 at 1:00 PM
To: Julie Cobleigh <[e-mail]>
Cc: Brad Rawson <[e-mail]>, Danielle Zebelean <[e-mail]>, [e-mail], Marty & Joan Verhoef
<[e-mail]>, Chet Cragun <[e-mail]>
Please be aware that comments on the source protection delineation provided in my email dated August 13, 2024, have not been addressed. I will need to
review the final stamped/signed DWSP plan for the source before I can determine what exceptions are required to the R309-600 rules. I believe the requested
exceptions to date are only for the R309-515 rules.
Let me know if you have any questions.
[Quoted text hidden]
Brad Rawson <[e-mail]>Wed, Jan 15, 2025 at 9:23 AM
To: Deidre Beck <[e-mail]>
Cc: Julie Cobleigh <[e-mail]>, Danielle Zebelean <[e-mail]>, Marty & Joan Verhoef <[e-mail]>
Deidre, I wanted to give you an update on our progress. To meet the requirements of the "source protection delineation" as you conveyed in your email dated
August 13, 2024 we have engaged the support of Hansen Allen & Luce, Inc., they will be able to use modeling software to better identify the needs of that
report.
We want to thank you for your patience as we work through these requirements.

Brad J. Rawson
Mountainview Steel Detailing
[e-mail]
Office- 801-523-2366
Cell- 801-608-5233
[Quoted text hidden]
1/27/25, 9:07 AM State of Utah Mail - Wilderness Acres Hydraulic Grade
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1806599237931148908&simpl=msg-f:180659923793114890…5/5