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HomeMy WebLinkAboutDDW-2025-002953 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) 536-4284 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor Deidre Henderson Lieutenant Governor Department of Environmental Quality Tim Davis Executive Director DIVISION OF DRINKING WATER Nathan Lunstad Ph.D., P.E. Director March 4, 2025 Upper Whittemore Canyon Water Company Attn: Shauna Woods 12 South 1550 West Lindon, Utah 84042 Subject: Stipulated Order to Disinfect Upper Whittemore Canyon Water Company UTAH25136 Dear Shauna Woods: We are writing to provide you with a draft of the Division’s proposed Stipulated Order to Disinfect (SOTD) that addresses the drinking water compliance issues currently affecting the Upper Whittemore Water Company (System). The SOTD includes milestones the Supplier responsible for the System must meet to comply with the applicable regulations. It also references stipulated penalties that will be assessed if the System does not meet the requirements and/or the deadlines. The SOTD is broken down into the following key sections: STATUTORY AND REGULATORY AUTHORITY: This section describes the basis for the authority of the Director of the Division of Drinking Water to issue the SOTD. FINDINGS: This section provides basic background information about the System, including its inventory and legal ownership. It also briefly explains the facts underlying the Director’s decision to require disinfection. ORDER: The Order Section states requirements for the System and incorporates the Stipulated Order to Disinfect Schedule as part of the Order. Page 2 of 13 GENERAL PROVISIONS: This section outlines conditions agreed to by the System and the Division of Drinking Water, including potential penalties and system ratings. COMPLIANCE NOTICE: This section states that compliance with this order is mandatory and falls under the authority of the Utah Safe Drinking Water Act. Please carefully review the enclosed SOTD, sign it, and return it to the Director within 30 days of receiving this letter. Once the document is fully executed, a copy will be returned for your records. Failure to return a signed copy within 30 days of this letter may result in a unilateral administrative order issued by the Director to ensure progress toward compliance. I encourage you to continue to work closely with our Division staff. Your primary contact is Sarah Page at sepage@utah.gov or (385) 272-5778. Sincerely, Nathan Lunstad Ph.D., P.E. Division of Drinking Water Page 3 of 13 Enclosure: Vulnerable Source Policy Upper Whittemore Water Company Master Report Primary Disinfection Requirements Secondary Disinfection Requirements cc: Tim Davis, Utah Department of Environmental Quality, tim.davis@utah.gov Daymon Swenson, Utah County Health Department, daymons@utahcounty.gov Justin Hambleton, Upper Whittemore Water Company, jhambleton1@live.com Bret Randall, Utah Attorney General’s Office. bfrandall@utahag.gov Brent Arns, Utah Division of Drinking Water, barns@utah.gov Chris Martin, P.E., Utah Division of Drinking Water, cmartin@utah.gov Heather Pattee, Utah Division of Drinking Water, hpattee@utah.gov Christopher Brown, Environmental Protection Agency-Region 8, brown.christopher.t@epa.gov EQDWMonitoring, EQDWCOA, EQDWVSA, and EQDWFS UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF DRINKING WATER In the Matter of: Upper Whittemore Water Company Public Water System Stipulated Order to Disinfect Docket No. UTAH25136-2024-01 This Stipulated Order to Disinfect (“SOTD”) has been issued by the Director of the Utah Division of Drinking Water (“Director”) under the Director’s legal authorities described below. This SOTD has been agreed to by Upper Whittemore Water Company, a Utah non-profit corporation, in its capacity as the “Supplier” who is legally responsible for the System. STATUTORY AND REGULATORY AUTHORITY 1. In 1974, Congress enacted the federal Safe Drinking Water Act, codified at 42 U.S.C. § 300f et seq ., as amended. 42 U.S.C. § 300g-2 allows states to achieve primary enforcement responsibility after the Environmental Protection Agency (“EPA”) has determined that the state has adopted and can implement a state program that is no less stringent than the federal public drinking water program (“Primacy”). 2. The Utah legislature has enacted the Utah Safe Drinking Water Act, codified at Utah Code § 19-4-101 (the “Act”), with the intent of achieving Primacy. 3. Utah Code § 19-4-104 authorizes the Utah Drinking Water Board (the “Board”), among other things, to make rules regulating public water systems in the state of Utah. Utah Code § 19-4-104(1)(c)(vi) charges the Board to “meet the requirements of federal law related or pertaining to drinking water.” The Board has promulgated the Utah Public Drinking Water Rules, codified at Utah Administrative Code (“UAC”) R309. 4. In 1980, the EPA Administrator determined, in accordance with 40 C.F.R. § 142.11, that the Utah public drinking water program met the federal requirements for Primacy. See 45 Fed. Reg. 6647 (January 29, 1980). In accordance with 40 C.F.R. § 142.17, the EPA Administrator has reviewed and continues to review annually, the Utah public drinking water program to evaluate its continuing compliance with the requirements set forth in 40 C.F.R. Part 142. 5. The Board has defined public water systems under the Utah Public Drinking Water Rules, UAC R309-110-4. 3 6. UAC R309-100-7 directs the Director to “assign a rating to each public water supply in order to provide a concise indication of its condition and performance” in accordance with R309-400. This rule is generally known as the Improvement Priority System (“IPS”) rating system. 7. The IPS rating system “is a point system used by the division to evaluate a public water system’s performance and compliance with the drinking water rules in Title 309, Environmental Quality, Drinking Water.” UAC R309-400-3(1). Under the IPS rating system, each public water system is assigned a rating “to characterize the water system’s compliance with drinking water rules and overall operation and performance.” UAC R309-400-3(2). The IPS rating system is used by the Division to assign compliance ratings to public water systems and to prioritize enforcement action based on points assessed for noncompliance with drinking water rules.” UAC R309-400-1(1). 8. UAC R309-400-4(1)(a)(ii) directs the Director to establish “the point thresholds for assigning an Approved or Not Approved rating for each type of water system.” The Director may issue a “Not Approved” rating for systems exceeding the point threshold. The thresholds are as follows: (i) for community water systems, 150 points; (ii) for non-transient, non-community water systems, 120 points; and (iii) for non-community water systems, 100 points. 9. UAC R309-400-4(4) allows the Director to assess points against public water systems upon their failure to comply with Division directives and orders. 10. UAC R309-400-5(1)(b)(ii) allows the Director to rate any public water system as “Not Approved” at any time if an immediate threat to public health exists. 11. UAC R309-400-5(1)(c) provides that a public water system may qualify for a “Corrective Action” rating for its public water system “based on a current, written agreement with the division to resolve underlying noncompliance according to a compliance schedule.” 12. Pursuant to Utah Code § 19-4-106(d), the Director may enforce rules promulgated by the Board by issuing orders. See also UAC R309-100-8. 13. Utah Code § 19-4-107 provides that upon discovery of any violation of the Act or a rule of the Board, the Director shall promptly notify the supplier of the violation, state the nature of the violation and issue an order requiring correction of that violation. 14. Utah Code § 19-4-109 provides that any person who violates the Act or a rule or order made or issued pursuant to the Act may be subject to an administrative penalty of up to $1,000 per day of violation or a civil penalty of up to $5,000 per day of violation. FINDINGS The Director makes the following Findings for purposes of this SOTD: 4 15. There exists approximately five miles east of Mapleton in Utah County, Utah, a drinking water system known as the Upper Whittemore Water Company (the “System”) that serves a population of approximately 128 persons. The System generally includes two active springs (Crandall Canyon Spring-WS001 and Bathtub Spring-WS003), one spring inactivated due to quantity/quality issues (Fern Basin Spring-WS002), two active concrete storage tanks totaling 50,000 gallons of storage, two proposed chlorinators, and independent distribution system serving approximately 21 residential connections. 16. The Supplier (defined above) is the owner and/or operator of the System and is therefore legally responsible for the System and for compliance with applicable laws, rules, and regulations. 17. The System is a public drinking water system within the meaning of the Utah Safe Drinking Water Act and the Utah Public Drinking Water Rules. 18. The System qualifies as a transient non-community under the Utah Public Drinking Water Rules. The maximum number of IPS points allowed for this type of system is 100. 19. The Master IPS Report attached hereto as Exhibit A describes several violations and deficiencies associated with the System, which form the basis of this SOTD (the “Violations and Deficiencies”). Supplier agrees and stipulates that the information contained in the attached IPS Report is true and correct as of the date shown on the Master IPS Report. 20. Monthly Assessment source sampling began in July 2019 for Crandall Canyon Spring (WS001) and Bathtub Spring (WS003). A total of thirty-three samples were taken at Crandall Canyon Spring. Nine of those samples were total coliform positive, E. coli absent. The other twenty-four samples were total coliform absent. A total of thirty-eight samples were taken at Bathtub Spring (WS003). Three of those samples were total coliform positive and E. coli positive. Four of those samples were total coliform positive, E. coli absent. The other thirty-one samples were total coliform absent. Monthly Assessment source sampling began in June 2020 for Fern Basin (WS002). A total of twelve samples were taken at Fern Basin. Of those twelve samples were taken three were total coliform positive, E. coli absent. The other nine samples were total coliform absent. 21. On October 4th, 2024 Utah Division of Drinking Water Scientist Brian Pattee conducted a Level Two Assessment of the Upper Whittemore Water Company. (a) This assessment concluded that EC+ samples at Bathtub Springs (WS003) could have been sampler error as the fence surrounding the collection area and downgradient of the two spring boxes had been compromised. Additionally, Pattee found evidence of cattle grazing within the fenced area. The sampler would have walked through this area to the spring box to collect samples, then opened the spring box and using a dip method to collect the sample, these sample methods combined with the surrounding cattle fecal matter, could have potentially contaminated samples resulting in positive coliform samples. 5 (b) Crandall Canyon Spring’s (WS001) fencing was intact, and there was no evidence of cattle grazing. However, the same challenges exist in collecting samples. (c) No new deficiencies were identified during this assessment. 22. The sample results detailed in item #20, above indicate the Crandall Canyon Spring (WS001), the Fern Basin Spring (WS002), and Bathtub Spring (WS003) are low-quality groundwater sources that do not consistently meet standards of bacteriologic quality. Based on your sample history, Upper Whittemore Water Company is subject to requirements to provide continuous secondary disinfection of the Crandall Canyon Spring (WS001), the Fern Basin Spring (WS002), and the Bathtub Spring (WS003) when those sources are active and may be subject to additional treatment if further water quality sampling results indicate that the source requires primary disinfection. Upper Whittemore Water Company is also subject to requirements to provide continuous secondary disinfection throughout the entire distribution system. ORDER Based on the foregoing Findings, the agreement of the Supplier, and good cause appearing, IT IS HEREBY ORDERED as follows: 23. Attached hereto as the Enforcement Order Schedule – UTAH25136 (“Stipulated Order to Disinfect Schedule”) listing the violations and deficiencies associated with the System as well as a description of specific corrective actions and other measures that are required for the System to comply with the Safe Drinking Water Act and the Board’s rules, including the dates by which such corrective actions and other measures shall be completed. The Supplier is hereby ordered to complete all corrective actions and other measures described in the Stipulated Order to Disinfect Schedule, to the satisfaction of the Director, on or before the due dates identified in the Stipulated Order to Disinfect Schedule. 24. The Supplier agrees to collect all samples required by the Safe Drinking Water Act and the Board’s rules and to report the sample results to the Director within the timeframe mandated by rule. 25. Within 60 days after the issuance of this Order, the Supplier shall provide the Division of Drinking Water with a schedule for the System to address the requirements for secondary disinfection at Crandall Canyon Spring (WS001), Bathtub Spring (WS003), and the Fern Basin Spring (WS002), as well as throughout the entire distribution system. The plan shall include proposed modifications to the System, estimated costs of modifications, a proposed plan, and schedule for project completion. The plan shall include specific milestone dates and a final compliance dat e (to be within six months from the date of DDW approval of the plan). The Director must approve the schedule before construction or modifications can begin. 26. The Supplier agrees to send all reporting and notifications required by this Order in writing to: 6 Utah Division of Drinking Water P.O. Box 144830 Salt Lake City, Utah 84114-4830 Email: eqdwvsa@utah.gov 27. Crandall Canyon Spring (WS001), the Fern Basin Spring (WS002), and Bathtub Spring (WS003) are hereby rated “Unapproved” as outlined in R309-515-6(5), R309-515-7(4), R309-500-9(2) and (3). This is a Significant Deficiency (S100), and 300 Improvement Priority System points were assessed. 28. The Supplier agrees to install and operate Division-approved permanent disinfection for the entire distribution system (DS001). The Supplier agrees to complete Division Plan Approval before construction of any disinfection facilities. 29. The Supplier agrees to design all disinfection treatment facilities with the ability to meet primary disinfection standards . Secondary Disinfection Requirements 30. To meet secondary disinfection requirements, the Supplier agrees to continuously maintain a minimum of 0.2 mg/L free chlorine residual at the Points of Entry (POEs) into the distribution system and demonstrate a detectable chlorine residual in the entire distribution system. 31. Chlorine Residual ‒ Points of Entry (POEs) to Distribution System (EP001, EP002 & EP003) a. The POE sampling locations will be identified as EP001, EP002 and EP003 in the Division’s database. o EP001 is the POE monitoring location for the Crandall Canyon Spring Chlorinator (TP001) and is the sample tap in the chlorine building. o EP002 is the POE monitoring location for the Fern Basin Spring Chlorinator (TP002) and will be identified during the design process. o EP003 is the POE monitoring location for the Bathtub Spring Chlorinator (TP003) and is the discharge piping of the treatment facility. b. Maintain a minimum of 0.2 mg/L residual (measured as free chlorine) at the POE sampling locations [UAC R309-215-16(3)(b)(iii)(A)(I) and (II)]. c. The chlorine residual concentration measured at the POE sampling locations shall not exceed the Maximum Residual Disinfectant Level (MRDL) of 4.0 mg/L (measured as free chlorine). [R309-200-5(3)(c)(iv)] d. Record and report the lowest daily chlorine residual concentration, measured as free chlorine, at the chlorinator POE sampling locations (EP001 & EP003) a minimum of daily. [R309-210- 8(3)(a)(ii)] 32. Chlorine Residual ‒ Distribution System (DS001) 7 a. This water system must maintain a detectable residual throughout the entire distribution system . Maintaining the chlorine residual above 0.1 ppm in the distribution system is recommended. [R309-520-5] b. 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)] c. Take a minimum of three (3) chlorine residual samples per week at varying locations throughout its distribution system UAC R309-105-10(1)(c). d. Distribution system chlorine residuals must be taken in conjunction with total coliform sampling. [R309-215-10(3)] 33. The Supplier must notify the Division by telephone at (801) 560-8456 within eight hours of the malfunction of any disinfection facility such that a detectable residual cannot be maintained at all points in the distribution system per R309-105-18(1)(a). GENERAL PROVISIONS 34. Based on this, the Director hereby determines that the System maintains its rating as “Approved” status. The “Approved” rating is conditioned upon the Supplier’s adherence to the requirements of this SOTD, the Act, and the Public Drinking Water Rules. The Director may re-rate the System as “Not Approved” at any time based on any violation of this SOTD, the Act, or the Public Drinking Water Rules. 35. Upon satisfactory compliance with the Stipulated Order to Disinfect Schedule requirements, the Director shall issue a subsequent administrative order closing out this SOTD as defined in UAC R309-400. Pursuant to such subsequent order, the Director may also take other appropriate actions or impose appropriate conditions based on the facts presented. 36. The Supplier hereby stipulates and agrees to pay, within 30 days of demand by the Director, administrative penalties in the following amounts arising from any and all violations of this SOTD, on a per-day, per-violation basis: Penalty Per Violation Per Day Period of Noncompliance $ 250 1st through 14th day $ 500 15th through 30th day $1,000 31st day and beyond 37. In the event of any violation of this SOTD with criminal negligence, within the meaning of Utah Code § 19-4-109(7)(b), the Director reserves the right, in the Director’s sole discretion, to seek the imposition of fines and civil penalties under that section in addition to stipulated administrative penalties under this SOTD. 8 38. Nothing in this SOTD shall be construed as prohibiting, altering, or in any way limiting the ability of the Director to seek injunctive relief pursuant to Utah Code § 19-4-107(2) arising from violations of this SOTD, the Act, or the Utah Public Drinking Water Rules. 39. This SOTD does not in any way relieve the Supplier from any other obligation imposed under the Act or any other state, federal, or local law, rule, or regulation. The Director reserves that this SOTD is without prejudice to all rights against the Supplier that the Director may have pertaining to matters not addressed in this SOTD, including (a) violations of this SOTD; (b) future violations of the Act or the Utah Public Drinking Water Rules; and (c) criminal liability. 40. The Director has the jurisdiction and authority to make the findings set forth in this SOTD and to otherwise enforce the terms of this SOTD. 41. The date of issuance shall be the date that this SOTD is executed by the Director. 42. As of the date of issuance, this SOTD shall constitute a final administrative order under the Act and shall operate as a final adjudication upon the merits of the matters addressed herein. In the Director’s sole discretion, violations of this SOTD may result in the commencement of an action for civil enforcement in state district court, by the attorney general, as provided in Utah Code Section 19-4-107. Such actions may seek injunctive or other relief, including the imposition and collection of civil penalties as allowed by law. The Supplier agrees that in any enforcement action, it shall not contest the finality or validity of this SOTD or the Director’s authority to enter it as a final administrative order under the Act. 43. The dates set forth in the Stipulated Order to Disinfect Schedule may be extended in writing by the Director, in the Director’s sole discretion, based on the Supplier’s showing of good cause. Good cause for an extension generally means events outside of the reasonable control of the Supplier, such as force majeure, inclement weather, contractor or supplier delays, and similar circumstances. However, the Director expects the Supplier to employ reasonable means to limit foreseeable causes of delay. The timeliness of the Supplier’s request for an extension shall constitute an important factor in the Director’s evaluation. 44. In partial or full satisfaction of the Stipulated Order to Disinfect Schedule, the Supplier may (a) obtain a variance or exception as allowed by the Act and the Public Drinking Water Rules; or (b) propose to the Director an alternate method for compliance with the Act and the Public Drinking Water Rules. No such alternate means of compliance with the Enforcement Order Schedule shall be accepted unless approved by the Director in writing. 45. The person signing this SOTD on behalf of the Supplier hereby represents to the Director that he or she has the full legal authorization to do so and agrees that the Director may rely on this representation. COMPLIANCE NOTICE 9 Compliance with the provisions of this SOTD is mandatory. All violations of the Utah Safe Drinking Water Act, the Drinking Water Rules, and this SOTD shall be strictly enforced during the time that this SOTD remains in effect. IT IS SO ORDERED AND AGREED. DIVISION OF DRINKING WATER By:_______________________________________ Nathan Lunstad Ph.D., P.E. Director DATE:_____________________________________ UPPER WHITTEMORE WATER COMPANY By:________________________________________ Name:_____________________________________ Title:______________________________________ DATE: ____________________________________ 10 Justin Hambleton (Mar 11, 2025 10:58 MDT) Justin Hambleton Justin Hambleton Water Board President 03/11/2025 at#an unsta (Mar 11, 2025 15:2т MDT) 03/11/2025 Stipulated Order to Disinfect Schedule UTAH25136 System Name: Upper Whittemore Water Company System Number: UTAH25136 Administrative Contact: Justin Hambleton Email: jhambleton1@live.com Phone Number: 801-916-1516 Corrective Action Requirements and Due Dates Date of Issuance:________________________ Crandall Canyon Spring, WS001 Item #1 Code Facility Violation Rule Citation S001 WS001 Source required to have secondary disinfection installed R309-500-9 Corrective Action Completion Due Date Submit a specific plan to install secondary disinfection as outlined in paragraph 25 of this order. Within sixty days of the date of issuance of this order. Fern Basin Spring, WS002 Item #2 Code Facility Violation Rule Citation S001 WS002 Source required to have secondary disinfection installed R309-500-9 Corrective Action Completion Due Date Submit a specific plan to install secondary disinfection as outlined in paragraph 25 of this order. Within sixty days of the date of issuance of this order. IT IS SO ORDERED AND AGREED. DIVISION OF DRINKING WATER By:_______________________________________ Nathan Lunstad Ph.D., P.E. Director 11 Nathan Lunstad (Mar 11, 2025 15:23 MDT) 03/11/2025 DATE:_____________________________________ UPPER WHITTEMORE WATER COMPANY By:________________________________________ Name:_____________________________________ Title:______________________________________ DATE: ____________________________________ 12 Justin Hambleton (Mar 11, 2025 10:58 MDT) Justin Hambleton Justin Hambleton Water Board President 03/11/2025 03/11/2025 Utah Department Of Environmental Quality Division Of Drinking Water Admin Contacts Inventory Report Service Connections Treatment Plants Storage Sources UPPER WHITTEMORE WATER CO PWS ID: UTAH25136 Rating: Approved 03/31/2016 Active Legal Contact UPPER WHITTEMORE WATER CO JUSTIN HAMBLETON 13083 S 2730 W RIVERTON, UT 84065 Phone: 801-916-1516 County: UTAH COUNTY System Type: Transient Non-Community Population: 128 Site Updates Last Inventory Update: 03/15/2024 Last Surveyor Update: 08/25/2023 Surveyor: GARY C RAGER Operating Period: 6/1 - 10/31 Last IPS Update: 03/07/2025 07:10:00 Consumptive Use Zone Irrigation Zone: null Date: Name Title Office Emergency Email HAMBLETON, JUSTIN 801-916-1516 jhambleton1@live.com Type Meter Type Meter Size # Of Connections Residential Unknown 0.000 21 Total Service Connections: 21 ID Plant Name Bin Status Date Design Cap Status TP001 CRANDALL CANYON SPRING CHLORINATOR Proposed Treatment Purposes GASEOUS CHLORINATION, POST TP003 BATHTUB SPRING CHLORINATOR 0 Proposed Treatment Purposes GASEOUS CHLORINATION, POST ID Name Type Effective Volume Material Status Status Reason ST001 CRANDALL TANK Ground 25,000 GAL Concrete Active ST002 FERN BASIN TANK Ground 25,000 GAL Concrete Active Total Effective Volume: 50,000 GAL DEQ | Drinking Water Run Date: 03/07/2025 08:36:54 | Rating: Approved UTAH25136 UPPER WHITTEMORE WATER CO page 1 of 7 Site Visit History ID Source Name OP Date Status Reason Source Type Water Type Period Of Op WS001 CRANDALL CANYON SPRING 09/20/2017 Active Op Issued - Check Spring Groundwater 4/1 - 9/30 Flow Flow Rate UOM SYLD 43 GPM WS002 FERN BASIN SPRING Inactive Quality/Quantity Problem Spring Groundwater 4/1 - 9/30 Flow Flow Rate UOM CYLD 15 GPM WS003 BATHTUB SPRING Active Spring Groundwater 4/1 - 9/30 Flow Flow Rate UOM CYLD 33 GPM Date Visited Survey Type Surveyor Notified Date Next Inspection 06/20/2003 Sanitary Survey, Finished SURVEYOR, DDW 09/10/2007 Sanitary Survey, Finished MORTENSEN, MICHAEL 09/21/2007 09/30/2015 09/09/2010 Sanitary Survey, Finished HOLDAWAY, BRAD K 10/08/2010 09/30/2015 08/14/2014 Sanitary Survey, Finished HANSEN, MARK E 08/14/2014 10/29/2014 Engineering Determination/Advice/Plan Review NORTH, TAMMY 05/03/2017 Wellhead Protection Program JOHNSON, KATE 05/03/2017 09/07/2017 Sanitary Survey, Finished KOBZEFF, GARY MICAH 10/26/2017 06/25/2018 Level 1 Assessment 06/25/2018 06/15/2020 Sanitary Survey, Finished HANSEN, DAVID F 06/17/2020 04/19/2021 Engineering Determination/Advice/Plan Review 04/19/2021 05/05/2022 Compliance Assessment 05/05/2022 08/01/2023 Engineering Determination/Advice/Plan Review 08/01/2023 08/25/2023 Sanitary Survey, Finished RAGER, GARY C 09/12/2023 01/16/2025 Wellhead Protection Program BECK, DEIDRE 01/16/2025 DEQ | Drinking Water Run Date: 03/07/2025 08:36:54 | Rating: Approved UTAH25136 UPPER WHITTEMORE WATER CO page 2 of 7 Bacterial Summary Report Routine Bacteriological Sampling Requirements Total Coliform Sample History 02/01/2024 - 03/31/2025 Sample Reuired Schedule Begin Schedule End Operation Begin Operation End 1/Monthly/Routine 07/01/2018 6/1 10/31 Routine Sampling Repeat Sampling Triggered Sampling Assessment Sampling Month #Sample s TC+Ecoli+#Sample s TC+Ecoli + #Sample s TC+Ecoli + #Sample s TC+Ecoli + Feb-24 0 0 0 0 0 0 0 0 0 0 0 0 Mar-24 0 0 0 0 0 0 0 0 0 0 0 0 Apr-24 0 0 0 0 0 0 0 0 0 0 0 0 May-24 0 0 0 0 0 0 0 0 0 0 0 0 Jun-24 0 0 0 0 0 0 0 0 0 0 0 0 Jul-24 1 1 0 0 0 0 0 0 0 2 2 1 Aug-24 0 0 0 4 2 0 7 4 2 0 0 0 Sep-24 1 1 0 0 0 0 1 1 0 1 1 0 Oct-24 1 0 0 0 0 0 0 0 0 2 0 0 Nov-24 0 0 0 0 0 0 0 0 0 0 0 0 Dec-24 0 0 0 0 0 0 0 0 0 0 0 0 Jan-25 0 0 0 0 0 0 0 0 0 0 0 0 Feb-25 0 0 0 0 0 0 0 0 0 0 0 0 Mar-25 0 0 0 0 0 0 0 0 0 0 0 0 DEQ | Drinking Water Run Date: 03/07/2025 08:36:54 | Rating: Approved UTAH25136 UPPER WHITTEMORE WATER CO page 3 of 7 Water Monitoring Report BACTERIOLOGICAL MONITORING MONITORING REQUIREMENTS BY FACILITY Sample Count Type Frequency Schedule Begin Schedule End Analyte Name 1 Routine Monthly 07/01/2018 COLIFORM (TCR) ID NAME WS001 CRANDALL CANYON SPRING Name Sample Count Type Frequency Last Sampled Next Sample Due NITRATE 1 Routine Yearly 09/07/2023 01/01/2024 - 12/31/2024 SULFATE 1 Routine 3 Years 05/08/2020 01/01/2023 - 12/31/2025 WS003 BATHTUB SPRING Name Sample Count Type Frequency Last Sampled Next Sample Due NITRATE 1 Routine Yearly 09/07/2023 01/01/2024 - 12/31/2024 SULFATE 1 Routine 3 Years 05/08/2020 01/01/2023 - 12/31/2025 Open Compliance Schedule Type Required Activities Severity Created Due TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 04/19/2021 06/13/2025 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 04/19/2021 04/16/2024 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 04/19/2021 06/13/2025 Revised Total Coliform Rule INSTALL TREATMENT 06/10/2019 08/31/2019 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 08/01/2023 07/31/2026 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 08/01/2023 07/31/2026 REQUIRED TO DISINFECT CORRECTIVE ACTION PLAN GWR CORRECT DEFICIENCY IMMEDIATE SIG 05/05/2022 11/01/2024 REQUIRED TO DISINFECT CORRECTIVE ACTION PLAN GWR CORRECT DEFICIENCY IMMEDIATE SIG 05/05/2022 11/01/2024 Revised Total Coliform Rule SEASONAL STARTUP PROCEDURES 01/01/2025 05/01/2025 SOURCE PROTECTION SOURCE PROTECTION PLAN- SUBMIT MIN 01/16/2025 04/16/2025 DEQ | Drinking Water Run Date: 03/07/2025 08:36:54 | Rating: Approved UTAH25136 UPPER WHITTEMORE WATER CO page 4 of 7 IPS 2020 Report IPS Report IPS Summary Total IPS Pts: 325 Admin & Physical Facilities Quality & Monitoring Significant Deficiency 200 125.0 0 DEQ | Drinking Water Run Date: 03/07/2025 08:36:54 | Rating: Approved UTAH25136 UPPER WHITTEMORE WATER CO page 5 of 7 Physical Facility Points 2020 Total Pts: 200 Facility Facility Name Status Points Effective TP001 CRANDALL CANYON SPRING CHLORINATOR P 0.0 Code Description Severity Comments Determined Date Not Assessed Assessed TD08 CHLORINATOR BUILDING NOT HEADED, LIGHTED OR VENTILATED MIN TEMPORARY EXCEPTION GRANTED 6/17/2022. SYSTEM MUST CORRECT DEFICIENCY OR RENEW EXCEPTION BY 6/13/2025. FILE #11378 04/19/2021 15 0 TD01 CONTINUOUS DISINFECTION IS REQUIRED BUT CHLORINATOR LACKS AUTOMATIC SWITCHOVER MIN TEMPORARY EXCEPTION GRANTED 4/19/2021. SYSTEM MUST CORRECT DEFICIENCY OR RENEW EXCEPTION BY 4/16/2024. FILE #11378 04/19/2021 TD12 LACK SEPARATE SWITCHES FOR FAN AND LIGHTS NEAR CHLORINE ROOM ENTRANCE MIN TEMPORARY EXCEPTION GRANTED 6/17/2022. SYSTEM MUST CORRECT DEFICIENCY OR RENEW EXCEPTION BY 6/13/2025. FILE #11378 04/19/2021 15 0 TP003 BATHTUB SPRING CHLORINATOR P 0.0 Code Description Severity Comments Determined Date Not Assessed Assessed TD08 CHLORINATOR BUILDING NOT HEADED, LIGHTED OR VENTILATED MIN TEMPORARY EXCEPTION GRANTED 8/1/2023. SYSTEM MUST CORRECT DEFICIENCY OR RENEW EXCEPTION BY 7/31/2026. FILE #13430 08/01/2023 15 0 TD12 LACK SEPARATE SWITCHES FOR FAN AND LIGHTS NEAR CHLORINE ROOM ENTRANCE MIN TEMPORARY EXCEPTION GRANTED 8/1/2023. SYSTEM MUST CORRECT DEFICIENCY OR RENEW EXCEPTION BY 7/31/2026. FILE #13430 08/01/2023 15 0 WS001 CRANDALL CANYON SPRING A 200.0 Code Description Severity Comments Determined Date Not Assessed Assessed S001 UNAPPROVED SOURCE IN SERVICE SIG SOURCE IS REQUIRED TO HAVE SECONDARY DISINFECTION INSTALLED. 05/05/2022 200 WS002 FERN BASIN SPRING I 0.0 Code Description Severity Comments Determined Date Not Assessed Assessed S001 UNAPPROVED SOURCE IN SERVICE SIG SOURCE IS REQUIRED TO HAVE SECONDARY DISINFECTION INSTALLED. 05/05/2022 200 WS003 BATHTUB SPRING A 0.0 Code Description Severity Comments Determined Date Not Assessed Assessed SP04 ACTIVE SOURCE LACKS APPROVED UPDATES TO DWSP PLAN MIN 01/16/2025 5 0 DEQ | Drinking Water Run Date: 03/07/2025 08:36:54 | Rating: Approved UTAH25136 UPPER WHITTEMORE WATER CO page 6 of 7 Chemical Monitoring Rule Violations Total Pts: 100 Facility Violation No.Period Violation Type Seasonality Point Effective WS001 2025- 4073435 01/01/2024-12/31/2024 Determined: 01/23/2025 [03] MONITORING, ROUTINE MAJOR Analyte/Group: NITRATE S 50.0 WS003 2025- 4073434 01/01/2024-12/31/2024 Determined: 01/23/2025 [03] MONITORING, ROUTINE MAJOR Analyte/Group: NITRATE S 50.0 Microbial Rule Violations Total Pts: 25 Determined Compliance Period Code Violation Type Return To Compliance Point Effective 10/02/2024 08/01/2024 - 08/31/2024 3A MONITORING, ROUTINE, MAJOR (RTCR) N 25.0 Operator Certification Type Level Required Highest Certificate Distribution Treatment Open Compliance Schedule Type Required Activities Severity Created Due TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 04/19/2021 06/13/2025 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 04/19/2021 04/16/2024 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 04/19/2021 06/13/2025 Revised Total Coliform Rule INSTALL TREATMENT 06/10/2019 08/31/2019 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 08/01/2023 07/31/2026 TEMPORARY EXCEPTION TREATMENT FACILITY DEFICIENCY- CORRECT MIN 08/01/2023 07/31/2026 REQUIRED TO DISINFECT CORRECTIVE ACTION PLAN GWR CORRECT DEFICIENCY IMMEDIATE SIG 05/05/2022 11/01/2024 REQUIRED TO DISINFECT CORRECTIVE ACTION PLAN GWR CORRECT DEFICIENCY IMMEDIATE SIG 05/05/2022 11/01/2024 Revised Total Coliform Rule SEASONAL STARTUP PROCEDURES 01/01/2025 05/01/2025 SOURCE PROTECTION SOURCE PROTECTION PLAN- SUBMIT MIN 01/16/2025 04/16/2025 DEQ | Drinking Water Run Date: 03/07/2025 08:36:54 | Rating: Approved UTAH25136 UPPER WHITTEMORE WATER CO page 7 of 7