DDW-2024-006955

April 1, 2024
Cody S Watkins
Ash Grove Cement Company
PO Box 38069
Leamington, Utah 84638
Subject:Concurrence, Updated Drinking Water Source Protection Plan for the Primary Well and Secondary Well Temporary Exception Granted to R309-600-9(6)(a)(iv) and R309-515-6(10)(b);
Ash Grove Cement Company; Water System #12039, Source No. WS001 and WS002
This Temporary Exception Expires on December 31, 2028.
Dear Cody S Watkins:
The Division of Drinking Water (the Division) received the updated Drinking Water Source Protection (DWSP) plan for the Primary Well (WS001) and Secondary Well (WS002) from Paul Pederson
on October 27, 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 these sources 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) and R309-515-6(10)(b)
On October 27, 2022, the Division received a request for an exception to Rule R309-600-9(6)(a)(iv) – Aquifer Data for New Wells and R309-515-6(10)(b) – Constant Rate Test. 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 these rules and based your request on the following:
The wells provide water to the plant fire‐protection system and over‐rides on safety features should be considered only under extreme circumstances, especially in light of the recent
wildfire in the region that surrounded the plant;
Allowing the tank to overflow would have been a waste of valuable water in this arid region;
The water level in both the Primary (pumping) Well (WS001) and the Secondary (observation) Well (WS002) had been stable for over 2 hours, and
Subsequent analysis indicated that the data collected from the shortened test were sufficient to determine the hydraulic characteristics of the local aquifer
On this basis, a temporary exception to R309-600-9(6)(a)(iv) – Aquifer Data for New Wells andR309-515-6(10)(b) – Constant Rate Test is hereby granted for the Ash Grove Cement Company
Primary Well (Source WS001) and Secondary Well (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 (12039) in your correspondence.
Sincerely,
Russell Seeley, P.E.
Assistant Director
NAZ/rs/mdbcc:Eric Larsen, Central Utah Health Department, [e-mail] Watkins, Ash Grove Cement Company, [e-mail] Watkins, Ash Grove Cement
Company, [e-mail] Pederson, Ash Grove Cement Company, [e-mail] Zorsky, P.G., Division of Drinking Water, [e-mail]
John Chartier, P.E., DEQ District Engineer, [e-mail]
NZorsky 12039 WS001 WS002 Update Concur Exception