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195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-4830
Telephone (801) 536-4200 • Fax (801) 536-4211 • T.D.D. (801) 536-4414
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF DRINKING WATER
Nathan Lunstad, Ph.D., P.E.
Director of Drinking Water
January 21, 2025
Trevor Paulson
Kennecott Section 21 Water
4700 Daybreak Parkway
South Jordan, UT 84095
Subject: Corrective Action Plan for Kennecott-Section 21, UTAH18003 (2025-01)
Dear Trevor Paulson:
The Division of Drinking Water (the Division) has received your request for a Corrective Action
Plan to address the significant deficiencies associated with The Kennecott-Section 21 water system.
A copy of the Corrective Action Plan is enclosed with this letter. Please review the agreement and
sign a copy if you agree with the terms and return the signed copy to the Division within 14 days of
receipt of this agreement. A copy of the fully executed document will be returned to you.
Please contact Brandi Smith at (385) 515-1650 or brandismith@utah.gov if you have any questions
regarding this letter or the enclosed copy of Corrective Action Plan.
Sincerely,
Helen Lau
Compliance and Operations Manager
Division of Drinking Water
Enclosures –Kennecott Section 21 Corrective Action Plan 2025-01
cc: Fuaah Hararah, Salt Lake County Health Department, fhararah@slco.org
Trevor Paulson, Kennecott Section 21, trevor.pailson@riotinto.com
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Corrective Action Plan (2025-01)
Kennecott Section 21 – UTAH18003
The purpose of this Corrective Action Plan (“CAP”) is to establish terms and conditions of
compliance for Kennecott Section 21 (“System”), system number UTAH18003, to take actions
and correct significant deficiencies identified in Exhibit A.
The Corrective Action Plan terms and conditions are described in detail in Exhibit A. As long as
the System complies with every one of the requirements in Exhibit A, the Division will:
• Temporarily allow the extended deadlines for correcting the identified significant
deficiencies,
• Temporarily hold off assessing additional points for failure to fix violations, and
• Temporarily silence the significant deficiencies and hold off reporting those to US EPA.
Nothing in this Corrective Action Plan prohibits the Division from taking further enforcement
actions if the System fails to comply with any of the requirements in Exhibit A or if an imminent
public risk exists in the System.
We, the undersigned parties, agree to the terms, conditions and deadlines set forth in the
Corrective Action Plan (see Exhibit A).
___________________________________ ___________________________________
Helen Lau Trevor Paulson
Compliance & Operations Manager Kennecott Section 21
_______________________, 2025 _______________________, 2025
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CAP Page 1
Exhibit A
Corrective Action Plan UTAH18003, 2025-01
System Name: Kennecott Section 21
System Number: UTAH18003
Administrative Contact: Trevor Paulson
Email: trevor.paulson@riotinto.com
Phone Number: 801-304-1256
Corrective Action Plan Requirements and Due Dates
Upper Refinery Tank (ST005)
Item #1 Deficiency
Code
Facility
ID
Significant Deficiency Rule Citation
V016 ST005 End of tank drain line lacks a clearance of at
least 12 inches
R309-545-10(1)(d)
Corrective Action Due Date
Ensure that the tank drain line has a 12 inch or greater clearance 07/31/2025
Lower Refinery Tank (ST006)
Item #2 Deficiency
Code
Facility
ID
Significant Deficiency Rule Citation
V016 ST006 End of tank drain line lacks a clearance of at
least 12 inches
R309-545-10(1)(d)
Corrective Action Due Date
Ensure that the tank drain line has a 12 inch or greater clearance 07/31/2025