DDW-2024-006954

April 1, 2024
Stanley Johnson
Kane Gulch Ranch Station
82 East Dogwood Avenue
Moab, Utah 84532
Subject:Concurrence, Updated Drinking Water Source Protection Plan for Well #1
Temporary Exception Granted to R309-600-9(6)(a)(iv); Kane Gulch Ranch Station; Water System #19066; Source No. WS002
This Temporary Exception Expires on December 31, 2028.
Dear Stanley Johnson:
The Division of Drinking Water (the Division) received the updated Drinking Water Source Protection (DWSP) plan for Well #1 from you on October 24, 2022.
We have completed our review of the updated DWSP plan and find that the plan basically complies with the applicable portions of Utah’s Administrative Rules for Public Drinking Water
Systems. The Division concurs with this updated plan. We commend you for establishing a program to protect this source from present and future contamination. This plan must be updated
often enough to ensure that it reflects current conditions in your protection zones.
The due date for submitting the next updated plan is December 31, 2028.
Temporary Exception Granted to R309-600-9(6)(a)(iv)
On October 24, 2022, the Division received a request for an exception to Rule R309-600-9(6)(a)(iv) – Aquifer Data for New Wells. R309-600-9(6)(a)(iv) states that the Public Water System
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). You requested an exception to this rule
and based your request on the following:
A constant-rate aquifer test was not performed on the well at the time it was constructed.
The well currently lacks a means for measuring drawdown.
The well is only equipped to pump three gallons per minute. Even if there were a means for measuring drawdown, at such a small discharge rate, the well may not experience enough drawdown
to calculate representative values for hydraulic conductivity.
The most conservative published value for hydraulic conductivity was used in the delineation calculations.
On this basis, a temporary exception to R309-600-9(6)(a)(iv) – Aquifer Data for New Wells is hereby granted for the Kane Gulch Ranger Station Well #1 (Source WS002) subject to the following
conditions:
This temporary exception expires on December 31, 2028, which coincides with the due date of the next updated DWSP plan.
You are required to re-submit an exception request along with confirmation that all conditions outlined have been fulfilled.
Exceptions granted by the Division include an expiration date to ensure that the basis and conditions for granting the exceptions are verified periodically and that drinking water quality
remains protected. After receiving your request, the Division will determine whether these exceptions can be re-issued.
This temporary exception may be rescinded at any time if new evidence indicates that the conditions of this exception are no longer being met or a public health risk exists due to the
granting of the exception.RemindersAs stated in R309-600 and 605: Implementing DWSP Plans - Each Public Water System (PWS) shall begin implementing each of its DWSP Plans in accordance
with the implementation schedule within 180 days after submittal if the plan is not disapproved. Be prepared to describe these efforts in your next update, which should include documentation
of how the land management strategies identified for existing and future potential contamination sources were implemented. Your updated plan will be disapproved, and 25 Improvement Priority
System (IPS) points will be assigned for failure to comply with this requirement.As stated in R309-600 and 605: Recordkeeping - As a DWSP Plan is executed, the PWS shall document any
land management strategies that are implemented. Please provide actual copies of memoranda of understanding, public education programs, bill stuffers, newsletters, or other correspondence
documenting the implementation of each land management strategy as it occurs, in this section of your updated plan.Please contact Noah Zorsky at [phone] or via email at [e-mail]
if you have questions or concerns about the review of your DWSP plan. To help us serve you more efficiently, please use the water system number (19066) in your correspondence.
Sincerely,
Russell Seeley, P.E.
Assistant Director
NAZ/DLB/mdbcc:Ronnie Nieves, San Juan County Health Department, [e-mail] Johnson, Kane Gultch Ranch Station, [e-mail] Zorsky, P.G., Division of Drinking
Water, [e-mail]
Russell Seeley, P.E., DEQ District Engineer, [e-mail]
NZorsky 19066 WS001 Update Concur Exception