HomeMy WebLinkAboutDDW-2025-002363
March 12, 2025
Scott Atwood
Red Wash
1108 East, South Union Avenue
Midvale, Utah 84047
Subject:After-the-Fact Operating Permit and Exceptions, System #24020, File #13625
On March 27, 2024, the Division of Drinking Water (the Division) issued an Initial Order informing you that the Red Wash water system would be regulated by the Division as a Non-Transient
Non-Community (NTNC) public water system. The Initial Order outlined
the requirements of becoming a public system, including the submission of an engineering evaluation report, and obtaining system approval and an operating permit for the facilities in
your water system.
The Division received the Engineering Evaluation Report from your consultant, Jones and DeMille Engineering on February 14, 2025. The report was stamped, and signed by Bart E. Jensen,
P.E. and dated February 14, 2025. Division staff conducted an initial site visit and sanitary survey on August 28, 2024.
Red Wash is an office complex associated with an Oil and Gas operation located approximately 20 miles south of Jensen at Latitude 40°11'58.8"N, Longitude 109°18'34.2"W. The water system
consists of two 3,500 gallon tanks (ST001 and ST002) that supply water to three buildings, two office buildings and a maintenance shop. The tanks are at ground level, with the water
system pressures being maintained by a pump station adjacent to each tank (PF001 and PF002). The source of water for the system is permanent water hauling, which was approved by the
Division on September 3, 2024. Water is hauled as needed, with a tanker truck delivering 2,100 gallons to ST001 and 1,500 gallons to ST002. Based on the 5 months of water hauling records
submitted, water is hauled on average about every two weeks, with 11 days being the shortest time between loads.
Based on the submitted information, staff inspections, and the Exceptions outlined below, the Division has determined that all requirements for After-the-Fact System Approval and Operating
Permit for the Red Wash water system have been met. On this basis, System Approval and an Operating Permit for the Permanent Hauled Water Source (WS004), Distribution System (DS001),
Tanks (ST001 and ST002) and Pump Stations (PF001 and PF002) is hereby issued as constituted by this letter.
Exceptions
The engineering report the Division received on February 14, 2025, included requests for exceptions to rule as outlined below.
Exception to R309-510-7, Source Sizing. According to this rule, system sources must be able to legally and physically supply minimum flows during Peak Day and Average Yearly demand scenarios.
Since the system uses permanent water hauling as its source, and orders loads of water delivered as needed, this minimum source requirement does not apply. On this basis, an exception
to R309-510-7, Source Sizing, is hereby granted for the Red Wash water system sources.
Exception to R309-540-6(2), Number of Pumps. According to this rule, a water supplier is required to have at least two pumps installed and in operation at a booster pump facility that
provides the only means available to meet minimum distribution system pressure requirements. The existing pump stations (PF001 and PF002) adjacent to the tanks (ST001 and ST002) have
only one pump installed and in operation at each location. The basis for the exception request is that there is not enough room in the existing structures that house the pumps to add
an additional pump. The exception request proposes to have a spare pump on hand to be switched out if a pump fails, and that the office staff at the NTNC system can either be sent home
or use the buildings served by the other tank and pump. On this basis, an Exception to R309-540-6(2) Number of Pumps, is hereby granted for PF001 and PF002.
Exception to R309-545-14(1) and (2), Access Opening Height and Shoebox Lid. According to this rule, a tank access opening is required to be fitted with a shoebox type lid that is framed
at least 4 inches above the surface of the tank. The access lids of existing Tanks ST001 and ST002 are fitted with a typical plastic tank threaded lid that sits flush with the top of
the tank. The basis for the exception request is that the tank is not structurally strong enough to support a retrofit of the access lid that would meet the elevation and shoebox requirements.
The exception request proposes that the existing threaded lid, which has an overlapping flange and rubber gasket, results in a tight seal on the gasket and protects the seam between
the lid and tank and meets the intent of the rule. On this basis, an Exception to R309-545-14(1) and (2), Access Opening Height and Shoebox Lid, is hereby granted for ST001 and ST002.
Exception to R309-545-13, Tank Overflow. According to this rule, a tank is required to have overflow piping separate from the air vent. Existing Tanks ST001 and ST002 do not have overflow
piping separate from the air vents. The basis for the exception request is that the tank is not structurally strong enough to support a retrofit to add overflow piping. The exception
request proposes that the existing design meets the intent of the rule as follows. The tanks are only filled when water is hauled to fill them, and the water hauler will manage the filling
to prevent tank overflow. On this basis, an Exception to R309-545-13, Tank Overflow, is hereby granted for ST001 and ST002.
Exception to R309-545-14(3), Access Opening Locking Device. According to this rule, a tank access opening is required to have a locking device. The access lids of existing Tanks ST001
and ST002 do not have a way of locking the threaded lid. The basis for the exception request is that there is not a good way to retroactively add locking mechanism loops to the existing
threaded tank lids. The exception request proposes that the ongoing security associated with being an oil and gas facility meets the intent of the rule. On this basis, an Exception to
R309-545-14(3), Access Opening Locking Device, is hereby granted for ST001 and ST002.The issuance of this Operating Permit resolves your water system’s deficiencies related to G001,
Unapproved Facilities. An updated IPS report isavailable at https://waterlink.utah.gov. Please contact Jennifer Yee at (385) 515-1501 or jyee@utah.gov for questions related to your water
system’s IPS report or deficiencies.
Please maintain a copy of this letter with your permanent records for future reference.
If you have any questions regarding this letter, please contact Nathan Hall, P.E., TriCounty DEQ District Engineer at (435) 630-3852, or Michael Newberry, P.E., Permitting and Engineering
Manager, at (385) 515-1464.
Sincerely,
Russell Seeley, P.E.
Assistant Director
NDH/mrn/mdb
cc: Joe Hadlock, TriCounty Health Department, jhadlock@tricountyhealthut.gov
Scott Atwood, Red Wash, scott.atwood@kodares.com
Bart Jensen, Jones and Demille Engineering, b.jensen@jonesanddemille.com
Nathan Hall, DEQ District Engineer, nhall@utah.gov
Jennifer Yee, Division of Drinking Water, jyee@utah.gov
Colt Smith, Division of Drinking Water, acsmith@utah.gov
Brandi Smith, Division of Drinking Water, brandismith@utah.gov
Nagendra Dev, Division of Drinking Water, ndev@utah.gov
Nhall 24020 13625 ATF OP New System