DDW-2025-002895

March 28, 2025
Roam America
Escape RV Resorts - Knotty Pine
5175 East State Route 35
Kamas, Utah 84036
Subject:After-the-Fact Operating Permit, Knotty Pines Chlorinator (TP001);
Escape RV Resorts - Knotty Pine, System #22022,File #18224
Dear Roam America:
During the 2023 Sanitary Survey for Escape RV Resorts - Knotty Pine (the System), Rocky Pace with the Summit County Health Department, identified a chlorinator that was not previously
on the system’s inventory report. The System then entered into a Compliance Agreement Enforcement Order with the Division of Drinking Water (the Division) on September 20, 2024, to allow
for more time to correct the deficiency. The Division received adequate documentation for the Knotty Pines Chlorinator (TP001) installation on March 18, 2025. This project has met all
conditions for receiving an after-the-fact operating permit.
The Division’s understanding of the project is that the Knotty Pines Chlorinator (TP001) was installed approximately six years ago in 2019 to help maintain water quality in the distribution
system. The Knotty Pines Chlorinatoris identified as TP001 in the Division’s database.
The Knotty Pines Chlorinator (TP001)included in this project has been completed according to the following:
The Knotty Pines Chlorinator (TP001)is a liquid chlorinator, adding sodium hypochlorite solution of 12.5% concentration.
The Knotty Pines Chlorinator (TP001)treats water from the Knotty Pine Well (WS001). The liquid sodium hypochloriteis added to the water at the well discharge piping.
The chlorinated water then enters the Hydropneumatic Tank (HD001) and flows into the distribution system.
The liquid sodium hypochlorite used for disinfection meets the ANSI/NSF 60 standard.
The chlorine dose is adjusted by a manually adjusted dosing pump set for the constant flow from the Knotty Pine Well (WS001).
We have received the following information for the Knotty Pines Chlorinator (TP001):
Photos demonstrating the chlorinator basically complies with the construction requirements of a chlorinator.
We have determined that all conditions for issuing an operating permit have been met. On this basis, an After-the-Fact Operating Permit for the Knotty Pines Chlorinator (TP001)is hereby
issued as constituted by this letter.
Please maintain a copy of this letter with your permanent records for future reference.
Construction without Plan Approval
It is our understanding that the Knotty Pines Chlorinator (TP001) was constructed without receiving the required Plan Approval by the Division. Please be advised that the construction
of public water system facilities requires obtaining Plan Approval and an Operating Permit [R309-105-6]. A public water system operating a facility without meeting the construction requirements
can be assessed 50 Improvement Priority System (IPS) deficiency points for construction (and operation) without proper approval [R309-400-11]. These IPS points are considered a significant
deficiency and therefore reportable to the EPA and subject to additional points if not resolved in a timely manner [R309-400-11(6)(a)].
Secondary Disinfection Requirements
The Escape RV Resort - Knotty Pine water systemis not required to disinfect the Knotty Pine Well (WS001)based on bacteriological source sample results currently available. However, that
will be re-evaluated after source samples are collected. The water systemhas elected to install the Knotty Pines Chlorinator (TP001) to provide a detectable disinfectant residual in
the distribution system for secondary disinfection.
Please be aware that, if any water source of the Escape RV Resort - Knotty Pine water system is found to require primary disinfection in the future per R309-200-5(7)(a)(i), additional
regulations will apply. This will include submitting disinfection CT information showing compliance with 4-log virus inactivation in accordance with the Ground Water Rule in R309-215-16.
The Escape RV Resort - Knotty Pine water systemis required to demonstrate ongoing compliance with the secondary disinfection requirements outlined in Addendum 1 of this letter as long
as the Knotty Pines Chlorinator (TP001)is in operation.
Monitoring and ReportingIssuance of this Operating Permit changes your water system’s monitoring and reporting requirements. The staff of the Rules Section will follow up to provide
an updated monitoring schedule to you. Please contact Mark Berger, Water Quality/Monitoring and Standards Manager at [phone] for questions regarding the monitoring and reporting
requirements for your water system.
Source Bacteriological Monitoring (WS001)
This water system is required to take monthly bacteriological samples of the Knotty Pine Well (WS001) prior to any treatment, for the months the well is in operation. The source sampling
requirement shall begin in April 2025 and last at least 12 months.
The purpose of the source sampling requirement is to gather data to evaluate the quality of the source water from Knotty Pine Well (WS001) and determine whether primary disinfection
treatment is required or not.
Label the source samples with WS001 as the sampling location.
The required source bacteriological sampling is shown on your monitoring schedule for this sample site. Please note that the source sampling is in addition to the distribution system
bacteriological sampling already in place, which is labeled DS001.
After 12 months of source sampling data becomes available, the Division will evaluate the results to determine whether primary disinfection is required for Knotty Pine Well (WS001).
There may be new changes in monitoring and reporting requirements in the future as the Division continues to improve the disinfection monitoring and reporting practices. Failure to adhere
to required monitoring and reporting will result in violations and the assessment of IPS points.The issuance of this Operating Permit resolves your water system’s deficiencies of G001
and G006 related to installing and operating a chlorinator without prior approval. An updated IPS report isavailable at https://waterlink.utah.gov. Please contact Jennifer Yee at (385)
515-1501 or [e-mail] for questions related to your water system’s IPS report or deficiencies.
If you have any questions regarding this Operating Permit, please contact Dani Zebelean, P.E., of this office, at [phone], or Michael Newberry, P.E., Permitting and Engineering
Support Manager, at [phone].
Sincerely,
Russell Seeley, P.E.
Assistant Director
DZ/mrn/mdbcc:Nathan Brooks, Summit County Health Department, [e-mail] Fishel, Escape RV Resorts - Knotty Pine, [e-mail] America, Escape RV Resorts

- Knotty Pine, 5175 E SR35, Kamas, UT 84036Dani Zebelean, P.E., Division of Drinking Water, [e-mail] Treutel, Division of Drinking Water, [e-mail] Federico,
Division of Drinking Water, [e-mail] Yee, Division of Drinking Water, [e-mail] Smith, Division of Drinking Water, [e-mail] Smith, Division
of Drinking Water, [e-mail] Source Assessment Team, Division of Drinking Water, [e-mail] 22022 18224 ATF OP TP001
Addendum 1 
Elective Monitoring and Reporting Requirements 
Chlorine Monitoring & Reporting Requirements
The water system is required to meet elective disinfection requirements. As a part of these requirements, the water system is required to continuously maintain a minimum free chlorine
residual at each chlorinator Point of Entry (POE) into the system and demonstrate a detectable chlorine residual in the distribution system. 
Elective Disinfection Requirements and Reporting 
Chlorine Residual ‒ Point of Entry (POE) to Distribution System
The POE sampling location is identified as EP001 in the Division’s database. This location has been identified as the smooth nose sample tap after the chlorine injection and before the
hydropneumatic tank. Maintain a minimum of 0.2 mg/L residual (measured as free chlorine) at the POE sampling location. [R309-215-16(3)(b)(iii)(A)(I) and (II)]
The chlorine residual concentration measured at the POE sampling location shall not exceed the maximum residual disinfectant level (MRDL) of 4.0 mg/L (measured as free chlorine). [R309-200-5(3)(c)(iv)]
Record and report the lowest daily chlorine residual concentration, measured as free chlorine, at the chlorinator POE sampling location a minimum of once per day. [R309-210- 8(3)(a)(ii)]
Our records show that your water system serves 354 people. Please be aware that R309-215-16(3)(b)(iii)(A)(II) requires water systems serving 3,300 people or fewer to monitor the POE
chlorine residuals and take daily grab sample(s). Alternatively, instead of taking daily grab samples, a groundwater system serving 3,300 or fewer people may choose to use an online
analyzer to continuously monitor the POE chlorine residuals entering the distribution system.
Chlorine Residual ‒ Distribution System (DS001)
This water system must maintain a detectable residualthroughout the distribution system. It is recommended to maintain the chlorine residual above 0.1 ppm in the distribution system.
[R309-520-5]
The chlorine residual measured in the distribution system shall not exceed the maximum residual disinfectant level (MRDL) of 4.0 mg/L (measured as free chlorine). [R309-200-5(3)(c)(iv)]
This water system must take a minimum of three (3) chlorine residual samples per weekat varying locations throughout its distribution system (DS001). [R309-105-10(1)(c)]
Distribution system chlorine residuals must be taken in conjunction with total coliform sampling. [R309-215-10(3)]
Disinfection Report Submission
To demonstrate ongoing compliance with secondary disinfection requirements, the water system must complete monthly operational reports for each active chlorinator using a template approved
by the Division. 
The monthly operational reports are submitted quarterly. The reports are due to the Division by the 10th day following the end of each reporting quarter (i.e., January 10th, April 10th,
July 10th and October 10th). The reports can be submitted by hardcopy, fax, or by uploading them to the Division’s chlorine residual reporting form which can be found at MRDL.utah.gov.
Please contact Luke Treutel at [phone] or [e-mail] to schedule training regarding proper reporting.
In addition to monthly disinfection reporting, this water system must submit the monthly average of chlorine residual samples taken in the distribution system. Distribution system chlorine
residual monitoring results are due quarterly by the same compliance dates as the monthly disinfection report and can be submitted via an online form found at mrdl.utah.gov. 
Records must be maintained for a minimum of 5 years. [R309-105-17(1)]
Source Bacteriological Monitoring 
This water system is required to take monthly bacteriological samples of the Knotty Pine Well (WS001) prior to any treatment, for the months the well is in operation. The source sampling
requirement shall begin in April 2025 and last at least 12 months.
The purpose of the source sampling requirement is to gather data to evaluate the quality of the source water from Knotty Pine Well (WS001) and determine whether primary disinfection
treatment is required or not.
Label the source samples with WS001 as the sampling location.
The required source bacteriological sampling is shown on your monitoring schedule for this sample site. Please note that the source sampling is in addition to the distribution system
bacteriological sampling already in place, which is labeled DS001.
After 12 months of source sampling data becomes available, the Division will evaluate the results to determine whether primary disinfection is required for Knotty Pine Well (WS001).