DDW-2025-002593

195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-4830 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov Printed on 100% recycled paper
State of Utah

SPENCER J. COX Governor DIEDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF DRINKING WATER Nathan Lunstad Ph.D., P.E. Director
January 14, 2025

Tracy Feltner Irontown 755 S Main Street Suite 4128 Cedar City, UT 84720
Subject: Notice of Violation, Combined Radium MCL Exceedance-Public Notice Requirement; Irontown: UTAH11070 Tracy Feltner:

This letter serves as notification that according to the Division of Drinking Waters (the Division) records, Irontown (the supplier) is in violation of the state and federal combined radium Maximum Contaminant Level (MCL) as defined in Utah administrative Rules Code (UAC) R309-200-5(4)(b). The MCL for combined radium is 5 pCi/L and is determined by calculating the Running Annual
Average (RAA) of quarterly sample results. The RAA of combined radium at the Irontown Well 1
(identified as WS001 in the Divisions database) is 6 pCi/L. As a result of this violation the Division Director is assessing 50 Improvement Priority System (IPS) points to the supplier. Additionally, the supplier must issue public notice to all connections served
within 30 days of receiving this notice. Additional violations shall be assessed each calendar quarter
that the combined radium RAA exceeds 5 pCi/L.
2024 Radium Sample Results (pCi/L)
01/21/2024 04/01/2024 07/01/2024 11/18/2024
Radium-226 4 4 7 5
Radium-228 2 0 1 0
Combined
Radium
6 4 7 5
Running Annual Average (RAA) 6
Required Actions by Rule for a Tier 2 MCL Exceedance Violation With the Irontown Well 1 (WS001) containing combined radium levels above the MCL, the
Supplier is required by rule to perform the following:
Tracy Feltner Page 2 of 3
January 14, 2025
1. The Supplier is required to notify its water users with the enclosed Tier 02 public notice protocol within 30 days of receiving this letter and repeat the notice every three months for as long as the violation exists. A copy of the public notice must be submitted to the
Division at [e-mail] and [e-mail] prior to distribution. Public notice shall be issued no later than 30 days from January 14, 2025. 2. Enact one of the following mitigation measures: a. Identify and implement operational strategies that can minimize combined radium exposure.
b. Identify possible alternative sources for drinking water.
3. Present MCL exceedance in annual CCR while including the Standard Health Effects Language listed in R309-220-15 for combined radium, and explain the corrective actions being taken.
Please be aware any permanent treatment option must comply with the Division’s plan review process
including submittal of design, engineering plans and specification, and obtaining plan approval (prior to construction) and then requesting and obtaining an operating permit prior to placing any facility into service. Please contact Paul Wright P.E., Southwest Utah District Engineer, at (435)-680-0163 or [e-mail] if you have any question regarding the potential plan review requirements.

Radium is a naturally occurring radioactive element, and its presence in drinking water can present a significant risk to public health. Long-term exposure to radium is associated with an increased risk of cancer, particularly bone cancer. The radiation emitted by radium can damage cells and their DNA, potentially leading to the development of cancerous cells. Therefore, regulatory standards are in place
to limit radium levels in drinking water and protect public health. Regular monitoring and appropriate
water treatment are essential to minimize exposure and ensure the safety of the drinking water supply. Because of the risk to public health and the length associated with installing treatment the Supplier is encouraged to enter into a formal Compliance Agreement Enforcement Order (CA/EO). This Order
will allow the Supplier the time to meet the Best Available Treatment (BAT) while establishing
milestones and deadlines that protect customers health to the best of Safe Drinking Water Act’s ability. To request such this agreement please contact Colt Smith at [e-mail]. Failure to enter into a CA/EO may result in the Director issuing other means of formal enforcement including a Not Approved order or seeking a court order to protect public health.

Please contact David Kruse at [phone] or ([e-mail]) if you have any questions or need assistance. Sincerely,
Mark Berger
Monitoring and Standards Implementation Manager
Tracy Feltner Page 3 of 3
January 14, 2025

Enclosures: Tier Two Public Notice Template and Instructions Master IPS Report cc: Tracy Feltner, Irontown, [e-mail] Jeremy Roberts, Southwest Utah Health Department, [e-mail] Paul Wright, P.E., DEQ District Engineer, [e-mail] Colt Smith, Utah Division of Drinking Water, [e-mail] Mark Berger, Division of Drinking Water, [e-mail] David Kruse, Division of Drinking Water, [e-mail] [e-mail]