DDW-2025-000863

Deidre Beck <[e-mail]>
RE: Ephraim City Draft Drinking Water Source Protection Plan
37 messages
Layne Jensen <[e-mail]>Mon, Jan 15, 2024 at 10:41 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of Ephraim’s drinking water
sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and get any necessary
signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that includes all of
Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the PCSs we identified. We are working
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…1/462
towards submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of Franson Civil Engineers or
any CADD adaptation from the specific purpose originally intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER concurrence letter for the North
Well was sent out on November 16, 2022. A full DWSP plan is due for both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…2/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

Deidre Beck <[e-mail]>Tue, Jan 16, 2024 at 10:06 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Hi Layne,
We don't typically review "draft submissions". Our preference is that the document be stamped and signed since this is a
requirement of rule. Any comments can be addressed after the official review.
[Quoted text hidden]
Layne Jensen <[e-mail]>Tue, Jan 16, 2024 at 10:17 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Diedre,

I will get it signed and stamped and get it back to you.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…3/462
Thanks,
[Quoted text hidden]
Layne Jensen <[e-mail]>Wed, Jan 17, 2024 at 3:36 PM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:f0511a8d-
30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,
[Quoted text hidden]
[Quoted text hidden]
Deidre Beck <[e-mail]>Thu, Jan 18, 2024 at 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North Well (WS017), and as
a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also mentioned. Is this supposed to function as an
updated plan for the spring sources? I'm not sure it meets that intent since plan implementation is not discussed for the springs.
Can you verify my understanding?
[Quoted text hidden]
Layne Jensen <[e-mail]>Thu, Jan 18, 2024 at 9:14 AM
To: Deidre Beck <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…4/462
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP. There have been
changes and additions for the wells. There have not been changes or additions for the springs. For the springs,
we simply copied the information for the springs from the 2010 plan without changes other than hopefully improvedmapping and tables identifying the location of the springs. Without changes to the plan for the springs we did not
think to include a plan implementation. We can add a section indicating the information relating to the springs was
copied from the 2010 plan to create a single document for all sources and that those plans have previously been
implemented.
[Quoted text hidden]
Deidre Beck <[e-mail]>Thu, Jan 18, 2024 at 10:03 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
If this will serve as an "update" for the springs, then under each major section you should specify no changes have occurred for
the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs so disregard that statement
from my last email.
As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide any comments
before reviewing the remainder of the plan.
Thanks,
[Quoted text hidden]
Deidre Beck <[e-mail]>Fri, Feb 16, 2024 at 10:40 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Hi Layne,
I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:
Section 2.3 - Aquifer Data
A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is completed in
unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells. If the three wells produce
from different aquifers, separate aquifer parameters need to be developed for each scenario (bedrock and unconsolidated) using
the results of a constant-rate test. Please be sure to confirm that the wells produce from different aquifers before proceeding with
revisions. It may be beneficial to draw a geologic cross-section. If they produce from separate aquifers then they need to be
modeled as such. That means that only the North and Central Wells should be modeled to show interference in WhAEM using
parameters derived from their constant-rate tests and the South Well should be modeled separately, i.e., the zones may overlap
those of the North and Central Wells.
For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test performed on
the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer test and then hydraulic conductivity is
determined using the equation T=K/b. The report states that the "pump data is preliminary; it will be updated once a pump test has
been completed". On page 325 of the PDF, there is data from a "constant flow test" conducted between April 12-13, 2022 on the
"Ephraim North Well Conversion". If these data are from a constant-rate test, they should be used to derive a value for
transmissivity and hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-hour constant-rate
test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv) unless the system wants to request an
exception to rule.
When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over one log cycle)),
I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is twice what is currently being
used in the WhAEM model. The hydraulic conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open
hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is the Central Well (Ephraim Well
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…5/462
#1) from 1991 that was in the appendices. Based on that test, the value for transmissivity also appears to be closer to 14,840
ft2/day. I used the Cooper-Jacob method described above and the values for drawdown at 100 minutes and at ~1000 minutes.
I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of screen was
perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft (open hole portion of
well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in WhAEM or decide what value is most
appropriate. Please update the aquifer parameters used for the North and Central Wells making sure to derive them from
as-built characteristics and the results of a constant-rate aquifer test. The delineation must also be updated to reflect only
interference from these two wells using aquifer parameters representative of bedrock wells if you believe that the three wells
produce from different aquifers.
For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to comply with
R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from 12-19-2019 is for the
South Well. The data do not appear to meet the rule definition for a constant-rate test because the rate was not held constant and
it was not continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let me know if you disagree.
If you think the data can be used to derive aquifer transmissivity, please do so. The updated value for transmissivity and
hydraulic conductivity should be used to remodel the zones for the South Well.
Section 2.7 - Protected Aquifer Classification
Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status have been met.
I am unable to concur with the protected aquifer classification for the South West Well. While it was concurred with in the
PER, the Well Driller's Report does not substantiate that 30 feet of clay were encountered in the uppermost 100 feet. A combined
total of 20 feet of clay was encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well
Driller's Reports near this source and found similar conditions. Given that the zones may change based on my comments above, I
will wait to provide a bunch of feedback on the Potential Contamination Source Inventory (PCS), but I did notice that sewer lines
are listed in zone one for the South Well but then it says under sewer lines in zone 2 that there are no sewer lines in zone 1.
Please update this to be consistent. It also states that it is unknown whether or not sewer lines in zone 2 have been constructed to
the R309-515-6(4) standard. I would imagine they haven't been since the system would have been under no obligation to specially
construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after
remodeling.
I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to avoid
unnecessary work.
Please contact me with any questions.
[Quoted text hidden]
Layne Jensen <[e-mail]>Fri, Feb 16, 2024 at 11:07 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Jeff Jensen <[e-mail]>
Thanks Diedre, we will get right on addressing these comments.
Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:40 AM
[Quoted text hidden]

[Quoted text hidden]
Layne Jensen <[e-mail]>Fri, Mar 1, 2024 at 3:53 PM
To: Deidre Beck <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…6/462
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as
clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different
depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we
videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris. The well is
producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the sourceprotection zones as if they are in the same aquifer since both are producing from fractured bedrock. I think that will
also produce more conservative source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the
city if they want to do another pump test with the installed pump that would stress the well more, but a decision has
not been made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided
above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based
on the video the well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This
calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate,
but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I
would consider a stabilized drawdown. I think the first attempt came close though. I have contacted a
hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of pumping and
recovery data available he felt he could calculate a representative hydraulic conductivity. I will share his conclusionwhen I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing
the well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the
soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP
appendix. We are looking at what is considered a clay differently. I have always felt that a soil that includes clay
will behave hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I would give
my perspective. The presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the
soil than does the presence or absence of sand or gravel. Clay fills the open spaces between the sand and gravel
particles making the soil behave more like a clay from a hydraulic perspective. I do not know whether the soils notidentified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to
be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of
thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction
behave hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the sewer
lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as justification for an
exemption

Thanks,
[Quoted text hidden]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…7/462
Deidre Beck <[e-mail]>Mon, Mar 4, 2024 at 7:58 AM
To: Layne Jensen <[e-mail]>
Hi,
I'm not seeing any attachments. Can you please attach the well log?
[Quoted text hidden]
Layne Jensen <[e-mail]>Mon, Mar 4, 2024 at 8:20 AM
To: Deidre Beck <[e-mail]>
Sorry, attached is the well log.
[Quoted text hidden]
2 attachments
Well Driller's Report.pdf
1615K
WDR Additional Data Form.pdf
690K
Deidre Beck <[e-mail]>Mon, Mar 4, 2024 at 4:55 PM
To: Layne Jensen <[e-mail]>
Hi Layne,
My answers are in red:
Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central well is
drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the bottom
160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are producing
from fractured bedrock. I think that will also produce more conservative source protection zones. What is your thought on this?
If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they want
to do another pump test with the installed pump that would stress the well more, but a decision has not been made yet. I
appreciate your calculations for the hydraulic conductivity. With the information provided above I would propose using a hydraulic
conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water from end of the
casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable
to you?
To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated aquifer
thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably has to do with the
quality of the constant-rate test data. If the system conducts another constant-rate test, the transmissivity could be further refined
but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well protection
zones if that is acceptable.
Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has been
calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down unexpectedly or
was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it fluctuates within the
accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized drawdown. I
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…8/462
think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the
data. With the combination of pumping and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.
Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well log for
the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil descriptions are similar,
but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We are looking at what is
considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay. Ultimately
you will make the call on this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills the open
spaces between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I do not know
whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample
for it to be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking
there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as
a clay the standard is met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a clay
than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to
request an exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and other
information is included as justification for an exemption.
The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would make me
think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the material will likely act
as clay, but the Well Driller's Report does not state anything that leads me to believe there is a predominance of clay besides
between 75-80 feet. I have to make my decision based on the information that is provided. If the Well Driller's Report denoted
"mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I would agree with your
arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes lithologic logs prepared by a
geologist or engineer during the drilling are used to supplement the Well Driller's Report. Since that is not available, I have to base
my decision on what is.
The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of Recharge
Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United States Geological
Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the principal aquifers and
recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water
Rights, and Utah Department of Health, Division of Environmental Health (now DEQ) databases were examined in the study.
Ground-water recharge-area mapping delineated locations where surface contaminants could move down to the principal
aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions between
DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely within the
secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that sufficient
evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the recharge and
discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for the
South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the primary
recharge area.
It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week we
received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed rules
remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer infrastructure in
zone one? If these rules get adopted, then the system will no longer need an exception for the sewer infrastructure currently
located in zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to R309-600-13(3)
and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if
you'd like more information.
[Quoted text hidden]
Layne Jensen <[e-mail]>Tue, Mar 5, 2024 at 10:13 AM
To: Deidre Beck <[e-mail]>
Diedre,

I appreciate your quick and thorough response. We will proceed with the WhAEM modeling based on your
responses. When we have the revised source protection zones for the South Well I will reach out with my thoughts
on the need to request an exemption.
[Quoted text hidden]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:178817913004399…9/462
Layne Jensen <[e-mail]>Wed, Mar 13, 2024 at 9:39 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection zones
based on hydraulic conductivities calculated from testing results. Before making changes to the DWSPP I wanted
to see if you have any concerns with the method and assumptions. I am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area. Assuming
these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination
sources that are now not in a source protection zone. The previous source protection zones were moreconservative from the point of view of including more potential contamination sources. How do you feel about this
approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if
the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North
and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater
than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or
more. In the model a greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock
aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow
is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…10/462
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down twice
and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with specific
capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen length, so
the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let me know
of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central well is
drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the bottom
160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are producing
from fractured bedrock. I think that will also produce more conservative source protection zones. What is your thought on this?

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…11/462
If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they want
to do another pump test with the installed pump that would stress the well more, but a decision has not been made yet. I
appreciate your calculations for the hydraulic conductivity. With the information provided above I would propose using a hydraulic
conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water from end of the
casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable
to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated aquifer
thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably has to do with the
quality of the constant-rate test data. If the system conducts another constant-rate test, the transmissivity could be further refined
but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well protection
zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has been
calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down unexpectedly or
was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it fluctuates within the
accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized drawdown. I
think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the
data. With the combination of pumping and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well log for
the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil descriptions are similar,
but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We are looking at what is
considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay. Ultimately
you will make the call on this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills the open
spaces between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I do not know
whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample
for it to be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking
there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as
a clay the standard is met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a clay
than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to
request an exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and other
information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would make me
think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the material will likely act
as clay, but the Well Driller's Report does not state anything that leads me to believe there is a predominance of clay besides
between 75-80 feet. I have to make my decision based on the information that is provided. If the Well Driller's Report denoted
"mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I would agree with your
arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes lithologic logs prepared by a
geologist or engineer during the drilling are used to supplement the Well Driller's Report. Since that is not available, I have to base
my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of Recharge
Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United States Geological
Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the principal aquifers and
recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water
Rights, and Utah Department of Health, Division of Environmental Health (now DEQ) databases were examined in the study.
Ground-water recharge-area mapping delineated locations where surface contaminants could move down to the principal
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…12/462
aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions between
DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely within the
secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that sufficient
evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the recharge and
discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for the
South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the primary
recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week we
received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed rules
remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer infrastructure in
zone one? If these rules get adopted, then the system will no longer need an exception for the sewer infrastructure currently
located in zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to R309-600-13(3)
and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if
you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as
clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…13/462
different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but
when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris.
The well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model
the source protection zones as if they are in the same aquifer since both are producing from fractured
bedrock. I think that will also produce more conservative source protection zones. What is your thought on
this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with
the city if they want to do another pump test with the installed pump that would stress the well more, but a
decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the
information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer
thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable to
you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the
well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does
fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not
achieve what I would consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of
pumping and recovery data available he felt he could calculate a representative hydraulic conductivity. I will
share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In the top
100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it
to the DWSPP appendix. We are looking at what is considered a clay differently. I have always felt that a soil
that includes clay will behave hydraulically more like a clay. Ultimately you will make the call on this.
However, I thought I would give my perspective. The presence or absence of clay in a soil has far more
impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills
the open spaces between the sand and gravel particles making the soil behave more like a clay from a
hydraulic perspective. I do not know whether the soils not identified as a straight clay are a sandy/gravely clayor a clayey sand, but if there is enough clay in a sample for it to be identified as having clay, I feel there is
enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the
top 100 feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a clay the
standard is met. However, I believe any soil with a significant clay fraction will behave hydraulically more like
a clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2.
We will assess the need to request an exemption after receiving your thoughts on this and redoing the
modeling. It could be that my logic above and other information is included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…14/462
From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is completed in
unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells. If the three wells
produce from different aquifers, separate aquifer parameters need to be developed for each scenario (bedrock and
unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the wells produce from different
aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they produce from
separate aquifers then they need to be modeled as such. That means that only the North and Central Wells should be
modeled to show interference in WhAEM using parameters derived from their constant-rate tests and the South Well should
be modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test performed
on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer test and then hydraulic conductivity is
determined using the equation T=K/b. The report states that the "pump data is preliminary; it will be updated once a pump
test has been completed". On page 325 of the PDF, there is data from a "constant flow test" conducted between April 12-13,
2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate test, they should be used to derive a
value for transmissivity and hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-hour
constant-rate test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv) unless the system wants
to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over one log
cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is twice what is
currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be equal to K = 14360
ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is the
Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for transmissivity also
appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the values for drawdown at
100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of screen
was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft (open hole
portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in WhAEM or decide what
value is most appropriate. Please update the aquifer parameters used for the North and Central Wells making sure to
derive them from as-built characteristics and the results of a constant-rate aquifer test. The delineation must also be
updated to reflect only interference from these two wells using aquifer parameters representative of bedrock wells if you
believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to comply with
R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from 12-19-2019 is for
the South Well. The data do not appear to meet the rule definition for a constant-rate test because the rate was not held
constant and it was not continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let me
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…15/462
know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so. The updated value for
transmissivity and hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status have
been met. I am unable to concur with the protected aquifer classification for the South West Well. While it was
concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were encountered in the
uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost 100 feet between 0-15 feet
and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar conditions. Given that the zones
may change based on my comments above, I will wait to provide a bunch of feedback on the Potential Contamination
Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the South Well but then it says under
sewer lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It also states that it is
unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4) standard. I would imagine they
haven't been since the system would have been under no obligation to specially construct them. Exceptions to R309-600-
13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to avoid
unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes have
occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs so
disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide any
comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP. There
have been changes and additions for the wells. There have not been changes or additions for the
springs. For the springs, we simply copied the information for the springs from the 2010 plan without
changes other than hopefully improved mapping and tables identifying the location of the springs.
Without changes to the plan for the springs we did not think to include a plan implementation. We can
add a section indicating the information relating to the springs was copied from the 2010 plan to create a
single document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…16/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North Well
(WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also mentioned. Is this
supposed to function as an updated plan for the spring sources? I'm not sure it meets that intent since plan
implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…17/462
We don't typically review "draft submissions". Our preference is that the document be stamped and signed since this
is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of Ephraim’s
drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and get any
necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that
includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the PCSs
we identified. We are working towards submitting a draft DWSP by November 16, 2023.

Thank you,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…18/462

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of Franson Civil
Engineers or any CADD adaptation from the specific purpose originally intended shall be at the owner's risk and full legal
responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER concurrence
letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for both by 11/16/2023.

Thanks,

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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…19/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…20/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…21/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…22/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…23/462
7 attachments
Old and New Well Protection Zones.jpg
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South Well PCS Locations.jpg
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New Zone Boundaries.jpg
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Central Well PCS Locations.jpg
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North Well PCS Locations.jpg
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image006.jpg
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f11415bf-2bc9-464d-8b8e-aaddab2afc8d.png
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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…24/462
Deidre Beck <[e-mail]>Wed, Mar 13, 2024 at 10:21 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
I will review the information you have submitted and respond by the end of the week.
[Quoted text hidden]
Layne Jensen <[e-mail]>Wed, Mar 13, 2024 at 10:53 AM
To: Deidre Beck <[e-mail]>
Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 10:21 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I will review the information you have submitted and respond by the end of the week.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection zones
based on hydraulic conductivities calculated from testing results. Before making changes to the DWSPP I
wanted to see if you have any concerns with the method and assumptions. I am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones were
more conservative from the point of view of including more potential contamination sources. How do you feel
about this approach?

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…25/462
The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if
the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North
and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater
than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or
more. In the model a greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen length,
so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let me
know of any concerns you may have.

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…26/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central well
is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the
bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone at a
depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are
producing from fractured bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they
want to do another pump test with the installed pump that would stress the well more, but a decision has not been made yet. I
appreciate your calculations for the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water
from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this
seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably has to
do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the transmissivity could be
further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well protection
zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has
been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down unexpectedly
or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it fluctuates within the
accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized drawdown. I
think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the
data. With the combination of pumping and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…27/462
Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well log
for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil descriptions are
similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We are looking at what
is considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. The presence or absence of clay in a
soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills
the open spaces between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I
do not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough
clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In
this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction
behave hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will behave
hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and
2. We will assess the need to request an exemption after receiving your thoughts on this and redoing the modeling. It could be
that my logic above and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would make me
think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the material will likely
act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a predominance of clay
besides between 75-80 feet. I have to make my decision based on the information that is provided. If the Well Driller's Report
denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I would agree
with your arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes lithologic logs
prepared by a geologist or engineer during the drilling are used to supplement the Well Driller's Report. Since that is not
available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United States
Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the principal
aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the USGS, Utah
Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ) databases were
examined in the study. Ground-water recharge-area mapping delineated locations where surface contaminants could move
down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely within
the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that sufficient
evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the recharge and
discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for the
South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the primary
recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week we
received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed rules
remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer infrastructure in
zone one? If these rules get adopted, then the system will no longer need an exception for the sewer infrastructure currently
located in zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to R309-600-13(3)
and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if
you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…28/462
Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not
as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing
from different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445feet, but when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with
debris. The well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined
to model the source protection zones as if they are in the same aquifer since both are producing from
fractured bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more, but
a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the
information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquiferthickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable
to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model
the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate doesfluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not
achieve what I would consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination
of pumping and recovery data available he felt he could calculate a representative hydraulic conductivity. I
will share his conclusion when I receive it next week.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…29/462
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In the
top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and will
add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have always felt
that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make the call on
this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel.
Clay fills the open spaces between the sand and gravel particles making the soil behave more like a clay
from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as havingclay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is
70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave
hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the
sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your
thoughts on this and redoing the modeling. It could be that my logic above and other information is included
as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is completed
in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells. If the three wells
produce from different aquifers, separate aquifer parameters need to be developed for each scenario (bedrock and
unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the wells produce from different
aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they produce from
separate aquifers then they need to be modeled as such. That means that only the North and Central Wells should be
modeled to show interference in WhAEM using parameters derived from their constant-rate tests and the South Well
should be modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that the PWS
shall obtain the hydraulic conductivity of the aquifer from a constant-rate aquifer test and provide the data as
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…30/462
described in R309-515-6(10)(b). Typically the transmissivity is determined from the constant-rate aquifer test and then
hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is preliminary; it will
be updated once a pump test has been completed". On page 325 of the PDF, there is data from a "constant flow test"
conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate test,
they should be used to derive a value for transmissivity and hydraulic conductivity for use in the WhAEM model for the
bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the North Well to comply with R309-
600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over one log
cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is twice what is
currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be equal to K = 14360
ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is
the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for transmissivity
also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the values for
drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of screen
was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft (open hole
portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in WhAEM or decide
what value is most appropriate. Please update the aquifer parameters used for the North and Central Wells making
sure to derive them from as-built characteristics and the results of a constant-rate aquifer test. The delineation
must also be updated to reflect only interference from these two wells using aquifer parameters representative of bedrock
wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to comply
with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from 12-19-2019
is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because the rate was not
held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let
me know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so. The updated
value for transmissivity and hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status have
been met. I am unable to concur with the protected aquifer classification for the South West Well. While it was
concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were encountered in the
uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost 100 feet between 0-15
feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the Potential
Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the South Well but then
it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It also
states that it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4) standard. I
would imagine they haven't been since the system would have been under no obligation to specially construct them.
Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to avoid
unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes have
occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs so
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…31/462
disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide any
comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP. There
have been changes and additions for the wells. There have not been changes or additions for the
springs. For the springs, we simply copied the information for the springs from the 2010 plan without
changes other than hopefully improved mapping and tables identifying the location of the springs.
Without changes to the plan for the springs we did not think to include a plan implementation. We can
add a section indicating the information relating to the springs was copied from the 2010 plan to create
a single document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North Well
(WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also mentioned. Is
this supposed to function as an updated plan for the spring sources? I'm not sure it meets that intent since plan
implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…32/462
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed since
this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of Ephraim’s
drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and get
any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…33/462
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that
includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the
PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of Franson
Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the owner's risk and
full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER concurrence
letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for both by
11/16/2023.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…34/462
Thanks,

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.

--
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.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…35/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…36/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…37/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…38/462
--
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.

--
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.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…39/462

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Deidre Beck <[e-mail]>Wed, Mar 13, 2024 at 4:25 PM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
Layne,
I have looked over the information you provided. My comments are in red, below. Please reach out with any further questions.
I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for the
North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system would
prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test data or use an
empirical approach like Neil did for the South Well.
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that are
now not in a source protection zone. The previous source protection zones were more conservative from the point of view of
including more potential contamination sources. How do you feel about this approach? It may be difficult for the system to
manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land management strategies have been
implemented for any not adequately controlled PCSs when the plan is updated during the normal update cycle. If you decide to go
this route, please add a column or in some way denote which PCSs are actually within the final zones and which are not so that
the system and DDW staff can discern the difference.
North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the actual
pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the pump in the
well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the thicknesses
used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and Central wells are
drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the North Well. Assuming
they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the model a greater thickness
reduces the size of the source protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you
can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one value/assumes
the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…40/462
[Quoted text hidden]
Layne Jensen <[e-mail]>Thu, Mar 14, 2024 at 7:43 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
Diedre,

I appreciate your quick response to our questions. We will get a revised DWSPP to you soon. Given your
guidance I feel it is best to remove the potential contamination sources that are not within the source protection
zones.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for the
North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system would
prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test data or use an
empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that are
now not in a source protection zone. The previous source protection zones were more conservative from the point of view of
including more potential contamination sources. How do you feel about this approach? It may be difficult for the system to
manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land management strategies have been
implemented for any not adequately controlled PCSs when the plan is updated during the normal update cycle. If you decide to go
this route, please add a column or in some way denote which PCSs are actually within the final zones and which are not so that
the system and DDW staff can discern the difference.

North and Central Well
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…41/462
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the actual
pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the pump in the
well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the thicknesses
used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and Central wells are
drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the North Well. Assuming
they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the model a greater thickness
reduces the size of the source protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you
can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one value/assumes
the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection zonesbased on hydraulic conductivities calculated from testing results. Before making changes to the DWSPP I
wanted to see if you have any concerns with the method and assumptions. I am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones were
more conservative from the point of view of including more potential contamination sources. How do you feel
about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…42/462
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if
the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North
and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater
than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or
more. In the model a greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen length,
so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let me
know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…43/462
From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central well
is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the
bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone at a
depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are
producing from fractured bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they
want to do another pump test with the installed pump that would stress the well more, but a decision has not been made yet. I
appreciate your calculations for the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water
from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this
seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably has to
do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the transmissivity could be
further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well protection
zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has
been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down unexpectedly
or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it fluctuates within the
accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized drawdown. I
think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the
data. With the combination of pumping and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well log
for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil descriptions are
similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We are looking at what
is considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. The presence or absence of clay in a
soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills
the open spaces between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…44/462
do not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough
clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In
this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction
behave hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will behave
hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and
2. We will assess the need to request an exemption after receiving your thoughts on this and redoing the modeling. It could be
that my logic above and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would make me
think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the material will likely
act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a predominance of clay
besides between 75-80 feet. I have to make my decision based on the information that is provided. If the Well Driller's Report
denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I would agree
with your arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes lithologic logs
prepared by a geologist or engineer during the drilling are used to supplement the Well Driller's Report. Since that is not
available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United States
Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the principal
aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the USGS, Utah
Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ) databases were
examined in the study. Ground-water recharge-area mapping delineated locations where surface contaminants could move
down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely within
the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that sufficient
evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the recharge and
discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for the
South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the primary
recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week we
received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed rules
remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer infrastructure in
zone one? If these rules get adopted, then the system will no longer need an exception for the sewer infrastructure currently
located in zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to R309-600-13(3)
and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if
you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…45/462
From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not
as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing
from different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445
feet, but when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled withdebris. The well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined
to model the source protection zones as if they are in the same aquifer since both are producing from
fractured bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more, but
a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the
information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer
thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’ to thebottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable
to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model
the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does
fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did notachieve what I would consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination
of pumping and recovery data available he felt he could calculate a representative hydraulic conductivity. I
will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In the
top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and will
add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have always felt
that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make the call onthis. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…46/462
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel.
Clay fills the open spaces between the sand and gravel particles making the soil behave more like a clay
from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having
clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is
70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave
hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the
sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your
thoughts on this and redoing the modeling. It could be that my logic above and other information is includedas justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is completed
in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells. If the three wells
produce from different aquifers, separate aquifer parameters need to be developed for each scenario (bedrock and
unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the wells produce from different
aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they produce from
separate aquifers then they need to be modeled as such. That means that only the North and Central Wells should be
modeled to show interference in WhAEM using parameters derived from their constant-rate tests and the South Well
should be modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer test and then
hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is preliminary; it will
be updated once a pump test has been completed". On page 325 of the PDF, there is data from a "constant flow test"
conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate test,
they should be used to derive a value for transmissivity and hydraulic conductivity for use in the WhAEM model for the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…47/462
bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the North Well to comply with R309-
600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over one log
cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is twice what is
currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be equal to K = 14360
ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is
the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for transmissivity
also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the values for
drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of screen
was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft (open hole
portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in WhAEM or decide
what value is most appropriate. Please update the aquifer parameters used for the North and Central Wells making
sure to derive them from as-built characteristics and the results of a constant-rate aquifer test. The delineation
must also be updated to reflect only interference from these two wells using aquifer parameters representative of bedrock
wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to comply
with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from 12-19-2019
is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because the rate was not
held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let
me know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so. The updated
value for transmissivity and hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status have
been met. I am unable to concur with the protected aquifer classification for the South West Well. While it was
concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were encountered in the
uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost 100 feet between 0-15
feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the Potential
Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the South Well but then
it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It also
states that it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4) standard. I
would imagine they haven't been since the system would have been under no obligation to specially construct them.
Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to avoid
unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes have
occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs so
disregard that statement from my last email.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…48/462
As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide any
comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP. There
have been changes and additions for the wells. There have not been changes or additions for the
springs. For the springs, we simply copied the information for the springs from the 2010 plan without
changes other than hopefully improved mapping and tables identifying the location of the springs.
Without changes to the plan for the springs we did not think to include a plan implementation. We can
add a section indicating the information relating to the springs was copied from the 2010 plan to createa single document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North Well
(WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also mentioned. Is
this supposed to function as an updated plan for the spring sources? I'm not sure it meets that intent since plan
implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…49/462

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed since
this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of Ephraim’s
drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and get
any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…50/462
From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that
includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the
PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of Franson
Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the owner's risk and
full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER concurrence
letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for both by
11/16/2023.

Thanks,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…51/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…52/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…53/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…54/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…55/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…56/462
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Layne Jensen <[e-mail]>Mon, Mar 25, 2024 at 9:34 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected aquifer
status for the South Well. In your previous email you mention that a portion of well protection zone 2 for the South
Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a protected aquifer. With the
revised well protection zones for the South Well being significantly smaller with the lower hydraulic conductivity and
pumping rate I was wondering if you could look at the mapping you have for Sanpete County and let me know if
portions of well protection zone 2 is still identified as being in a primary recharge area? The report you referenced
in your email about your concerns related to whether the South Well met the criteria for protected aquifer status did
not include Sanpete County or I would check myself. I would like to reference the study in the DWSPP. Please
give me the reference for the report/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can
justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is potential for
a sewer line to be constructed about 80 feet from the well. There are existing sewer lines within zone 2. Any new
sewer lines constructed within zone 1 would need to comply with R309-515-6(4). Depending on the decision on the
protected aquifer status Ephraim may need to seek a temporary exemption for sewer lines in zone 2. What is the
process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…57/462
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for the
North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system would
prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test data or use an
empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that are
now not in a source protection zone. The previous source protection zones were more conservative from the point of view of
including more potential contamination sources. How do you feel about this approach? It may be difficult for the system to
manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land management strategies have been
implemented for any not adequately controlled PCSs when the plan is updated during the normal update cycle. If you decide to go
this route, please add a column or in some way denote which PCSs are actually within the final zones and which are not so that
the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the actual
pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the pump in the
well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the thicknesses
used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and Central wells are
drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the North Well. Assuming
they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the model a greater thickness
reduces the size of the source protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you
can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one value/assumes
the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…58/462
I appreciate your help on improving the source protection zones. We have updated the source protection zones
based on hydraulic conductivities calculated from testing results. Before making changes to the DWSPP I
wanted to see if you have any concerns with the method and assumptions. I am attaching the following maps:

North Well protection zonesCentral Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones were
more conservative from the point of view of including more potential contamination sources. How do you feelabout this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if
the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North
and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater
than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or
more. In the model a greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…59/462
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen length,
so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let meknow of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central well
is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the
bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone at a
depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are
producing from fractured bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they
want to do another pump test with the installed pump that would stress the well more, but a decision has not been made yet. I
appreciate your calculations for the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water
from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this
seem reasonable to you?

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…60/462
To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably has to
do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the transmissivity could be
further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well protection
zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has
been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down unexpectedly
or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it fluctuates within the
accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized drawdown. I
think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the
data. With the combination of pumping and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well log
for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil descriptions are
similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We are looking at what
is considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. The presence or absence of clay in a
soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills
the open spaces between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I
do not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough
clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In
this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction
behave hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will behave
hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and
2. We will assess the need to request an exemption after receiving your thoughts on this and redoing the modeling. It could be
that my logic above and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would make me
think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the material will likely
act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a predominance of clay
besides between 75-80 feet. I have to make my decision based on the information that is provided. If the Well Driller's Report
denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I would agree
with your arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes lithologic logs
prepared by a geologist or engineer during the drilling are used to supplement the Well Driller's Report. Since that is not
available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United States
Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the principal
aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the USGS, Utah
Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ) databases were
examined in the study. Ground-water recharge-area mapping delineated locations where surface contaminants could move
down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely within
the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that sufficient
evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the recharge and
discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for the
South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the primary
recharge area.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…61/462
It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week we
received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed rules
remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer infrastructure in
zone one? If these rules get adopted, then the system will no longer need an exception for the sewer infrastructure currently
located in zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to R309-600-13(3)
and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if
you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not
as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing
from different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445
feet, but when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with
debris. The well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined
to model the source protection zones as if they are in the same aquifer since both are producing from
fractured bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more, but
a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…62/462
information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer
thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable
to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model
the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does
fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not
achieve what I would consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination
of pumping and recovery data available he felt he could calculate a representative hydraulic conductivity. I
will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In the
top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and will
add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have always felt
that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make the call on
this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel.
Clay fills the open spaces between the sand and gravel particles making the soil behave more like a clay
from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are asandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having
clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is
70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave
hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the
sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your
thoughts on this and redoing the modeling. It could be that my logic above and other information is included
as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…63/462
I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is completed
in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells. If the three wells
produce from different aquifers, separate aquifer parameters need to be developed for each scenario (bedrock and
unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the wells produce from different
aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they produce from
separate aquifers then they need to be modeled as such. That means that only the North and Central Wells should be
modeled to show interference in WhAEM using parameters derived from their constant-rate tests and the South Well
should be modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer test and then
hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is preliminary; it will
be updated once a pump test has been completed". On page 325 of the PDF, there is data from a "constant flow test"
conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate test,
they should be used to derive a value for transmissivity and hydraulic conductivity for use in the WhAEM model for the
bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the North Well to comply with R309-
600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over one log
cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is twice what is
currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be equal to K = 14360
ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is
the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for transmissivity
also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the values for
drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of screen
was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft (open hole
portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in WhAEM or decide
what value is most appropriate. Please update the aquifer parameters used for the North and Central Wells making
sure to derive them from as-built characteristics and the results of a constant-rate aquifer test. The delineation
must also be updated to reflect only interference from these two wells using aquifer parameters representative of bedrock
wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to comply
with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from 12-19-2019
is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because the rate was not
held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let
me know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so. The updated
value for transmissivity and hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status have
been met. I am unable to concur with the protected aquifer classification for the South West Well. While it was
concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were encountered in the
uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost 100 feet between 0-15
feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the Potential
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…64/462
Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the South Well but then
it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It also
states that it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4) standard. I
would imagine they haven't been since the system would have been under no obligation to specially construct them.
Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to avoid
unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes have
occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs so
disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide any
comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP. There
have been changes and additions for the wells. There have not been changes or additions for the
springs. For the springs, we simply copied the information for the springs from the 2010 plan without
changes other than hopefully improved mapping and tables identifying the location of the springs.
Without changes to the plan for the springs we did not think to include a plan implementation. We can
add a section indicating the information relating to the springs was copied from the 2010 plan to create
a single document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…65/462
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North Well
(WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also mentioned. Is
this supposed to function as an updated plan for the spring sources? I'm not sure it meets that intent since plan
implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed since
this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of Ephraim’s
drinking water sources including the mountain springs and three wells.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…66/462

Please review and provide any comments you may have. We will finalize the document and get
any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that
includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the
PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…67/462

Any use or reuse of original or altered files by the owner or others without the express written verification of Franson
Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the owner's risk and
full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER concurrence
letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for both by
11/16/2023.

Thanks,

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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…68/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…69/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…70/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…71/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…72/462
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.

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Deidre Beck <[e-mail]>Mon, Mar 25, 2024 at 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong report.
You can access the correct report here. It looks like the new zone two is almost entirely within the secondary recharge area. To be
clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of zone 2, not necessarily
whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can try to argue protected aquifer
status, but it is unlikely I will be able to concur with that classification since the Well Driller's report does not indicate that 30 feet of
clay was encountered.
Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and R309-515-
6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to R309-600-13(3) and
R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared by a consultant, but we prefer
that the letter be signed by the system because we have had situations in the past where systems had no idea that exceptions
had been requested or granted. Historically, the Division has required information on the age of the sewer infrastructure, which
portions of the rules are not being met, etc. We have also required inspection by video/camera of any sewer lines located within
zones one and/or two. It appears that these sewer lines may be newer, just based on aerial photography, so a camera inspection
may have been done recently that would fulfill this requirement. Typically the conditions for granting the exceptions will be to
camera/video at least once every 3 years, and there may be additional nitrate monitoring required. Once the new rules are
enacted, those requirements will no longer be required.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…73/462
Let me know if you have any other questions.
On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected aquifer
status for the South Well. In your previous email you mention that a portion of well protection zone 2 for the
South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a protected aquifer.
With the revised well protection zones for the South Well being significantly smaller with the lower hydraulic
conductivity and pumping rate I was wondering if you could look at the mapping you have for Sanpete County
and let me know if portions of well protection zone 2 is still identified as being in a primary recharge area? The
report you referenced in your email about your concerns related to whether the South Well met the criteria for
protected aquifer status did not include Sanpete County or I would check myself. I would like to reference the
study in the DWSPP. Please give me the reference for the report/mapping for Sanpete County. I am hopeful thatwith the smaller Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is potential
for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines within zone 2. Any
new sewer lines constructed within zone 1 would need to comply with R309-515-6(4). Depending on the decision
on the protected aquifer status Ephraim may need to seek a temporary exemption for sewer lines in zone 2.
What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for the
North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system would
prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test data or use
an empirical approach like Neil did for the South Well.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…74/462
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that are
now not in a source protection zone. The previous source protection zones were more conservative from the point of view of
including more potential contamination sources. How do you feel about this approach? It may be difficult for the system to
manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land management strategies have
been implemented for any not adequately controlled PCSs when the plan is updated during the normal update cycle. If you
decide to go this route, please add a column or in some way denote which PCSs are actually within the final zones and which
are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the actual
pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the pump in
the well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and
Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the
North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness assumed provides a more
conservative estimate. Yes, you can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds
good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection
zones based on hydraulic conductivities calculated from testing results. Before making changes to the
DWSPP I wanted to see if you have any concerns with the method and assumptions. I am attaching the
following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…75/462
contamination sources that are now not in a source protection zone. The previous source protection zones
were more conservative from the point of view of including more potential contamination sources. How do you
feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but
the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so
that if the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the
North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth
much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer
to 200 feet or more. In the model a greater thickness reduces the size of the source protection zones. The lower
thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen length,
so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let me
know of any concerns you may have.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…76/462
Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central
well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that
the bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone at
a depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since both
are producing from fractured bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they
want to do another pump test with the installed pump that would stress the well more, but a decision has not been made yet.
I appreciate your calculations for the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water
from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does
this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably has to
do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the transmissivity could
be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has
been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it
fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a
stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…77/462
he felt he could do with the data. With the combination of pumping and recovery data available he felt he could calculate a
representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well
log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil descriptions
are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We are looking at
what is considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. The presence or absence of clay
in a soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel.
Clay fills the open spaces between the sand and gravel particles making the soil behave more like a clay from a hydraulic
perspective. I do not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if
there is enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to behave
hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified
as having a clay fraction behave hydraulically as a clay the standard is met. However, I believe any soil with a significant
clay fraction will behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the
sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would make
me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the material will
likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a predominance of
clay besides between 75-80 feet. I have to make my decision based on the information that is provided. If the Well Driller's
Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I
would agree with your arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes
lithologic logs prepared by a geologist or engineer during the drilling are used to supplement the Well Driller's Report. Since
that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United
States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the
principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the
USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ)
databases were examined in the study. Ground-water recharge-area mapping delineated locations where surface
contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely within
the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that sufficient
evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the recharge and
discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for
the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the
primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week
we received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed
rules remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer
infrastructure in zone one? If these rules get adopted, then the system will no longer need an exception for the sewer
infrastructure currently located in zone two. Due to the timing, it may be necessary for the system to request temporary
exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no
longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…78/462

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is
not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they aredrawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had caved
in or filled with debris. The well is producing its water from a water bearing zone at a depth of about 285
feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are
producing from fractured bedrock. I think that will also produce more conservative source protection
zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more,
but a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. Withthe information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an
aquifer thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’
to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem
reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generatorshut down unexpectedly or was turned off during both of our attempts at a long term test. The pumping
rate does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the
well did not achieve what I would consider a stabilized drawdown. I think the first attempt came close
though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…79/462
the combination of pumping and recovery data available he felt he could calculate a representative
hydraulic conductivity. I will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. Inthe top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email
and will add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have
always felt that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make
the call on this. However, I thought I would give my perspective. The presence or absence of clay in a
soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence of
sand or gravel. Clay fills the open spaces between the sand and gravel particles making the soil behave
more like a clay from a hydraulic perspective. I do not know whether the soils not identified as a straight
clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified
as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of
thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay
fraction behave hydraulically as a clay the standard is met. However, I believe any soil with a significant
clay fraction will behave hydraulically more like a clay than a sand or gravel. We will correct the
inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above
and other information is included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells. If
the three wells produce from different aquifers, separate aquifer parameters need to be developed for each scenario
(bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the wells produce
from different aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they
produce from separate aquifers then they need to be modeled as such. That means that only the North and
Central Wells should be modeled to show interference in WhAEM using parameters derived from their constant-rate
tests and the South Well should be modeled separately, i.e., the zones may overlap those of the North and Central
Wells.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…80/462

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer test
and then hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is
preliminary; it will be updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are
from a constant-rate test, they should be used to derive a value for transmissivity and hydraulic conductivity for use in
the WhAEM model for the bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the
North Well to comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over one
log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is twice
what is currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be equal to
K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I
assume is the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for
transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the
values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of
screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft
(open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in
WhAEM or decide what value is most appropriate. Please update the aquifer parameters used for the North and
Central Wells making sure to derive them from as-built characteristics and the results of a constant-rate aquifer
test. The delineation must also be updated to reflect only interference from these two wells using aquifer parameters
representative of bedrock wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to comply
with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from 12-19-
2019 is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because the rate
was not held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized drawdown".
Please let me know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so. The
updated value for transmissivity and hydraulic conductivity should be used to remodel the zones for the South
Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status have
been met. I am unable to concur with the protected aquifer classification for the South West Well. While it was
concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were encountered in the
uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost 100 feet between 0-15
feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the Potential
Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the South Well but
then it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It
also states that it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4)
standard. I would imagine they haven't been since the system would have been under no obligation to specially
construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2
after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to avoid
unnecessary work.

Please contact me with any questions.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…81/462

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes have
occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs so
disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide any
comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP. There
have been changes and additions for the wells. There have not been changes or additions for the
springs. For the springs, we simply copied the information for the springs from the 2010 plan without
changes other than hopefully improved mapping and tables identifying the location of the springs.
Without changes to the plan for the springs we did not think to include a plan implementation. We
can add a section indicating the information relating to the springs was copied from the 2010 plan to
create a single document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North Well
(WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also mentioned. Is
this supposed to function as an updated plan for the spring sources? I'm not sure it meets that intent since plan
implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…82/462

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed
since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of Ephraim’s
drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and get
any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…83/462

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that
includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the
PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of
Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the
owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…84/462

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for both
by 11/16/2023.

Thanks,

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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…85/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…86/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…87/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…88/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…89/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.
b27754a7-480d-4e29-a187-7c307c4394a4.png
5K
Layne Jensen <[e-mail]>Fri, Mar 29, 2024 at 1:00 PM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1 for the
South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject to the rules untilthe rule change is completed. Ephraim City will be seeking an exemption until the rule change is finalized. As far
as the sewer in Zone 2 being a potential contamination source should it be identified as controlled or not
adequately controlled? If it is considered not adequately controlled, after the rule change would that change? Any
suggestions how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…90/462
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong report.
You can access the correct report here. It looks like the new zone two is almost entirely within the secondary recharge area. To be
clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of zone 2, not necessarily
whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can try to argue protected aquifer
status, but it is unlikely I will be able to concur with that classification since the Well Driller's report does not indicate that 30 feet of
clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and R309-515-
6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to R309-600-13(3) and
R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared by a consultant, but we prefer
that the letter be signed by the system because we have had situations in the past where systems had no idea that exceptions
had been requested or granted. Historically, the Division has required information on the age of the sewer infrastructure, which
portions of the rules are not being met, etc. We have also required inspection by video/camera of any sewer lines located within
zones one and/or two. It appears that these sewer lines may be newer, just based on aerial photography, so a camera inspection
may have been done recently that would fulfill this requirement. Typically the conditions for granting the exceptions will be to
camera/video at least once every 3 years, and there may be additional nitrate monitoring required. Once the new rules are
enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected aquifer
status for the South Well. In your previous email you mention that a portion of well protection zone 2 for the
South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a protected aquifer.
With the revised well protection zones for the South Well being significantly smaller with the lower hydraulic
conductivity and pumping rate I was wondering if you could look at the mapping you have for Sanpete County
and let me know if portions of well protection zone 2 is still identified as being in a primary recharge area? Thereport you referenced in your email about your concerns related to whether the South Well met the criteria for
protected aquifer status did not include Sanpete County or I would check myself. I would like to reference the
study in the DWSPP. Please give me the reference for the report/mapping for Sanpete County. I am hopeful that
with the smaller Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is potential
for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines within zone 2. Any
new sewer lines constructed within zone 1 would need to comply with R309-515-6(4). Depending on the
decision on the protected aquifer status Ephraim may need to seek a temporary exemption for sewer lines in
zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…91/462

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for the
North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system would
prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test data or use
an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that are
now not in a source protection zone. The previous source protection zones were more conservative from the point of view of
including more potential contamination sources. How do you feel about this approach? It may be difficult for the system to
manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land management strategies have
been implemented for any not adequately controlled PCSs when the plan is updated during the normal update cycle. If you
decide to go this route, please add a column or in some way denote which PCSs are actually within the final zones and which
are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the actual
pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the pump in
the well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and
Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the
North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness assumed provides a more
conservative estimate. Yes, you can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds
good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…92/462

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection
zones based on hydraulic conductivities calculated from testing results. Before making changes to the
DWSPP I wanted to see if you have any concerns with the method and assumptions. I am attaching the
following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potentialcontamination sources that are now not in a source protection zone. The previous source protection zones
were more conservative from the point of view of including more potential contamination sources. How do you
feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but
the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so
that if the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the
North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth
much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer
to 200 feet or more. In the model a greater thickness reduces the size of the source protection zones. The lower
thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…93/462

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen length,
so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let me
know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central
well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that
the bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone at
a depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since both
are producing from fractured bedrock. I think that will also produce more conservative source protection zones. What is
your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…94/462
want to do another pump test with the installed pump that would stress the well more, but a decision has not been made yet.
I appreciate your calculations for the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water
from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does
this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably has
to do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the transmissivity could
be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has
been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it
fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a
stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what
he felt he could do with the data. With the combination of pumping and recovery data available he felt he could calculate a
representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well
log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil descriptions
are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We are looking at
what is considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a
clay. Ultimately you will make the call on this. However, I thought I would give my perspective. The presence or absence of
clay in a soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or
gravel. Clay fills the open spaces between the sand and gravel particles making the soil behave more like a clay from a
hydraulic perspective. I do not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey
sand, but if there is enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to
behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils
identified as having a clay fraction behave hydraulically as a clay the standard is met. However, I believe any soil with a
significant clay fraction will behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency
regarding the sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your thoughts
on this and redoing the modeling. It could be that my logic above and other information is included as justification for an
exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would make
me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the material will
likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a predominance of
clay besides between 75-80 feet. I have to make my decision based on the information that is provided. If the Well Driller's
Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I
would agree with your arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes
lithologic logs prepared by a geologist or engineer during the drilling are used to supplement the Well Driller's Report. Since
that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United
States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the
principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the
USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ)
databases were examined in the study. Ground-water recharge-area mapping delineated locations where surface
contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…95/462
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely
within the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that
sufficient evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the
recharge and discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed
zone two for the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two was
located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week
we received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed
rules remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer
infrastructure in zone one? If these rules get adopted, then the system will no longer need an exception for the sewer
infrastructure currently located in zone two. Due to the timing, it may be necessary for the system to request temporary
exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no
longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is
not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had
caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…96/462
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer
since both are producing from fractured bedrock. I think that will also produce more conservative source
protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussingwith the city if they want to do another pump test with the installed pump that would stress the well more,
but a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With
the information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an
aquifer thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’
to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem
reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator
shut down unexpectedly or was turned off during both of our attempts at a long term test. The pumping
rate does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the
well did not achieve what I would consider a stabilized drawdown. I think the first attempt came close
though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With
the combination of pumping and recovery data available he felt he could calculate a representative
hydraulic conductivity. I will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it wasmissing the well log for the actual production well. The well log in the appendix was for the test well. In
the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email
and will add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have
always felt that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make
the call on this. However, I thought I would give my perspective. The presence or absence of clay in a
soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence of
sand or gravel. Clay fills the open spaces between the sand and gravel particles making the soil behave
more like a clay from a hydraulic perspective. I do not know whether the soils not identified as a straight
clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified
as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of
thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clayfraction behave hydraulically as a clay the standard is met. However, I believe any soil with a significant
clay fraction will behave hydraulically more like a clay than a sand or gravel. We will correct the
inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above
and other information is included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…97/462
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells. If
the three wells produce from different aquifers, separate aquifer parameters need to be developed for each scenario
(bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the wells produce
from different aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they
produce from separate aquifers then they need to be modeled as such. That means that only the North and
Central Wells should be modeled to show interference in WhAEM using parameters derived from their constant-rate
tests and the South Well should be modeled separately, i.e., the zones may overlap those of the North and Central
Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer test
and then hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is
preliminary; it will be updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are
from a constant-rate test, they should be used to derive a value for transmissivity and hydraulic conductivity for use in
the WhAEM model for the bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the
North Well to comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over one
log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is twice
what is currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be equal to
K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I
assume is the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for
transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the
values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of
screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft
(open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in
WhAEM or decide what value is most appropriate. Please update the aquifer parameters used for the North and
Central Wells making sure to derive them from as-built characteristics and the results of a constant-rate
aquifer test. The delineation must also be updated to reflect only interference from these two wells using aquifer
parameters representative of bedrock wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to comply
with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from 12-19-
2019 is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because the rate
was not held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized
drawdown". Please let me know if you disagree. If you think the data can be used to derive aquifer transmissivity,
please do so. The updated value for transmissivity and hydraulic conductivity should be used to remodel the
zones for the South Well.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…98/462

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status have
been met. I am unable to concur with the protected aquifer classification for the South West Well. While it was
concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were encountered in the
uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost 100 feet between 0-15
feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the Potential
Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the South Well but
then it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It
also states that it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4)
standard. I would imagine they haven't been since the system would have been under no obligation to specially
construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2
after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to avoid
unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes have
occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs so
disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide
any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP. There
have been changes and additions for the wells. There have not been changes or additions for the
springs. For the springs, we simply copied the information for the springs from the 2010 plan without
changes other than hopefully improved mapping and tables identifying the location of the springs.
Without changes to the plan for the springs we did not think to include a plan implementation. We
can add a section indicating the information relating to the springs was copied from the 2010 plan to
create a single document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…99/462
Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North Well
(WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also mentioned. Is
this supposed to function as an updated plan for the spring sources? I'm not sure it meets that intent since plan
implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed
since this is a requirement of rule. Any comments can be addressed after the official review.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…100/462

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of Ephraim’s
drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and getany necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that
includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the
PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…101/462
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of
Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the
owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for
both by 11/16/2023.

Thanks,

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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…102/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…103/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…104/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…105/462
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

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requirements.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
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Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

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requirements.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…107/462
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Deidre Beck <[e-mail]>Fri, Mar 29, 2024 at 1:05 PM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-600-
13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using one of the
four control types. Did I answer all of your questions?
On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1 for the
South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject to the rules
until the rule change is completed. Ephraim City will be seeking an exemption until the rule change is finalized.
As far as the sewer in Zone 2 being a potential contamination source should it be identified as controlled or notadequately controlled? If it is considered not adequately controlled, after the rule change would that change?
Any suggestions how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…108/462
From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong
report. You can access the correct report here. It looks like the new zone two is almost entirely within the secondary recharge
area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of zone 2, not
necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can try to argue
protected aquifer status, but it is unlikely I will be able to concur with that classification since the Well Driller's report does not
indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and R309-
515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to R309-600-13(3)
and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared by a consultant, but we
prefer that the letter be signed by the system because we have had situations in the past where systems had no idea that
exceptions had been requested or granted. Historically, the Division has required information on the age of the sewer
infrastructure, which portions of the rules are not being met, etc. We have also required inspection by video/camera of any
sewer lines located within zones one and/or two. It appears that these sewer lines may be newer, just based on aerial
photography, so a camera inspection may have been done recently that would fulfill this requirement. Typically the conditions for
granting the exceptions will be to camera/video at least once every 3 years, and there may be additional nitrate monitoring
required. Once the new rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected aquifer
status for the South Well. In your previous email you mention that a portion of well protection zone 2 for the
South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a protected
aquifer. With the revised well protection zones for the South Well being significantly smaller with the lower
hydraulic conductivity and pumping rate I was wondering if you could look at the mapping you have for
Sanpete County and let me know if portions of well protection zone 2 is still identified as being in a primary
recharge area? The report you referenced in your email about your concerns related to whether the South
Well met the criteria for protected aquifer status did not include Sanpete County or I would check myself. I
would like to reference the study in the DWSPP. Please give me the reference for the report/mapping for
Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines within
zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-6(4). Depending
on the decision on the protected aquifer status Ephraim may need to seek a temporary exemption for sewer
lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…109/462
Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for the
North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system would
prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test data or
use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that
are now not in a source protection zone. The previous source protection zones were more conservative from the point of
view of including more potential contamination sources. How do you feel about this approach? It may be difficult for the
system to manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land
management strategies have been implemented for any not adequately controlled PCSs when the plan is updated during the
normal update cycle. If you decide to go this route, please add a column or in some way denote which PCSs are actually
within the final zones and which are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the
pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and
Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the
North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness assumed provides a more
conservative estimate. Yes, you can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds
good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…110/462
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection
zones based on hydraulic conductivities calculated from testing results. Before making changes to the
DWSPP I wanted to see if you have any concerns with the method and assumptions. I am attaching the
following maps:

North Well protection zonesCentral Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones
were more conservative from the point of view of including more potential contamination sources. How doyou feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows,
but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher
flow so that if the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than
the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming
the North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a
depth much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is
probably closer to 200 feet or more. In the model a greater thickness reduces the size of the source protection
zones. The lower thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:17881791300439…111/462
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen
length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let
me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for the
Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The central
well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that
the bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water bearing zone
at a depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer since
both are producing from fractured bedrock. I think that will also produce more conservative source protection zones.
What is your thought on this?
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…112/462

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if
they want to do another pump test with the installed pump that would stress the well more, but a decision has not been
made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well
is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity
of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably
has to do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the
transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that has
been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it
fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a
stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see
what he felt he could do with the data. With the combination of pumping and recovery data available he felt he could
calculate a representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the well
log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil
descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We
are looking at what is considered a clay differently. I have always felt that a soil that includes clay will behave hydraulically
more like a clay. Ultimately you will make the call on this. However, I thought I would give my perspective. The presence
or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than does the presence or
absence of sand or gravel. Clay fills the open spaces between the sand and gravel particles making the soil behave more
like a clay from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having clay, I feel there
is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100
feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a clay the standard is met.
However, I believe any soil with a significant clay fraction will behave hydraulically more like a clay than a sand or gravel.
We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and other
information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would
make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the
material will likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a
predominance of clay besides between 75-80 feet. I have to make my decision based on the information that is provided. If
the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay was
predominant, I would agree with your arguments. I also reviewed other well logs near this source to come to my
conclusion. Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used to supplement the
Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United
States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…113/462
principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the
USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ)
databases were examined in the study. Ground-water recharge-area mapping delineated locations where surface
contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely
within the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that
sufficient evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the
recharge and discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source.
Proposed zone two for the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone
Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week
we received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed
rules remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer
infrastructure in zone one? If these rules get adopted, then the system will no longer need an exception for the sewer
infrastructure currently located in zone two. Due to the timing, it may be necessary for the system to request temporary
exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will
no longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…114/462
Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is
not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had
caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer
since both are producing from fractured bedrock. I think that will also produce more conservative
source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am
discussing with the city if they want to do another pump test with the installed pump that would stress
the well more, but a decision has not been made yet. I appreciate your calculations for the hydraulic
conductivity. With the information provided above I would propose using a hydraulic conductivity of
14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water from
end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of
359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator
shut down unexpectedly or was turned off during both of our attempts at a long term test. The pumping
rate does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the
well did not achieve what I would consider a stabilized drawdown. I think the first attempt came close
though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of pumping and recovery data available he felt he could calculate a representative
hydraulic conductivity. I will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it
was missing the well log for the actual production well. The well log in the appendix was for the test
well. In the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to
this email and will add it to the DWSPP appendix. We are looking at what is considered a clay
differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. The
presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil thandoes the presence or absence of sand or gravel. Clay fills the open spaces between the sand and
gravel particles making the soil behave more like a clay from a hydraulic perspective. I do not know
whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there
is enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to
behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if
only half of the soils identified as having a clay fraction behave hydraulically as a clay the standard is
met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a
clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and
2. We will assess the need to request an exemption after receiving your thoughts on this and redoing
the modeling. It could be that my logic above and other information is included as justification for an
exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…115/462

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells.
If the three wells produce from different aquifers, separate aquifer parameters need to be developed for each
scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the
wells produce from different aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-
section. If they produce from separate aquifers then they need to be modeled as such. That means that only
the North and Central Wells should be modeled to show interference in WhAEM using parameters derived from their
constant-rate tests and the South Well should be modeled separately, i.e., the zones may overlap those of the North
and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer
test and then hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is
preliminary; it will be updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are
from a constant-rate test, they should be used to derive a value for transmissivity and hydraulic conductivity for use in
the WhAEM model for the bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the
North Well to comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over
one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is
twice what is currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be
equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data
provided for what I assume is the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on
that test, the value for transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method
described above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of
screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15 ft
(open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in
WhAEM or decide what value is most appropriate. Please update the aquifer parameters used for the North and
Central Wells making sure to derive them from as-built characteristics and the results of a constant-rate
aquifer test. The delineation must also be updated to reflect only interference from these two wells using aquifer
parameters representative of bedrock wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to
comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…116/462
12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because
the rate was not held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized
drawdown". Please let me know if you disagree. If you think the data can be used to derive aquifer transmissivity,
please do so. The updated value for transmissivity and hydraulic conductivity should be used to remodel the
zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status
have been met. I am unable to concur with the protected aquifer classification for the South West Well. While
it was concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were
encountered in the uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost
100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar
conditions. Given that the zones may change based on my comments above, I will wait to provide a bunch of
feedback on the Potential Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone
one for the South Well but then it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please
update this to be consistent. It also states that it is unknown whether or not sewer lines in zone 2 have been
constructed to the R309-515-6(4) standard. I would imagine they haven't been since the system would have been
under no obligation to specially construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required
depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to
avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes have
occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the springs
so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide
any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP.
There have been changes and additions for the wells. There have not been changes or additions
for the springs. For the springs, we simply copied the information for the springs from the 2010
plan without changes other than hopefully improved mapping and tables identifying the location of
the springs. Without changes to the plan for the springs we did not think to include a plan
implementation. We can add a section indicating the information relating to the springs was copied
from the 2010 plan to create a single document for all sources and that those plans have
previously been implemented.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…117/462
Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North
Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also
mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not sure it meets that
intent since plan implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…118/462
Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed
since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and
get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP that
includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy of the
PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…119/462
Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of
Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the
owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for
both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…120/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…121/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…122/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…123/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…124/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…125/462
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.
2 attachments
image008.jpg
5K
4da3b9bd-f1dc-471a-9ef5-d7d958d97bb3.png
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Layne Jensen <[e-mail]>Fri, Mar 29, 2024 at 1:08 PM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>
Yes, thank you

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…126/462
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-600-
13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using one of the
four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1 for theSouth Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject to the rules
until the rule change is completed. Ephraim City will be seeking an exemption until the rule change is finalized.
As far as the sewer in Zone 2 being a potential contamination source should it be identified as controlled or not
adequately controlled? If it is considered not adequately controlled, after the rule change would that change?
Any suggestions how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong
report. You can access the correct report here. It looks like the new zone two is almost entirely within the secondary recharge
area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of zone 2, not
necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can try to argue
protected aquifer status, but it is unlikely I will be able to concur with that classification since the Well Driller's report does not
indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and R309-
515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to R309-600-13(3)
and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared by a consultant, but we
prefer that the letter be signed by the system because we have had situations in the past where systems had no idea that
exceptions had been requested or granted. Historically, the Division has required information on the age of the sewer
infrastructure, which portions of the rules are not being met, etc. We have also required inspection by video/camera of any
sewer lines located within zones one and/or two. It appears that these sewer lines may be newer, just based on aerial
photography, so a camera inspection may have been done recently that would fulfill this requirement. Typically the conditions
for granting the exceptions will be to camera/video at least once every 3 years, and there may be additional nitrate monitoring
required. Once the new rules are enacted, those requirements will no longer be required.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…127/462

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection zone 2
for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a protected
aquifer. With the revised well protection zones for the South Well being significantly smaller with the lower
hydraulic conductivity and pumping rate I was wondering if you could look at the mapping you have for
Sanpete County and let me know if portions of well protection zone 2 is still identified as being in a primary
recharge area? The report you referenced in your email about your concerns related to whether the South
Well met the criteria for protected aquifer status did not include Sanpete County or I would check myself. I
would like to reference the study in the DWSPP. Please give me the reference for the report/mapping for
Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines within
zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-6(4). Depending
on the decision on the protected aquifer status Ephraim may need to seek a temporary exemption for sewer
lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for
the North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system
would prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test
data or use an empirical approach like Neil did for the South Well.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…128/462

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that
are now not in a source protection zone. The previous source protection zones were more conservative from the point of
view of including more potential contamination sources. How do you feel about this approach? It may be difficult for the
system to manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land
management strategies have been implemented for any not adequately controlled PCSs when the plan is updated during the
normal update cycle. If you decide to go this route, please add a column or in some way denote which PCSs are actually
within the final zones and which are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the
pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and
Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the
North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness assumed provides a more
conservative estimate. Yes, you can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds
good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection
zones based on hydraulic conductivities calculated from testing results. Before making changes to the
DWSPP I wanted to see if you have any concerns with the method and assumptions. I am attaching the
following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…129/462
The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete the previously
identified potential contamination sources that are now not in a source protection zone. The previous
source protection zones were more conservative from the point of view of including more potential
contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows,
but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher
flow so that if the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than
the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming
the North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a
depth much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is
probably closer to 200 feet or more. In the model a greater thickness reduces the size of the source protection
zones. The lower thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen
length, so the hydraulic conductivity is 4.8 ft/day.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…130/462
Ultimately many conservative assumptions are made to compensate for limited available data. Please let
me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for
the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The
central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we
learned that the bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water
bearing zone at a depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same
aquifer since both are producing from fractured bedrock. I think that will also produce more conservative source
protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if
they want to do another pump test with the installed pump that would stress the well more, but a decision has not been
made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well
is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity
of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably
has to do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the
transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that
has been calculated. If you can't use two different values, then an average of the two could be used.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…131/462

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it
fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider
a stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see
what he felt he could do with the data. With the combination of pumping and recovery data available he felt he could
calculate a representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the
well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil
descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix.
We are looking at what is considered a clay differently. I have always felt that a soil that includes clay will behave
hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I would give my perspective.
The presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than does the
presence or absence of sand or gravel. Clay fills the open spaces between the sand and gravel particles making the soil
behave more like a clay from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are
a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having clay, I feel
there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top
100 feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a clay the standard is
met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a clay than a sand or
gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request
an exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and other
information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would
make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the
material will likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a
predominance of clay besides between 75-80 feet. I have to make my decision based on the information that is provided.
If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay
was predominant, I would agree with your arguments. I also reviewed other well logs near this source to come to my
conclusion. Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used to supplement the
Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United
States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the
principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the
USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ)
databases were examined in the study. Ground-water recharge-area mapping delineated locations where surface
contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely
within the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that
sufficient evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the
recharge and discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source.
Proposed zone two for the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone
Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week
we received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed
rules remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer
infrastructure in zone one? If these rules get adopted, then the system will no longer need an exception for the sewer
infrastructure currently located in zone two. Due to the timing, it may be necessary for the system to request temporary
exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will
no longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…132/462
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It isnot as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had
caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer
since both are producing from fractured bedrock. I think that will also produce more conservative
source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am
discussing with the city if they want to do another pump test with the installed pump that would stressthe well more, but a decision has not been made yet. I appreciate your calculations for the hydraulic
conductivity. With the information provided above I would propose using a hydraulic conductivity of
14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water from
end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of
359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…133/462
South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator
shut down unexpectedly or was turned off during both of our attempts at a long term test. The pumping
rate does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the
well did not achieve what I would consider a stabilized drawdown. I think the first attempt came close
though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data.
With the combination of pumping and recovery data available he felt he could calculate a representative
hydraulic conductivity. I will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it
was missing the well log for the actual production well. The well log in the appendix was for the test
well. In the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to
this email and will add it to the DWSPP appendix. We are looking at what is considered a clay
differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. The
presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than
does the presence or absence of sand or gravel. Clay fills the open spaces between the sand and
gravel particles making the soil behave more like a clay from a hydraulic perspective. I do not know
whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there
is enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to
behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even ifonly half of the soils identified as having a clay fraction behave hydraulically as a clay the standard is
met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a
clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and
2. We will assess the need to request an exemption after receiving your thoughts on this and redoing
the modeling. It could be that my logic above and other information is included as justification for an
exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…134/462
If the three wells produce from different aquifers, separate aquifer parameters need to be developed for each
scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the
wells produce from different aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-
section. If they produce from separate aquifers then they need to be modeled as such. That means that only
the North and Central Wells should be modeled to show interference in WhAEM using parameters derived from their
constant-rate tests and the South Well should be modeled separately, i.e., the zones may overlap those of the North
and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer
test and then hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is
preliminary; it will be updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are
from a constant-rate test, they should be used to derive a value for transmissivity and hydraulic conductivity for use
in the WhAEM model for the bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on
the North Well to comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over
one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is
twice what is currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be
equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data
provided for what I assume is the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on
that test, the value for transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method
described above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of
screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15
ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in
WhAEM or decide what value is most appropriate. Please update the aquifer parameters used for the North and
Central Wells making sure to derive them from as-built characteristics and the results of a constant-rate
aquifer test. The delineation must also be updated to reflect only interference from these two wells using aquifer
parameters representative of bedrock wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to
comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from
12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because
the rate was not held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized
drawdown". Please let me know if you disagree. If you think the data can be used to derive aquifer transmissivity,
please do so. The updated value for transmissivity and hydraulic conductivity should be used to remodel the
zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status
have been met. I am unable to concur with the protected aquifer classification for the South West Well. While
it was concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were
encountered in the uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost
100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar
conditions. Given that the zones may change based on my comments above, I will wait to provide a bunch of
feedback on the Potential Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone
one for the South Well but then it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please
update this to be consistent. It also states that it is unknown whether or not sewer lines in zone 2 have been
constructed to the R309-515-6(4) standard. I would imagine they haven't been since the system would have been
under no obligation to specially construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required
depending on the extent of zone 2 after remodeling.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…135/462
I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to
avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes
have occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the
springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide
any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP.
There have been changes and additions for the wells. There have not been changes or additions
for the springs. For the springs, we simply copied the information for the springs from the 2010
plan without changes other than hopefully improved mapping and tables identifying the location of
the springs. Without changes to the plan for the springs we did not think to include a plan
implementation. We can add a section indicating the information relating to the springs was copied
from the 2010 plan to create a single document for all sources and that those plans have
previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North
Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…136/462
mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not sure it meets that
intent since plan implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed
since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and
get any necessary signatures after your review.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…137/462
I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP
that includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy
of the PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of
Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the
owner's risk and full legal responsibility.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…138/462
From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for
both by 11/16/2023.

Thanks,

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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…139/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…140/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…141/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…142/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…143/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…144/462
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.

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Layne Jensen <[e-mail]>Fri, May 24, 2024 at 1:23 PM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water Source
Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that you can use to
download the full document with appendicies. Included in the DWSPP and attached to this email is a letter
requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking an exemption until the
rule is formally changed. The sewer line in question is not currently in use and will likely be replaced with a larger
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…145/462
pipeline in the next year or two. Please inform the city if the new sewer line will need to comply with requirements
in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-600-
13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using one of the
four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1 for the
South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject to the rules
until the rule change is completed. Ephraim City will be seeking an exemption until the rule change is finalized.
As far as the sewer in Zone 2 being a potential contamination source should it be identified as controlled or not
adequately controlled? If it is considered not adequately controlled, after the rule change would that change?
Any suggestions how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…146/462
From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong
report. You can access the correct report here. It looks like the new zone two is almost entirely within the secondary recharge
area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of zone 2, not
necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can try to argue
protected aquifer status, but it is unlikely I will be able to concur with that classification since the Well Driller's report does not
indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and R309-
515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to R309-600-13(3)
and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared by a consultant, but we
prefer that the letter be signed by the system because we have had situations in the past where systems had no idea that
exceptions had been requested or granted. Historically, the Division has required information on the age of the sewer
infrastructure, which portions of the rules are not being met, etc. We have also required inspection by video/camera of any
sewer lines located within zones one and/or two. It appears that these sewer lines may be newer, just based on aerial
photography, so a camera inspection may have been done recently that would fulfill this requirement. Typically the conditions
for granting the exceptions will be to camera/video at least once every 3 years, and there may be additional nitrate monitoring
required. Once the new rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection zone 2
for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a protected
aquifer. With the revised well protection zones for the South Well being significantly smaller with the lower
hydraulic conductivity and pumping rate I was wondering if you could look at the mapping you have for
Sanpete County and let me know if portions of well protection zone 2 is still identified as being in a primary
recharge area? The report you referenced in your email about your concerns related to whether the South
Well met the criteria for protected aquifer status did not include Sanpete County or I would check myself. I
would like to reference the study in the DWSPP. Please give me the reference for the report/mapping for
Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines within
zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-6(4). Depending
on the decision on the protected aquifer status Ephraim may need to seek a temporary exemption for sewer
lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…147/462
Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for
the North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system
would prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test
data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources that
are now not in a source protection zone. The previous source protection zones were more conservative from the point of
view of including more potential contamination sources. How do you feel about this approach? It may be difficult for the
system to manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land
management strategies have been implemented for any not adequately controlled PCSs when the plan is updated during the
normal update cycle. If you decide to go this route, please add a column or in some way denote which PCSs are actually
within the final zones and which are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if the
pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North and
Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater than the
North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness assumed provides a more
conservative estimate. Yes, you can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total rainfall/snowfall
SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock aquifer. Sounds
good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow is
assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…148/462
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge value.
Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection
zones based on hydraulic conductivities calculated from testing results. Before making changes to the
DWSPP I wanted to see if you have any concerns with the method and assumptions. I am attaching the
following maps:

North Well protection zonesCentral Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete the previously
identified potential contamination sources that are now not in a source protection zone. The previous
source protection zones were more conservative from the point of view of including more potentialcontamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows,
but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher
flow so that if the pump in the well is replaced to increase production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than
the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming
the North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a
depth much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is
probably closer to 200 feet or more. In the model a greater thickness reduces the size of the source protection
zones. The lower thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…149/462
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut down
twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an empirical method with
specific capacity. I used the Mace (2001) method to estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen
length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let
me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for
the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The
central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we
learned that the bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a water
bearing zone at a depth of about 285 feet. I am inclined to model the source protection zones as if they are in the same
aquifer since both are producing from fractured bedrock. I think that will also produce more conservative source
protection zones. What is your thought on this?
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…150/462

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model them
together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if
they want to do another pump test with the installed pump that would stress the well more, but a decision has not been
made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well
is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity
of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the saturated
aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It probably
has to do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the
transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that
has been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it
fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider
a stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see
what he felt he could do with the data. With the combination of pumping and recovery data available he felt he could
calculate a representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the
well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil
descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix.
We are looking at what is considered a clay differently. I have always felt that a soil that includes clay will behave
hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I would give my perspective.
The presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than does the
presence or absence of sand or gravel. Clay fills the open spaces between the sand and gravel particles making the soil
behave more like a clay from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are
a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having clay, I feel
there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top
100 feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a clay the standard is
met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a clay than a sand or
gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request
an exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and other
information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would
make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the
material will likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a
predominance of clay besides between 75-80 feet. I have to make my decision based on the information that is provided.
If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me think that clay
was predominant, I would agree with your arguments. I also reviewed other well logs near this source to come to my
conclusion. Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used to supplement the
Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United
States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…151/462
principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the
USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ)
databases were examined in the study. Ground-water recharge-area mapping delineated locations where surface
contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely
within the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider that
sufficient evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped the
recharge and discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source.
Proposed zone two for the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone
Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last week
we received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The proposed
rules remove the special construction requirements in zone two regardless of aquifer type. I assume there isn't sewer
infrastructure in zone one? If these rules get adopted, then the system will no longer need an exception for the sewer
infrastructure currently located in zone two. Due to the timing, it may be necessary for the system to request temporary
exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will
no longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…152/462
Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is
not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had
caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifersince both are producing from fractured bedrock. I think that will also produce more conservative
source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am
discussing with the city if they want to do another pump test with the installed pump that would stress
the well more, but a decision has not been made yet. I appreciate your calculations for the hydraulic
conductivity. With the information provided above I would propose using a hydraulic conductivity of
14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water from
end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of
359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator
shut down unexpectedly or was turned off during both of our attempts at a long term test. The pumping
rate does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the
well did not achieve what I would consider a stabilized drawdown. I think the first attempt came close
though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of pumping and recovery data available he felt he could calculate a representative
hydraulic conductivity. I will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it
was missing the well log for the actual production well. The well log in the appendix was for the test
well. In the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to
this email and will add it to the DWSPP appendix. We are looking at what is considered a clay
differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. The
presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil thandoes the presence or absence of sand or gravel. Clay fills the open spaces between the sand and
gravel particles making the soil behave more like a clay from a hydraulic perspective. I do not know
whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there
is enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to
behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if
only half of the soils identified as having a clay fraction behave hydraulically as a clay the standard is
met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a
clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and
2. We will assess the need to request an exemption after receiving your thoughts on this and redoing
the modeling. It could be that my logic above and other information is included as justification for an
exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…153/462

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North Wells.
If the three wells produce from different aquifers, separate aquifer parameters need to be developed for each
scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm that the
wells produce from different aquifers before proceeding with revisions. It may be beneficial to draw a geologic cross-
section. If they produce from separate aquifers then they need to be modeled as such. That means that only
the North and Central Wells should be modeled to show interference in WhAEM using parameters derived from their
constant-rate tests and the South Well should be modeled separately, i.e., the zones may overlap those of the North
and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states that 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). Typically the transmissivity is determined from the constant-rate aquifer
test and then hydraulic conductivity is determined using the equation T=K/b. The report states that the "pump data is
preliminary; it will be updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are
from a constant-rate test, they should be used to derive a value for transmissivity and hydraulic conductivity for use
in the WhAEM model for the bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on
the North Well to comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over
one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This is
twice what is currently being used in the WhAEM model. The hydraulic conductivity for the North Well would then be
equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test data
provided for what I assume is the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on
that test, the value for transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method
described above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of
screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/ 15
ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity in
WhAEM or decide what value is most appropriate. Please update the aquifer parameters used for the North and
Central Wells making sure to derive them from as-built characteristics and the results of a constant-rate
aquifer test. The delineation must also be updated to reflect only interference from these two wells using aquifer
parameters representative of bedrock wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to
comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report from
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…154/462
12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a constant-rate test because
the rate was not held constant and it was not continued for at least 24 hours or until the Well experienced "stabilized
drawdown". Please let me know if you disagree. If you think the data can be used to derive aquifer transmissivity,
please do so. The updated value for transmissivity and hydraulic conductivity should be used to remodel the
zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status
have been met. I am unable to concur with the protected aquifer classification for the South West Well. While
it was concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were
encountered in the uppermost 100 feet. A combined total of 20 feet of clay was encountered in the uppermost
100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's Reports near this source and found similar
conditions. Given that the zones may change based on my comments above, I will wait to provide a bunch of
feedback on the Potential Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone
one for the South Well but then it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please
update this to be consistent. It also states that it is unknown whether or not sewer lines in zone 2 have been
constructed to the R309-515-6(4) standard. I would imagine they haven't been since the system would have been
under no obligation to specially construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required
depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to
avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes
have occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the
springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and provide
any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP.
There have been changes and additions for the wells. There have not been changes or additions
for the springs. For the springs, we simply copied the information for the springs from the 2010
plan without changes other than hopefully improved mapping and tables identifying the location of
the springs. Without changes to the plan for the springs we did not think to include a plan
implementation. We can add a section indicating the information relating to the springs was copied
from the 2010 plan to create a single document for all sources and that those plans have
previously been implemented.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…155/462
Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North
Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also
mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not sure it meets that
intent since plan implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…156/462
Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed
since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and
get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: hps://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP
that includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the accuracy
of the PCSs we identified. We are working towards submitting a draft DWSP by November 16, 2023.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…157/462
Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of
Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the
owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due for
both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…158/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…159/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…160/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…161/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…162/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…163/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
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Deidre Beck <[e-mail]>Tue, May 28, 2024 at 11:46 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any other
questions.
On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water Source
Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that you can use to
download the full document with appendicies. Included in the DWSPP and attached to this email is a letter
requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking an exemption until the
rule is formally changed. The sewer line in question is not currently in use and will likely be replaced with a larger
pipeline in the next year or two. Please inform the city if the new sewer line will need to comply with requirements
in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…165/462
From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-600-
13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using one of the
four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1 for the
South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject to the rules
until the rule change is completed. Ephraim City will be seeking an exemption until the rule change is
finalized. As far as the sewer in Zone 2 being a potential contamination source should it be identified as
controlled or not adequately controlled? If it is considered not adequately controlled, after the rule change
would that change? Any suggestions how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong
report. You can access the correct report here. It looks like the new zone two is almost entirely within the secondary recharge
area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of zone 2, not
necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can try to argue
protected aquifer status, but it is unlikely I will be able to concur with that classification since the Well Driller's report does not
indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and R309-
515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to R309-600-
13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared by a
consultant, but we prefer that the letter be signed by the system because we have had situations in the past where systems
had no idea that exceptions had been requested or granted. Historically, the Division has required information on the age of
the sewer infrastructure, which portions of the rules are not being met, etc. We have also required inspection by
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…166/462
video/camera of any sewer lines located within zones one and/or two. It appears that these sewer lines may be newer, just
based on aerial photography, so a camera inspection may have been done recently that would fulfill this requirement.
Typically the conditions for granting the exceptions will be to camera/video at least once every 3 years, and there may be
additional nitrate monitoring required. Once the new rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection zone 2for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a
protected aquifer. With the revised well protection zones for the South Well being significantly smaller with
the lower hydraulic conductivity and pumping rate I was wondering if you could look at the mapping you have
for Sanpete County and let me know if portions of well protection zone 2 is still identified as being in a
primary recharge area? The report you referenced in your email about your concerns related to whether the
South Well met the criteria for protected aquifer status did not include Sanpete County or I would check
myself. I would like to reference the study in the DWSPP. Please give me the reference for the
report/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a protected
aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines within
zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-6(4).
Depending on the decision on the protected aquifer status Ephraim may need to seek a temporary
exemption for sewer lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…167/462

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity for
the North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the system
would prefer to make the zones smaller for management purposes, you could try to refine the value for T using better test
data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources not
previously included in a source protection zone, but not delete the previously identified potential contamination sources
that are now not in a source protection zone. The previous source protection zones were more conservative from the point
of view of including more potential contamination sources. How do you feel about this approach? It may be difficult for the
system to manage a larger number of PCSs and it will make it difficult for DDW staff to determine if land
management strategies have been implemented for any not adequately controlled PCSs when the plan is updated during
the normal update cycle. If you decide to go this route, please add a column or in some way denote which PCSs are
actually within the final zones and which are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but the
actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so that if
the pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North
and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater
than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or
more. In the model a greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate. Yes, you can always use a smaller aquifer thickness as it is considered more
conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured bedrock
aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher flow
is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source protection
zones based on hydraulic conductivities calculated from testing results. Before making changes to the
DWSPP I wanted to see if you have any concerns with the method and assumptions. I am attaching the
following maps:

North Well protection zones
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…168/462
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete the previously
identified potential contamination sources that are now not in a source protection zone. The previous
source protection zones were more conservative from the point of view of including more potential
contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows,
but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the
higher flow so that if the pump in the well is replaced to increase production the DWSPP would not need to be
updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than
the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming
the North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a
depth much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is
probably closer to 200 feet or more. In the model a greater thickness reduces the size of the source protection
zones. The lower thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts
one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the
fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut
down twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an
empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with the following
parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…169/462
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen
length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let
me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear for
the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths. The
central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the well we
learned that the bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from a
water bearing zone at a depth of about 285 feet. I am inclined to model the source protection zones as if they are in the
same aquifer since both are producing from fractured bedrock. I think that will also produce more conservative source
protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model
them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if
they want to do another pump test with the installed pump that would stress the well more, but a decision has not been
made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the
well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a
transmissivity of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the
saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers. It
probably has to do with the quality of the constant-rate test data. If the system conducts another constant-rate test, the
transmissivity could be further refined but I'm not suggesting they have to do that.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…170/462
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity that
has been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it
fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would
consider a stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil
Burk) to see what he felt he could do with the data. With the combination of pumping and recovery data available he
felt he could calculate a representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing the
well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the soil
descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP appendix.
We are looking at what is considered a clay differently. I have always felt that a soil that includes clay will behave
hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I would give my
perspective. The presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than
does the presence or absence of sand or gravel. Clay fills the open spaces between the sand and gravel particles
making the soil behave more like a clay from a hydraulic perspective. I do not know whether the soils not identified as a
straight clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as
having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70
feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a
clay the standard is met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a
clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will
assess the need to request an exemption after receiving your thoughts on this and redoing the modeling. It could be
that my logic above and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would
make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then the
material will likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there is a
predominance of clay besides between 75-80 feet. I have to make my decision based on the information that is
provided. If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me think
that clay was predominant, I would agree with your arguments. I also reviewed other well logs near this source to come
to my conclusion. Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used to
supplement the Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology of
Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah; United
States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report mapped the
principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from 2,828 wells in
the USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental Health (now DEQ)
databases were examined in the study. Ground-water recharge-area mapping delineated locations where surface
contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on discussions
between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two are completely
within the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff would consider
that sufficient evidence to demonstrate the extent of the clay layer throughout zone two. Anderson and others mapped
the recharge and discharge areas based on dominantly clay layers, 20 feet thick or more. I checked this data source.
Proposed zone two for the South Well was not entirely within the secondary recharge area or discharge area. Part of
Zone Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last
week we received approval from the DDW board to move forward with rule-making regarding the sewer line rules. The
proposed rules remove the special construction requirements in zone two regardless of aquifer type. I assume there
isn't sewer infrastructure in zone one? If these rules get adopted, then the system will no longer need an exception for
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…171/462
the sewer infrastructure currently located in zone two. Due to the timing, it may be necessary for the system to request
temporary exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the
exceptions will no longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It
is not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had
caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer
since both are producing from fractured bedrock. I think that will also produce more conservative
source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I amdiscussing with the city if they want to do another pump test with the installed pump that would stress
the well more, but a decision has not been made yet. I appreciate your calculations for the hydraulic
conductivity. With the information provided above I would propose using a hydraulic conductivity of
14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water
from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a
transmissivity of 359 ft/day. Does this seem reasonable to you?
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…172/462

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator
shut down unexpectedly or was turned off during both of our attempts at a long term test. The
pumping rate does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%).
I agree the well did not achieve what I would consider a stabilized drawdown. I think the first attemptcame close though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do
with the data. With the combination of pumping and recovery data available he felt he could calculate
a representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it
was missing the well log for the actual production well. The well log in the appendix was for the test
well. In the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to
this email and will add it to the DWSPP appendix. We are looking at what is considered a clay
differently. I have always felt that a soil that includes clay will behave hydraulically more like a clay.
Ultimately you will make the call on this. However, I thought I would give my perspective. Thepresence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than
does the presence or absence of sand or gravel. Clay fills the open spaces between the sand and
gravel particles making the soil behave more like a clay from a hydraulic perspective. I do not know
whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if
there is enough clay in a sample for it to be identified as having clay, I feel there is enough clay for
the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100
feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a clay
the standard is met. However, I believe any soil with a significant clay fraction will behave
hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the
sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your
thoughts on this and redoing the modeling. It could be that my logic above and other information is
included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…173/462

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North
Wells. If the three wells produce from different aquifers, separate aquifer parameters need to be developed for
each scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm
that the wells produce from different aquifers before proceeding with revisions. It may be beneficial to draw a
geologic cross-section. If they produce from separate aquifers then they need to be modeled as such. That
means that only the North and Central Wells should be modeled to show interference in WhAEM using parameters
derived from their constant-rate tests and the South Well should be modeled separately, i.e., the zones may
overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer test
performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states
that 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). Typically the transmissivity is determined from the
constant-rate aquifer test and then hydraulic conductivity is determined using the equation T=K/b. The report
states that the "pump data is preliminary; it will be updated once a pump test has been completed". On page 325
of the PDF, there is data from a "constant flow test" conducted between April 12-13, 2022 on the "Ephraim North
Well Conversion". If these data are from a constant-rate test, they should be used to derive a value for
transmissivity and hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-
hour constant-rate test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv) unless the
system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown over
one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I use. This
is twice what is currently being used in the WhAEM model. The hydraulic conductivity for the North Well would
then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at the pump test
data provided for what I assume is the Central Well (Ephraim Well #1) from 1991 that was in the appendices.
Based on that test, the value for transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-
Jacob method described above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet of
screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840 ft2/day/
15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic conductivity
in WhAEM or decide what value is most appropriate. Please update the aquifer parameters used for the North
and Central Wells making sure to derive them from as-built characteristics and the results of a constant-
rate aquifer test. The delineation must also be updated to reflect only interference from these two wells using
aquifer parameters representative of bedrock wells if you believe that the three wells produce from different
aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to
comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report
from 12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a constant-rate test
because the rate was not held constant and it was not continued for at least 24 hours or until the Well experienced
"stabilized drawdown". Please let me know if you disagree. If you think the data can be used to derive aquifer
transmissivity, please do so. The updated value for transmissivity and hydraulic conductivity should be used
to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer status
have been met. I am unable to concur with the protected aquifer classification for the South West Well.
While it was concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay were
encountered in the uppermost 100 feet. A combined total of 20 feet of clay was encountered in the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…174/462
uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's Reports near this source
and found similar conditions. Given that the zones may change based on my comments above, I will wait to
provide a bunch of feedback on the Potential Contamination Source Inventory (PCS), but I did notice that sewer
lines are listed in zone one for the South Well but then it says under sewer lines in zone 2 that there are no sewer
lines in zone 1. Please update this to be consistent. It also states that it is unknown whether or not sewer lines in
zone 2 have been constructed to the R309-515-6(4) standard. I would imagine they haven't been since the system
would have been under no obligation to specially construct them. Exceptions to R309-600-13(3) and R309-515-
6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections to
avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes
have occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for the
springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and
provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP.
There have been changes and additions for the wells. There have not been changes or
additions for the springs. For the springs, we simply copied the information for the springs fromthe 2010 plan without changes other than hopefully improved mapping and tables identifying the
location of the springs. Without changes to the plan for the springs we did not think to include a
plan implementation. We can add a section indicating the information relating to the springs was
copied from the 2010 plan to create a single document for all sources and that those plans have
previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…175/462
From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North
Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also
mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not sure it meets that
intent since plan implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and signed
since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…176/462

Below is a link that will allow you to download a draft of a DWSPP that includes all ofEphraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document and
get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at: hps://acrobat.adobe.com/id/
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Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a DWSP
that includes all of Ephraim’s sources (wells and springs). The city is currently reviewing the
accuracy of the PCSs we identified. We are working towards submitting a draft DWSP by November
16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…177/462
Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of
Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at the
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From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due
for both by 11/16/2023.

Thanks,

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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…178/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…179/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…180/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…181/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…182/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…183/462

--
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.

--
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.
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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…184/462
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Deidre Beck <[e-mail]>Fri, Jun 21, 2024 at 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Hello Layne,
I've reviewed the latest submission and need the following items addressed:
The report needs to be stamped and signed by a licensed geologist or engineer.
After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need to be
referenced in each section, and a statement made that no changes have occurred.
Sections 3 and 4
The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance with
R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control type will need
to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely inspecting its lines or
performing other periodic maintenance, best management/pollution prevention practices can be used to assess the sewer lines as
adequately controlled. We also don't consider "protected aquifer" status as a reason for assessing a potential contamination
source (PCS) as adequately controlled.
I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW Board will
vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.
Section 5
This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard presented by
these potential contamination sources. What does this mean? Will the system send out mailers, add information to their CCR, or
website concerning BMPs? We do have fact sheets that can be used. If you would like to see examples of how other systems
have handled this requirement, particularly for residents, please let me know. The strategies need to be explicit so that the
system is aware and knows exactly what they need to implement. Otherwise, the next time their update is due, the plans may
be disapproved for lack of plan implementation. Lack of plan implementation is considered a significant deficiency under the
Improvement Priority System (IPS) rule, so we emphasize the importance of this with consultants/systems.
For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land management
strategies have been implemented for the residential properties and the septic system owners. As such, I will be conditionally
concurring with the plan with the condition being that strategies be implemented and documentation provided the next time the
plan(s) are updated.
Section 7
Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage residents to
use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please update this section
with a specific schedule for the completion of the land management strategies added to Section 5. Technically, the rule
states they need to be implemented within 180 days of concurrence, so be sure whatever schedule is proposed, that it doesn't
violate this requirement.
Waivers
The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to renew
these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update. The system will
want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.
Please reach out with any questions.
On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any other
questions.
On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…185/462

We have updated the source protection zones as you recommended and updated the Drinking Water Source
Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that you can use to
download the full document with appendicies. Included in the DWSPP and attached to this email is a letter
requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking an exemption until
the rule is formally changed. The sewer line in question is not currently in use and will likely be replaced with a
larger pipeline in the next year or two. Please inform the city if the new sewer line will need to comply with
requirements in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-600-
13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using one of
the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1 for
the South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject to the
rules until the rule change is completed. Ephraim City will be seeking an exemption until the rule change is
finalized. As far as the sewer in Zone 2 being a potential contamination source should it be identified as
controlled or not adequately controlled? If it is considered not adequately controlled, after the rule change
would that change? Any suggestions how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…186/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong
report. You can access the correct report here. It looks like the new zone two is almost entirely within the secondary
recharge area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of
zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can
try to argue protected aquifer status, but it is unlikely I will be able to concur with that classification since the Well Driller's
report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and
R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to R309-
600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared by a
consultant, but we prefer that the letter be signed by the system because we have had situations in the past where
systems had no idea that exceptions had been requested or granted. Historically, the Division has required information on
the age of the sewer infrastructure, which portions of the rules are not being met, etc. We have also required inspection by
video/camera of any sewer lines located within zones one and/or two. It appears that these sewer lines may be newer, just
based on aerial photography, so a camera inspection may have been done recently that would fulfill this requirement.
Typically the conditions for granting the exceptions will be to camera/video at least once every 3 years, and there may be
additional nitrate monitoring required. Once the new rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection zone
2 for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as a
protected aquifer. With the revised well protection zones for the South Well being significantly smaller with
the lower hydraulic conductivity and pumping rate I was wondering if you could look at the mapping you
have for Sanpete County and let me know if portions of well protection zone 2 is still identified as being in
a primary recharge area? The report you referenced in your email about your concerns related to whether
the South Well met the criteria for protected aquifer status did not include Sanpete County or I would
check myself. I would like to reference the study in the DWSPP. Please give me the reference for the
report/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a protected
aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines
within zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-6(4).
Depending on the decision on the protected aquifer status Ephraim may need to seek a temporary
exemption for sewer lines in zone 2. What is the process to seek the exemption?
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…187/462

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity
for the North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the
system would prefer to make the zones smaller for management purposes, you could try to refine the value for T using
better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources
not previously included in a source protection zone, but not delete the previously identified potential contamination
sources that are now not in a source protection zone. The previous source protection zones were more conservative
from the point of view of including more potential contamination sources. How do you feel about this approach? It may
be difficult for the system to manage a larger number of PCSs and it will make it difficult for DDW staff to determine if
land management strategies have been implemented for any not adequately controlled PCSs when the plan is updated
during the normal update cycle. If you decide to go this route, please add a column or in some way denote which PCSs
are actually within the final zones and which are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but
the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so
that if the pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a good
idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North
and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much greater
than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200 feet or
more. In the model a greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate. Yes, you can always use a smaller aquifer thickness as it is considered more
conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…188/462
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before making
changes to the DWSPP I wanted to see if you have any concerns with the method and assumptions. I
am attaching the following maps:

North Well protection zones
Central Well protection zonesSouth Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city area.
Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete the previously
identified potential contamination sources that are now not in a source protection zone. The previous
source protection zones were more conservative from the point of view of including more potential
contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed
the higher flow so that if the pump in the well is replaced to increase production the DWSPP would not need to
be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer the
thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of the
source protection zones. The lower thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts
one value/assumes the aquifer is homogeneous)
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…189/462
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the
fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut
down twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an
empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with the following
parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the screen
length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please
let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…190/462

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear
for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different depths.
The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the
well we learned that the bottom 160 feet of the well had caved in or filled with debris. The well is producing its water
from a water bearing zone at a depth of about 285 feet. I am inclined to model the source protection zones as if they
are in the same aquifer since both are producing from fractured bedrock. I think that will also produce more
conservative source protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model
them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the
city if they want to do another pump test with the installed pump that would stress the well more, but a decision has
not been made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided above
I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the
video the well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This calculates
to a transmissivity of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the
saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock aquifers.
It probably has to do with the quality of the constant-rate test data. If the system conducts another constant-rate test,
the transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different hydraulic
conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the transmissivity
that has been calculated. If you can't use two different values, then an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but it
fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would
consider a stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil
Burk) to see what he felt he could do with the data. With the combination of pumping and recovery data available he
felt he could calculate a representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing
the well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the
soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP
appendix. We are looking at what is considered a clay differently. I have always felt that a soil that includes clay will
behave hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I would give my
perspective. The presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil
than does the presence or absence of sand or gravel. Clay fills the open spaces between the sand and gravel
particles making the soil behave more like a clay from a hydraulic perspective. I do not know whether the soils not
identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to
be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of
thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction
behave hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the sewer
lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as justification for an
exemption.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…191/462
The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would
make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then
the material will likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there is
a predominance of clay besides between 75-80 feet. I have to make my decision based on the information that is
provided. If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me
think that clay was predominant, I would agree with your arguments. I also reviewed other well logs near this source
to come to my conclusion. Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used
to supplement the Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology
of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah;
United States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report
mapped the principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from
2,828 wells in the USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental
Health (now DEQ) databases were examined in the study. Ground-water recharge-area mapping delineated locations
where surface contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two
are completely within the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff
would consider that sufficient evidence to demonstrate the extent of the clay layer throughout zone two. Anderson
and others mapped the recharge and discharge areas based on dominantly clay layers, 20 feet thick or more. I
checked this data source. Proposed zone two for the South Well was not entirely within the secondary recharge area
or discharge area. Part of Zone Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last
week we received approval from the DDW board to move forward with rule-making regarding the sewer line rules.
The proposed rules remove the special construction requirements in zone two regardless of aquifer type. I assume
there isn't sewer infrastructure in zone one? If these rules get adopted, then the system will no longer need an
exception for the sewer infrastructure currently located in zone two. Due to the timing, it may be necessary for the
system to request temporary exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are
adopted/enacted, the exceptions will no longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…192/462
I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer.
It is not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they
are drawing from different depths. The central well is drawing from 437 to 452 feet. The North Wellwas drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the
well had caved in or filled with debris. The well is producing its water from a water bearing zone at
a depth of about 285 feet. I am inclined to model the source protection zones as if they are in the
same aquifer since both are producing from fractured bedrock. I think that will also produce more
conservative source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am
discussing with the city if they want to do another pump test with the installed pump that would
stress the well more, but a decision has not been made yet. I appreciate your calculations for the
hydraulic conductivity. With the information provided above I would propose using a hydraulicconductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is
producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This
calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated
to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long term
test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of the flow meter
(+/- 1.25%). I agree the well did not achieve what I would consider a stabilized drawdown. I think
the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what he
felt he could do with the data. With the combination of pumping and recovery data available he felt
he could calculate a representative hydraulic conductivity. I will share his conclusion when I receive
it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice
it was missing the well log for the actual production well. The well log in the appendix was for the
test well. In the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well
log to this email and will add it to the DWSPP appendix. We are looking at what is considered a
clay differently. I have always felt that a soil that includes clay will behave hydraulically more like a
clay. Ultimately you will make the call on this. However, I thought I would give my perspective.
The presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the
soil than does the presence or absence of sand or gravel. Clay fills the open spaces between the
sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I
do not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey
sand, but if there is enough clay in a sample for it to be identified as having clay, I feel there is
enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of
clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave
hydraulically as a clay the standard is met. However, I believe any soil with a significant clayfraction will behave hydraulically more like a clay than a sand or gravel. We will correct the
inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…193/462
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic
above and other information is included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North
Wells. If the three wells produce from different aquifers, separate aquifer parameters need to be developed for
each scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm
that the wells produce from different aquifers before proceeding with revisions. It may be beneficial to draw a
geologic cross-section. If they produce from separate aquifers then they need to be modeled as such. That
means that only the North and Central Wells should be modeled to show interference in WhAEM using
parameters derived from their constant-rate tests and the South Well should be modeled separately, i.e., the
zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer
test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which states
that 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). Typically the transmissivity is determined from the
constant-rate aquifer test and then hydraulic conductivity is determined using the equation T=K/b. The report
states that the "pump data is preliminary; it will be updated once a pump test has been completed". On page
325 of the PDF, there is data from a "constant flow test" conducted between April 12-13, 2022 on the "Ephraim
North Well Conversion". If these data are from a constant-rate test, they should be used to derive a value for
transmissivity and hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-
hour constant-rate test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv) unless
the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown
over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I
use. This is twice what is currently being used in the WhAEM model. The hydraulic conductivity for the North
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…194/462
Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at
the pump test data provided for what I assume is the Central Well (Ephraim Well #1) from 1991 that was in the
appendices. Based on that test, the value for transmissivity also appears to be closer to 14,840 ft2/day. I used
the Cooper-Jacob method described above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet
of screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840
ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic
conductivity in WhAEM or decide what value is most appropriate. Please update the aquifer parameters used
for the North and Central Wells making sure to derive them from as-built characteristics and the results
of a constant-rate aquifer test. The delineation must also be updated to reflect only interference from these
two wells using aquifer parameters representative of bedrock wells if you believe that the three wells produce
from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to
comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test Report
from 12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a constant-rate test
because the rate was not held constant and it was not continued for at least 24 hours or until the Well
experienced "stabilized drawdown". Please let me know if you disagree. If you think the data can be used to
derive aquifer transmissivity, please do so. The updated value for transmissivity and hydraulic conductivity
should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer
status have been met. I am unable to concur with the protected aquifer classification for the South West
Well. While it was concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay
were encountered in the uppermost 100 feet. A combined total of 20 feet of clay was encountered in the
uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's Reports near this source
and found similar conditions. Given that the zones may change based on my comments above, I will wait to
provide a bunch of feedback on the Potential Contamination Source Inventory (PCS), but I did notice that sewer
lines are listed in zone one for the South Well but then it says under sewer lines in zone 2 that there are no
sewer lines in zone 1. Please update this to be consistent. It also states that it is unknown whether or not sewer
lines in zone 2 have been constructed to the R309-515-6(4) standard. I would imagine they haven't been since
the system would have been under no obligation to specially construct them. Exceptions to R309-600-13(3) and
R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections
to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes
have occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for
the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and
provide any comments before reviewing the remainder of the plan.

Thanks,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…195/462

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single DWSPP.
There have been changes and additions for the wells. There have not been changes or
additions for the springs. For the springs, we simply copied the information for the springs
from the 2010 plan without changes other than hopefully improved mapping and tables
identifying the location of the springs. Without changes to the plan for the springs we did notthink to include a plan implementation. We can add a section indicating the information
relating to the springs was copied from the 2010 plan to create a single document for all
sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and North
Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs are also
mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not sure it meets
that intent since plan implementation is not discussed for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…196/462
Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and
signed since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document
and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…197/462
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a
DWSP that includes all of Ephraim’s sources (wells and springs). The city is currently reviewing
the accuracy of the PCSs we identified. We are working towards submitting a draft DWSP by
November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification of
Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be at
the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is due
for both by 11/16/2023.

Thanks,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…198/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…199/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…200/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…201/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…202/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…203/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…204/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.
--
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.
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Layne Jensen <[e-mail]>Mon, Jun 24, 2024 at 8:26 AM
To: Deidre Beck <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…205/462
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management strategies. Iwould like to take your offer to provide examples of how other entities have handled the BMP and land
management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment on the
sewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need to be
referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance with
R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control type will need
to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely inspecting its lines or
performing other periodic maintenance, best management/pollution prevention practices can be used to assess the sewer lines as
adequately controlled. We also don't consider "protected aquifer" status as a reason for assessing a potential contamination
source (PCS) as adequately controlled.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…206/462

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW Board will
vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard presented by
these potential contamination sources. What does this mean? Will the system send out mailers, add information to their CCR, or
website concerning BMPs? We do have fact sheets that can be used. If you would like to see examples of how other systems
have handled this requirement, particularly for residents, please let me know. The strategies need to be explicit so that the
system is aware and knows exactly what they need to implement. Otherwise, the next time their update is due, the plans may
be disapproved for lack of plan implementation. Lack of plan implementation is considered a significant deficiency under the
Improvement Priority System (IPS) rule, so we emphasize the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land management
strategies have been implemented for the residential properties and the septic system owners. As such, I will be conditionally
concurring with the plan with the condition being that strategies be implemented and documentation provided the next time the
plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage residents to
use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please update this section
with a specific schedule for the completion of the land management strategies added to Section 5. Technically, the rule
states they need to be implemented within 180 days of concurrence, so be sure whatever schedule is proposed, that it doesn't
violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to renew
these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update. The system will
want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any other
questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water Source
Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that you can use
to download the full document with appendicies. Included in the DWSPP and attached to this email is a letter
requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking an exemption until
the rule is formally changed. The sewer line in question is not currently in use and will likely be replaced with a
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…207/462
larger pipeline in the next year or two. Please inform the city if the new sewer line will need to comply with
requirements in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-
600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using one
of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1 for
the South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject to the
rules until the rule change is completed. Ephraim City will be seeking an exemption until the rule change is
finalized. As far as the sewer in Zone 2 being a potential contamination source should it be identified as
controlled or not adequately controlled? If it is considered not adequately controlled, after the rule change
would that change? Any suggestions how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…208/462
From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the wrong
report. You can access the correct report here. It looks like the new zone two is almost entirely within the secondary
recharge area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to the extent of
zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the well. So you can
try to argue protected aquifer status, but it is unlikely I will be able to concur with that classification since the Well Driller's
report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and
R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to
R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared
by a consultant, but we prefer that the letter be signed by the system because we have had situations in the past where
systems had no idea that exceptions had been requested or granted. Historically, the Division has required information on
the age of the sewer infrastructure, which portions of the rules are not being met, etc. We have also required inspection by
video/camera of any sewer lines located within zones one and/or two. It appears that these sewer lines may be newer, just
based on aerial photography, so a camera inspection may have been done recently that would fulfill this requirement.
Typically the conditions for granting the exceptions will be to camera/video at least once every 3 years, and there may be
additional nitrate monitoring required. Once the new rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection
zone 2 for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify as
a protected aquifer. With the revised well protection zones for the South Well being significantly smaller
with the lower hydraulic conductivity and pumping rate I was wondering if you could look at the mapping
you have for Sanpete County and let me know if portions of well protection zone 2 is still identified as
being in a primary recharge area? The report you referenced in your email about your concerns related to
whether the South Well met the criteria for protected aquifer status did not include Sanpete County or I
would check myself. I would like to reference the study in the DWSPP. Please give me the reference for
the report/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a
protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines
within zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-6(4).
Depending on the decision on the protected aquifer status Ephraim may need to seek a temporary
exemption for sewer lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…209/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the transmissivity
for the North and Central Wells is probably high. But the value is conservative, so it meets the intent of the rule. If the
system would prefer to make the zones smaller for management purposes, you could try to refine the value for T using
better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources
not previously included in a source protection zone, but not delete the previously identified potential contamination
sources that are now not in a source protection zone. The previous source protection zones were more conservative
from the point of view of including more potential contamination sources. How do you feel about this approach? It may
be difficult for the system to manage a larger number of PCSs and it will make it difficult for DDW staff to determine if
land management strategies have been implemented for any not adequately controlled PCSs when the plan is updated
during the normal update cycle. If you decide to go this route, please add a column or in some way denote which PCSs
are actually within the final zones and which are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but
the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow so
that if the pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a good
idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the North
and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth much
greater than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer to 200
feet or more. In the model a greater thickness reduces the size of the source protection zones. The lower thickness
assumed provides a more conservative estimate. Yes, you can always use a smaller aquifer thickness as it is
considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer. Sounds good.

South Well
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…210/462
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher recharge
value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before making
changes to the DWSPP I wanted to see if you have any concerns with the method and assumptions. I
am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same mapRevised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city
area. Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete the previously
identified potential contamination sources that are now not in a source protection zone. The previous
source protection zones were more conservative from the point of view of including more potential
contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed
the higher flow so that if the pump in the well is replaced to increase production the DWSPP would not need
to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer the
thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of the
source protection zones. The lower thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts
one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the
fractured bedrock aquifer.

South Well
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…211/462

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was shut
down twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an
empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with the following
parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the
screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please
let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as clear
for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different
depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…212/462
videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris. The well is
producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the source
protection zones as if they are in the same aquifer since both are producing from fractured bedrock. I think that will
also produce more conservative source protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to model
them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the
city if they want to do another pump test with the installed pump that would stress the well more, but a decision has
not been made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided
above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based
on the video the well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This
calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the
saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock
aquifers. It probably has to do with the quality of the constant-rate test data. If the system conducts another constant-
rate test, the transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the well
protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different
hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the
transmissivity that has been calculated. If you can't use two different values, then an average of the two could be
used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate, but
it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would
consider a stabilized drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil
Burk) to see what he felt he could do with the data. With the combination of pumping and recovery data available he
felt he could calculate a representative hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing
the well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet the
soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the DWSPP
appendix. We are looking at what is considered a clay differently. I have always felt that a soil that includes clay will
behave hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I would give my
perspective. The presence or absence of clay in a soil has far more impact on the hydraulic conductivity of the soil
than does the presence or absence of sand or gravel. Clay fills the open spaces between the sand and gravel
particles making the soil behave more like a clay from a hydraulic perspective. I do not know whether the soils not
identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to
be identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of
thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction
behave hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the sewer
lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as justification for an
exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that would
make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-70%), then
the material will likely act as clay, but the Well Driller's Report does not state anything that leads me to believe there
is a predominance of clay besides between 75-80 feet. I have to make my decision based on the information that is
provided. If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or something that made me
think that clay was predominant, I would agree with your arguments. I also reviewed other well logs near this source
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…213/462
to come to my conclusion. Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used
to supplement the Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled Hydrogeology
of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and Adjacent Areas, Utah;
United States Geological Survey Water Resources Investigations Report 93-4221, published in 1994. This report
mapped the principal aquifers and recharge areas along the Wasatch Front. Water-level data and drillers' logs from
2,828 wells in the USGS, Utah Division of Water Rights, and Utah Department of Health, Division of Environmental
Health (now DEQ) databases were examined in the study. Ground-water recharge-area mapping delineated
locations where surface contaminants could move down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone two
are completely within the secondary recharge area or discharge area as mapped by Anderson and others, DDW staff
would consider that sufficient evidence to demonstrate the extent of the clay layer throughout zone two. Anderson
and others mapped the recharge and discharge areas based on dominantly clay layers, 20 feet thick or more. I
checked this data source. Proposed zone two for the South Well was not entirely within the secondary recharge area
or discharge area. Part of Zone Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just last
week we received approval from the DDW board to move forward with rule-making regarding the sewer line rules.
The proposed rules remove the special construction requirements in zone two regardless of aquifer type. I assume
there isn't sewer infrastructure in zone one? If these rules get adopted, then the system will no longer need an
exception for the sewer infrastructure currently located in zone two. Due to the timing, it may be necessary for the
system to request temporary exceptions to R309-600-13(3) and R309-515-6(4), but once the proposed rules are
adopted/enacted, the exceptions will no longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…214/462
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate
aquifer. It is not as clear for the Central and North Wells. Both are completed in fractured bedrock,
but they are drawing from different depths. The central well is drawing from 437 to 452 feet. The
North Well was drilled to 445 feet, but when we videoed the well we learned that the bottom 160
feet of the well had caved in or filled with debris. The well is producing its water from a water
bearing zone at a depth of about 285 feet. I am inclined to model the source protection zones as if
they are in the same aquifer since both are producing from fractured bedrock. I think that will also
produce more conservative source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I amdiscussing with the city if they want to do another pump test with the installed pump that would
stress the well more, but a decision has not been made yet. I appreciate your calculations for the
hydraulic conductivity. With the information provided above I would propose using a hydraulic
conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is
producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This
calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated
to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long term
test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of the flow meter
(+/- 1.25%). I agree the well did not achieve what I would consider a stabilized drawdown. I think
the first attempt came close though. I have contacted a hydrogeologist (Neil Burk) to see what he
felt he could do with the data. With the combination of pumping and recovery data available he felt
he could calculate a representative hydraulic conductivity. I will share his conclusion when I
receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I
notice it was missing the well log for the actual production well. The well log in the appendix was
for the test well. In the top 100 feet the soil descriptions are similar, but not exact. I am attaching
the well log to this email and will add it to the DWSPP appendix. We are looking at what is
considered a clay differently. I have always felt that a soil that includes clay will behave
hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I would
give my perspective. The presence or absence of clay in a soil has far more impact on the
hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills
the open spaces between the sand and gravel particles making the soil behave more like a clay
from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified ashaving clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of
thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having
a clay fraction behave hydraulically as a clay the standard is met. However, I believe any soil with
a significant clay fraction will behave hydraulically more like a clay than a sand or gravel. We will
correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to
request an exemption after receiving your thoughts on this and redoing the modeling. It could be
that my logic above and other information is included as justification for an exemption

Thanks,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…215/462

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well is
completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and North
Wells. If the three wells produce from different aquifers, separate aquifer parameters need to be developed for
each scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please be sure to confirm
that the wells produce from different aquifers before proceeding with revisions. It may be beneficial to draw a
geologic cross-section. If they produce from separate aquifers then they need to be modeled as such.
That means that only the North and Central Wells should be modeled to show interference in WhAEM using
parameters derived from their constant-rate tests and the South Well should be modeled separately, i.e., the
zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate aquifer
test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells, which
states that 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). Typically the transmissivity is determined from
the constant-rate aquifer test and then hydraulic conductivity is determined using the equation T=K/b. The
report states that the "pump data is preliminary; it will be updated once a pump test has been completed". On
page 325 of the PDF, there is data from a "constant flow test" conducted between April 12-13, 2022 on the
"Ephraim North Well Conversion". If these data are from a constant-rate test, they should be used to derive a
value for transmissivity and hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or
another 24-hour constant-rate test will need to be conducted on the North Well to comply with R309-600-9(6)(a)
(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown
over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle I
use. This is twice what is currently being used in the WhAEM model. The hydraulic conductivity for the North
Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also looked at
the pump test data provided for what I assume is the Central Well (Ephraim Well #1) from 1991 that was in the
appendices. Based on that test, the value for transmissivity also appears to be closer to 14,840 ft2/day. I used
the Cooper-Jacob method described above and the values for drawdown at 100 minutes and at ~1000 minutes.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…216/462
I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15 feet
of screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K = 14840
ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for hydraulic
conductivity in WhAEM or decide what value is most appropriate. Please update the aquifer parameters
used for the North and Central Wells making sure to derive them from as-built characteristics and the
results of a constant-rate aquifer test. The delineation must also be updated to reflect only interference from
these two wells using aquifer parameters representative of bedrock wells if you believe that the three wells
produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test to
comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test
Report from 12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a constant-
rate test because the rate was not held constant and it was not continued for at least 24 hours or until the Well
experienced "stabilized drawdown". Please let me know if you disagree. If you think the data can be used to
derive aquifer transmissivity, please do so. The updated value for transmissivity and hydraulic
conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer
status have been met. I am unable to concur with the protected aquifer classification for the South West
Well. While it was concurred with in the PER, the Well Driller's Report does not substantiate that 30 feet of clay
were encountered in the uppermost 100 feet. A combined total of 20 feet of clay was encountered in the
uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's Reports near this source
and found similar conditions. Given that the zones may change based on my comments above, I will wait to
provide a bunch of feedback on the Potential Contamination Source Inventory (PCS), but I did notice that sewer
lines are listed in zone one for the South Well but then it says under sewer lines in zone 2 that there are no
sewer lines in zone 1. Please update this to be consistent. It also states that it is unknown whether or not sewer
lines in zone 2 have been constructed to the R309-515-6(4) standard. I would imagine they haven't been since
the system would have been under no obligation to specially construct them. Exceptions to R309-600-13(3)
and R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other sections
to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no changes
have occurred for the springs so that it's not confusing. It doesn't look like there is anything to implement for
the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and
provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…217/462

The intent was for this document to include all of Ephraim’s water sources in a singleDWSPP. There have been changes and additions for the wells. There have not been
changes or additions for the springs. For the springs, we simply copied the information for the
springs from the 2010 plan without changes other than hopefully improved mapping and
tables identifying the location of the springs. Without changes to the plan for the springs we
did not think to include a plan implementation. We can add a section indicating the
information relating to the springs was copied from the 2010 plan to create a single document
for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and
North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs
are also mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not sure it
meets that intent since plan implementation is not discussed for the springs. Can you verify my
understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…218/462
Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and
signed since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the document
and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…219/462
Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a
DWSP that includes all of Ephraim’s sources (wells and springs). The city is currently reviewing
the accuracy of the PCSs we identified. We are working towards submitting a draft DWSP by
November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written verification
of Franson Civil Engineers or any CADD adaptation from the specific purpose originally intended shall be
at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is
due for both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…220/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…221/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…222/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…223/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…224/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…225/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…226/462

--
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.

--
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.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…227/462

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Deidre Beck <[e-mail]>Mon, Jun 24, 2024 at 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.
The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or added to
their CCR. It has to address hazards associated with residents and septic systems. Many systems have successfully added a
page dedicated to source protection to their website. The page may include the actual source protection plans (it doesn't have to)
and fact sheets for best management practices. I've attached all Division-prepared Fact sheets for your reference and also an EPA
fact sheet on Septic systems.
An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another example
from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will need to do is
periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.
A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides and
herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system owners,
which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill the rule, it just
needs to spell out the most important best management practices.
Let me know if you have any other questions.
On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…228/462
I will reach out to the city to determine how they want to implement BMPs and land management strategies. I
would like to take your offer to provide examples of how other entities have handled the BMP and land
management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment on thesewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need to be
referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance with
R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control type will
need to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely inspecting its
lines or performing other periodic maintenance, best management/pollution prevention practices can be used to assess the
sewer lines as adequately controlled. We also don't consider "protected aquifer" status as a reason for assessing a potential
contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW Board
will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…229/462
Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard presented by
these potential contamination sources. What does this mean? Will the system send out mailers, add information to their CCR, or
website concerning BMPs? We do have fact sheets that can be used. If you would like to see examples of how other systems
have handled this requirement, particularly for residents, please let me know. The strategies need to be explicit so that the
system is aware and knows exactly what they need to implement. Otherwise, the next time their update is due, the plans
may be disapproved for lack of plan implementation. Lack of plan implementation is considered a significant deficiency under
the Improvement Priority System (IPS) rule, so we emphasize the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land management
strategies have been implemented for the residential properties and the septic system owners. As such, I will be conditionally
concurring with the plan with the condition being that strategies be implemented and documentation provided the next time the
plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage residents to
use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please update this
section with a specific schedule for the completion of the land management strategies added to Section 5. Technically,
the rule states they need to be implemented within 180 days of concurrence, so be sure whatever schedule is proposed, that it
doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to renew
these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update. The system will
want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any other
questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water Source
Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that you can
use to download the full document with appendicies. Included in the DWSPP and attached to this email is a
letter requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking an
exemption until the rule is formally changed. The sewer line in question is not currently in use and will likely
be replaced with a larger pipeline in the next year or two. Please inform the city if the new sewer line will
need to comply with requirements in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…230/462
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-
600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using
one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1
for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject
to the rules until the rule change is completed. Ephraim City will be seeking an exemption until the rule
change is finalized. As far as the sewer in Zone 2 being a potential contamination source should it be
identified as controlled or not adequately controlled? If it is considered not adequately controlled, after the
rule change would that change? Any suggestions how we should handle the sewer in Zone 2 would be
appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…231/462
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the
wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within the
secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to
the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the
well. So you can try to argue protected aquifer status, but it is unlikely I will be able to concur with that classification
since the Well Driller's report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and
R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to
R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be prepared
by a consultant, but we prefer that the letter be signed by the system because we have had situations in the past where
systems had no idea that exceptions had been requested or granted. Historically, the Division has required information
on the age of the sewer infrastructure, which portions of the rules are not being met, etc. We have also required
inspection by video/camera of any sewer lines located within zones one and/or two. It appears that these sewer lines
may be newer, just based on aerial photography, so a camera inspection may have been done recently that would fulfill
this requirement. Typically the conditions for granting the exceptions will be to camera/video at least once every 3 years,
and there may be additional nitrate monitoring required. Once the new rules are enacted, those requirements will no
longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection
zone 2 for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify
as a protected aquifer. With the revised well protection zones for the South Well being significantlysmaller with the lower hydraulic conductivity and pumping rate I was wondering if you could look at the
mapping you have for Sanpete County and let me know if portions of well protection zone 2 is still
identified as being in a primary recharge area? The report you referenced in your email about your
concerns related to whether the South Well met the criteria for protected aquifer status did not include
Sanpete County or I would check myself. I would like to reference the study in the DWSPP. Please
give me the reference for the report/mapping for Sanpete County. I am hopeful that with the smaller
Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lineswithin zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-
6(4). Depending on the decision on the protected aquifer status Ephraim may need to seek a
temporary exemption for sewer lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…232/462
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the intent of
the rule. If the system would prefer to make the zones smaller for management purposes, you could try to refine the
value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination sources
not previously included in a source protection zone, but not delete the previously identified potential contamination
sources that are now not in a source protection zone. The previous source protection zones were more conservative
from the point of view of including more potential contamination sources. How do you feel about this
approach? It may be difficult for the system to manage a larger number of PCSs and it will make it difficult for DDW
staff to determine if land management strategies have been implemented for any not adequately controlled PCSs
when the plan is updated during the normal update cycle. If you decide to go this route, please add a column or in
some way denote which PCSs are actually within the final zones and which are not so that the system and DDW staff
can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but
the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow
so that if the pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a
good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the
North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth
much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is probably closer
to 200 feet or more. In the model a greater thickness reduces the size of the source protection zones. The lower
thickness assumed provides a more conservative estimate. Yes, you can always use a smaller aquifer thickness as it
is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…233/462
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before making
changes to the DWSPP I wanted to see if you have any concerns with the method and assumptions. I
am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city
area. Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete thepreviously identified potential contamination sources that are now not in a source protection zone.
The previous source protection zones were more conservative from the point of view of including
more potential contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We
assumed the higher flow so that if the pump in the well is replaced to increase production the DWSPP
would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer
the thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of
the source protection zones. The lower thickness assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median
total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges
the fractured bedrock aquifer.

South Well

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…234/462
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm.
The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a
higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was
shut down twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an
empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with the
following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the
screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data.
Please let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as
clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from different
depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we
videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris. The well is
producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the source
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…235/462
protection zones as if they are in the same aquifer since both are producing from fractured bedrock. I think that
will also produce more conservative source protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to
model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the
city if they want to do another pump test with the installed pump that would stress the well more, but a decision
has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the information provided
above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based
on the video the well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’. This
calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the
saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock
aquifers. It probably has to do with the quality of the constant-rate test data. If the system conducts another
constant-rate test, the transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the
well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different
hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the
transmissivity that has been calculated. If you can't use two different values, then an average of the two could be
used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate,
but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I
would consider a stabilized drawdown. I think the first attempt came close though. I have contacted a
hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of pumping and
recovery data available he felt he could calculate a representative hydraulic conductivity. I will share his
conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing
the well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet
the soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the
DWSPP appendix. We are looking at what is considered a clay differently. I have always felt that a soil that
includes clay will behave hydraulically more like a clay. Ultimately you will make the call on this. However, I
thought I would give my perspective. The presence or absence of clay in a soil has far more impact on the
hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills the open spaces
between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I do
not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is
enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to behave
hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the
soils identified as having a clay fraction behave hydraulically as a clay the standard is met. However, I believe
any soil with a significant clay fraction will behave hydraulically more like a clay than a sand or gravel. We will
correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and
other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that
would make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-
70%), then the material will likely act as clay, but the Well Driller's Report does not state anything that leads me to
believe there is a predominance of clay besides between 75-80 feet. I have to make my decision based on the
information that is provided. If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or
something that made me think that clay was predominant, I would agree with your arguments. I also reviewed
other well logs near this source to come to my conclusion. Oftentimes lithologic logs prepared by a geologist or
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…236/462
engineer during the drilling are used to supplement the Well Driller's Report. Since that is not available, I have to
base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front. Water-
level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah Department of
Health, Division of Environmental Health (now DEQ) databases were examined in the study. Ground-water
recharge-area mapping delineated locations where surface contaminants could move down to the principal
aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone
two are completely within the secondary recharge area or discharge area as mapped by Anderson and others,
DDW staff would consider that sufficient evidence to demonstrate the extent of the clay layer throughout zone two.
Anderson and others mapped the recharge and discharge areas based on dominantly clay layers, 20 feet thick or
more. I checked this data source. Proposed zone two for the South Well was not entirely within the secondary
recharge area or discharge area. Part of Zone Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just
last week we received approval from the DDW board to move forward with rule-making regarding the sewer line
rules. The proposed rules remove the special construction requirements in zone two regardless of aquifer type. I
assume there isn't sewer infrastructure in zone one? If these rules get adopted, then the system will no longer
need an exception for the sewer infrastructure currently located in zone two. Due to the timing, it may be
necessary for the system to request temporary exceptions to R309-600-13(3) and R309-515-6(4), but once the
proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if you'd like more
information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…237/462
On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate
aquifer. It is not as clear for the Central and North Wells. Both are completed in fractured
bedrock, but they are drawing from different depths. The central well is drawing from 437 to 452
feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the
bottom 160 feet of the well had caved in or filled with debris. The well is producing its water from
a water bearing zone at a depth of about 285 feet. I am inclined to model the source protection
zones as if they are in the same aquifer since both are producing from fractured bedrock. I think
that will also produce more conservative source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am
discussing with the city if they want to do another pump test with the installed pump that wouldstress the well more, but a decision has not been made yet. I appreciate your calculations for
the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video
the well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’.
This calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long term
test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of the flow
meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized
drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil
Burk) to see what he felt he could do with the data. With the combination of pumping and
recovery data available he felt he could calculate a representative hydraulic conductivity. I will
share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I
notice it was missing the well log for the actual production well. The well log in the appendix was
for the test well. In the top 100 feet the soil descriptions are similar, but not exact. I am
attaching the well log to this email and will add it to the DWSPP appendix. We are looking at
what is considered a clay differently. I have always felt that a soil that includes clay will behave
hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I
would give my perspective. The presence or absence of clay in a soil has far more impact on
the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay
fills the open spaces between the sand and gravel particles making the soil behave more like a
clay from a hydraulic perspective. I do not know whether the soils not identified as a straight
clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be
identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils
identified as having a clay fraction behave hydraulically as a clay the standard is met. However,
I believe any soil with a significant clay fraction will behave hydraulically more like a clay than a
sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2.
We will assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as
justification for an exemption

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…238/462
Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well
is completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and
North Wells. If the three wells produce from different aquifers, separate aquifer parameters need to be
developed for each scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please
be sure to confirm that the wells produce from different aquifers before proceeding with revisions. It may be
beneficial to draw a geologic cross-section. If they produce from separate aquifers then they need to be
modeled as such. That means that only the North and Central Wells should be modeled to show
interference in WhAEM using parameters derived from their constant-rate tests and the South Well should be
modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate
aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells,
which states that 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). Typically the transmissivity is
determined from the constant-rate aquifer test and then hydraulic conductivity is determined using the
equation T=K/b. The report states that the "pump data is preliminary; it will be updated once a pump test has
been completed". On page 325 of the PDF, there is data from a "constant flow test" conducted between April
12-13, 2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate test, they should
be used to derive a value for transmissivity and hydraulic conductivity for use in the WhAEM model for the
bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the North Well to
comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in drawdown
over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on the log cycle
I use. This is twice what is currently being used in the WhAEM model. The hydraulic conductivity for the
North Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) = 71.8 ft/day. I also
looked at the pump test data provided for what I assume is the Central Well (Ephraim Well #1) from 1991 that
was in the appendices. Based on that test, the value for transmissivity also appears to be closer to 14,840
ft2/day. I used the Cooper-Jacob method described above and the values for drawdown at 100 minutes and
at ~1000 minutes.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…239/462

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15
feet of screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K =
14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for
hydraulic conductivity in WhAEM or decide what value is most appropriate. Please update the aquifer
parameters used for the North and Central Wells making sure to derive them from as-built
characteristics and the results of a constant-rate aquifer test. The delineation must also be updated to
reflect only interference from these two wells using aquifer parameters representative of bedrock wells if you
believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer test
to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping Test
Report from 12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a
constant-rate test because the rate was not held constant and it was not continued for at least 24 hours or
until the Well experienced "stabilized drawdown". Please let me know if you disagree. If you think the data
can be used to derive aquifer transmissivity, please do so. The updated value for transmissivity and
hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer
status have been met. I am unable to concur with the protected aquifer classification for the South
West Well. While it was concurred with in the PER, the Well Driller's Report does not substantiate that 30
feet of clay were encountered in the uppermost 100 feet. A combined total of 20 feet of clay was
encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's
Reports near this source and found similar conditions. Given that the zones may change based on my
comments above, I will wait to provide a bunch of feedback on the Potential Contamination Source Inventory
(PCS), but I did notice that sewer lines are listed in zone one for the South Well but then it says under sewer
lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It also states that
it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4) standard. I
would imagine they haven't been since the system would have been under no obligation to specially
construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent
of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no
changes have occurred for the springs so that it's not confusing. It doesn't look like there is anything to
implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and
provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…240/462
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not been
changes or additions for the springs. For the springs, we simply copied the information forthe springs from the 2010 plan without changes other than hopefully improved mapping and
tables identifying the location of the springs. Without changes to the plan for the springs we
did not think to include a plan implementation. We can add a section indicating the
information relating to the springs was copied from the 2010 plan to create a single
document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and
North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs
are also mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not sure
it meets that intent since plan implementation is not discussed for the springs. Can you verify my
understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…241/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and
signed since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…242/462

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a
DWSP that includes all of Ephraim’s sources (wells and springs). The city is currently reviewing
the accuracy of the PCSs we identified. We are working towards submitting a draft DWSP by
November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose originally
intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is
due for both by 11/16/2023.

Thanks,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…243/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…244/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…245/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…246/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…247/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…248/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…249/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…250/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.
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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…251/462
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Layne Jensen <[e-mail]>Mon, Jun 24, 2024 at 8:55 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Thank you, this is very helpful.

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or added to
their CCR. It has to address hazards associated with residents and septic systems. Many systems have successfully added a
page dedicated to source protection to their website. The page may include the actual source protection plans (it doesn't have to)
and fact sheets for best management practices. I've attached all Division-prepared Fact sheets for your reference and also an EPA
fact sheet on Septic systems.

An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another example
from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will need to do is
periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides and
herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system owners,
which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill the rule, it just
needs to spell out the most important best management practices.

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…252/462
I will reach out to the city to determine how they want to implement BMPs and land management strategies. I
would like to take your offer to provide examples of how other entities have handled the BMP and land
management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment on thesewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need to be
referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance with
R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control type will
need to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely inspecting its
lines or performing other periodic maintenance, best management/pollution prevention practices can be used to assess the
sewer lines as adequately controlled. We also don't consider "protected aquifer" status as a reason for assessing a potential
contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW Board
will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…253/462
Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard presented by
these potential contamination sources. What does this mean? Will the system send out mailers, add information to their CCR,
or website concerning BMPs? We do have fact sheets that can be used. If you would like to see examples of how other
systems have handled this requirement, particularly for residents, please let me know. The strategies need to be explicit so
that the system is aware and knows exactly what they need to implement. Otherwise, the next time their update is due,
the plans may be disapproved for lack of plan implementation. Lack of plan implementation is considered a significant
deficiency under the Improvement Priority System (IPS) rule, so we emphasize the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I will be
conditionally concurring with the plan with the condition being that strategies be implemented and documentation provided the
next time the plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage residents to
use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please update this
section with a specific schedule for the completion of the land management strategies added to Section 5. Technically,
the rule states they need to be implemented within 180 days of concurrence, so be sure whatever schedule is proposed, that it
doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to renew
these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update. The system will
want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any other
questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water
Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that you
can use to download the full document with appendicies. Included in the DWSPP and attached to this email
is a letter requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking an
exemption until the rule is formally changed. The sewer line in question is not currently in use and will likelybe replaced with a larger pipeline in the next year or two. Please inform the city if the new sewer line will
need to comply with requirements in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…254/462
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-
600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using
one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1
for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject
to the rules until the rule change is completed. Ephraim City will be seeking an exemption until the rule
change is finalized. As far as the sewer in Zone 2 being a potential contamination source should it be
identified as controlled or not adequately controlled? If it is considered not adequately controlled, after the
rule change would that change? Any suggestions how we should handle the sewer in Zone 2 would be
appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…255/462
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the
wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within the
secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to
the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the
well. So you can try to argue protected aquifer status, but it is unlikely I will be able to concur with that classification
since the Well Driller's report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and
R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to
R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be
prepared by a consultant, but we prefer that the letter be signed by the system because we have had situations in the
past where systems had no idea that exceptions had been requested or granted. Historically, the Division has required
information on the age of the sewer infrastructure, which portions of the rules are not being met, etc. We have also
required inspection by video/camera of any sewer lines located within zones one and/or two. It appears that these
sewer lines may be newer, just based on aerial photography, so a camera inspection may have been done recently that
would fulfill this requirement. Typically the conditions for granting the exceptions will be to camera/video at least once
every 3 years, and there may be additional nitrate monitoring required. Once the new rules are enacted, those
requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection
zone 2 for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify
as a protected aquifer. With the revised well protection zones for the South Well being significantlysmaller with the lower hydraulic conductivity and pumping rate I was wondering if you could look at the
mapping you have for Sanpete County and let me know if portions of well protection zone 2 is still
identified as being in a primary recharge area? The report you referenced in your email about your
concerns related to whether the South Well met the criteria for protected aquifer status did not include
Sanpete County or I would check myself. I would like to reference the study in the DWSPP. Please
give me the reference for the report/mapping for Sanpete County. I am hopeful that with the smaller
Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lineswithin zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-
6(4). Depending on the decision on the protected aquifer status Ephraim may need to seek a
temporary exemption for sewer lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…256/462
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the intent of
the rule. If the system would prefer to make the zones smaller for management purposes, you could try to refine the
value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones were
more conservative from the point of view of including more potential contamination sources. How do you feel about
this approach? It may be difficult for the system to manage a larger number of PCSs and it will make it difficult for
DDW staff to determine if land management strategies have been implemented for any not adequately controlled
PCSs when the plan is updated during the normal update cycle. If you decide to go this route, please add a column
or in some way denote which PCSs are actually within the final zones and which are not so that the system and
DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but
the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow
so that if the pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a
good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the
North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth
much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is probably
closer to 200 feet or more. In the model a greater thickness reduces the size of the source protection zones. The
lower thickness assumed provides a more conservative estimate. Yes, you can always use a smaller aquifer
thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…257/462
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before making
changes to the DWSPP I wanted to see if you have any concerns with the method and assumptions.
I am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city
area. Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete thepreviously identified potential contamination sources that are now not in a source protection zone.
The previous source protection zones were more conservative from the point of view of including
more potential contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We
assumed the higher flow so that if the pump in the well is replaced to increase production the DWSPP
would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We
are assuming the North and Central wells are drawing from the same aquifer. The Central Well is
producing its water from a depth much greater than the North Well. Assuming they are drawing from the
same aquifer the thickness is probably closer to 200 feet or more. In the model a greater thickness
reduces the size of the source protection zones. The lower thickness assumed provides a more
conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median
total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges
the fractured bedrock aquifer.

South Well

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…258/462
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm.
The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a
higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was
shut down twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an
empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with the
following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the
screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data.
Please let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as
clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from
different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but
when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris. The
well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…259/462
source protection zones as if they are in the same aquifer since both are producing from fractured bedrock. I think
that will also produce more conservative source protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to
model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the
city if they want to do another pump test with the installed pump that would stress the well more, but a decision
has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the information
provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40
feet. Based on the video the well is producing water from end of the casing at 245’ to the bottom of the open hole
at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the
saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock
aquifers. It probably has to do with the quality of the constant-rate test data. If the system conducts another
constant-rate test, the transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the
well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different
hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the
transmissivity that has been calculated. If you can't use two different values, then an average of the two could be
used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate,
but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I
would consider a stabilized drawdown. I think the first attempt came close though. I have contacted a
hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of pumping and
recovery data available he felt he could calculate a representative hydraulic conductivity. I will share his
conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing
the well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet
the soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the
DWSPP appendix. We are looking at what is considered a clay differently. I have always felt that a soil that
includes clay will behave hydraulically more like a clay. Ultimately you will make the call on this. However, I
thought I would give my perspective. The presence or absence of clay in a soil has far more impact on the
hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills the open spaces
between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I do
not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is
enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to behave
hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the
soils identified as having a clay fraction behave hydraulically as a clay the standard is met. However, I believe
any soil with a significant clay fraction will behave hydraulically more like a clay than a sand or gravel. We will
correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and
other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that
would make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-
70%), then the material will likely act as clay, but the Well Driller's Report does not state anything that leads me to
believe there is a predominance of clay besides between 75-80 feet. I have to make my decision based on the
information that is provided. If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or
something that made me think that clay was predominant, I would agree with your arguments. I also reviewed
other well logs near this source to come to my conclusion. Oftentimes lithologic logs prepared by a geologist or
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…260/462
engineer during the drilling are used to supplement the Well Driller's Report. Since that is not available, I have to
base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front. Water-
level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah Department of
Health, Division of Environmental Health (now DEQ) databases were examined in the study. Ground-water
recharge-area mapping delineated locations where surface contaminants could move down to the principal
aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone
two are completely within the secondary recharge area or discharge area as mapped by Anderson and others,
DDW staff would consider that sufficient evidence to demonstrate the extent of the clay layer throughout zone two.
Anderson and others mapped the recharge and discharge areas based on dominantly clay layers, 20 feet thick or
more. I checked this data source. Proposed zone two for the South Well was not entirely within the secondary
recharge area or discharge area. Part of Zone Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just
last week we received approval from the DDW board to move forward with rule-making regarding the sewer line
rules. The proposed rules remove the special construction requirements in zone two regardless of aquifer type. I
assume there isn't sewer infrastructure in zone one? If these rules get adopted, then the system will no longer
need an exception for the sewer infrastructure currently located in zone two. Due to the timing, it may be
necessary for the system to request temporary exceptions to R309-600-13(3) and R309-515-6(4), but once the
proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if you'd like more
information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…261/462
On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separateaquifer. It is not as clear for the Central and North Wells. Both are completed in fractured
bedrock, but they are drawing from different depths. The central well is drawing from 437 to 452
feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the
bottom 160 feet of the well had caved in or filled with debris. The well is producing its water
from a water bearing zone at a depth of about 285 feet. I am inclined to model the source
protection zones as if they are in the same aquifer since both are producing from fractured
bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I amdiscussing with the city if they want to do another pump test with the installed pump that would
stress the well more, but a decision has not been made yet. I appreciate your calculations for
the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video
the well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’.
This calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long term
test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of the flow
meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized
drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil
Burk) to see what he felt he could do with the data. With the combination of pumping and
recovery data available he felt he could calculate a representative hydraulic conductivity. I will
share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I
notice it was missing the well log for the actual production well. The well log in the appendix
was for the test well. In the top 100 feet the soil descriptions are similar, but not exact. I am
attaching the well log to this email and will add it to the DWSPP appendix. We are looking at
what is considered a clay differently. I have always felt that a soil that includes clay will behave
hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I
would give my perspective. The presence or absence of clay in a soil has far more impact on
the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay
fills the open spaces between the sand and gravel particles making the soil behave more like a
clay from a hydraulic perspective. I do not know whether the soils not identified as a straight
clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to beidentified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay.
In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils
identified as having a clay fraction behave hydraulically as a clay the standard is met. However,
I believe any soil with a significant clay fraction will behave hydraulically more like a clay than a
sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2.
We will assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as
justification for an exemption
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…262/462

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well
is completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and
North Wells. If the three wells produce from different aquifers, separate aquifer parameters need to be
developed for each scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please
be sure to confirm that the wells produce from different aquifers before proceeding with revisions. It may be
beneficial to draw a geologic cross-section. If they produce from separate aquifers then they need to be
modeled as such. That means that only the North and Central Wells should be modeled to show
interference in WhAEM using parameters derived from their constant-rate tests and the South Well should
be modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate
aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells,
which states that 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). Typically the transmissivity is
determined from the constant-rate aquifer test and then hydraulic conductivity is determined using the
equation T=K/b. The report states that the "pump data is preliminary; it will be updated once a pump test has
been completed". On page 325 of the PDF, there is data from a "constant flow test" conducted between April
12-13, 2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate test, they should
be used to derive a value for transmissivity and hydraulic conductivity for use in the WhAEM model for the
bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the North Well to
comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on
the log cycle I use. This is twice what is currently being used in the WhAEM model. The hydraulic
conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) =
71.8 ft/day. I also looked at the pump test data provided for what I assume is the Central Well (Ephraim Well
#1) from 1991 that was in the appendices. Based on that test, the value for transmissivity also appears to be
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…263/462
closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the values for drawdown at
100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15
feet of screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K =
14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for
hydraulic conductivity in WhAEM or decide what value is most appropriate. Please update the aquifer
parameters used for the North and Central Wells making sure to derive them from as-built
characteristics and the results of a constant-rate aquifer test. The delineation must also be updated to
reflect only interference from these two wells using aquifer parameters representative of bedrock wells if you
believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer
test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping
Test Report from 12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a
constant-rate test because the rate was not held constant and it was not continued for at least 24 hours or
until the Well experienced "stabilized drawdown". Please let me know if you disagree. If you think the data
can be used to derive aquifer transmissivity, please do so. The updated value for transmissivity and
hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer
status have been met. I am unable to concur with the protected aquifer classification for the South
West Well. While it was concurred with in the PER, the Well Driller's Report does not substantiate that 30
feet of clay were encountered in the uppermost 100 feet. A combined total of 20 feet of clay was
encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's
Reports near this source and found similar conditions. Given that the zones may change based on my
comments above, I will wait to provide a bunch of feedback on the Potential Contamination Source Inventory
(PCS), but I did notice that sewer lines are listed in zone one for the South Well but then it says under sewer
lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It also states that
it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4) standard. I
would imagine they haven't been since the system would have been under no obligation to specially
construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent
of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no
changes have occurred for the springs so that it's not confusing. It doesn't look like there is anything to
implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and
provide any comments before reviewing the remainder of the plan.

Thanks,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…264/462

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not been
changes or additions for the springs. For the springs, we simply copied the information for
the springs from the 2010 plan without changes other than hopefully improved mapping and
tables identifying the location of the springs. Without changes to the plan for the springs wedid not think to include a plan implementation. We can add a section indicating the
information relating to the springs was copied from the 2010 plan to create a single
document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and
North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs
are also mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not
sure it meets that intent since plan implementation is not discussed for the springs. Can you verify my
understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…265/462
Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and
signed since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…266/462
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a
DWSP that includes all of Ephraim’s sources (wells and springs). The city is currently
reviewing the accuracy of the PCSs we identified. We are working towards submitting a draft
DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose originally
intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is
due for both by 11/16/2023.

Thanks,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…267/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…268/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…269/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…270/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…271/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…272/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…273/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…274/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
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Layne Jensen <[e-mail]>Wed, Jun 26, 2024 at 1:49 PM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Diedre,

Thank you for the information. Before we modify the DWSPP I wanted to verify that our responses will be
acceptable.

Section 2: The springs will be referenced in each section.

Sections 3 and 4: We will propose the sewer lines be considered adequately controlled based on the city’s
inspection and maintenance program. The entire sewer system is cleaned at least every 3 years. Monitoring is
constantly occurring to identify problems while they are minor. Areas that have been identified as having potential
issues during monitoring are cleaned every six months. The city monitors the sewer system by pulling manholes
and observing flows. If there is any indication of problems during monitoring, the section is cleaned, and the city
uses their camara to observe the condition of the pipe. We will remove the reference to the sewer lines being incompliance with R309-515-6(4).

Section 5: The city will add the fact sheets provided to their website by creating a webpage similar to the examples
you provided.

Will these proposed actions adequately address your comments?

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…276/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or added to
their CCR. It has to address hazards associated with residents and septic systems. Many systems have successfully added a
page dedicated to source protection to their website. The page may include the actual source protection plans (it doesn't have to)
and fact sheets for best management practices. I've attached all Division-prepared Fact sheets for your reference and also an EPA
fact sheet on Septic systems.

An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another example
from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will need to do is
periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides and
herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system owners,
which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill the rule, it just
needs to spell out the most important best management practices.

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management strategies. I
would like to take your offer to provide examples of how other entities have handled the BMP and land
management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment on the
sewer lines?

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…277/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need to be
referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance with
R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control type will
need to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely inspecting its
lines or performing other periodic maintenance, best management/pollution prevention practices can be used to assess the
sewer lines as adequately controlled. We also don't consider "protected aquifer" status as a reason for assessing a potential
contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW Board
will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard presented by
these potential contamination sources. What does this mean? Will the system send out mailers, add information to their CCR,
or website concerning BMPs? We do have fact sheets that can be used. If you would like to see examples of how other
systems have handled this requirement, particularly for residents, please let me know. The strategies need to be explicit so
that the system is aware and knows exactly what they need to implement. Otherwise, the next time their update is due,
the plans may be disapproved for lack of plan implementation. Lack of plan implementation is considered a significant
deficiency under the Improvement Priority System (IPS) rule, so we emphasize the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I will be
conditionally concurring with the plan with the condition being that strategies be implemented and documentation provided the
next time the plan(s) are updated.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…278/462

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage residents to
use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please update this
section with a specific schedule for the completion of the land management strategies added to Section 5. Technically,
the rule states they need to be implemented within 180 days of concurrence, so be sure whatever schedule is proposed, that it
doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to renew
these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update. The system will
want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any other
questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water
Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that you
can use to download the full document with appendicies. Included in the DWSPP and attached to this email
is a letter requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking anexemption until the rule is formally changed. The sewer line in question is not currently in use and will likely
be replaced with a larger pipeline in the next year or two. Please inform the city if the new sewer line will
need to comply with requirements in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…279/462
From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule R309-
600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled using
one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1
for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be subject
to the rules until the rule change is completed. Ephraim City will be seeking an exemption until the rule
change is finalized. As far as the sewer in Zone 2 being a potential contamination source should it be
identified as controlled or not adequately controlled? If it is considered not adequately controlled, after the
rule change would that change? Any suggestions how we should handle the sewer in Zone 2 would beappreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the
wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within the
secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer to
the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of the
well. So you can try to argue protected aquifer status, but it is unlikely I will be able to concur with that classification
since the Well Driller's report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3) and
R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting exceptions to
R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter can be
prepared by a consultant, but we prefer that the letter be signed by the system because we have had situations in the
past where systems had no idea that exceptions had been requested or granted. Historically, the Division has required
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…280/462
information on the age of the sewer infrastructure, which portions of the rules are not being met, etc. We have also
required inspection by video/camera of any sewer lines located within zones one and/or two. It appears that these
sewer lines may be newer, just based on aerial photography, so a camera inspection may have been done recently that
would fulfill this requirement. Typically the conditions for granting the exceptions will be to camera/video at least once
every 3 years, and there may be additional nitrate monitoring required. Once the new rules are enacted, those
requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on protected
aquifer status for the South Well. In your previous email you mention that a portion of well protection
zone 2 for the South Well was in a Primary Recharge zone which suggested the aquifer did not qualify
as a protected aquifer. With the revised well protection zones for the South Well being significantly
smaller with the lower hydraulic conductivity and pumping rate I was wondering if you could look at the
mapping you have for Sanpete County and let me know if portions of well protection zone 2 is still
identified as being in a primary recharge area? The report you referenced in your email about your
concerns related to whether the South Well met the criteria for protected aquifer status did not include
Sanpete County or I would check myself. I would like to reference the study in the DWSPP. Pleasegive me the reference for the report/mapping for Sanpete County. I am hopeful that with the smaller
Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there is
potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer lines
within zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-515-
6(4). Depending on the decision on the protected aquifer status Ephraim may need to seek a
temporary exemption for sewer lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…281/462
I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the intent of
the rule. If the system would prefer to make the zones smaller for management purposes, you could try to refine the
value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones were
more conservative from the point of view of including more potential contamination sources. How do you feel about
this approach? It may be difficult for the system to manage a larger number of PCSs and it will make it difficult for
DDW staff to determine if land management strategies have been implemented for any not adequately controlled
PCSs when the plan is updated during the normal update cycle. If you decide to go this route, please add a column
or in some way denote which PCSs are actually within the final zones and which are not so that the system and
DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows, but
the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher flow
so that if the pump in the well is replaced to increase production the DWSPP would not need to be updated. This is a
good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than the
thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming the
North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a depth
much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is probably
closer to 200 feet or more. In the model a greater thickness reduces the size of the source protection zones. The
lower thickness assumed provides a more conservative estimate. Yes, you can always use a smaller aquifer
thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The higher
flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before making
changes to the DWSPP I wanted to see if you have any concerns with the method and assumptions.
I am attaching the following maps:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…282/462

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the cityarea. Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete the
previously identified potential contamination sources that are now not in a source protection zone.
The previous source protection zones were more conservative from the point of view of including
more potential contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We
assumed the higher flow so that if the pump in the well is replaced to increase production the DWSPP
would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We
are assuming the North and Central wells are drawing from the same aquifer. The Central Well is
producing its water from a depth much greater than the North Well. Assuming they are drawing from the
same aquifer the thickness is probably closer to 200 feet or more. In the model a greater thickness
reduces the size of the source protection zones. The lower thickness assumed provides a more
conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median
total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges
the fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm.
The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a
higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was
shut down twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an
empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with the
following parameters:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…283/462
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the
screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data.
Please let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as
clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from
different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but
when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris. The
well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the
source protection zones as if they are in the same aquifer since both are producing from fractured bedrock. I think
that will also produce more conservative source protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to
model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the
city if they want to do another pump test with the installed pump that would stress the well more, but a decision
has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the information
provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40
feet. Based on the video the well is producing water from end of the casing at 245’ to the bottom of the open hole
at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the
saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…284/462
aquifers. It probably has to do with the quality of the constant-rate test data. If the system conducts another
constant-rate test, the transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the
well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different
hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the
transmissivity that has been calculated. If you can't use two different values, then an average of the two could be
used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut down
unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does fluctuate,
but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not achieve what I
would consider a stabilized drawdown. I think the first attempt came close though. I have contacted a
hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of pumping and
recovery data available he felt he could calculate a representative hydraulic conductivity. I will share his
conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was missing
the well log for the actual production well. The well log in the appendix was for the test well. In the top 100 feet
the soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it to the
DWSPP appendix. We are looking at what is considered a clay differently. I have always felt that a soil that
includes clay will behave hydraulically more like a clay. Ultimately you will make the call on this. However, I
thought I would give my perspective. The presence or absence of clay in a soil has far more impact on the
hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills the open spaces
between the sand and gravel particles making the soil behave more like a clay from a hydraulic perspective. I do
not know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is
enough clay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to behave
hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the
soils identified as having a clay fraction behave hydraulically as a clay the standard is met. However, I believe
any soil with a significant clay fraction will behave hydraulically more like a clay than a sand or gravel. We will
correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above and
other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that
would make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-
70%), then the material will likely act as clay, but the Well Driller's Report does not state anything that leads me to
believe there is a predominance of clay besides between 75-80 feet. I have to make my decision based on the
information that is provided. If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or
something that made me think that clay was predominant, I would agree with your arguments. I also reviewed
other well logs near this source to come to my conclusion. Oftentimes lithologic logs prepared by a geologist or
engineer during the drilling are used to supplement the Well Driller's Report. Since that is not available, I have to
base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front. Water-
level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah Department of
Health, Division of Environmental Health (now DEQ) databases were examined in the study. Ground-water
recharge-area mapping delineated locations where surface contaminants could move down to the principal
aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone
two are completely within the secondary recharge area or discharge area as mapped by Anderson and others,
DDW staff would consider that sufficient evidence to demonstrate the extent of the clay layer throughout zone two.
Anderson and others mapped the recharge and discharge areas based on dominantly clay layers, 20 feet thick or
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…285/462
more. I checked this data source. Proposed zone two for the South Well was not entirely within the secondary
recharge area or discharge area. Part of Zone Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just
last week we received approval from the DDW board to move forward with rule-making regarding the sewer line
rules. The proposed rules remove the special construction requirements in zone two regardless of aquifer type. I
assume there isn't sewer infrastructure in zone one? If these rules get adopted, then the system will no longer
need an exception for the sewer infrastructure currently located in zone two. Due to the timing, it may be
necessary for the system to request temporary exceptions to R309-600-13(3) and R309-515-6(4), but once the
proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if you'd like more
information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate
aquifer. It is not as clear for the Central and North Wells. Both are completed in fractured
bedrock, but they are drawing from different depths. The central well is drawing from 437 to 452
feet. The North Well was drilled to 445 feet, but when we videoed the well we learned that the
bottom 160 feet of the well had caved in or filled with debris. The well is producing its water
from a water bearing zone at a depth of about 285 feet. I am inclined to model the source
protection zones as if they are in the same aquifer since both are producing from fractured
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…286/462
bedrock. I think that will also produce more conservative source protection zones. What is your
thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am
discussing with the city if they want to do another pump test with the installed pump that wouldstress the well more, but a decision has not been made yet. I appreciate your calculations for
the hydraulic conductivity. With the information provided above I would propose using a
hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video
the well is producing water from end of the casing at 245’ to the bottom of the open hole at 285’.
This calculates to a transmissivity of 359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long term
test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of the flow
meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized
drawdown. I think the first attempt came close though. I have contacted a hydrogeologist (Neil
Burk) to see what he felt he could do with the data. With the combination of pumping and
recovery data available he felt he could calculate a representative hydraulic conductivity. I will
share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, Inotice it was missing the well log for the actual production well. The well log in the appendix
was for the test well. In the top 100 feet the soil descriptions are similar, but not exact. I am
attaching the well log to this email and will add it to the DWSPP appendix. We are looking at
what is considered a clay differently. I have always felt that a soil that includes clay will behave
hydraulically more like a clay. Ultimately you will make the call on this. However, I thought I
would give my perspective. The presence or absence of clay in a soil has far more impact on
the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay
fills the open spaces between the sand and gravel particles making the soil behave more like a
clay from a hydraulic perspective. I do not know whether the soils not identified as a straight
clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be
identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils
identified as having a clay fraction behave hydraulically as a clay the standard is met. However,
I believe any soil with a significant clay fraction will behave hydraulically more like a clay than a
sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2.
We will assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as
justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…287/462
From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South Well
is completed in unconsolidated material, and is likely drawing from a different aquifer than the Central and
North Wells. If the three wells produce from different aquifers, separate aquifer parameters need to be
developed for each scenario (bedrock and unconsolidated) using the results of a constant-rate test. Please
be sure to confirm that the wells produce from different aquifers before proceeding with revisions. It may be
beneficial to draw a geologic cross-section. If they produce from separate aquifers then they need to be
modeled as such. That means that only the North and Central Wells should be modeled to show
interference in WhAEM using parameters derived from their constant-rate tests and the South Well should
be modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate
aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells,
which states that 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). Typically the transmissivity is
determined from the constant-rate aquifer test and then hydraulic conductivity is determined using the
equation T=K/b. The report states that the "pump data is preliminary; it will be updated once a pump test has
been completed". On page 325 of the PDF, there is data from a "constant flow test" conducted between April
12-13, 2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate test, they should
be used to derive a value for transmissivity and hydraulic conductivity for use in the WhAEM model for the
bedrock scenario. Or another 24-hour constant-rate test will need to be conducted on the North Well to
comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on
the log cycle I use. This is twice what is currently being used in the WhAEM model. The hydraulic
conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of well) =
71.8 ft/day. I also looked at the pump test data provided for what I assume is the Central Well (Ephraim Well
#1) from 1991 that was in the appendices. Based on that test, the value for transmissivity also appears to be
closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the values for drawdown at
100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only 15
feet of screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K =
14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the values for
hydraulic conductivity in WhAEM or decide what value is most appropriate. Please update the aquifer
parameters used for the North and Central Wells making sure to derive them from as-built
characteristics and the results of a constant-rate aquifer test. The delineation must also be updated to
reflect only interference from these two wells using aquifer parameters representative of bedrock wells if you
believe that the three wells produce from different aquifers.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…288/462
For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer
test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping
Test Report from 12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a
constant-rate test because the rate was not held constant and it was not continued for at least 24 hours or
until the Well experienced "stabilized drawdown". Please let me know if you disagree. If you think the data
can be used to derive aquifer transmissivity, please do so. The updated value for transmissivity and
hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected aquifer
status have been met. I am unable to concur with the protected aquifer classification for the South
West Well. While it was concurred with in the PER, the Well Driller's Report does not substantiate that 30
feet of clay were encountered in the uppermost 100 feet. A combined total of 20 feet of clay was
encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's
Reports near this source and found similar conditions. Given that the zones may change based on my
comments above, I will wait to provide a bunch of feedback on the Potential Contamination Source Inventory
(PCS), but I did notice that sewer lines are listed in zone one for the South Well but then it says under sewer
lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It also states that
it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-515-6(4) standard. I
would imagine they haven't been since the system would have been under no obligation to specially
construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required depending on the extent
of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no
changes have occurred for the springs so that it's not confusing. It doesn't look like there is anything to
implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2) and
provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not been
changes or additions for the springs. For the springs, we simply copied the information for
the springs from the 2010 plan without changes other than hopefully improved mapping and
tables identifying the location of the springs. Without changes to the plan for the springs we
did not think to include a plan implementation. We can add a section indicating the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…289/462
information relating to the springs was copied from the 2010 plan to create a single
document for all sources and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and
North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the springs
are also mentioned. Is this supposed to function as an updated plan for the spring sources? I'm not
sure it meets that intent since plan implementation is not discussed for the springs. Can you verify my
understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…290/462
From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped and
signed since this is a requirement of rule. Any comments can be addressed after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…291/462
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a
DWSP that includes all of Ephraim’s sources (wells and springs). The city is currently
reviewing the accuracy of the PCSs we identified. We are working towards submitting a draft
DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose originally
intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The PER
concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP plan is
due for both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…292/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…293/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…294/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…295/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…296/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…297/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…298/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…299/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
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Deidre Beck <[e-mail]>Wed, Jun 26, 2024 at 2:12 PM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
That all sounds fine. To close the loop on plan implementation, please be sure to indicate how the system will distribute the link to
their website where the fact sheets will be placed, i.e., how will their consumers be made aware? Will a link be placed in a bill
stuffer, in their next CCR, etc.?
On Wed, Jun 26, 2024 at 1:50 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Thank you for the information. Before we modify the DWSPP I wanted to verify that our responses will be
acceptable.

Section 2: The springs will be referenced in each section.

Sections 3 and 4: We will propose the sewer lines be considered adequately controlled based on the city’s
inspection and maintenance program. The entire sewer system is cleaned at least every 3 years. Monitoring is
constantly occurring to identify problems while they are minor. Areas that have been identified as having potential
issues during monitoring are cleaned every six months. The city monitors the sewer system by pulling manholes
and observing flows. If there is any indication of problems during monitoring, the section is cleaned, and the city
uses their camara to observe the condition of the pipe. We will remove the reference to the sewer lines being in
compliance with R309-515-6(4).

Section 5: The city will add the fact sheets provided to their website by creating a webpage similar to the
examples you provided.

Will these proposed actions adequately address your comments?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…301/462

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or added to
their CCR. It has to address hazards associated with residents and septic systems. Many systems have successfully added a
page dedicated to source protection to their website. The page may include the actual source protection plans (it doesn't have
to) and fact sheets for best management practices. I've attached all Division-prepared Fact sheets for your reference and also
an EPA fact sheet on Septic systems.

An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another example
from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will need to do is
periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides and
herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system owners,
which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill the rule, it just
needs to spell out the most important best management practices.

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management strategies. I
would like to take your offer to provide examples of how other entities have handled the BMP and land
management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment on the
sewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…302/462

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need to
be referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance
with R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control type
will need to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely
inspecting its lines or performing other periodic maintenance, best management/pollution prevention practices can be used to
assess the sewer lines as adequately controlled. We also don't consider "protected aquifer" status as a reason for assessing
a potential contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW Board
will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard presented
by these potential contamination sources. What does this mean? Will the system send out mailers, add information to their
CCR, or website concerning BMPs? We do have fact sheets that can be used. If you would like to see examples of how other
systems have handled this requirement, particularly for residents, please let me know. The strategies need to be explicit so
that the system is aware and knows exactly what they need to implement. Otherwise, the next time their update is due,
the plans may be disapproved for lack of plan implementation. Lack of plan implementation is considered a significant
deficiency under the Improvement Priority System (IPS) rule, so we emphasize the importance of this with
consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I will
be conditionally concurring with the plan with the condition being that strategies be implemented and documentation provided
the next time the plan(s) are updated.

Section 7
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…303/462

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage residents
to use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please update this
section with a specific schedule for the completion of the land management strategies added to Section 5.
Technically, the rule states they need to be implemented within 180 days of concurrence, so be sure whatever schedule is
proposed, that it doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to renew
these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update. The system
will want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any
other questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water
Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that
you can use to download the full document with appendicies. Included in the DWSPP and attached to this
email is a letter requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is seeking
an exemption until the rule is formally changed. The sewer line in question is not currently in use and will
likely be replaced with a larger pipeline in the next year or two. Please inform the city if the new sewer line
will need to comply with requirements in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…304/462
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule
R309-600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately controlled
using one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone 1
for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be
subject to the rules until the rule change is completed. Ephraim City will be seeking an exemption until
the rule change is finalized. As far as the sewer in Zone 2 being a potential contamination source
should it be identified as controlled or not adequately controlled? If it is considered not adequately
controlled, after the rule change would that change? Any suggestions how we should handle the sewerin Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the
wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within the
secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the clay layer
to the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost 100 feet of
the well. So you can try to argue protected aquifer status, but it is unlikely I will be able to concur with that
classification since the Well Driller's report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3)
and R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting
exceptions to R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The letter
can be prepared by a consultant, but we prefer that the letter be signed by the system because we have had
situations in the past where systems had no idea that exceptions had been requested or granted. Historically, the
Division has required information on the age of the sewer infrastructure, which portions of the rules are not being
met, etc. We have also required inspection by video/camera of any sewer lines located within zones one and/or two.
It appears that these sewer lines may be newer, just based on aerial photography, so a camera inspection may have
been done recently that would fulfill this requirement. Typically the conditions for granting the exceptions will be to
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…305/462
camera/video at least once every 3 years, and there may be additional nitrate monitoring required. Once the new
rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on
protected aquifer status for the South Well. In your previous email you mention that a portion of well
protection zone 2 for the South Well was in a Primary Recharge zone which suggested the aquifer
did not qualify as a protected aquifer. With the revised well protection zones for the South Well being
significantly smaller with the lower hydraulic conductivity and pumping rate I was wondering if you
could look at the mapping you have for Sanpete County and let me know if portions of well protectionzone 2 is still identified as being in a primary recharge area? The report you referenced in your email
about your concerns related to whether the South Well met the criteria for protected aquifer status did
not include Sanpete County or I would check myself. I would like to reference the study in the
DWSPP. Please give me the reference for the report/mapping for Sanpete County. I am hopeful that
with the smaller Zone 2 we can justify a protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development there
is potential for a sewer line to be constructed about 80 feet from the well. There are existing sewer
lines within zone 2. Any new sewer lines constructed within zone 1 would need to comply with R309-
515-6(4). Depending on the decision on the protected aquifer status Ephraim may need to seek atemporary exemption for sewer lines in zone 2. What is the process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any further
questions.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…306/462
I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the intent
of the rule. If the system would prefer to make the zones smaller for management purposes, you could try to refine
the value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones were
more conservative from the point of view of including more potential contamination sources. How do you feel
about this approach? It may be difficult for the system to manage a larger number of PCSs and it will make it
difficult for DDW staff to determine if land management strategies have been implemented for any not adequately
controlled PCSs when the plan is updated during the normal update cycle. If you decide to go this route, please
add a column or in some way denote which PCSs are actually within the final zones and which are not so that the
system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed flows,
but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed the higher
flow so that if the pump in the well is replaced to increase production the DWSPP would not need to be updated.
This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than
the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are assuming
the North and Central wells are drawing from the same aquifer. The Central Well is producing its water from a
depth much greater than the North Well. Assuming they are drawing from the same aquifer the thickness is
probably closer to 200 feet or more. In the model a greater thickness reduces the size of the source protection
zones. The lower thickness assumed provides a more conservative estimate. Yes, you can always use a smaller
aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts one
value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the fractured
bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before making
changes to the DWSPP I wanted to see if you have any concerns with the method and
assumptions. I am attaching the following maps:

North Well protection zones
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…307/462
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the city
area. Assuming these protection zones are acceptable, I would like to propose that we add
potential contamination sources not previously included in a source protection zone, but not delete
the previously identified potential contamination sources that are now not in a source protection
zone. The previous source protection zones were more conservative from the point of view of
including more potential contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these
assumed flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed
flows. We assumed the higher flow so that if the pump in the well is replaced to increase production the
DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is
higher than the thicknesses used to calculate the hydraulic conductivity, but less than the actual
thickness. We are assuming the North and Central wells are drawing from the same aquifer. The
Central Well is producing its water from a depth much greater than the North Well. Assuming they are
drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the model a
greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median
total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges
the fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400
gpm. The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a
higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump was
shut down twice and pumping time was limited, I think the best approach to estimate transmissivity is to use an
empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with the
following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…308/462
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on the
screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data.
Please let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not as
clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from
different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but
when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris. The
well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the
source protection zones as if they are in the same aquifer since both are producing from fractured bedrock. I
think that will also produce more conservative source protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to
model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with
the city if they want to do another pump test with the installed pump that would stress the well more, but a
decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the
information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer
thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable to
you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as the
saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured bedrock
aquifers. It probably has to do with the quality of the constant-rate test data. If the system conducts another
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…309/462
constant-rate test, the transmissivity could be further refined but I'm not suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model the
well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different
hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the
transmissivity that has been calculated. If you can't use two different values, then an average of the two could
be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does
fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not
achieve what I would consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of
pumping and recovery data available he felt he could calculate a representative hydraulic conductivity. I will
share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In the top
100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and will add it to
the DWSPP appendix. We are looking at what is considered a clay differently. I have always felt that a soil that
includes clay will behave hydraulically more like a clay. Ultimately you will make the call on this. However, I
thought I would give my perspective. The presence or absence of clay in a soil has far more impact on the
hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay fills the open
spaces between the sand and gravel particles making the soil behave more like a clay from a hydraulic
perspective. I do not know whether the soils not identified as a straight clay are a sandy/gravely clay or a
clayey sand, but if there is enough clay in a sample for it to be identified as having clay, I feel there is enough
clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100
feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a clay the standard
is met. However, I believe any soil with a significant clay fraction will behave hydraulically more like a clay than
a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess
the need to request an exemption after receiving your thoughts on this and redoing the modeling. It could be
that my logic above and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks that
would make me think that there is a predominance of clay. I agree that if there is a significant clay fraction (60-
70%), then the material will likely act as clay, but the Well Driller's Report does not state anything that leads me
to believe there is a predominance of clay besides between 75-80 feet. I have to make my decision based on
the information that is provided. If the Well Driller's Report denoted "mostly clay", "clayey sand", "70% clay", or
something that made me think that clay was predominant, I would agree with your arguments. I also reviewed
other well logs near this source to come to my conclusion. Oftentimes lithologic logs prepared by a geologist or
engineer during the drilling are used to supplement the Well Driller's Report. Since that is not available, I have
to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front.
Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah
Department of Health, Division of Environmental Health (now DEQ) databases were examined in the study.
Ground-water recharge-area mapping delineated locations where surface contaminants could move down to
the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying zone
two are completely within the secondary recharge area or discharge area as mapped by Anderson and others,
DDW staff would consider that sufficient evidence to demonstrate the extent of the clay layer throughout zone
two. Anderson and others mapped the recharge and discharge areas based on dominantly clay layers, 20 feet
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…310/462
thick or more. I checked this data source. Proposed zone two for the South Well was not entirely within the
secondary recharge area or discharge area. Part of Zone Two was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other two. Just
last week we received approval from the DDW board to move forward with rule-making regarding the sewer line
rules. The proposed rules remove the special construction requirements in zone two regardless of aquifer type.
I assume there isn't sewer infrastructure in zone one? If these rules get adopted, then the system will no longer
need an exception for the sewer infrastructure currently located in zone two. Due to the timing, it may be
necessary for the system to request temporary exceptions to R309-600-13(3) and R309-515-6(4), but once the
proposed rules are adopted/enacted, the exceptions will no longer be required. Let me know if you'd like more
information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts
on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate
aquifer. It is not as clear for the Central and North Wells. Both are completed in fractured
bedrock, but they are drawing from different depths. The central well is drawing from 437 to
452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned
that the bottom 160 feet of the well had caved in or filled with debris. The well is producing its
water from a water bearing zone at a depth of about 285 feet. I am inclined to model the
source protection zones as if they are in the same aquifer since both are producing from
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…311/462
fractured bedrock. I think that will also produce more conservative source protection zones.
What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I
am discussing with the city if they want to do another pump test with the installed pump thatwould stress the well more, but a decision has not been made yet. I appreciate your
calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet.
Based on the video the well is producing water from end of the casing at 245’ to the bottom of
the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem
reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long term
test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of the flow
meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized
drawdown. I think the first attempt came close though. I have contacted a hydrogeologist
(Neil Burk) to see what he felt he could do with the data. With the combination of pumping
and recovery data available he felt he could calculate a representative hydraulic conductivity. I
will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I
notice it was missing the well log for the actual production well. The well log in the appendix
was for the test well. In the top 100 feet the soil descriptions are similar, but not exact. I am
attaching the well log to this email and will add it to the DWSPP appendix. We are looking at
what is considered a clay differently. I have always felt that a soil that includes clay will
behave hydraulically more like a clay. Ultimately you will make the call on this. However, I
thought I would give my perspective. The presence or absence of clay in a soil has far more
impact on the hydraulic conductivity of the soil than does the presence or absence of sand or
gravel. Clay fills the open spaces between the sand and gravel particles making the soil
behave more like a clay from a hydraulic perspective. I do not know whether the soils not
identified as a straight clay are a sandy/gravely clay or a clayey sand, but if there is enoughclay in a sample for it to be identified as having clay, I feel there is enough clay for the soil to
behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in the top 100
feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a
clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency
regarding the sewer lines in Zones 1 and 2. We will assess the need to request an exemption
after receiving your thoughts on this and redoing the modeling. It could be that my logic above
and other information is included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…312/462
From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South
Well is completed in unconsolidated material, and is likely drawing from a different aquifer than the Central
and North Wells. If the three wells produce from different aquifers, separate aquifer parameters need to be
developed for each scenario (bedrock and unconsolidated) using the results of a constant-rate test.
Please be sure to confirm that the wells produce from different aquifers before proceeding with revisions. It
may be beneficial to draw a geologic cross-section. If they produce from separate aquifers then they
need to be modeled as such. That means that only the North and Central Wells should be modeled to
show interference in WhAEM using parameters derived from their constant-rate tests and the South Well
should be modeled separately, i.e., the zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate
aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New Wells,
which states that 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). Typically the transmissivity is
determined from the constant-rate aquifer test and then hydraulic conductivity is determined using the
equation T=K/b. The report states that the "pump data is preliminary; it will be updated once a pump test
has been completed". On page 325 of the PDF, there is data from a "constant flow test" conducted
between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data are from a constant-rate
test, they should be used to derive a value for transmissivity and hydraulic conductivity for use in the
WhAEM model for the bedrock scenario. Or another 24-hour constant-rate test will need to be conducted
on the North Well to comply with R309-600-9(6)(a)(iv) unless the system wants to request an exception to
rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending on
the log cycle I use. This is twice what is currently being used in the WhAEM model. The hydraulic
conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of well)
= 71.8 ft/day. I also looked at the pump test data provided for what I assume is the Central Well (Ephraim
Well #1) from 1991 that was in the appendices. Based on that test, the value for transmissivity also
appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the values
for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only
15 feet of screen was perforated. The hydraulic conductivity for the Central Well would then be equal to K
= 14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the values
for hydraulic conductivity in WhAEM or decide what value is most appropriate. Please update the aquifer
parameters used for the North and Central Wells making sure to derive them from as-built
characteristics and the results of a constant-rate aquifer test. The delineation must also be updated to
reflect only interference from these two wells using aquifer parameters representative of bedrock wells if
you believe that the three wells produce from different aquifers.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…313/462
For the South Well, the aquifer parameters should also be based on the results of a constant-rate aquifer
test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if the Pumping
Test Report from 12-19-2019 is for the South Well. The data do not appear to meet the rule definition for a
constant-rate test because the rate was not held constant and it was not continued for at least 24 hours or
until the Well experienced "stabilized drawdown". Please let me know if you disagree. If you think the data
can be used to derive aquifer transmissivity, please do so. The updated value for transmissivity and
hydraulic conductivity should be used to remodel the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected
aquifer status have been met. I am unable to concur with the protected aquifer classification for the
South West Well. While it was concurred with in the PER, the Well Driller's Report does not substantiate
that 30 feet of clay were encountered in the uppermost 100 feet. A combined total of 20 feet of clay was
encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I also looked at Well Driller's
Reports near this source and found similar conditions. Given that the zones may change based on my
comments above, I will wait to provide a bunch of feedback on the Potential Contamination Source
Inventory (PCS), but I did notice that sewer lines are listed in zone one for the South Well but then it says
under sewer lines in zone 2 that there are no sewer lines in zone 1. Please update this to be consistent. It
also states that it is unknown whether or not sewer lines in zone 2 have been constructed to the R309-
515-6(4) standard. I would imagine they haven't been since the system would have been under no
obligation to specially construct them. Exceptions to R309-600-13(3) and R309-515-6(4) may be required
depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no
changes have occurred for the springs so that it's not confusing. It doesn't look like there is anything to
implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2)
and provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not been
changes or additions for the springs. For the springs, we simply copied the information
for the springs from the 2010 plan without changes other than hopefully improved
mapping and tables identifying the location of the springs. Without changes to the plan
for the springs we did not think to include a plan implementation. We can add a section
indicating the information relating to the springs was copied from the 2010 plan to create
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…314/462
a single document for all sources and that those plans have previously been
implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016) and
North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the
springs are also mentioned. Is this supposed to function as an updated plan for the spring sources?
I'm not sure it meets that intent since plan implementation is not discussed for the springs. Can you
verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your
review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…315/462
From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped
and signed since this is a requirement of rule. Any comments can be addressed after the official
review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all of
Ephraim’s drinking water sources including the mountain springs and three wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
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Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…316/462
On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing a
DWSP that includes all of Ephraim’s sources (wells and springs). The city is currently
reviewing the accuracy of the PCSs we identified. We are working towards submitting a draft
DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose originally
intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The
PER concurrence letter for the North Well was sent out on November 16, 2022. A full DWSP
plan is due for both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…317/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…318/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…319/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…320/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…321/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…322/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…323/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…324/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
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.
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https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…325/462
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Deidre Beck <[e-mail]>Mon, Dec 23, 2024 at 1:48 PM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
Hi Layne,
I don't believe I've heard anything from you since June. Do you have an update as to where things are at with this project?
Happy Holidays!
On Wed, Jun 26, 2024 at 2:12 PM Deidre Beck <[e-mail]> wrote:
That all sounds fine. To close the loop on plan implementation, please be sure to indicate how the system will distribute the link
to their website where the fact sheets will be placed, i.e., how will their consumers be made aware? Will a link be placed in a bill
stuffer, in their next CCR, etc.?
On Wed, Jun 26, 2024 at 1:50 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Thank you for the information. Before we modify the DWSPP I wanted to verify that our responses will be
acceptable.

Section 2: The springs will be referenced in each section.

Sections 3 and 4: We will propose the sewer lines be considered adequately controlled based on the city’s
inspection and maintenance program. The entire sewer system is cleaned at least every 3 years. Monitoring is
constantly occurring to identify problems while they are minor. Areas that have been identified as having
potential issues during monitoring are cleaned every six months. The city monitors the sewer system by pulling
manholes and observing flows. If there is any indication of problems during monitoring, the section is cleaned,
and the city uses their camara to observe the condition of the pipe. We will remove the reference to the sewer
lines being in compliance with R309-515-6(4).

Section 5: The city will add the fact sheets provided to their website by creating a webpage similar to the
examples you provided.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…326/462
Will these proposed actions adequately address your comments?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or added
to their CCR. It has to address hazards associated with residents and septic systems. Many systems have successfully
added a page dedicated to source protection to their website. The page may include the actual source protection plans (it
doesn't have to) and fact sheets for best management practices. I've attached all Division-prepared Fact sheets for
your reference and also an EPA fact sheet on Septic systems.

An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another
example from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will need
to do is periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides
and herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system
owners, which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill the
rule, it just needs to spell out the most important best management practices.

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management strategies.
I would like to take your offer to provide examples of how other entities have handled the BMP and land
management strategy requirements.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…327/462
One clarification, If the board does vote to adopt the rule change will we need to address your comment on
the sewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need
to be referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance
with R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control
type will need to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely
inspecting its lines or performing other periodic maintenance, best management/pollution prevention practices can be used
to assess the sewer lines as adequately controlled. We also don't consider "protected aquifer" status as a reason for
assessing a potential contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW
Board will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard
presented by these potential contamination sources. What does this mean? Will the system send out mailers, add
information to their CCR, or website concerning BMPs? We do have fact sheets that can be used. If you would like to see
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…328/462
examples of how other systems have handled this requirement, particularly for residents, please let me know. The
strategies need to be explicit so that the system is aware and knows exactly what they need to implement.
Otherwise, the next time their update is due, the plans may be disapproved for lack of plan implementation. Lack of plan
implementation is considered a significant deficiency under the Improvement Priority System (IPS) rule, so we emphasize
the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I will
be conditionally concurring with the plan with the condition being that strategies be implemented and documentation
provided the next time the plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage
residents to use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please
update this section with a specific schedule for the completion of the land management strategies added to
Section 5. Technically, the rule states they need to be implemented within 180 days of concurrence, so be sure whatever
schedule is proposed, that it doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to
renew these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update. The
system will want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any
other questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water
Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link that
you can use to download the full document with appendicies. Included in the DWSPP and attached to
this email is a letter requesting an exemption for a sewer line in Zone 2 for the South Well. Ephraim is
seeking an exemption until the rule is formally changed. The sewer line in question is not currently in
use and will likely be replaced with a larger pipeline in the next year or two. Please inform the city if the
new sewer line will need to comply with requirements in R309-600-13(3) and R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…329/462

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule
R309-600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately
controlled using one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within Zone
1 for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that will be
subject to the rules until the rule change is completed. Ephraim City will be seeking an exemption
until the rule change is finalized. As far as the sewer in Zone 2 being a potential contamination
source should it be identified as controlled or not adequately controlled? If it is considered not
adequately controlled, after the rule change would that change? Any suggestions how we should
handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to the
wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…330/462
secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the clay
layer to the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost 100
feet of the well. So you can try to argue protected aquifer status, but it is unlikely I will be able to concur with that
classification since the Well Driller's report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3)
and R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting
exceptions to R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The
letter can be prepared by a consultant, but we prefer that the letter be signed by the system because we have had
situations in the past where systems had no idea that exceptions had been requested or granted. Historically, the
Division has required information on the age of the sewer infrastructure, which portions of the rules are not being
met, etc. We have also required inspection by video/camera of any sewer lines located within zones one and/or
two. It appears that these sewer lines may be newer, just based on aerial photography, so a camera inspection
may have been done recently that would fulfill this requirement. Typically the conditions for granting the exceptions
will be to camera/video at least once every 3 years, and there may be additional nitrate monitoring required. Once
the new rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on
protected aquifer status for the South Well. In your previous email you mention that a portion of
well protection zone 2 for the South Well was in a Primary Recharge zone which suggested the
aquifer did not qualify as a protected aquifer. With the revised well protection zones for the South
Well being significantly smaller with the lower hydraulic conductivity and pumping rate I was
wondering if you could look at the mapping you have for Sanpete County and let me know if
portions of well protection zone 2 is still identified as being in a primary recharge area? The report
you referenced in your email about your concerns related to whether the South Well met the criteria
for protected aquifer status did not include Sanpete County or I would check myself. I would like toreference the study in the DWSPP. Please give me the reference for the report/mapping for
Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a protected aquifer
status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development
there is potential for a sewer line to be constructed about 80 feet from the well. There are existing
sewer lines within zone 2. Any new sewer lines constructed within zone 1 would need to comply
with R309-515-6(4). Depending on the decision on the protected aquifer status Ephraim may need
to seek a temporary exemption for sewer lines in zone 2. What is the process to seek the
exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…331/462
From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any
further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the
intent of the rule. If the system would prefer to make the zones smaller for management purposes, you could try
to refine the value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones were
more conservative from the point of view of including more potential contamination sources. How do you feel
about this approach? It may be difficult for the system to manage a larger number of PCSs and it will make it
difficult for DDW staff to determine if land management strategies have been implemented for any not
adequately controlled PCSs when the plan is updated during the normal update cycle. If you decide to go this
route, please add a column or in some way denote which PCSs are actually within the final zones and which are
not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed
the higher flow so that if the pump in the well is replaced to increase production the DWSPP would not need to
be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher than
the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer the
thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of the source
protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you can always
use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts
one value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the
fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…332/462
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before
making changes to the DWSPP I wanted to see if you have any concerns with the method and
assumptions. I am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the
city area. Assuming these protection zones are acceptable, I would like to propose that we addpotential contamination sources not previously included in a source protection zone, but not
delete the previously identified potential contamination sources that are now not in a source
protection zone. The previous source protection zones were more conservative from the point of
view of including more potential contamination sources. How do you feel about this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these
assumed flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed
flows. We assumed the higher flow so that if the pump in the well is replaced to increase production
the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is
higher than the thicknesses used to calculate the hydraulic conductivity, but less than the actual
thickness. We are assuming the North and Central wells are drawing from the same aquifer. The
Central Well is producing its water from a depth much greater than the North Well. Assuming they are
drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the model a
greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the
median total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water
recharges the fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400
gpm. The higher flow is assumed to be conservative.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…333/462
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a
higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump
was shut down twice and pumping time was limited, I think the best approach to estimate transmissivity is to
use an empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity with
the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on
the screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data. Please let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not
as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from
different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but
when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris.
The well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to model
the source protection zones as if they are in the same aquifer since both are producing from fractured
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…334/462
bedrock. I think that will also produce more conservative source protection zones. What is your thought on
this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense to
model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more, but
a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the
information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer
thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable
to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as
the saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured
bedrock aquifers. It probably has to do with the quality of the constant-rate test data. If the system conducts
another constant-rate test, the transmissivity could be further refined but I'm not suggesting they have to do
that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model
the well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different
hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use the
transmissivity that has been calculated. If you can't use two different values, then an average of the two could
be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does
fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not
achieve what I would consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of
pumping and recovery data available he felt he could calculate a representative hydraulic conductivity. I will
share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In the
top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and will
add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have always felt
that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make the call on
this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far more
impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel. Clay
fills the open spaces between the sand and gravel particles making the soil behave more like a clay from a
hydraulic perspective. I do not know whether the soils not identified as a straight clay are a sandy/gravely
clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having clay, I feel there
is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of clay in
the top 100 feet. Even if only half of the soils identified as having a clay fraction behave hydraulically as a
clay the standard is met. However, I believe any soil with a significant clay fraction will behave hydraulically
more like a clay than a sand or gravel. We will correct the inconsistency regarding the sewer lines in Zones 1
and 2. We will assess the need to request an exemption after receiving your thoughts on this and redoing the
modeling. It could be that my logic above and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks
that would make me think that there is a predominance of clay. I agree that if there is a significant clay
fraction (60-70%), then the material will likely act as clay, but the Well Driller's Report does not state anything
that leads me to believe there is a predominance of clay besides between 75-80 feet. I have to make my
decision based on the information that is provided. If the Well Driller's Report denoted "mostly clay", "clayey
sand", "70% clay", or something that made me think that clay was predominant, I would agree with your
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…335/462
arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes lithologic
logs prepared by a geologist or engineer during the drilling are used to supplement the Well Driller's Report.
Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front.
Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah
Department of Health, Division of Environmental Health (now DEQ) databases were examined in the study.
Ground-water recharge-area mapping delineated locations where surface contaminants could move down to
the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying
zone two are completely within the secondary recharge area or discharge area as mapped by Anderson and
others, DDW staff would consider that sufficient evidence to demonstrate the extent of the clay layer
throughout zone two. Anderson and others mapped the recharge and discharge areas based on dominantly
clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for the South Well was not
entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the primary
recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other
two. Just last week we received approval from the DDW board to move forward with rule-making regarding
the sewer line rules. The proposed rules remove the special construction requirements in zone two
regardless of aquifer type. I assume there isn't sewer infrastructure in zone one? If these rules get adopted,
then the system will no longer need an exception for the sewer infrastructure currently located in zone two.
Due to the timing, it may be necessary for the system to request temporary exceptions to R309-600-13(3)
and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no longer be
required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…336/462

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your thoughts
on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separateaquifer. It is not as clear for the Central and North Wells. Both are completed in fractured
bedrock, but they are drawing from different depths. The central well is drawing from 437 to
452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned
that the bottom 160 feet of the well had caved in or filled with debris. The well is producing
its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the
source protection zones as if they are in the same aquifer since both are producing from
fractured bedrock. I think that will also produce more conservative source protection zones.
What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. Iam discussing with the city if they want to do another pump test with the installed pump that
would stress the well more, but a decision has not been made yet. I appreciate your
calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40 feet.
Based on the video the well is producing water from end of the casing at 245’ to the bottom
of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem
reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long
term test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of the
flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a stabilized
drawdown. I think the first attempt came close though. I have contacted a hydrogeologist
(Neil Burk) to see what he felt he could do with the data. With the combination of pumping
and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix,
I notice it was missing the well log for the actual production well. The well log in the
appendix was for the test well. In the top 100 feet the soil descriptions are similar, but not
exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We
are looking at what is considered a clay differently. I have always felt that a soil that
includes clay will behave hydraulically more like a clay. Ultimately you will make the call on
this. However, I thought I would give my perspective. The presence or absence of clay in a
soil has far more impact on the hydraulic conductivity of the soil than does the presence or
absence of sand or gravel. Clay fills the open spaces between the sand and gravel particles
making the soil behave more like a clay from a hydraulic perspective. I do not know whetherthe soils not identified as a straight clay are a sandy/gravely clay or a clayey sand, but if
there is enough clay in a sample for it to be identified as having clay, I feel there is enough
clay for the soil to behave hydraulically as a clay. In this line of thinking there is 70 feet of
clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction
behave hydraulically as a clay the standard is met. However, I believe any soil with a
significant clay fraction will behave hydraulically more like a clay than a sand or gravel. We
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…337/462
will correct the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the
need to request an exemption after receiving your thoughts on this and redoing the
modeling. It could be that my logic above and other information is included as justification
for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the South
Well is completed in unconsolidated material, and is likely drawing from a different aquifer than the
Central and North Wells. If the three wells produce from different aquifers, separate aquifer parameters
need to be developed for each scenario (bedrock and unconsolidated) using the results of a constant-
rate test. Please be sure to confirm that the wells produce from different aquifers before proceeding with
revisions. It may be beneficial to draw a geologic cross-section. If they produce from separate
aquifers then they need to be modeled as such. That means that only the North and Central Wells
should be modeled to show interference in WhAEM using parameters derived from their constant-rate
tests and the South Well should be modeled separately, i.e., the zones may overlap those of the North
and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate
aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New
Wells, which states that 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). Typically the
transmissivity is determined from the constant-rate aquifer test and then hydraulic conductivity is
determined using the equation T=K/b. The report states that the "pump data is preliminary; it will be
updated once a pump test has been completed". On page 325 of the PDF, there is data from a "constant
flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If these data
are from a constant-rate test, they should be used to derive a value for transmissivity and hydraulic
conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-hour constant-rate
test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv) unless the system
wants to request an exception to rule.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…338/462
When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending
on the log cycle I use. This is twice what is currently being used in the WhAEM model. The hydraulic
conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of
well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is the Central Well
(Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for transmissivity
also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described above and the
values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that only
15 feet of screen was perforated. The hydraulic conductivity for the Central Well would then be equal to
K = 14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average of the
values for hydraulic conductivity in WhAEM or decide what value is most appropriate. Please update
the aquifer parameters used for the North and Central Wells making sure to derive them from as-
built characteristics and the results of a constant-rate aquifer test. The delineation must also be
updated to reflect only interference from these two wells using aquifer parameters representative of
bedrock wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate
aquifer test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if
the Pumping Test Report from 12-19-2019 is for the South Well. The data do not appear to meet the rule
definition for a constant-rate test because the rate was not held constant and it was not continued for at
least 24 hours or until the Well experienced "stabilized drawdown". Please let me know if you disagree.
If you think the data can be used to derive aquifer transmissivity, please do so. The updated value for
transmissivity and hydraulic conductivity should be used to remodel the zones for the South
Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected
aquifer status have been met. I am unable to concur with the protected aquifer classification for
the South West Well. While it was concurred with in the PER, the Well Driller's Report does not
substantiate that 30 feet of clay were encountered in the uppermost 100 feet. A combined total of 20
feet of clay was encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I also
looked at Well Driller's Reports near this source and found similar conditions. Given that the zones may
change based on my comments above, I will wait to provide a bunch of feedback on the Potential
Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the
South Well but then it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please
update this to be consistent. It also states that it is unknown whether or not sewer lines in zone 2 have
been constructed to the R309-515-6(4) standard. I would imagine they haven't been since the system
would have been under no obligation to specially construct them. Exceptions to R309-600-13(3) and
R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no
changes have occurred for the springs so that it's not confusing. It doesn't look like there is anything
to implement for the springs so disregard that statement from my last email.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…339/462
As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2)
and provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not been
changes or additions for the springs. For the springs, we simply copied the information
for the springs from the 2010 plan without changes other than hopefully improved
mapping and tables identifying the location of the springs. Without changes to the plan
for the springs we did not think to include a plan implementation. We can add a sectionindicating the information relating to the springs was copied from the 2010 plan to
create a single document for all sources and that those plans have previously been
implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016)
and North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that the
springs are also mentioned. Is this supposed to function as an updated plan for the spring
sources? I'm not sure it meets that intent since plan implementation is not discussed for the
springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your
review.

I'm using Adobe Acrobat.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…340/462
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped
and signed since this is a requirement of rule. Any comments can be addressed after the official
review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes all
of Ephraim’s drinking water sources including the mountain springs and three
wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-
ace2f50e8c98

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…341/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently preparing
a DWSP that includes all of Ephraim’s sources (wells and springs). The city is currently
reviewing the accuracy of the PCSs we identified. We are working towards submitting a
draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose
originally intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…342/462
Would you happen to have an update on the final DWSP plan for these two sources? The
PER concurrence letter for the North Well was sent out on November 16, 2022. A full
DWSP plan is due for both by 11/16/2023.

Thanks,

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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…343/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…344/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…345/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…346/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…347/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…348/462
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.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…349/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…350/462
--
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.
--
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.
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Layne Jensen <[e-mail]>Thu, Jan 2, 2025 at 8:12 AM
To: Deidre Beck <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…351/462
Hi Diedre,

I hope you had a great Christmas and New Years. I appreciate the follow up. We addressed the comments and
sent it to Ephraim for review and to answer a couple of questions. There have been some staff changes in Ephraim
and a lot of pressure on Bryan and Jeff lately so it appears it has fallen through the cracks. I will follow up with
them and get you hopefully the final version of the DWSPP.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, December 23, 2024 1:49 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I don't believe I've heard anything from you since June. Do you have an update as to where things are at with this project?

Happy Holidays!

On Wed, Jun 26, 2024 at 2:12 PM Deidre Beck <[e-mail]> wrote:
That all sounds fine. To close the loop on plan implementation, please be sure to indicate how the system will distribute the link
to their website where the fact sheets will be placed, i.e., how will their consumers be made aware? Will a link be placed in a bill
stuffer, in their next CCR, etc.?

On Wed, Jun 26, 2024 at 1:50 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Thank you for the information. Before we modify the DWSPP I wanted to verify that our responses will be
acceptable.

Section 2: The springs will be referenced in each section.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…352/462

Sections 3 and 4: We will propose the sewer lines be considered adequately controlled based on the city’sinspection and maintenance program. The entire sewer system is cleaned at least every 3 years. Monitoring
is constantly occurring to identify problems while they are minor. Areas that have been identified as having
potential issues during monitoring are cleaned every six months. The city monitors the sewer system by
pulling manholes and observing flows. If there is any indication of problems during monitoring, the section is
cleaned, and the city uses their camara to observe the condition of the pipe. We will remove the reference to
the sewer lines being in compliance with R309-515-6(4).

Section 5: The city will add the fact sheets provided to their website by creating a webpage similar to the
examples you provided.

Will these proposed actions adequately address your comments?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or added
to their CCR. It has to address hazards associated with residents and septic systems. Many systems have successfully
added a page dedicated to source protection to their website. The page may include the actual source protection plans (it
doesn't have to) and fact sheets for best management practices. I've attached all Division-prepared Fact sheets for
your reference and also an EPA fact sheet on Septic systems.

An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another
example from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will need
to do is periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides
and herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system
owners, which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill
the rule, it just needs to spell out the most important best management practices.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…353/462

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management strategies.
I would like to take your offer to provide examples of how other entities have handled the BMP and land
management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment on
the sewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they need
to be referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in accordance
with R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so another control
type will need to be used to assess the sewer lines as adequately controlled. Generally, if a sewer utility is routinely
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…354/462
inspecting its lines or performing other periodic maintenance, best management/pollution prevention practices can be
used to assess the sewer lines as adequately controlled. We also don't consider "protected aquifer" status as a reason for
assessing a potential contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW
Board will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard
presented by these potential contamination sources. What does this mean? Will the system send out mailers, add
information to their CCR, or website concerning BMPs? We do have fact sheets that can be used. If you would like to see
examples of how other systems have handled this requirement, particularly for residents, please let me know. The
strategies need to be explicit so that the system is aware and knows exactly what they need to implement.
Otherwise, the next time their update is due, the plans may be disapproved for lack of plan implementation. Lack of plan
implementation is considered a significant deficiency under the Improvement Priority System (IPS) rule, so we emphasize
the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I
will be conditionally concurring with the plan with the condition being that strategies be implemented and documentation
provided the next time the plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage
residents to use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished? Please
update this section with a specific schedule for the completion of the land management strategies added to
Section 5. Technically, the rule states they need to be implemented within 180 days of concurrence, so be sure whatever
schedule is proposed, that it doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to
renew these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update.
The system will want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with any
other questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…355/462
We have updated the source protection zones as you recommended and updated the Drinking Water
Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link
that you can use to download the full document with appendicies. Included in the DWSPP and
attached to this email is a letter requesting an exemption for a sewer line in Zone 2 for the South Well.
Ephraim is seeking an exemption until the rule is formally changed. The sewer line in question is not
currently in use and will likely be replaced with a larger pipeline in the next year or two. Please informthe city if the new sewer line will need to comply with requirements in R309-600-13(3) and R309-515-
6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule
R309-600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately
controlled using one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within
Zone 1 for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that
will be subject to the rules until the rule change is completed. Ephraim City will be seeking an
exemption until the rule change is finalized. As far as the sewer in Zone 2 being a potential
contamination source should it be identified as controlled or not adequately controlled? If it isconsidered not adequately controlled, after the rule change would that change? Any suggestions
how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…356/462

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to
the wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within
the secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the
clay layer to the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the uppermost
100 feet of the well. So you can try to argue protected aquifer status, but it is unlikely I will be able to concur with
that classification since the Well Driller's report does not indicate that 30 feet of clay was encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-13(3)
and R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter requesting
exceptions to R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director approval. The
letter can be prepared by a consultant, but we prefer that the letter be signed by the system because we have had
situations in the past where systems had no idea that exceptions had been requested or granted. Historically, the
Division has required information on the age of the sewer infrastructure, which portions of the rules are not being
met, etc. We have also required inspection by video/camera of any sewer lines located within zones one and/or
two. It appears that these sewer lines may be newer, just based on aerial photography, so a camera inspection
may have been done recently that would fulfill this requirement. Typically the conditions for granting the
exceptions will be to camera/video at least once every 3 years, and there may be additional nitrate monitoring
required. Once the new rules are enacted, those requirements will no longer be required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on
protected aquifer status for the South Well. In your previous email you mention that a portion of
well protection zone 2 for the South Well was in a Primary Recharge zone which suggested the
aquifer did not qualify as a protected aquifer. With the revised well protection zones for the South
Well being significantly smaller with the lower hydraulic conductivity and pumping rate I was
wondering if you could look at the mapping you have for Sanpete County and let me know if
portions of well protection zone 2 is still identified as being in a primary recharge area? The report
you referenced in your email about your concerns related to whether the South Well met the
criteria for protected aquifer status did not include Sanpete County or I would check myself. I
would like to reference the study in the DWSPP. Please give me the reference for thereport/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a
protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development
there is potential for a sewer line to be constructed about 80 feet from the well. There are existing
sewer lines within zone 2. Any new sewer lines constructed within zone 1 would need to comply
with R309-515-6(4). Depending on the decision on the protected aquifer status Ephraim may need
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…357/462
to seek a temporary exemption for sewer lines in zone 2. What is the process to seek the
exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any
further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the
intent of the rule. If the system would prefer to make the zones smaller for management purposes, you could try
to refine the value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones
were more conservative from the point of view of including more potential contamination sources. How do you
feel about this approach? It may be difficult for the system to manage a larger number of PCSs and it will make
it difficult for DDW staff to determine if land management strategies have been implemented for any not
adequately controlled PCSs when the plan is updated during the normal update cycle. If you decide to go this
route, please add a column or in some way denote which PCSs are actually within the final zones and which
are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We assumed
the higher flow so that if the pump in the well is replaced to increase production the DWSPP would not need to
be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…358/462
thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of the
source protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you can
always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only accepts
one value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the
fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm. The
higher flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before
making changes to the DWSPP I wanted to see if you have any concerns with the method and
assumptions. I am attaching the following maps:

North Well protection zonesCentral Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection zones

The revised protection zones generally extend farther into the mountains but cover less of the
city area. Assuming these protection zones are acceptable, I would like to propose that we add
potential contamination sources not previously included in a source protection zone, but not
delete the previously identified potential contamination sources that are now not in a source
protection zone. The previous source protection zones were more conservative from the pointof view of including more potential contamination sources. How do you feel about this
approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these
assumed flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed
flows. We assumed the higher flow so that if the pump in the well is replaced to increase production
the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is
higher than the thicknesses used to calculate the hydraulic conductivity, but less than the actual
thickness. We are assuming the North and Central wells are drawing from the same aquifer. The
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…359/462
Central Well is producing its water from a depth much greater than the North Well. Assuming they are
drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the model a
greater thickness reduces the size of the source protection zones. The lower thickness assumed
provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the
median total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total
water recharges the fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400
gpm. The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a
higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test pump
was shut down twice and pumping time was limited, I think the best approach to estimate transmissivity is to
use an empirical method with specific capacity. I used the Mace (2001) method to estimate transmissivity
with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on
the screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available data.
Please let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…360/462
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is not
as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are drawing from
different depths. The central well is drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but
when we videoed the well we learned that the bottom 160 feet of the well had caved in or filled with debris.
The well is producing its water from a water bearing zone at a depth of about 285 feet. I am inclined to
model the source protection zones as if they are in the same aquifer since both are producing from fractured
bedrock. I think that will also produce more conservative source protection zones. What is your thought on
this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense
to model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more, but
a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With the
information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer
thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem reasonable
to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as
the saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured
bedrock aquifers. It probably has to do with the quality of the constant-rate test data. If the system conducts
another constant-rate test, the transmissivity could be further refined but I'm not suggesting they have to do
that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to model
the well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two different
hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be acceptable to use
the transmissivity that has been calculated. If you can't use two different values, then an average of the two
could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate does
fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well did not
achieve what I would consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the combination of
pumping and recovery data available he felt he could calculate a representative hydraulic conductivity. I will
share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In the
top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and will
add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have always felt
that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make the call on
this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…361/462
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or gravel.
Clay fills the open spaces between the sand and gravel particles making the soil behave more like a clay
from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having
clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is
70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave
hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding the
sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your
thoughts on this and redoing the modeling. It could be that my logic above and other information is included
as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks
that would make me think that there is a predominance of clay. I agree that if there is a significant clay
fraction (60-70%), then the material will likely act as clay, but the Well Driller's Report does not state anything
that leads me to believe there is a predominance of clay besides between 75-80 feet. I have to make my
decision based on the information that is provided. If the Well Driller's Report denoted "mostly clay", "clayey
sand", "70% clay", or something that made me think that clay was predominant, I would agree with your
arguments. I also reviewed other well logs near this source to come to my conclusion. Oftentimes lithologic
logs prepared by a geologist or engineer during the drilling are used to supplement the Well Driller's Report.
Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front.
Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah
Department of Health, Division of Environmental Health (now DEQ) databases were examined in the study.
Ground-water recharge-area mapping delineated locations where surface contaminants could move down to
the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based on
discussions between DDW staff and the USGS at the time, it was decided that if a well and accompanying
zone two are completely within the secondary recharge area or discharge area as mapped by Anderson and
others, DDW staff would consider that sufficient evidence to demonstrate the extent of the clay layer
throughout zone two. Anderson and others mapped the recharge and discharge areas based on dominantly
clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for the South Well was not
entirely within the secondary recharge area or discharge area. Part of Zone Two was located in the primary
recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other
two. Just last week we received approval from the DDW board to move forward with rule-making regarding
the sewer line rules. The proposed rules remove the special construction requirements in zone two
regardless of aquifer type. I assume there isn't sewer infrastructure in zone one? If these rules get adopted,
then the system will no longer need an exception for the sewer infrastructure currently located in zone two.
Due to the timing, it may be necessary for the system to request temporary exceptions to R309-600-13(3)
and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no longer be
required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…362/462
Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your
thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate
aquifer. It is not as clear for the Central and North Wells. Both are completed in fracturedbedrock, but they are drawing from different depths. The central well is drawing from 437 to
452 feet. The North Well was drilled to 445 feet, but when we videoed the well we learned
that the bottom 160 feet of the well had caved in or filled with debris. The well is producing
its water from a water bearing zone at a depth of about 285 feet. I am inclined to model the
source protection zones as if they are in the same aquifer since both are producing from
fractured bedrock. I think that will also produce more conservative source protection
zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I
am discussing with the city if they want to do another pump test with the installed pump thatwould stress the well more, but a decision has not been made yet. I appreciate your
calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40
feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this
seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The
generator shut down unexpectedly or was turned off during both of our attempts at a long
term test. The pumping rate does fluctuate, but it fluctuates within the accuracy range of
the flow meter (+/- 1.25%). I agree the well did not achieve what I would consider a
stabilized drawdown. I think the first attempt came close though. I have contacted a
hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the
combination of pumping and recovery data available he felt he could calculate a
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…363/462
representative hydraulic conductivity. I will share his conclusion when I receive it next
week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix,
I notice it was missing the well log for the actual production well. The well log in theappendix was for the test well. In the top 100 feet the soil descriptions are similar, but not
exact. I am attaching the well log to this email and will add it to the DWSPP appendix. We
are looking at what is considered a clay differently. I have always felt that a soil that
includes clay will behave hydraulically more like a clay. Ultimately you will make the call on
this. However, I thought I would give my perspective. The presence or absence of clay in a
soil has far more impact on the hydraulic conductivity of the soil than does the presence or
absence of sand or gravel. Clay fills the open spaces between the sand and gravel
particles making the soil behave more like a clay from a hydraulic perspective. I do not
know whether the soils not identified as a straight clay are a sandy/gravely clay or a clayey
sand, but if there is enough clay in a sample for it to be identified as having clay, I feel there
is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay
fraction behave hydraulically as a clay the standard is met. However, I believe any soil
with a significant clay fraction will behave hydraulically more like a clay than a sand or
gravel. We will correct the inconsistency regarding the sewer lines in Zones 1 and 2. Wewill assess the need to request an exemption after receiving your thoughts on this and
redoing the modeling. It could be that my logic above and other information is included as
justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items are
addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the
South Well is completed in unconsolidated material, and is likely drawing from a different aquifer than
the Central and North Wells. If the three wells produce from different aquifers, separate aquifer
parameters need to be developed for each scenario (bedrock and unconsolidated) using the results of
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…364/462
a constant-rate test. Please be sure to confirm that the wells produce from different aquifers before
proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they produce from
separate aquifers then they need to be modeled as such. That means that only the North and
Central Wells should be modeled to show interference in WhAEM using parameters derived from their
constant-rate tests and the South Well should be modeled separately, i.e., the zones may overlap those
of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-rate
aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for New
Wells, which states that 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). Typically the
transmissivity is determined from the constant-rate aquifer test and then hydraulic conductivity is
determined using the equation T=K/b. The report states that the "pump data is preliminary; it will be
updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If
these data are from a constant-rate test, they should be used to derive a value for transmissivity and
hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-hour
constant-rate test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv)
unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day, depending
on the log cycle I use. This is twice what is currently being used in the WhAEM model. The hydraulic
conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open hole portion of
well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is the Central Well
(Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the value for
transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method described
above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that
only 15 feet of screen was perforated. The hydraulic conductivity for the Central Well would then be
equal to K = 14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an average
of the values for hydraulic conductivity in WhAEM or decide what value is most appropriate. Please
update the aquifer parameters used for the North and Central Wells making sure to derive them
from as-built characteristics and the results of a constant-rate aquifer test. The delineation must
also be updated to reflect only interference from these two wells using aquifer parameters
representative of bedrock wells if you believe that the three wells produce from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate
aquifer test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if
the Pumping Test Report from 12-19-2019 is for the South Well. The data do not appear to meet the
rule definition for a constant-rate test because the rate was not held constant and it was not continued
for at least 24 hours or until the Well experienced "stabilized drawdown". Please let me know if you
disagree. If you think the data can be used to derive aquifer transmissivity, please do so. The updated
value for transmissivity and hydraulic conductivity should be used to remodel the zones for
the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected
aquifer status have been met. I am unable to concur with the protected aquifer classification for
the South West Well. While it was concurred with in the PER, the Well Driller's Report does not
substantiate that 30 feet of clay were encountered in the uppermost 100 feet. A combined total of 20
feet of clay was encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I also
looked at Well Driller's Reports near this source and found similar conditions. Given that the zones may
change based on my comments above, I will wait to provide a bunch of feedback on the Potential
Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone one for the
South Well but then it says under sewer lines in zone 2 that there are no sewer lines in zone 1. Please
update this to be consistent. It also states that it is unknown whether or not sewer lines in zone 2 have
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…365/462
been constructed to the R309-515-6(4) standard. I would imagine they haven't been since the system
would have been under no obligation to specially construct them. Exceptions to R309-600-13(3) and
R309-515-6(4) may be required depending on the extent of zone 2 after remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify no
changes have occurred for the springs so that it's not confusing. It doesn't look like there is anything
to implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section 2)
and provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not been
changes or additions for the springs. For the springs, we simply copied the information
for the springs from the 2010 plan without changes other than hopefully improved
mapping and tables identifying the location of the springs. Without changes to the plan
for the springs we did not think to include a plan implementation. We can add asection indicating the information relating to the springs was copied from the 2010 plan
to create a single document for all sources and that those plans have previously been
implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…366/462
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well (WS016)
and North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014). I see that
the springs are also mentioned. Is this supposed to function as an updated plan for the spring
sources? I'm not sure it meets that intent since plan implementation is not discussed for the
springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your
review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be stamped
and signed since this is a requirement of rule. Any comments can be addressed after the
official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…367/462
Below is a link that will allow you to download a draft of a DWSPP that includes all
of Ephraim’s drinking water sources including the mountain springs and three
wells.

Please review and provide any comments you may have. We will finalize thedocument and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-
ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently
preparing a DWSP that includes all of Ephraim’s sources (wells and springs). The city is
currently reviewing the accuracy of the PCSs we identified. We are working towards
submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…368/462

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose
originally intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources? The
PER concurrence letter for the North Well was sent out on November 16, 2022. A full
DWSP plan is due for both by 11/16/2023.

Thanks,

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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…369/462
--
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.

--
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.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…370/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…371/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…372/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…373/462
--
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.

--
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.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…374/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…375/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…376/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…377/462
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.

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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…378/462
Deidre Beck <[e-mail]>Fri, Jan 24, 2025 at 12:03 PM
To: Layne Jensen <[e-mail]>
Cc: "bryan.kimball" <[e-mail]>, Matt Evans <[e-mail]>, Jeff Jensen
<[e-mail]>, John Chartier <[e-mail]>, Melissa Noble <[e-mail]>
Thanks! I have taken a new position with the Division of Water Quality and would really like to wrap this project up before my last
day at Drinking Water (January 31, 2025). Otherwise, concurrence may be delayed since staff will have to be caught up to speed.
Technically, I should have issued a formal disapproval letter a while ago. I'd like to hold off on that, but at some point it will be
inevitable.
Regardless, please be sure to include Melissa Noble (cc'd) on all future correspondence related to this project.
On Thu, Jan 2, 2025 at 8:12 AM Layne Jensen <[e-mail]> wrote:
Hi Diedre,

I hope you had a great Christmas and New Years. I appreciate the follow up. We addressed the comments and
sent it to Ephraim for review and to answer a couple of questions. There have been some staff changes in
Ephraim and a lot of pressure on Bryan and Jeff lately so it appears it has fallen through the cracks. I will follow
up with them and get you hopefully the final version of the DWSPP.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, December 23, 2024 1:49 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I don't believe I've heard anything from you since June. Do you have an update as to where things are at with this project?

Happy Holidays!

On Wed, Jun 26, 2024 at 2:12 PM Deidre Beck <[e-mail]> wrote:
That all sounds fine. To close the loop on plan implementation, please be sure to indicate how the system will distribute the
link to their website where the fact sheets will be placed, i.e., how will their consumers be made aware? Will a link be placed
in a bill stuffer, in their next CCR, etc.?

On Wed, Jun 26, 2024 at 1:50 PM Layne Jensen <[e-mail]> wrote:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…379/462
Diedre,

Thank you for the information. Before we modify the DWSPP I wanted to verify that our responses will be
acceptable.

Section 2: The springs will be referenced in each section.

Sections 3 and 4: We will propose the sewer lines be considered adequately controlled based on the city’s
inspection and maintenance program. The entire sewer system is cleaned at least every 3 years.
Monitoring is constantly occurring to identify problems while they are minor. Areas that have been identifiedas having potential issues during monitoring are cleaned every six months. The city monitors the sewer
system by pulling manholes and observing flows. If there is any indication of problems during monitoring,
the section is cleaned, and the city uses their camara to observe the condition of the pipe. We will remove
the reference to the sewer lines being in compliance with R309-515-6(4).

Section 5: The city will add the fact sheets provided to their website by creating a webpage similar to the
examples you provided.

Will these proposed actions adequately address your comments?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or
added to their CCR. It has to address hazards associated with residents and septic systems. Many systems have
successfully added a page dedicated to source protection to their website. The page may include the actual source
protection plans (it doesn't have to) and fact sheets for best management practices. I've attached all Division-prepared
Fact sheets for your reference and also an EPA fact sheet on Septic systems.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…380/462
An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another
example from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will
need to do is periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides
and herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system
owners, which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill
the rule, it just needs to spell out the most important best management practices.

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management
strategies. I would like to take your offer to provide examples of how other entities have handled the BMP
and land management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment
on the sewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…381/462
After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they
need to be referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in
accordance with R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so
another control type will need to be used to assess the sewer lines as adequately controlled. Generally, if a
sewer utility is routinely inspecting its lines or performing other periodic maintenance, best management/pollution
prevention practices can be used to assess the sewer lines as adequately controlled. We also don't consider "protected
aquifer" status as a reason for assessing a potential contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW
Board will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until
then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard
presented by these potential contamination sources. What does this mean? Will the system send out mailers, add
information to their CCR, or website concerning BMPs? We do have fact sheets that can be used. If you would like to
see examples of how other systems have handled this requirement, particularly for residents, please let me know. The
strategies need to be explicit so that the system is aware and knows exactly what they need to implement.
Otherwise, the next time their update is due, the plans may be disapproved for lack of plan implementation. Lack of plan
implementation is considered a significant deficiency under the Improvement Priority System (IPS) rule, so we
emphasize the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I
will be conditionally concurring with the plan with the condition being that strategies be implemented and documentation
provided the next time the plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage
residents to use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished?
Please update this section with a specific schedule for the completion of the land management strategies
added to Section 5. Technically, the rule states they need to be implemented within 180 days of concurrence, so be
sure whatever schedule is proposed, that it doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to
renew these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update.
The system will want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…382/462
On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with
any other questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water
Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link
that you can use to download the full document with appendicies. Included in the DWSPP and
attached to this email is a letter requesting an exemption for a sewer line in Zone 2 for the South
Well. Ephraim is seeking an exemption until the rule is formally changed. The sewer line in questionis not currently in use and will likely be replaced with a larger pipeline in the next year or two. Please
inform the city if the new sewer line will need to comply with requirements in R309-600-13(3) and
R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule
R309-600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately
controlled using one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within
Zone 1 for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that
will be subject to the rules until the rule change is completed. Ephraim City will be seeking an
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…383/462
exemption until the rule change is finalized. As far as the sewer in Zone 2 being a potential
contamination source should it be identified as controlled or not adequately controlled? If it is
considered not adequately controlled, after the rule change would that change? Any suggestions
how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to
the wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within
the secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the
clay layer to the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the
uppermost 100 feet of the well. So you can try to argue protected aquifer status, but it is unlikely I will be able to
concur with that classification since the Well Driller's report does not indicate that 30 feet of clay was
encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-
13(3) and R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter
requesting exceptions to R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director
approval. The letter can be prepared by a consultant, but we prefer that the letter be signed by the system
because we have had situations in the past where systems had no idea that exceptions had been requested or
granted. Historically, the Division has required information on the age of the sewer infrastructure, which portions
of the rules are not being met, etc. We have also required inspection by video/camera of any sewer lines
located within zones one and/or two. It appears that these sewer lines may be newer, just based on aerial
photography, so a camera inspection may have been done recently that would fulfill this requirement. Typically
the conditions for granting the exceptions will be to camera/video at least once every 3 years, and there may be
additional nitrate monitoring required. Once the new rules are enacted, those requirements will no longer be
required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on
protected aquifer status for the South Well. In your previous email you mention that a portion of
well protection zone 2 for the South Well was in a Primary Recharge zone which suggested the
aquifer did not qualify as a protected aquifer. With the revised well protection zones for the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…384/462
South Well being significantly smaller with the lower hydraulic conductivity and pumping rate I
was wondering if you could look at the mapping you have for Sanpete County and let me know if
portions of well protection zone 2 is still identified as being in a primary recharge area? The
report you referenced in your email about your concerns related to whether the South Well met
the criteria for protected aquifer status did not include Sanpete County or I would check myself. I
would like to reference the study in the DWSPP. Please give me the reference for thereport/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a
protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development
there is potential for a sewer line to be constructed about 80 feet from the well. There are
existing sewer lines within zone 2. Any new sewer lines constructed within zone 1 would need to
comply with R309-515-6(4). Depending on the decision on the protected aquifer status Ephraim
may need to seek a temporary exemption for sewer lines in zone 2. What is the process to seek
the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any
further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the
intent of the rule. If the system would prefer to make the zones smaller for management purposes, you could
try to refine the value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones
were more conservative from the point of view of including more potential contamination sources. How do
you feel about this approach? It may be difficult for the system to manage a larger number of PCSs and it will
make it difficult for DDW staff to determine if land management strategies have been implemented for any
not adequately controlled PCSs when the plan is updated during the normal update cycle. If you decide to go
this route, please add a column or in some way denote which PCSs are actually within the final zones and
which are not so that the system and DDW staff can discern the difference.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…385/462

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We
assumed the higher flow so that if the pump in the well is replaced to increase production the DWSPP would
not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer the
thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of the
source protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you can
always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the
fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm.
The higher flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the source
protection zones based on hydraulic conductivities calculated from testing results. Before
making changes to the DWSPP I wanted to see if you have any concerns with the method and
assumptions. I am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection
zones

The revised protection zones generally extend farther into the mountains but cover less of thecity area. Assuming these protection zones are acceptable, I would like to propose that we
add potential contamination sources not previously included in a source protection zone, but
not delete the previously identified potential contamination sources that are now not in a
source protection zone. The previous source protection zones were more conservative from
the point of view of including more potential contamination sources. How do you feel about
this approach?
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…386/462

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these
assumed flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed
flows. We assumed the higher flow so that if the pump in the well is replaced to increase
production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This
is higher than the thicknesses used to calculate the hydraulic conductivity, but less than the actual
thickness. We are assuming the North and Central wells are drawing from the same aquifer. The
Central Well is producing its water from a depth much greater than the North Well. Assuming they
are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness
assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM
only accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the
median total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total
water recharges the fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400
gpm. The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results
than a higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test
pump was shut down twice and pumping time was limited, I think the best approach to estimate
transmissivity is to use an empirical method with specific capacity. I used the Mace (2001) method to
estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on
the screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available
data. Please let me know of any concerns you may have.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…387/462
Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is
not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had caved
in or filled with debris. The well is producing its water from a water bearing zone at a depth of about 285
feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are
producing from fractured bedrock. I think that will also produce more conservative source protection
zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense
to model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more,
but a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With
the information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an
aquifer thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’
to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem
reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as
the saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured
bedrock aquifers. It probably has to do with the quality of the constant-rate test data. If the system
conducts another constant-rate test, the transmissivity could be further refined but I'm not suggesting they
have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two
different hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be
acceptable to use the transmissivity that has been calculated. If you can't use two different values, then an
average of the two could be used.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…388/462
South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate
does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well
did not achieve what I would consider a stabilized drawdown. I think the first attempt came close though.
I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the
combination of pumping and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In
the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and
will add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have always
felt that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make the call
on this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or
gravel. Clay fills the open spaces between the sand and gravel particles making the soil behave more like
a clay from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having
clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is
70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave
hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding
the sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your
thoughts on this and redoing the modeling. It could be that my logic above and other information is
included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks
that would make me think that there is a predominance of clay. I agree that if there is a significant clay
fraction (60-70%), then the material will likely act as clay, but the Well Driller's Report does not state
anything that leads me to believe there is a predominance of clay besides between 75-80 feet. I have to
make my decision based on the information that is provided. If the Well Driller's Report denoted "mostly
clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I would
agree with your arguments. I also reviewed other well logs near this source to come to my conclusion.
Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used to supplement
the Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front.
Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah
Department of Health, Division of Environmental Health (now DEQ) databases were examined in the
study. Ground-water recharge-area mapping delineated locations where surface contaminants could move
down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based
on discussions between DDW staff and the USGS at the time, it was decided that if a well and
accompanying zone two are completely within the secondary recharge area or discharge area as mapped
by Anderson and others, DDW staff would consider that sufficient evidence to demonstrate the extent of
the clay layer throughout zone two. Anderson and others mapped the recharge and discharge areas
based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for
the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two
was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other
two. Just last week we received approval from the DDW board to move forward with rule-making regarding
the sewer line rules. The proposed rules remove the special construction requirements in zone two
regardless of aquifer type. I assume there isn't sewer infrastructure in zone one? If these rules get
adopted, then the system will no longer need an exception for the sewer infrastructure currently located in
zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to R309-
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…389/462
600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no
longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your
thoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as aseparate aquifer. It is not as clear for the Central and North Wells. Both are completed in
fractured bedrock, but they are drawing from different depths. The central well is drawing
from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the
well we learned that the bottom 160 feet of the well had caved in or filled with debris. The
well is producing its water from a water bearing zone at a depth of about 285 feet. I am
inclined to model the source protection zones as if they are in the same aquifer since both
are producing from fractured bedrock. I think that will also produce more conservative
source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing with the city if they want to do another pump test with the installed pump
that would stress the well more, but a decision has not been made yet. I appreciate your
calculations for the hydraulic conductivity. With the information provided above I would
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40
feet. Based on the video the well is producing water from end of the casing at 245’ to the
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…390/462
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does
this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well.
The generator shut down unexpectedly or was turned off during both of our attempts at a
long term test. The pumping rate does fluctuate, but it fluctuates within the accuracy
range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would
consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With
the combination of pumping and recovery data available he felt he could calculate a
representative hydraulic conductivity. I will share his conclusion when I receive it next
week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the
appendix, I notice it was missing the well log for the actual production well. The well log
in the appendix was for the test well. In the top 100 feet the soil descriptions are similar,
but not exact. I am attaching the well log to this email and will add it to the DWSPP
appendix. We are looking at what is considered a clay differently. I have always felt that
a soil that includes clay will behave hydraulically more like a clay. Ultimately you will
make the call on this. However, I thought I would give my perspective. The presence or
absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than
does the presence or absence of sand or gravel. Clay fills the open spaces between thesand and gravel particles making the soil behave more like a clay from a hydraulic
perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be
identified as having clay, I feel there is enough clay for the soil to behave hydraulically as
a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half
of the soils identified as having a clay fraction behave hydraulically as a clay the standard
is met. However, I believe any soil with a significant clay fraction will behave
hydraulically more like a clay than a sand or gravel. We will correct the inconsistency
regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that
my logic above and other information is included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…391/462
Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items
are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the
South Well is completed in unconsolidated material, and is likely drawing from a different aquifer than
the Central and North Wells. If the three wells produce from different aquifers, separate aquifer
parameters need to be developed for each scenario (bedrock and unconsolidated) using the results
of a constant-rate test. Please be sure to confirm that the wells produce from different aquifers before
proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they produce
from separate aquifers then they need to be modeled as such. That means that only the North
and Central Wells should be modeled to show interference in WhAEM using parameters derived from
their constant-rate tests and the South Well should be modeled separately, i.e., the zones may
overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-
rate aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for
New Wells, which states that 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). Typically
the transmissivity is determined from the constant-rate aquifer test and then hydraulic conductivity is
determined using the equation T=K/b. The report states that the "pump data is preliminary; it will be
updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If
these data are from a constant-rate test, they should be used to derive a value for transmissivity and
hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-hour
constant-rate test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv)
unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day,
depending on the log cycle I use. This is twice what is currently being used in the WhAEM model.
The hydraulic conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open
hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is
the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the
value for transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method
described above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that
only 15 feet of screen was perforated. The hydraulic conductivity for the Central Well would then be
equal to K = 14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an
average of the values for hydraulic conductivity in WhAEM or decide what value is most
appropriate. Please update the aquifer parameters used for the North and Central Wells
making sure to derive them from as-built characteristics and the results of a constant-rate
aquifer test. The delineation must also be updated to reflect only interference from these two wells
using aquifer parameters representative of bedrock wells if you believe that the three wells produce
from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate
aquifer test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if
the Pumping Test Report from 12-19-2019 is for the South Well. The data do not appear to meet the
rule definition for a constant-rate test because the rate was not held constant and it was not
continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let me
know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…392/462
The updated value for transmissivity and hydraulic conductivity should be used to remodel
the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected
aquifer status have been met. I am unable to concur with the protected aquifer classification for
the South West Well. While it was concurred with in the PER, the Well Driller's Report does not
substantiate that 30 feet of clay were encountered in the uppermost 100 feet. A combined total of
20 feet of clay was encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I
also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the
Potential Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone
one for the South Well but then it says under sewer lines in zone 2 that there are no sewer lines in
zone 1. Please update this to be consistent. It also states that it is unknown whether or not sewer
lines in zone 2 have been constructed to the R309-515-6(4) standard. I would imagine they haven't
been since the system would have been under no obligation to specially construct them. Exceptions
to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after
remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify
no changes have occurred for the springs so that it's not confusing. It doesn't look like there is
anything to implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section
2) and provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not
been changes or additions for the springs. For the springs, we simply copied the
information for the springs from the 2010 plan without changes other than hopefully
improved mapping and tables identifying the location of the springs. Without
changes to the plan for the springs we did not think to include a plan
implementation. We can add a section indicating the information relating to the
springs was copied from the 2010 plan to create a single document for all sources
and that those plans have previously been implemented.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…393/462
Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well
(WS016) and North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014).
I see that the springs are also mentioned. Is this supposed to function as an updated plan for
the spring sources? I'm not sure it meets that intent since plan implementation is not discussed
for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your
review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at:https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-
cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…394/462
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be
stamped and signed since this is a requirement of rule. Any comments can be addressed
after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes
all of Ephraim’s drinking water sources including the mountain springs and three
wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-
ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…395/462
On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently
preparing a DWSP that includes all of Ephraim’s sources (wells and springs). The city
is currently reviewing the accuracy of the PCSs we identified. We are working towards
submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose
originally intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources?
The PER concurrence letter for the North Well was sent out on November 16, 2022. A
full DWSP plan is due for both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…396/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…397/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…398/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…399/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…400/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…401/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…402/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…403/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…404/462
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
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.
11 attachments
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…405/462
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Bryan Kimball <[e-mail]>Fri, Jan 24, 2025 at 12:32 PM
To: Deidre Beck <[e-mail]>, Layne Jensen <[e-mail]>
Cc: Matt Evans <[e-mail]>, John Chartier <[e-mail]>, Melissa Noble <[e-mail]>, Jeff Jensen
<[e-mail]>
Hi Deidre,
Thanks for all your help on this. As a status update, I was able to sit down with Jeff and we went over the final edits
together. We accept all of the comments and final edits and have no further comments on the final dra. Unless
I'm missing something that final report should be good to go. As I understand it, the last missing piece was creang
a webpage and noces in the newsleer, per the updated secon in our final report. I've submied a request to
our IT department to help create that page and we're planning to send out noces in our next newsleer with our
ulity billing about the new webpage. I'm hoping that webpage will be up and going on our site within the next 1
to 2 weeks. If there's anything else needed, let us know and we'll try and get it resolved as soon as we can.
Finally, we have new emails. My new email is [e-mail]
Thanks,

BRYAN KIMBALL, P.E., MPA, AICP
Community Development Director/City Engineer
5 South Main, Ephraim, UT 84627
PH: [phone] FAX: [phone]
Web: www.ephraim.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…406/462
From: Deidre Beck <[e-mail]>
Sent: Friday, January 24, 2025 12:03 PM
To: Layne Jensen <[e-mail]>
Cc: Bryan Kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>; John Charer <[e-mail]>; Melissa Noble <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Thanks! I have taken a new position with the Division of Water Quality and would really like to wrap this project up before my last
day at Drinking Water (January 31, 2025). Otherwise, concurrence may be delayed since staff will have to be caught up to speed.
Technically, I should have issued a formal disapproval letter a while ago. I'd like to hold off on that, but at some point it will be
inevitable.
Regardless, please be sure to include Melissa Noble (cc'd) on all future correspondence related to this project.
On Thu, Jan 2, 2025 at 8:12 AM Layne Jensen <[e-mail]> wrote:
Hi Diedre,

I hope you had a great Christmas and New Years. I appreciate the follow up. We addressed the comments and
sent it to Ephraim for review and to answer a couple of questions. There have been some staff changes in
Ephraim and a lot of pressure on Bryan and Jeff lately so it appears it has fallen through the cracks. I will followup with them and get you hopefully the final version of the DWSPP.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, December 23, 2024 1:49 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I don't believe I've heard anything from you since June. Do you have an update as to where things are at with this project?

Happy Holidays!

On Wed, Jun 26, 2024 at 2:12 PM Deidre Beck <[e-mail]> wrote:
That all sounds fine. To close the loop on plan implementation, please be sure to indicate how the system will distribute the
link to their website where the fact sheets will be placed, i.e., how will their consumers be made aware? Will a link be placed
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…407/462
in a bill stuffer, in their next CCR, etc.?

On Wed, Jun 26, 2024 at 1:50 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Thank you for the information. Before we modify the DWSPP I wanted to verify that our responses will be
acceptable.

Section 2: The springs will be referenced in each section.

Sections 3 and 4: We will propose the sewer lines be considered adequately controlled based on the city’s
inspection and maintenance program. The entire sewer system is cleaned at least every 3 years.
Monitoring is constantly occurring to identify problems while they are minor. Areas that have been identified
as having potential issues during monitoring are cleaned every six months. The city monitors the sewer
system by pulling manholes and observing flows. If there is any indication of problems during monitoring,
the section is cleaned, and the city uses their camara to observe the condition of the pipe. We will remove
the reference to the sewer lines being in compliance with R309-515-6(4).

Section 5: The city will add the fact sheets provided to their website by creating a webpage similar to the
examples you provided.

Will these proposed actions adequately address your comments?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or
added to their CCR. It has to address hazards associated with residents and septic systems. Many systems have
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…408/462
successfully added a page dedicated to source protection to their website. The page may include the actual source
protection plans (it doesn't have to) and fact sheets for best management practices. I've attached all Division-prepared
Fact sheets for your reference and also an EPA fact sheet on Septic systems.

An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another
example from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will
need to do is periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides
and herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system
owners, which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill
the rule, it just needs to spell out the most important best management practices.

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management
strategies. I would like to take your offer to provide examples of how other entities have handled the BMP
and land management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment
on the sewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…409/462

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they
need to be referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in
accordance with R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so
another control type will need to be used to assess the sewer lines as adequately controlled. Generally, if a
sewer utility is routinely inspecting its lines or performing other periodic maintenance, best management/pollution
prevention practices can be used to assess the sewer lines as adequately controlled. We also don't consider "protected
aquifer" status as a reason for assessing a potential contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW
Board will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until
then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard
presented by these potential contamination sources. What does this mean? Will the system send out mailers, add
information to their CCR, or website concerning BMPs? We do have fact sheets that can be used. If you would like to
see examples of how other systems have handled this requirement, particularly for residents, please let me know. The
strategies need to be explicit so that the system is aware and knows exactly what they need to implement.
Otherwise, the next time their update is due, the plans may be disapproved for lack of plan implementation. Lack of plan
implementation is considered a significant deficiency under the Improvement Priority System (IPS) rule, so we
emphasize the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I
will be conditionally concurring with the plan with the condition being that strategies be implemented and documentation
provided the next time the plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage
residents to use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished?
Please update this section with a specific schedule for the completion of the land management strategies
added to Section 5. Technically, the rule states they need to be implemented within 180 days of concurrence, so be
sure whatever schedule is proposed, that it doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to
renew these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update.
The system will want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…410/462

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with
any other questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking Water
Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is a link
that you can use to download the full document with appendicies. Included in the DWSPP and
attached to this email is a letter requesting an exemption for a sewer line in Zone 2 for the South
Well. Ephraim is seeking an exemption until the rule is formally changed. The sewer line in question
is not currently in use and will likely be replaced with a larger pipeline in the next year or two. Please
inform the city if the new sewer line will need to comply with requirements in R309-600-13(3) and
R309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in rule
R309-600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as adequately
controlled using one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…411/462

After discussion with Ephraim City there is not a need to install a sewer line that would be within
Zone 1 for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that
will be subject to the rules until the rule change is completed. Ephraim City will be seeking an
exemption until the rule change is finalized. As far as the sewer in Zone 2 being a potential
contamination source should it be identified as controlled or not adequately controlled? If it is
considered not adequately controlled, after the rule change would that change? Any suggestions
how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to
the wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within
the secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the
clay layer to the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the
uppermost 100 feet of the well. So you can try to argue protected aquifer status, but it is unlikely I will be able to
concur with that classification since the Well Driller's report does not indicate that 30 feet of clay was
encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-
13(3) and R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter
requesting exceptions to R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director
approval. The letter can be prepared by a consultant, but we prefer that the letter be signed by the system
because we have had situations in the past where systems had no idea that exceptions had been requested or
granted. Historically, the Division has required information on the age of the sewer infrastructure, which portions
of the rules are not being met, etc. We have also required inspection by video/camera of any sewer lines
located within zones one and/or two. It appears that these sewer lines may be newer, just based on aerial
photography, so a camera inspection may have been done recently that would fulfill this requirement. Typically
the conditions for granting the exceptions will be to camera/video at least once every 3 years, and there may be
additional nitrate monitoring required. Once the new rules are enacted, those requirements will no longer be
required.

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…412/462
I have appreciated your quick response to our questions. I have been updating the section on
protected aquifer status for the South Well. In your previous email you mention that a portion of
well protection zone 2 for the South Well was in a Primary Recharge zone which suggested the
aquifer did not qualify as a protected aquifer. With the revised well protection zones for the
South Well being significantly smaller with the lower hydraulic conductivity and pumping rate I
was wondering if you could look at the mapping you have for Sanpete County and let me know ifportions of well protection zone 2 is still identified as being in a primary recharge area? The
report you referenced in your email about your concerns related to whether the South Well met
the criteria for protected aquifer status did not include Sanpete County or I would check myself. I
would like to reference the study in the DWSPP. Please give me the reference for the
report/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can justify a
protected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development
there is potential for a sewer line to be constructed about 80 feet from the well. There are
existing sewer lines within zone 2. Any new sewer lines constructed within zone 1 would need tocomply with R309-515-6(4). Depending on the decision on the protected aquifer status Ephraim
may need to seek a temporary exemption for sewer lines in zone 2. What is the process to seek
the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any
further questions.

I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the
intent of the rule. If the system would prefer to make the zones smaller for management purposes, you could
try to refine the value for T using better test data or use an empirical approach like Neil did for the South Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential contamination
sources not previously included in a source protection zone, but not delete the previously identified potential
contamination sources that are now not in a source protection zone. The previous source protection zones
were more conservative from the point of view of including more potential contamination sources. How do
you feel about this approach? It may be difficult for the system to manage a larger number of PCSs and it will
make it difficult for DDW staff to determine if land management strategies have been implemented for any
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…413/462
not adequately controlled PCSs when the plan is updated during the normal update cycle. If you decide to go
this route, please add a column or in some way denote which PCSs are actually within the final zones and
which are not so that the system and DDW staff can discern the difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We
assumed the higher flow so that if the pump in the well is replaced to increase production the DWSPP would
not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer the
thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of the
source protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you can
always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median total
rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges the
fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm.
The higher flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in the
Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a higher
recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the sourceprotection zones based on hydraulic conductivities calculated from testing results. Before
making changes to the DWSPP I wanted to see if you have any concerns with the method and
assumptions. I am attaching the following maps:

North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection
zones

The revised protection zones generally extend farther into the mountains but cover less of the
city area. Assuming these protection zones are acceptable, I would like to propose that we
add potential contamination sources not previously included in a source protection zone, but
not delete the previously identified potential contamination sources that are now not in a
source protection zone. The previous source protection zones were more conservative from
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…414/462
the point of view of including more potential contamination sources. How do you feel about
this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these
assumed flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed
flows. We assumed the higher flow so that if the pump in the well is replaced to increase
production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This
is higher than the thicknesses used to calculate the hydraulic conductivity, but less than the actual
thickness. We are assuming the North and Central wells are drawing from the same aquifer. The
Central Well is producing its water from a depth much greater than the North Well. Assuming they
are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness
assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM
only accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the
median total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total
water recharges the fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400
gpm. The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results
than a higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test
pump was shut down twice and pumping time was limited, I think the best approach to estimate
transmissivity is to use an empirical method with specific capacity. I used the Mace (2001) method to
estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based on
the screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available
data. Please let me know of any concerns you may have.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…415/462

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is
not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had caved
in or filled with debris. The well is producing its water from a water bearing zone at a depth of about 285
feet. I am inclined to model the source protection zones as if they are in the same aquifer since both are
producing from fractured bedrock. I think that will also produce more conservative source protection
zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes sense
to model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am discussing
with the city if they want to do another pump test with the installed pump that would stress the well more,
but a decision has not been made yet. I appreciate your calculations for the hydraulic conductivity. With
the information provided above I would propose using a hydraulic conductivity of 14,360 ft2/day and an
aquifer thickness of 40 feet. Based on the video the well is producing water from end of the casing at 245’
to the bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does this seem
reasonable to you?

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet as
the saturated aquifer thickness. I do think these values are a bit high for what I typically see in fractured
bedrock aquifers. It probably has to do with the quality of the constant-rate test data. If the system
conducts another constant-rate test, the transmissivity could be further refined but I'm not suggesting they
have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two
different hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be
acceptable to use the transmissivity that has been calculated. If you can't use two different values, then an
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…416/462
average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator shut
down unexpectedly or was turned off during both of our attempts at a long term test. The pumping rate
does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the well
did not achieve what I would consider a stabilized drawdown. I think the first attempt came close though.
I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With the
combination of pumping and recovery data available he felt he could calculate a representative hydraulic
conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it was
missing the well log for the actual production well. The well log in the appendix was for the test well. In
the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email and
will add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have always
felt that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will make the call
on this. However, I thought I would give my perspective. The presence or absence of clay in a soil has far
more impact on the hydraulic conductivity of the soil than does the presence or absence of sand or
gravel. Clay fills the open spaces between the sand and gravel particles making the soil behave more like
a clay from a hydraulic perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be identified as having
clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this line of thinking there is
70 feet of clay in the top 100 feet. Even if only half of the soils identified as having a clay fraction behave
hydraulically as a clay the standard is met. However, I believe any soil with a significant clay fraction will
behave hydraulically more like a clay than a sand or gravel. We will correct the inconsistency regarding
the sewer lines in Zones 1 and 2. We will assess the need to request an exemption after receiving your
thoughts on this and redoing the modeling. It could be that my logic above and other information is
included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or remarks
that would make me think that there is a predominance of clay. I agree that if there is a significant clay
fraction (60-70%), then the material will likely act as clay, but the Well Driller's Report does not state
anything that leads me to believe there is a predominance of clay besides between 75-80 feet. I have to
make my decision based on the information that is provided. If the Well Driller's Report denoted "mostly
clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I would
agree with your arguments. I also reviewed other well logs near this source to come to my conclusion.
Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used to supplement
the Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front and
Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-4221,
published in 1994. This report mapped the principal aquifers and recharge areas along the Wasatch Front.
Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water Rights, and Utah
Department of Health, Division of Environmental Health (now DEQ) databases were examined in the
study. Ground-water recharge-area mapping delineated locations where surface contaminants could move
down to the principal aquifer(s).
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based
on discussions between DDW staff and the USGS at the time, it was decided that if a well and
accompanying zone two are completely within the secondary recharge area or discharge area as mapped
by Anderson and others, DDW staff would consider that sufficient evidence to demonstrate the extent of
the clay layer throughout zone two. Anderson and others mapped the recharge and discharge areas
based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for
the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two
was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other
two. Just last week we received approval from the DDW board to move forward with rule-making regarding
the sewer line rules. The proposed rules remove the special construction requirements in zone two
regardless of aquifer type. I assume there isn't sewer infrastructure in zone one? If these rules get
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…417/462
adopted, then the system will no longer need an exception for the sewer infrastructure currently located in
zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to R309-
600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions will no
longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate yourthoughts on.

Production Zone for Each Well: the South Well clearly needs to be modeled as a
separate aquifer. It is not as clear for the Central and North Wells. Both are completed in
fractured bedrock, but they are drawing from different depths. The central well is drawing
from 437 to 452 feet. The North Well was drilled to 445 feet, but when we videoed the
well we learned that the bottom 160 feet of the well had caved in or filled with debris. The
well is producing its water from a water bearing zone at a depth of about 285 feet. I am
inclined to model the source protection zones as if they are in the same aquifer since both
are producing from fractured bedrock. I think that will also produce more conservativesource protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North Well.
I am discussing with the city if they want to do another pump test with the installed pump
that would stress the well more, but a decision has not been made yet. I appreciate your
calculations for the hydraulic conductivity. With the information provided above I would
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…418/462
propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer thickness of 40
feet. Based on the video the well is producing water from end of the casing at 245’ to the
bottom of the open hole at 285’. This calculates to a transmissivity of 359 ft/day. Does
this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well.
The generator shut down unexpectedly or was turned off during both of our attempts at a
long term test. The pumping rate does fluctuate, but it fluctuates within the accuracy
range of the flow meter (+/- 1.25%). I agree the well did not achieve what I would
consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With
the combination of pumping and recovery data available he felt he could calculate arepresentative hydraulic conductivity. I will share his conclusion when I receive it next
week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the
appendix, I notice it was missing the well log for the actual production well. The well log
in the appendix was for the test well. In the top 100 feet the soil descriptions are similar,
but not exact. I am attaching the well log to this email and will add it to the DWSPP
appendix. We are looking at what is considered a clay differently. I have always felt that
a soil that includes clay will behave hydraulically more like a clay. Ultimately you will
make the call on this. However, I thought I would give my perspective. The presence orabsence of clay in a soil has far more impact on the hydraulic conductivity of the soil than
does the presence or absence of sand or gravel. Clay fills the open spaces between the
sand and gravel particles making the soil behave more like a clay from a hydraulic
perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be
identified as having clay, I feel there is enough clay for the soil to behave hydraulically as
a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half
of the soils identified as having a clay fraction behave hydraulically as a clay the standard
is met. However, I believe any soil with a significant clay fraction will behave
hydraulically more like a clay than a sand or gravel. We will correct the inconsistency
regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that
my logic above and other information is included as justification for an exemption

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…419/462

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items
are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the
South Well is completed in unconsolidated material, and is likely drawing from a different aquifer than
the Central and North Wells. If the three wells produce from different aquifers, separate aquifer
parameters need to be developed for each scenario (bedrock and unconsolidated) using the results
of a constant-rate test. Please be sure to confirm that the wells produce from different aquifers before
proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they produce
from separate aquifers then they need to be modeled as such. That means that only the North
and Central Wells should be modeled to show interference in WhAEM using parameters derived from
their constant-rate tests and the South Well should be modeled separately, i.e., the zones may
overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-
rate aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for
New Wells, which states that 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). Typically
the transmissivity is determined from the constant-rate aquifer test and then hydraulic conductivity is
determined using the equation T=K/b. The report states that the "pump data is preliminary; it will be
updated once a pump test has been completed". On page 325 of the PDF, there is data from a
"constant flow test" conducted between April 12-13, 2022 on the "Ephraim North Well Conversion". If
these data are from a constant-rate test, they should be used to derive a value for transmissivity and
hydraulic conductivity for use in the WhAEM model for the bedrock scenario. Or another 24-hour
constant-rate test will need to be conducted on the North Well to comply with R309-600-9(6)(a)(iv)
unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day,
depending on the log cycle I use. This is twice what is currently being used in the WhAEM model.
The hydraulic conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open
hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is
the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the
value for transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method
described above and the values for drawdown at 100 minutes and at ~1000 minutes.

I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that
only 15 feet of screen was perforated. The hydraulic conductivity for the Central Well would then be
equal to K = 14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an
average of the values for hydraulic conductivity in WhAEM or decide what value is most
appropriate. Please update the aquifer parameters used for the North and Central Wells
making sure to derive them from as-built characteristics and the results of a constant-rate
aquifer test. The delineation must also be updated to reflect only interference from these two wells
using aquifer parameters representative of bedrock wells if you believe that the three wells produce
from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate
aquifer test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices if
the Pumping Test Report from 12-19-2019 is for the South Well. The data do not appear to meet the
rule definition for a constant-rate test because the rate was not held constant and it was not
continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let me
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…420/462
know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so.
The updated value for transmissivity and hydraulic conductivity should be used to remodel
the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected
aquifer status have been met. I am unable to concur with the protected aquifer classification for
the South West Well. While it was concurred with in the PER, the Well Driller's Report does not
substantiate that 30 feet of clay were encountered in the uppermost 100 feet. A combined total of
20 feet of clay was encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I
also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the
Potential Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone
one for the South Well but then it says under sewer lines in zone 2 that there are no sewer lines in
zone 1. Please update this to be consistent. It also states that it is unknown whether or not sewer
lines in zone 2 have been constructed to the R309-515-6(4) standard. I would imagine they haven't
been since the system would have been under no obligation to specially construct them. Exceptions
to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after
remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the other
sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify
no changes have occurred for the springs so that it's not confusing. It doesn't look like there is
anything to implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report (Section
2) and provide any comments before reviewing the remainder of the plan.

Thanks,

On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a single
DWSPP. There have been changes and additions for the wells. There have not
been changes or additions for the springs. For the springs, we simply copied the
information for the springs from the 2010 plan without changes other than hopefully
improved mapping and tables identifying the location of the springs. Without
changes to the plan for the springs we did not think to include a plan
implementation. We can add a section indicating the information relating to the
springs was copied from the 2010 plan to create a single document for all sources
and that those plans have previously been implemented.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…421/462

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well
(WS016) and North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014).
I see that the springs are also mentioned. Is this supposed to function as an updated plan for
the spring sources? I'm not sure it meets that intent since plan implementation is not discussed
for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your
review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at:
https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-
cd86a5f682d1

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…422/462
From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be
stamped and signed since this is a requirement of rule. Any comments can be addressed
after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes
all of Ephraim’s drinking water sources including the mountain springs and three
wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-
ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City South and North Wells

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…423/462
Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently
preparing a DWSP that includes all of Ephraim’s sources (wells and springs). The city
is currently reviewing the accuracy of the PCSs we identified. We are working towards
submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose
originally intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources?
The PER concurrence letter for the North Well was sent out on November 16, 2022. A
full DWSP plan is due for both by 11/16/2023.

Thanks,

Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…424/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…425/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…426/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…427/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…428/462
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…429/462
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.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…430/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…431/462
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…432/462
drinkingwater.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
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.
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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…433/462
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Deidre Beck <[e-mail]>Fri, Jan 24, 2025 at 12:35 PM
To: Bryan Kimball <[e-mail]>
Cc: Layne Jensen <[e-mail]>, Matt Evans <[e-mail]>, John Chartier <[e-mail]>, Melissa
Noble <[e-mail]>, Jeff Jensen <[e-mail]>
Okay, thanks for the update. I will draft a concurrence letter that can be finalized by Melissa once we receive the report from your
consultant and the information from you on plan implementation for the spring sources.
On Fri, Jan 24, 2025 at 12:32 PM Bryan Kimball <[e-mail]> wrote:
Hi Deidre,
Thanks for all your help on this. As a status update, I was able to sit down with Jeff and we went over the final
edits together. We accept all of the comments and final edits and have no further comments on the final dra.
Unless I'm missing something that final report should be good to go. As I understand it, the last missing piece was
creang a webpage and noces in the newsleer, per the updated secon in our final report. I've submied a
request to our IT department to help create that page and we're planning to send out noces in our next
newsleer with our ulity billing about the new webpage. I'm hoping that webpage will be up and going on our
site within the next 1 to 2 weeks. If there's anything else needed, let us know and we'll try and get it resolved as
soon as we can.
Finally, we have new emails. My new email is [e-mail]
Thanks,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…434/462

BRYAN KIMBALL, P.E., MPA, AICP
Community Development Director/City Engineer
5 South Main, Ephraim, UT 84627
PH: [phone] FAX: [phone]
Web: www.ephraim.gov
From: Deidre Beck <[e-mail]>
Sent: Friday, January 24, 2025 12:03 PM
To: Layne Jensen <[e-mail]>
Cc: Bryan Kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>; John Charer <[e-mail]>; Melissa Noble <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Thanks! I have taken a new position with the Division of Water Quality and would really like to wrap this project up before my last
day at Drinking Water (January 31, 2025). Otherwise, concurrence may be delayed since staff will have to be caught up to speed.
Technically, I should have issued a formal disapproval letter a while ago. I'd like to hold off on that, but at some point it will be
inevitable.
Regardless, please be sure to include Melissa Noble (cc'd) on all future correspondence related to this project.
On Thu, Jan 2, 2025 at 8:12 AM Layne Jensen <[e-mail]> wrote:
Hi Diedre,

I hope you had a great Christmas and New Years. I appreciate the follow up. We addressed the comments and
sent it to Ephraim for review and to answer a couple of questions. There have been some staff changes in
Ephraim and a lot of pressure on Bryan and Jeff lately so it appears it has fallen through the cracks. I will follow
up with them and get you hopefully the final version of the DWSPP.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, December 23, 2024 1:49 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…435/462

I don't believe I've heard anything from you since June. Do you have an update as to where things are at with this project?

Happy Holidays!

On Wed, Jun 26, 2024 at 2:12 PM Deidre Beck <[e-mail]> wrote:
That all sounds fine. To close the loop on plan implementation, please be sure to indicate how the system will distribute the
link to their website where the fact sheets will be placed, i.e., how will their consumers be made aware? Will a link be placed
in a bill stuffer, in their next CCR, etc.?

On Wed, Jun 26, 2024 at 1:50 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Thank you for the information. Before we modify the DWSPP I wanted to verify that our responses will be
acceptable.

Section 2: The springs will be referenced in each section.

Sections 3 and 4: We will propose the sewer lines be considered adequately controlled based on the city’sinspection and maintenance program. The entire sewer system is cleaned at least every 3 years.
Monitoring is constantly occurring to identify problems while they are minor. Areas that have been identified
as having potential issues during monitoring are cleaned every six months. The city monitors the sewer
system by pulling manholes and observing flows. If there is any indication of problems during monitoring,
the section is cleaned, and the city uses their camara to observe the condition of the pipe. We will remove
the reference to the sewer lines being in compliance with R309-515-6(4).

Section 5: The city will add the fact sheets provided to their website by creating a webpage similar to the
examples you provided.

Will these proposed actions adequately address your comments?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, June 24, 2024 8:46 AM
To: Layne Jensen <[e-mail]>
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…436/462
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Yes, you will still need to address my comments on the sewer lines because the statement that they're constructed in
accordance with R309-515-6(4) isn't accurate.

The public education information can be sent in a bill stuffer, included in a Newsletter (if Ephraim sends those out), or
added to their CCR. It has to address hazards associated with residents and septic systems. Many systems have
successfully added a page dedicated to source protection to their website. The page may include the actual source
protection plans (it doesn't have to) and fact sheets for best management practices. I've attached all Division-prepared
Fact sheets for your reference and also an EPA fact sheet on Septic systems.

An example from Layton City can be accessed by clicking here. An example from SLC can be accessed here. Another
example from St. George City can be accessed here. Then the information is readily available, and all that Eprhaim will
need to do is periodically (at least once every six years) include a link to this page in a bill stuffer or their CCR.

A CCR example from Orem City is attached. They have included information on the proper handling and use of pesticides
and herbicides on Page 7 and protecting their sources on Page 8. The only thing this CCR lacks is info for septic system
owners, which Ephraim City will need to include. The public education information does not need to be exhaustive to fulfill
the rule, it just needs to spell out the most important best management practices.

Let me know if you have any other questions.

On Mon, Jun 24, 2024 at 8:26 AM Layne Jensen <[e-mail]> wrote:
Thanks Diedre,

I will reach out to the city to determine how they want to implement BMPs and land management
strategies. I would like to take your offer to provide examples of how other entities have handled the
BMP and land management strategy requirements.

One clarification, If the board does vote to adopt the rule change will we need to address your comment
on the sewer lines?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, June 21, 2024 1:45 PM
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…437/462
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hello Layne,

I've reviewed the latest submission and need the following items addressed:

The report needs to be stamped and signed by a licensed geologist or engineer.

After Section 2, there is no mention of the springs, only the wells. If this document is an update for the springs, they
need to be referenced in each section, and a statement made that no changes have occurred.

Sections 3 and 4

The sewer lines are being assessed as adequately controlled in these sections stating they are constructed in
accordance with R309-515-6(4). I believe they are not specially constructed in accordance with R309-515-6(4), so
another control type will need to be used to assess the sewer lines as adequately controlled. Generally, if a
sewer utility is routinely inspecting its lines or performing other periodic maintenance, best management/pollution
prevention practices can be used to assess the sewer lines as adequately controlled. We also don't consider "protected
aquifer" status as a reason for assessing a potential contamination source (PCS) as adequately controlled.

I have not taken the exception request for the sewer line(s) in zone 2 for the South Well to management yet. The DDW
Board will vote on June 25th to adopt the rule revisions. We don't believe there will be an issue so I will hold off until
then.

Section 5

This section states that implementation of Best Management Practices will be encouraged to mitigate the hazard
presented by these potential contamination sources. What does this mean? Will the system send out mailers, add
information to their CCR, or website concerning BMPs? We do have fact sheets that can be used. If you would like to
see examples of how other systems have handled this requirement, particularly for residents, please let me know. The
strategies need to be explicit so that the system is aware and knows exactly what they need to implement.
Otherwise, the next time their update is due, the plans may be disapproved for lack of plan implementation. Lack of
plan implementation is considered a significant deficiency under the Improvement Priority System (IPS) rule, so we
emphasize the importance of this with consultants/systems.

For whatever reason, past plans/updates were concurred with even though it doesn't appear that any specific land
management strategies have been implemented for the residential properties and the septic system owners. As such, I
will be conditionally concurring with the plan with the condition being that strategies be implemented and
documentation provided the next time the plan(s) are updated.

Section 7

Again, the land management strategies need to be explicit. Under this section, it states that the city will encourage
residents to use chemicals and fertilizers according to manufacturer's guidelines. How will this be accomplished?
Please update this section with a specific schedule for the completion of the land management strategies
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…438/462
added to Section 5. Technically, the rule states they need to be implemented within 180 days of concurrence, so be
sure whatever schedule is proposed, that it doesn't violate this requirement.

Waivers

The spring sources currently have "use monitoring reduction waivers" for pesticides and VOCs. If the system wants to
renew these waivers, the attached statement needs to be filled out, signed, and submitted with the plan update.
The system will want to keep these since it reduces their monitoring frequency, i.e., no pesticide sampling is required.

Please reach out with any questions.

On Tue, May 28, 2024 at 11:46 AM Deidre Beck <[e-mail]> wrote:
Received, thank you. I have added this plan and the exception request to our queue for review. I will reach out with
any other questions.

On Fri, May 24, 2024 at 1:23 PM Layne Jensen <[e-mail]> wrote:
Diedre,

We have updated the source protection zones as you recommended and updated the Drinking
Water Source Protection Plan for all of Ephraim’s water sources based on your comments. Below is
a link that you can use to download the full document with appendicies. Included in the DWSPP and
attached to this email is a letter requesting an exemption for a sewer line in Zone 2 for the South
Well. Ephraim is seeking an exemption until the rule is formally changed. The sewer line in question
is not currently in use and will likely be replaced with a larger pipeline in the next year or two. Please
inform the city if the new sewer line will need to comply with requirements in R309-600-13(3) andR309-515-6(4).

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL (2).pdf" at: https://acrobat.adobe.com/id/
urn:aaid:sc:VA6C2:c621b865-c046-4170-b050-f74d6c9973a9

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, March 29, 2024 1:06 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…439/462

The sewer lines should be classified as not adequately controlled for now because that is how it is specified in
rule R309-600-13(3). Once the new rules are enacted the sewer lines in zone two can be assessed as
adequately controlled using one of the four control types. Did I answer all of your questions?

On Fri, Mar 29, 2024 at 1:00 PM Layne Jensen <[e-mail]> wrote:
Deidre,

After discussion with Ephraim City there is not a need to install a sewer line that would be within
Zone 1 for the South Well. However, and mentioned previously there is sewer lines in Zone 2 that
will be subject to the rules until the rule change is completed. Ephraim City will be seeking anexemption until the rule change is finalized. As far as the sewer in Zone 2 being a potential
contamination source should it be identified as controlled or not adequately controlled? If it is
considered not adequately controlled, after the rule change would that change? Any suggestions
how we should handle the sewer in Zone 2 would be appreciated.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 25, 2024 10:27 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

I use a GIS layer administered by the UGRC, which includes all studies. I apologize for providing a reference to
the wrong report. You can access the correct report here. It looks like the new zone two is almost entirely within
the secondary recharge area. To be clear, these data are primarily used for establishing lateral continuity of the
clay layer to the extent of zone 2, not necessarily whether or not 30 feet of clay was encountered in the
uppermost 100 feet of the well. So you can try to argue protected aquifer status, but it is unlikely I will be able
to concur with that classification since the Well Driller's report does not indicate that 30 feet of clay was
encountered.

Yes, if sewer infrastructure will be placed within zone one in the future, it will need to comply with R309-600-
13(3) and R309-515-6(4). As far as the existing sewer infrastructure in zone two is concerned, a letter
requesting exceptions to R309-600-13(3) and R309-515-6(4) will need to be submitted for Assistant Director
approval. The letter can be prepared by a consultant, but we prefer that the letter be signed by the system
because we have had situations in the past where systems had no idea that exceptions had been requested or
granted. Historically, the Division has required information on the age of the sewer infrastructure, which
portions of the rules are not being met, etc. We have also required inspection by video/camera of any sewer
lines located within zones one and/or two. It appears that these sewer lines may be newer, just based on aerial
photography, so a camera inspection may have been done recently that would fulfill this requirement. Typically
the conditions for granting the exceptions will be to camera/video at least once every 3 years, and there may
be additional nitrate monitoring required. Once the new rules are enacted, those requirements will no longer be
required.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…440/462

Let me know if you have any other questions.

On Mon, Mar 25, 2024 at 9:34 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I have appreciated your quick response to our questions. I have been updating the section on
protected aquifer status for the South Well. In your previous email you mention that a portion of
well protection zone 2 for the South Well was in a Primary Recharge zone which suggested the
aquifer did not qualify as a protected aquifer. With the revised well protection zones for the
South Well being significantly smaller with the lower hydraulic conductivity and pumping rate I
was wondering if you could look at the mapping you have for Sanpete County and let me know
if portions of well protection zone 2 is still identified as being in a primary recharge area? Thereport you referenced in your email about your concerns related to whether the South Well met
the criteria for protected aquifer status did not include Sanpete County or I would check myself.
I would like to reference the study in the DWSPP. Please give me the reference for the
report/mapping for Sanpete County. I am hopeful that with the smaller Zone 2 we can justify aprotected aquifer status.

There is not currently a sewer line within Zone 1 of the South Well. However, with development
there is potential for a sewer line to be constructed about 80 feet from the well. There are
existing sewer lines within zone 2. Any new sewer lines constructed within zone 1 would need
to comply with R309-515-6(4). Depending on the decision on the protected aquifer status
Ephraim may need to seek a temporary exemption for sewer lines in zone 2. What is the
process to seek the exemption?

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Wednesday, March 13, 2024 4:26 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Ma Evans <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Layne,

I have looked over the information you provided. My comments are in red, below. Please reach out with any
further questions.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…441/462
I think the zones look reasonable. Based on the value for T that Neil found for the South Well, I think the
transmissivity for the North and Central Wells is probably high. But the value is conservative, so it meets the
intent of the rule. If the system would prefer to make the zones smaller for management purposes, you could
try to refine the value for T using better test data or use an empirical approach like Neil did for the South
Well.

Assuming these protection zones are acceptable, I would like to propose that we add potential
contamination sources not previously included in a source protection zone, but not delete the previously
identified potential contamination sources that are now not in a source protection zone. The previous
source protection zones were more conservative from the point of view of including more potential
contamination sources. How do you feel about this approach? It may be difficult for the system to manage a
larger number of PCSs and it will make it difficult for DDW staff to determine if land management strategies
have been implemented for any not adequately controlled PCSs when the plan is updated during the normal
update cycle. If you decide to go this route, please add a column or in some way denote which PCSs are
actually within the final zones and which are not so that the system and DDW staff can discern the
difference.

North and Central Well
Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these assumed
flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed flows. We
assumed the higher flow so that if the pump in the well is replaced to increase production the DWSPP would
not need to be updated. This is a good idea.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This is higher
than the thicknesses used to calculate the hydraulic conductivity, but less than the actual thickness. We are
assuming the North and Central wells are drawing from the same aquifer. The Central Well is producing its
water from a depth much greater than the North Well. Assuming they are drawing from the same aquifer the
thickness is probably closer to 200 feet or more. In the model a greater thickness reduces the size of the
source protection zones. The lower thickness assumed provides a more conservative estimate. Yes, you
can always use a smaller aquifer thickness as it is considered more conservative.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM only
accepts one value/assumes the aquifer is homogeneous) Sounds appropriate.
Porosity = .15 Sounds good.
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the median
total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total water recharges
the fractured bedrock aquifer. Sounds good.

South Well
Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to 400 gpm.
The higher flow is assumed to be conservative. Sounds good.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below) Be sure to include this information in
the Delineation Section.
Aquifer Thickness = 125 ft (screened zone in the well) Sounds good.
Porosity = 0.15 Sounds good.
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results than a
higher recharge value. Sounds good.

On Wed, Mar 13, 2024 at 9:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

I appreciate your help on improving the source protection zones. We have updated the
source protection zones based on hydraulic conductivities calculated from testing results.
Before making changes to the DWSPP I wanted to see if you have any concerns with the
method and assumptions. I am attaching the following maps:

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…442/462
North Well protection zones
Central Well protection zones
South Well protection zones
Protection zones for all three wells plotted on the same map
Revised protection zones for all three wells and the previously calculated protection
zones

The revised protection zones generally extend farther into the mountains but cover less of the
city area. Assuming these protection zones are acceptable, I would like to propose that we
add potential contamination sources not previously included in a source protection zone, but
not delete the previously identified potential contamination sources that are now not in a
source protection zone. The previous source protection zones were more conservative from
the point of view of including more potential contamination sources. How do you feel about
this approach?

The source protection zones estimates were based on the following assumptions:

North and Central Well

Central Well flow rate 1500 gpm, North Well flow rate 2000 gpm. These wells can produce these
assumed flows, but the actual pumps in the wells produce roughly 500 gpm less than the assumed
flows. We assumed the higher flow so that if the pump in the well is replaced to increase
production the DWSPP would not need to be updated.
Wells are assumed to be in the same aquifer since both are completed in fractured bedrock.
Aquifer thickness = 60 ft. This is the value used in the original modeling for the Central Well. This
is higher than the thicknesses used to calculate the hydraulic conductivity, but less than the actual
thickness. We are assuming the North and Central wells are drawing from the same aquifer. The
Central Well is producing its water from a depth much greater than the North Well. Assuming they
are drawing from the same aquifer the thickness is probably closer to 200 feet or more. In the
model a greater thickness reduces the size of the source protection zones. The lower thickness
assumed provides a more conservative estimate.
Hydraulic Conductivity = 657 ft/day (average of the two values provided by you because WhAEM
only accepts one value/assumes the aquifer is homogeneous)
Porosity = .15
Recharge (concentrated in the mountains) = .002 ft/day. This number is generated by taking the
median total rainfall/snowfall SWE from the nearby SNOTEL sites and assumed 30% of the total
water recharges the fractured bedrock aquifer.

South Well

Flow rate = 500 gpm, The well would struggle to produce this flow. Actual capacity is closer to
400 gpm. The higher flow is assumed to be conservative.
Hydraulic Conductivity = 4.8 ft/day (see notes from Neil Burk below)
Aquifer Thickness = 125 ft (screened zone in the well)
Porosity = 0.15
Recharge (concentrated in the mountains) = .001 ft/day. This yielded more conservative results
than a higher recharge value.

Notes from Neil Burk (hydrogeologist) on the hydraulic conductivity for the South Well

I plotted the test pumping data to understand what happened during the test pump. Because the test
pump was shut down twice and pumping time was limited, I think the best approach to estimate
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…443/462
transmissivity is to use an empirical method with specific capacity. I used the Mace (2001) method to
estimate transmissivity with the following parameters:
Q = 430 gpm (approximate average pumping rate)
Drawdown = 169 feet
Pumping time = 1264 minutes
Storage coefficient = 0.0005
Well radius = 0.8 feet
I estimated transmissivity to be 600 ft2/day (rounded). The saturated thickness is 125 feet and is based
on the screen length, so the hydraulic conductivity is 4.8 ft/day.

Ultimately many conservative assumptions are made to compensate for limited available
data. Please let me know of any concerns you may have.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 4:56 PM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

My answers are in red:

Production Zone for Each Well: the South Well clearly needs to be modeled as a separate aquifer. It is
not as clear for the Central and North Wells. Both are completed in fractured bedrock, but they are
drawing from different depths. The central well is drawing from 437 to 452 feet. The North Well was
drilled to 445 feet, but when we videoed the well we learned that the bottom 160 feet of the well had
caved in or filled with debris. The well is producing its water from a water bearing zone at a depth of
about 285 feet. I am inclined to model the source protection zones as if they are in the same aquifer
since both are producing from fractured bedrock. I think that will also produce more conservative source
protection zones. What is your thought on this?

If they are producing from the same aquifer, just a different water-bearing zone, then I think it makes
sense to model them together.
North Well Transmissivity: Another pump test has not been performed on the North Well. I am
discussing with the city if they want to do another pump test with the installed pump that would stress the
well more, but a decision has not been made yet. I appreciate your calculations for the hydraulic
conductivity. With the information provided above I would propose using a hydraulic conductivity of
14,360 ft2/day and an aquifer thickness of 40 feet. Based on the video the well is producing water from
end of the casing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity of 359
ft/day. Does this seem reasonable to you?
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…444/462

To be clear, the transmissivity is 14,360 ft2/day and the hydraulic conductivity is 359 ft/day using 40 feet
as the saturated aquifer thickness. I do think these values are a bit high for what I typically see in
fractured bedrock aquifers. It probably has to do with the quality of the constant-rate test data. If the
system conducts another constant-rate test, the transmissivity could be further refined but I'm not
suggesting they have to do that.
Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you calculated to
model the well protection zones if that is acceptable.

Again, 989 ft/day is the hydraulic conductivity, not the transmissivity. I don't know if you can use two
different hydraulic conductivities in WhAEM for the same aquifer, but if you can, then it would be
acceptable to use the transmissivity that has been calculated. If you can't use two different values, then
an average of the two could be used.

South Well Transmissivity: We had some bad luck when pump testing the South Well. The generator
shut down unexpectedly or was turned off during both of our attempts at a long term test. The pumping
rate does fluctuate, but it fluctuates within the accuracy range of the flow meter (+/- 1.25%). I agree the
well did not achieve what I would consider a stabilized drawdown. I think the first attempt came close
though. I have contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data. With
the combination of pumping and recovery data available he felt he could calculate a representative
hydraulic conductivity. I will share his conclusion when I receive it next week.

Sounds good.
Protected Aquifer Status for the South Well: When I looked at the well logs in the appendix, I notice it
was missing the well log for the actual production well. The well log in the appendix was for the test well.
In the top 100 feet the soil descriptions are similar, but not exact. I am attaching the well log to this email
and will add it to the DWSPP appendix. We are looking at what is considered a clay differently. I have
always felt that a soil that includes clay will behave hydraulically more like a clay. Ultimately you will
make the call on this. However, I thought I would give my perspective. The presence or absence of clay
in a soil has far more impact on the hydraulic conductivity of the soil than does the presence or absence
of sand or gravel. Clay fills the open spaces between the sand and gravel particles making the soil
behave more like a clay from a hydraulic perspective. I do not know whether the soils not identified as a
straight clay are a sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be
identified as having clay, I feel there is enough clay for the soil to behave hydraulically as a clay. In this
line of thinking there is 70 feet of clay in the top 100 feet. Even if only half of the soils identified as having
a clay fraction behave hydraulically as a clay the standard is met. However, I believe any soil with a
significant clay fraction will behave hydraulically more like a clay than a sand or gravel. We will correct
the inconsistency regarding the sewer lines in Zones 1 and 2. We will assess the need to request an
exemption after receiving your thoughts on this and redoing the modeling. It could be that my logic above
and other information is included as justification for an exemption.

The Well Driller's Report (even for the production well) does not provide additional descriptions or
remarks that would make me think that there is a predominance of clay. I agree that if there is a
significant clay fraction (60-70%), then the material will likely act as clay, but the Well Driller's Report does
not state anything that leads me to believe there is a predominance of clay besides between 75-80 feet. I
have to make my decision based on the information that is provided. If the Well Driller's Report denoted
"mostly clay", "clayey sand", "70% clay", or something that made me think that clay was predominant, I
would agree with your arguments. I also reviewed other well logs near this source to come to my
conclusion. Oftentimes lithologic logs prepared by a geologist or engineer during the drilling are used to
supplement the Well Driller's Report. Since that is not available, I have to base my decision on what is.

The protected aquifer definition in the source protection rule was informed, in part, by the report titled
Hydrogeology of Recharge Areas and Water Quality of the Principal Aquifers Along the Wasatch Front
and Adjacent Areas, Utah; United States Geological Survey Water Resources Investigations Report 93-
4221, published in 1994. This report mapped the principal aquifers and recharge areas along the
Wasatch Front. Water-level data and drillers' logs from 2,828 wells in the USGS, Utah Division of Water
Rights, and Utah Department of Health, Division of Environmental Health (now DEQ) databases were
examined in the study. Ground-water recharge-area mapping delineated locations where surface
contaminants could move down to the principal aquifer(s).
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…445/462
Areas were classified as primary recharge areas, secondary recharge areas, or discharge areas. Based
on discussions between DDW staff and the USGS at the time, it was decided that if a well and
accompanying zone two are completely within the secondary recharge area or discharge area as mapped
by Anderson and others, DDW staff would consider that sufficient evidence to demonstrate the extent of
the clay layer throughout zone two. Anderson and others mapped the recharge and discharge areas
based on dominantly clay layers, 20 feet thick or more. I checked this data source. Proposed zone two for
the South Well was not entirely within the secondary recharge area or discharge area. Part of Zone Two
was located in the primary recharge area.

It will be interesting to see what the zones look like when the well is modeled separately from the other
two. Just last week we received approval from the DDW board to move forward with rule-making
regarding the sewer line rules. The proposed rules remove the special construction requirements in zone
two regardless of aquifer type. I assume there isn't sewer infrastructure in zone one? If these rules get
adopted, then the system will no longer need an exception for the sewer infrastructure currently located in
zone two. Due to the timing, it may be necessary for the system to request temporary exceptions to
R309-600-13(3) and R309-515-6(4), but once the proposed rules are adopted/enacted, the exceptions
will no longer be required. Let me know if you'd like more information.

On Mon, Mar 4, 2024 at 8:20 AM Layne Jensen <[e-mail]> wrote:
Sorry, attached is the well log.

Thanks,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Monday, March 4, 2024 7:58 AM
To: Layne Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi,

I'm not seeing any attachments. Can you please attach the well log?

On Fri, Mar 1, 2024 at 3:53 PM Layne Jensen <[e-mail]> wrote:
Diedre,

I have been working on your comments. I have some items I would appreciate your
thoughts on.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…446/462
Production Zone for Each Well: the South Well clearly needs to be modeled as a
separate aquifer. It is not as clear for the Central and North Wells. Both are completed
in fractured bedrock, but they are drawing from different depths. The central well is
drawing from 437 to 452 feet. The North Well was drilled to 445 feet, but when we
videoed the well we learned that the bottom 160 feet of the well had caved in or filled
with debris. The well is producing its water from a water bearing zone at a depth ofabout 285 feet. I am inclined to model the source protection zones as if they are in the
same aquifer since both are producing from fractured bedrock. I think that will also
produce more conservative source protection zones. What is your thought on this?

North Well Transmissivity: Another pump test has not been performed on the North
Well. I am discussing with the city if they want to do another pump test with the installed
pump that would stress the well more, but a decision has not been made yet. I
appreciate your calculations for the hydraulic conductivity. With the information provided
above I would propose using a hydraulic conductivity of 14,360 ft2/day and an aquifer
thickness of 40 feet. Based on the video the well is producing water from end of thecasing at 245’ to the bottom of the open hole at 285’. This calculates to a transmissivity
of 359 ft/day. Does this seem reasonable to you?

Central Well Transmissivity: I would like to use the transmissivity of 989 ft/day that you
calculated to model the well protection zones if that is acceptable.

South Well Transmissivity: We had some bad luck when pump testing the South Well.
The generator shut down unexpectedly or was turned off during both of our attempts at a
long term test. The pumping rate does fluctuate, but it fluctuates within the accuracyrange of the flow meter (+/- 1.25%). I agree the well did not achieve what I would
consider a stabilized drawdown. I think the first attempt came close though. I have
contacted a hydrogeologist (Neil Burk) to see what he felt he could do with the data.
With the combination of pumping and recovery data available he felt he could calculate a
representative hydraulic conductivity. I will share his conclusion when I receive it next
week.

Protected Aquifer Status for the South Well: When I looked at the well logs in the
appendix, I notice it was missing the well log for the actual production well. The well log
in the appendix was for the test well. In the top 100 feet the soil descriptions are similar,but not exact. I am attaching the well log to this email and will add it to the DWSPP
appendix. We are looking at what is considered a clay differently. I have always felt that
a soil that includes clay will behave hydraulically more like a clay. Ultimately you will
make the call on this. However, I thought I would give my perspective. The presence or
absence of clay in a soil has far more impact on the hydraulic conductivity of the soil than
does the presence or absence of sand or gravel. Clay fills the open spaces between the
sand and gravel particles making the soil behave more like a clay from a hydraulic
perspective. I do not know whether the soils not identified as a straight clay are a
sandy/gravely clay or a clayey sand, but if there is enough clay in a sample for it to be
identified as having clay, I feel there is enough clay for the soil to behave hydraulically as
a clay. In this line of thinking there is 70 feet of clay in the top 100 feet. Even if only half
of the soils identified as having a clay fraction behave hydraulically as a clay the
standard is met. However, I believe any soil with a significant clay fraction will behave
hydraulically more like a clay than a sand or gravel. We will correct the inconsistency
regarding the sewer lines in Zones 1 and 2. We will assess the need to request anexemption after receiving your thoughts on this and redoing the modeling. It could be
that my logic above and other information is included as justification for an exemption

Thanks,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…447/462
Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Friday, February 16, 2024 10:41 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen <[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

I have reviewed the Delineation Report; however, I'm unable to concur until the following items
are addressed:

Section 2.3 - Aquifer Data

A statement is made that the North and Central Wells are drawing from fractured bedrock and the
South Well is completed in unconsolidated material, and is likely drawing from a different aquifer
than the Central and North Wells. If the three wells produce from different aquifers, separate aquifer
parameters need to be developed for each scenario (bedrock and unconsolidated) using the results
of a constant-rate test. Please be sure to confirm that the wells produce from different aquifers
before proceeding with revisions. It may be beneficial to draw a geologic cross-section. If they
produce from separate aquifers then they need to be modeled as such. That means that only
the North and Central Wells should be modeled to show interference in WhAEM using parameters
derived from their constant-rate tests and the South Well should be modeled separately, i.e., the
zones may overlap those of the North and Central Wells.

For the North (and Central) Well, aquifer parameters should be based on the results of a constant-
rate aquifer test performed on the North Well to comply with R309-600-9(6)(a)(iv) - Aquifer Data for
New Wells, which states that 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).
Typically the transmissivity is determined from the constant-rate aquifer test and then hydraulic
conductivity is determined using the equation T=K/b. The report states that the "pump data is
preliminary; it will be updated once a pump test has been completed". On page 325 of the PDF,
there is data from a "constant flow test" conducted between April 12-13, 2022 on the "Ephraim North
Well Conversion". If these data are from a constant-rate test, they should be used to derive a value
for transmissivity and hydraulic conductivity for use in the WhAEM model for the bedrock scenario.
Or another 24-hour constant-rate test will need to be conducted on the North Well to comply with
R309-600-9(6)(a)(iv) unless the system wants to request an exception to rule.

When I use the data in the appendices and the Cooper-Jacob method (T=2.303*Q/(4*pi*change in
drawdown over one log cycle)), I calculate a value ranging between 14,360 - 25,240 ft2/day,
depending on the log cycle I use. This is twice what is currently being used in the WhAEM model.
The hydraulic conductivity for the North Well would then be equal to K = 14360 ft2/day/ 200 ft (open
hole portion of well) = 71.8 ft/day. I also looked at the pump test data provided for what I assume is
the Central Well (Ephraim Well #1) from 1991 that was in the appendices. Based on that test, the
value for transmissivity also appears to be closer to 14,840 ft2/day. I used the Cooper-Jacob method
described above and the values for drawdown at 100 minutes and at ~1000 minutes.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…448/462
I am not sure where the aquifer thickness of 60 feet came from. The well log for Well #1 shows that
only 15 feet of screen was perforated. The hydraulic conductivity for the Central Well would then be
equal to K = 14840 ft2/day/ 15 ft (open hole portion of well) = 989 ft/day. You can either use an
average of the values for hydraulic conductivity in WhAEM or decide what value is most
appropriate. Please update the aquifer parameters used for the North and Central Wells
making sure to derive them from as-built characteristics and the results of a constant-rate
aquifer test. The delineation must also be updated to reflect only interference from these two wells
using aquifer parameters representative of bedrock wells if you believe that the three wells produce
from different aquifers.

For the South Well, the aquifer parameters should also be based on the results of a constant-rate
aquifer test to comply with R309-600-9(6)(a)(iv). It appears the data are included in the appendices
if the Pumping Test Report from 12-19-2019 is for the South Well. The data do not appear to meet
the rule definition for a constant-rate test because the rate was not held constant and it was not
continued for at least 24 hours or until the Well experienced "stabilized drawdown". Please let me
know if you disagree. If you think the data can be used to derive aquifer transmissivity, please do so.
The updated value for transmissivity and hydraulic conductivity should be used to remodel
the zones for the South Well.

Section 2.7 - Protected Aquifer Classification

Information provided for the North Well was sufficient to document that all three criteria for protected
aquifer status have been met. I am unable to concur with the protected aquifer classification
for the South West Well. While it was concurred with in the PER, the Well Driller's Report does not
substantiate that 30 feet of clay were encountered in the uppermost 100 feet. A combined total of
20 feet of clay was encountered in the uppermost 100 feet between 0-15 feet and 75-80 feet. I
also looked at Well Driller's Reports near this source and found similar conditions. Given that the
zones may change based on my comments above, I will wait to provide a bunch of feedback on the
Potential Contamination Source Inventory (PCS), but I did notice that sewer lines are listed in zone
one for the South Well but then it says under sewer lines in zone 2 that there are no sewer lines in
zone 1. Please update this to be consistent. It also states that it is unknown whether or not sewer
lines in zone 2 have been constructed to the R309-515-6(4) standard. I would imagine they haven't
been since the system would have been under no obligation to specially construct them. Exceptions
to R309-600-13(3) and R309-515-6(4) may be required depending on the extent of zone 2 after
remodeling.

I would recommend submitting the revised information for Section 2.0 before revising any of the
other sections to avoid unnecessary work.

Please contact me with any questions.

On Thu, Jan 18, 2024 at 10:03 AM Deidre Beck <[e-mail]> wrote:
If this will serve as an "update" for the springs, then under each major section you should specify
no changes have occurred for the springs so that it's not confusing. It doesn't look like there is
anything to implement for the springs so disregard that statement from my last email.

As discussed over the phone today, I will proceed with a review of the Delineation Report
(Section 2) and provide any comments before reviewing the remainder of the plan.

Thanks,

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…449/462
On Thu, Jan 18, 2024 at 9:14 AM Layne Jensen <[e-mail]> wrote:
Diedre,

The intent was for this document to include all of Ephraim’s water sources in a
single DWSPP. There have been changes and additions for the wells. There have
not been changes or additions for the springs. For the springs, we simply copied
the information for the springs from the 2010 plan without changes other thanhopefully improved mapping and tables identifying the location of the springs.
Without changes to the plan for the springs we did not think to include a plan
implementation. We can add a section indicating the information relating to the
springs was copied from the 2010 plan to create a single document for all sources
and that those plans have previously been implemented.

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Thursday, January 18, 2024 8:36 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Received, thank you. I am logging this in as a final DWSP plan for the South West Well
(WS016) and North Well (WS017), and as a revised DWSP plan for Ephraim Well #1 (WS014).
I see that the springs are also mentioned. Is this supposed to function as an updated plan for
the spring sources? I'm not sure it meets that intent since plan implementation is not discussed
for the springs. Can you verify my understanding?

On Wed, Jan 17, 2024 at 3:36 PM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link to download the stamped and signed DWSPP for Ephraim for your
review.

I'm using Adobe Acrobat.
You can view "Ephraim 2024 DWSPP - FINAL.pdf" at:
https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:f0511a8d-30e2-44ea-b78d-
cd86a5f682d1

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…450/462
Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

From: Deidre Beck <[e-mail]>
Sent: Tuesday, January 16, 2024 10:07 AM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City Dra Drinking Water Source Protecon Plan

Hi Layne,

We don't typically review "draft submissions". Our preference is that the document be
stamped and signed since this is a requirement of rule. Any comments can be addressed
after the official review.

On Mon, Jan 15, 2024 at 10:41 AM Layne Jensen <[e-mail]> wrote:
Diedre,

Below is a link that will allow you to download a draft of a DWSPP that includes
all of Ephraim’s drinking water sources including the mountain springs andthree wells.

Please review and provide any comments you may have. We will finalize the
document and get any necessary signatures after your review.

I'm using Adobe Acrobat.
You can view and comment on "Ephraim 2023 DWSPP_Dra.pdf" at:
hps://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:83256f6b-173b-445c-a76d-
ace2f50e8c98

Thank you,

Layne Jensen, P.E.

Franson Civil Engineers
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…451/462

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 1:04 PM
To: Layne Jensen <[e-mail]>
Cc: bryan.kimball <[e-mail]>; Jeff Jensen
<[e-mail]>
Subject: Re: Ephraim City South and North Wells

Thanks for the update!

On Thu, Nov 2, 2023 at 1:02 PM Layne Jensen <[e-mail]> wrote:
Deidre,

Lauren Ploeger forwarded your email to me from earlier today. We are currently
preparing a DWSP that includes all of Ephraim’s sources (wells and springs). The city
is currently reviewing the accuracy of the PCSs we identified. We are working towards
submitting a draft DWSP by November 16, 2023.

Thank you,

Layne Jensen, P.E. | Principal | [e-mail]
Licensed in the states of Utah, Idaho, Colorado

Franson Civil Engineers
1276 South 820 East, Suite 100, American Fork, Utah 84003
Office: 801.756.0309 | Mobile: [phone] | Direct: 801.769.2046

Any use or reuse of original or altered files by the owner or others without the express written
verification of Franson Civil Engineers or any CADD adaptation from the specific purpose
originally intended shall be at the owner's risk and full legal responsibility.

From: Deidre Beck <[e-mail]>
Sent: Thursday, November 2, 2023 11:43 AM
To: Lauren Ploeger <[e-mail]>
Subject: Ephraim City South and North Wells

Hi Lauren,

Would you happen to have an update on the final DWSP plan for these two sources?
The PER concurrence letter for the North Well was sent out on November 16, 2022. A
full DWSP plan is due for both by 11/16/2023.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…452/462
Thanks,

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.

--
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.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…453/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…454/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…455/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…456/462
--
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.

--
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.
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…457/462

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
P: [phone]
drinkingwater.utah.gov
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…458/462

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

--
Deidre Beck, PG, GISP
Environmental Scientist III | Permitting
M: [phone]
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…459/462
P: [phone]
drinkingwater.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

--
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.

1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…460/462
--
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.

--
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.

--
1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…461/462
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.
--
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.
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1/27/25, 3:12 PM State of Utah Mail - RE: Ephraim City Draft Drinking Water Source Protection Plan
https://mail.google.com/mail/u/0/?ik=c26a5d4cc7&view=pt&search=all&permthid=thread-f:1788179130043992780&simpl=msg-f:1788179130043…462/462