DDW-2025-002948

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

Department of Environmental Quality
Tim Davis Executive Director DIVISION OF DRINKING WATER Nathan Lunstad, PhD, P.E. Director
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
March 6, 2025

James William Papola NPS – Zion National Park Zion National Park St Rt 9
Springdale, UT 84767
Subject: NOTICE OF VIOLATION – Zion Canyon Water System (#27051) Failure to Report Chlorine Residual Entering the Distribution System at Birch Creek-Watercress Treatment Plant (TP001)

Dear James William Papola: The Division of Drinking Water records indicate that Zion Canyon Water System (#27051) is in violation of the State of Utah Public Drinking Water Rule 309-215-10 as follows:

Zion Canyon Water System (#27051) is required to monitor chlorine residual daily at the Birch Creek-Watercress Treatment Plant’s point of entry. Zion Canyon Water System Birch Creek-Watercress Treatment Plant December 2024 Water Treatment Operation Report was missing records of point of entry chlorine residuals December 20, 21, 22, 25, 28, and 31 of
2024. Additionally, Zion Canyon Water System Birch Creek-Watercress Treatment Plant January 2025 Water Treatment Operations Report was missing records of point of entry chlorine residuals January 1, 4, 5, 11, and 12 of 2025. Failure to provide adequate records of point of entry chlorine has resulted in the addition of 100
Improvement Priority System (IPS) points to your IPS report (R309-400-5) as summarized below.

• Violation type 10 (50 points) – System fails to meet reporting and recordkeeping requirements [R309-215-9] (December 2024)
• Violation type 10 (50 points) – System fails to meet reporting and recordkeeping requirements [R309-215-9] (January 2025) Return to compliance and removal of IPS points will be achieved by demonstrating six months of compliance through monthly Water Treatment Reports.

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This marks a total of three months in the past year where required point of entry chlorine monitoring has failed. Per R309-215-10(1), Treatment plant management shall continuously
monitor disinfectant residuals and report the following to the Division… (1) For each day, the
lowest measurement of residual disinfection concentration in mg/L in water entering the
distribution system, except that if there is a failure in the continuous monitoring equipment, grab sampling every 4 hours may be conducted in lieu of continuous monitoring, but for no more than 5 working days following the failure of the equipment.

Given the ongoing nature of the continuous monitoring failures, a deficiency has been assessed as follows:
• Deficiency type A075 (50 points) – Administrative Issues: Nonfunctional chlorine
analyzer as required by R309-215-10 To resolve this deficiency, the chlorine analyzer must be functioning continuously, and an SOP must be developed and followed that will ensure a minimum of daily chlorine residual grab
samples at the POE in case of continuous chlorine analyzer failure. The SOP must be reviewed
and approved by the Division. Because these are Tier 3 violations, you must notify all consumers of the violation within one year of the violation according to R309-220-7. This public notice requirement cannot be waived
once a violation has occurred. Public notification must be designed to reach all users. Water
systems are to use, at a minimum, one or more of the following forms of delivery: broadcast media (such as radio and television), posting notice in a conspicuous location throughout the areas served by water system, hand delivery, or another delivery method approved in writing by the director. The public notice must be approved by the Division before it is distributed. Please
refer to the enclosed example of a public notice for instructions and send a draft of the public notice to Sarah Page at [e-mail] for approval. Proof of public notification and a copy of the notification must be provided to the Division at [e-mail] and [e-mail] within 10 days of notifying the water system customers. Please refer to the enclosed example of a public notice.

Please contact Sarah Page at [phone] or [e-mail] if you have any questions or need assistance. Sincerely,
Mark Berger Monitoring and Standards Section Manager

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Enclosure: Public notice template cc: Jeremy Roberts, Southwest Utah Health Department, [e-mail] Bry Carter, National Park Service, [e-mail] Matthew MacKay, National Park Service, [e-mail] Paul Wright, Department of Environmental Quality, [e-mail]
Mark Berger, Division of Drinking Water, [e-mail] Colt Smith, Division of Drinking Water, [e-mail] Jennifer Yee, Division of Drinking Water, [e-mail] Luke Treutel, Division of Drinking Water, [e-mail] Sarah Page, Division of Drinking Water, [e-mail]