DWQ-2025-000925

**NOTICE OF VIOLATION**

**To Whom It May Concern,**

This document serves as a formal notice of violation regarding the Total Phosphorus levels at the Jordanelle Special Service District Water Reclamation Facility. As per our discharge
permit, we are required to adhere to a strict Total Phosphorus Daily Maximum limit of 0.10 mg/L. On December 30, 2024, our weekly sampling indicated a Total Phosphorus concentration
of 0.4 mg/L, which, falls within a significant range of concern.

After receiving the laboratory data confirming this discrepancy, I immediately let my permit writer know within 24 hours of confirming the violation, as required by regulatory protocols.
After a thorough review, the primary cause of this non-compliance has been attributed to a sample bottle contamination error, which we believe impacted the test results without any underlying
issues within our operational systems.

During the time this violation occurred, we conducted an exhaustive review of our plant operations and found no evidence of an upset or failure in our treatment processes. The duration
of non-compliance was brief, approximately 24 hours or less, and we can confirm that our chemical feed systems functioned normally throughout this period, ensuring there were no disruptions
that would coincide with phosphorus treatment. Our evaluation of our system performance confirmed that biological treatment processes within our process basins were also operating efficiently,
as evidenced by consistent data reflective of normal operational conditions.

We have designated this incident as an anomaly, primarily rooted in procedural error rather than systemic failure. Our investigations suggest that a contaminant may have inadvertently
entered our sub-sample bottle intended for official laboratory analysis. Attached below is a screenshot of our Monthly Operating Report, showcasing the in-house phosphorus testing data
over the days leading up to and including the date of the exceedance. The data indicates that we consistently maintained phosphorus levels within the Non-Detect range up until the incident,
reflecting our commitment environmental and public health. In the attached chart, you can view the results from our official lab (TP - Chemtech Lab) alongside results from our in-house
process control lab (TP - TNT 873). Notably, there exists a significant disparity between these two sets of data, as illustrated by the red and green columns; this discrepancy further
emphasizes the likelihood of a sampling error.
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Looking forward, we have implemented a plan to prevent a recurrence of this issue. This includes a temporary increase in sampling frequency for Total Phosphorus within our in-house process
control lab, where we will now collect at least two samples per day. Additionally, we will conduct a thorough audit of our phosphorus removal chemical feed systems to be certain that
chemical feed was not the issue.

At this juncture, I want to express my confidence that this recent exceedance will remain a singular violation and is unlikely to be repeated. While we are committed to addressing this
matter, I believe that minor quality control adjustments for sampling practices will suffice as our main mitigation efforts. Water quality remains our highest priority at the JSSD Wastewater
Treatment Plant, and we are dedicated to continuous improvement in our operations. Please rest assured that we will adopt all necessary measures to prevent similar incidents in the future.
Quality control, particularly concerning sampling, will be prioritized moving forward, as we firmly believe that this procedural slip rather than an actual discharge of high Total Phosphorus
into the environment prompted the exceedance.

Thank you for your attention to this matter.

Sincerely,

[cid:2118c4a6-7ad0-49fc-b4f6-4b4bfa3e3ae3]

Drew Robinson

Wastewater Treatment Plant Manager

Mobile: [phone]

Email: [e-mail]<mailto:[e-mail]>

5780 N. Old Hwy 40

Heber, Utah 84032