HomeMy WebLinkAboutDDW-2025-003952
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
April 17, 2025
Castle Valley, Inc.
dba Daystar Adventist Academy at Castle Valley Farms
℅ Randy Ward
HC 64 Box 2201
Moab, Utah 84532
Subject: Compliance Agreement / Enforcement Order-Stipulated Order to Disinfect Day
Star Adventist Academy UTAH10012
Dear Randy Ward:
We are writing to provide you with a copy of the Compliance Agreement/Enforcement Order
(CA/EO) that addresses the drinking water compliance issues currently affecting the Day Star
Adventist Academy (System).
In addition to the compliance milestones and stipulated penalties outlined in the CA/EO, this order
requires you to install secondary disinfection. This disinfection requirement may be temporary if
the existing water source can be remediated to the Director’s satisfaction. The need for secondary
disinfection is due to ongoing detections of total coliform bacteria, which indicate possible
contamination pathways and the condition of your system’s sole source Artesian Well (WS001),
outlined in the findings section of this order. While total coliform bacteria are not always harmful,
their presence suggests potential contamination from more dangerous pathogens that pose a risk to
public health.
Furthermore, this order formalizes the ongoing boil order issued on October 27, 2022. The System
is required to maintain the boil order until the director provides written notification confirming that
it may be lifted. As part of this requirement, you must provide public notice to your customers and
update the Division of Drinking Water in accordance with Utah Administrative Code R309-220
(Public Notice Rule) and R309-105-18. All public notices must follow the attached public notice
template format.
Please carefully review the enclosed CA/EO, 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.
Day Star Adventist Academy
Page 2 of 16
April 17, 2025
Failure to return a signed copy within 30 days may result in an 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 Colt
Smith at acsmith@utah.gov or (385) 515-1529.
Sincerely,
Nathan Lunstad, Ph.D., P.E.
Director
Division of Drinking Water
Enclosures: Day Star Adventist Academy Master IPS Report
Day Star Adventist Boil Order Template
October 15, 2024, RTCR Level 2 Assessment-Day Star Adventist Academy
Secondary Disinfection Requirements
Stipulated Order to Disinfect (SOTD) Response Plan
Day Star Adventist Enforcement Order Schedule
cc: Tim Davis, Utah Department of Environmental Quality, tim.davis@utah.gov
Curtis Page, P.E., Utah Department of Environmental Quality, cmpage@utah.gov
Ty Leydig, Rural Community Assistance Corporation, tleydig@rcac.org
Matthew Kennedy, Rural Community Assistance Corporation, mkennedy@rcac.org
Castle Valley Inc., Registered Agent, HC 64 Box 2201, Castle Valley, Utah, 84532
Orion Rogers, Southeast Utah Health Department, orogers@utah.gov
Bret F. Randall, Assistant Attorney General, bfrandall@agutah.gov
Christopher Brown, EPA Region 8, brown.christopher.t@epa.gov
EQDWMonitoring, EQDWVSA, EQDWCOA, and EQDWFS
Day Star Adventist Academy
Page 3 of 16
April 17, 2025
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF DRINKING WATER
In the Matter of:
Day Star Adventist Academy Public Water
System
COMPLIANCE AGREEMENT /
ENFORCEMENT ORDER
Docket No. UTAH10012-2025-01
This COMPLIANCE AGREEMENT / ENFORCEMENT ORDER (“CA/EO”) has been issued
by the Director of the Utah Division of Drinking Water (“Director”), under the Director’s legal
authorities described below. This CA/EO has been agreed to by Castle Valley, Inc., dba Daystar
Adventist Academy at Castle Valley Farms, 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.
Day Star Adventist Academy
Page 4 of 16
April 17, 2025
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.” For systems
exceeding the point threshold, the Director may issue a “Not Approved” rating. 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 through the issuance of 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 CA/EO:
Day Star Adventist Academy
Page 5 of 16
April 17, 2025
15. There exists at 320 East Castleton Road, Castle Valley in Grand County Utah a drinking
water system, known as the Day Star Adventist Academy (the “System”) that serves a
population of approximately 35 persons. The System generally includes a single
groundwater well, hydropneumatic tanks, and an independent distribution system serving
approximately fifteen 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 community under the Utah Public Drinking Water Rules. The
maximum number of IPS points allowed for this type of system is 150.
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 CA/EO (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. On October 21, 2022, the Supplier was notified that a routine water sample collected on
October 20, 2022, tested positive for total coliform and negative for E. coli. In response,
repeat samples were taken on October 25, 2022, and results received on October 26, 2022,
confirmed that one of the three repeat samples was total coliform positive and E. coli
negative, while the other two samples tested positive for E. coli. The triggered source sample
was total coliform negative. Following these results, the system operator planned to take an
additional sample at the storage tank before initiating chlorination and flushing of the system
over the weekend and potentially into the following week.
a) Due to the confirmed presence of E. coli in the distribution system, the system was
placed under an ongoing boil order beginning October 27, 2022.
21. A Level 2 assessment conducted by Utah Division of Drinking Water Environmental
Scientist Brian Pattee on October 15, 2024, was initiated due to multiple Level 1 and Level
2 assessments starting in 2021 through 2024. The assessments were prompted by a series of
compliance issues, including repeated Total Coliform-positive (TC+) and E. coli-negative
(EC-) routine, repeat, and triggered samples, as well as the failure to collect required routine,
repeat, and triggered source samples. During the site visit, the following observations were
made:
a) Artesian Well (WS001): Based on Pattee’s training and experience, and in
consultation with the Department of Environmental Quality District Engineer Curtis
Page, Division of Drinking Water Assistant Director Russell Seeley, and Division of
Drinking Water Permitting Section Manager Michael Newberry, it was determined
the well’s sanitary seal is compromised. The concrete around the wellhead was
Day Star Adventist Academy
Page 6 of 16
April 17, 2025
missing, and water was observed flowing up from around the well casing when the
pump was not running. When the pump was activated, the water subsided back into
the area surrounding the wellhead, indicating potential vulnerabilities to the well’s
integrity.
b) Hydropneumatic Tank (HD001): The 2,500-gallon steel hydropneumatic tank had
not been cleaned or disinfected for an extended period, raising concerns about
potential contamination and system maintenance deficiencies.
c) Boil Order: The system was under a boil order due to the high number of Total
Coliform-positive (TC+) bacteriological samples, further highlighting the need for
corrective action.
22. The deficiencies observed in Artesian Well WS001 compromise public health by creating
pathways for contaminants to enter the drinking water supply. A compromised sanitary seal
and missing concrete around the wellhead can allow surface water, debris, and bacteria to
infiltrate the system, increasing the risk of contamination. The presence of water flowing
around the well casing when the pump is off, then subsiding when the pump runs, suggests
possible breaches in the well’s integrity, which can introduce harmful microorganisms into
the drinking water, posing a significant risk to consumers.
23. Total coliform bacteria naturally occur in soil, vegetation, and surface water. While not all
coliforms are harmful, their presence in drinking water indicates potential contamination
and an increased risk of pathogenic bacteria, such as E. coli. Consuming water contaminated
with this bacteria can cause gastrointestinal illnesses, including diarrhea, nausea, vomiting,
and stomach cramps. Infants, young children, the elderly, and individuals with weakened
immune systems are most at risk for severe health effects.
24. These findings emphasize the necessity of immediate corrective measures to address the
deficiencies identified during the assessment.
ORDER
Based on the foregoing Findings, the agreement of the Supplier, and good cause appearing, IT IS
HEREBY ORDERED as follows:
25. Attached hereto as the Enforcement Order Schedule – UTAH10012 (“Enforcement Order
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 Enforcement
Order Schedule, to the satisfaction of the Director, on or before the due dates identified in
the Enforcement Order Schedule.
Day Star Adventist Academy
Page 7 of 16
April 17, 2025
26. 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 flooding around Artesian Well
(WS001) and the significant deficiencies associated with the flooding listed in the attached
Enforcement Order Schedule and Master Improvement Priority System Report. The plan
shall include proposed modifications to the System, estimated costs of modifications, a
proposed plan, and a schedule for project completion. The plan shall also include specific
milestone dates and a final compliance date. The Director and Supplier anticipate and agree
that this Order may be amended by updating and replacing the Enforcement Order Schedule
without needing to amend the Order itself further. If the Director issues a new Enforcement
Order Schedule, with the Supplier’s consent, the new schedule shall supersede and replace
all previous schedules. The Order itself shall remain in full force and effect.
27. 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 WS001. The plan shall include proposed modifications to the System,
estimated costs of modifications, a proposed plan, and schedule for project completion. The
plan shall also include specific milestone dates and a final compliance date (to be within six
months from the date of DDW approval of the plan). The Director and Supplier anticipate
and agree that this Order may be amended by updating and replacing the Enforcement Order
Schedule without need to amend the Order itself further. If the Director issues a new
Enforcement Order Schedule, with the Supplier’s consent, the new schedule shall supersede
and replace all previous schedules. The Order itself shall remain in full force and effect.
Secondary Disinfection Requirements
28. The Supplier agrees to maintain the existing boil order until the Director provides written
notification that it has been lifted. The Supplier shall provide the required public notice to
all system customers and ensure ongoing updates to the Division of Drinking Water in
compliance with the Public Notice Rule, as outlined in Utah Administrative Code R309-
220. All public notices must adhere to the requirements specified in R309-105-18 and follow
the format provided in the attached public notice template.
29. The Supplier agrees to install and operate temporary secondary disinfection as required in
paragraphs 27 until the Director provides written notification that the necessary
modifications or corrections to the system’s drinking water source (Artesian Well, WS001)
have been completed and disinfection is no longer required to protect public health.
Modifications may include repairing the existing well or replacing it with an alternative
approved drinking water source. All modifications and new sources must receive prior
approval from the Director, comply with the Division of Drinking Water’s plan approval
process, and obtain all required operating permits before being placed into service.
30. To meet secondary disinfection requirements, the Supplier agrees to continuously
maintain a minimum of 0.2 mg/L free chlorine residual at the Point of Entry(ies) (POE)
into the distribution system and demonstrate a detectable chlorine residual in the
entire distribution system.
Day Star Adventist Academy
Page 8 of 16
April 17, 2025
31. Chlorine Residual ‒ Point of Entry(ies) (POE) to Distribution System (EP001)
a. The POE sampling location will be identified as EP001 in the Division’s
database.The specific location will need to be identified and provided to the
Division during the plan approval process.
b. Maintain a minimum of 0.2 mg/L residual (measured as free chlorine) at the POE
sampling location UAC R309-215-16(3)(b)(iii)(A)(I) and (II).
c. 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)]
d. Record and report the lowest daily chlorine residual concentration, measured as
free chlorine, at the chlorinator POE sampling location (EP001) a minimum of
daily. [R309-210- 8(3)(a)(ii)]
32. Chlorine Residual ‒ Distribution System (DS001)
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. [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).
Bacteriological Source Assessment Sampling Requirements
34. Based on the determination that the System must treat its Distribution System (DS001) to
secondary disinfection standards, the Supplier agrees to the following monitoring
requirements:
a) Bacteriological Source Sampling
Day Star Adventist Academy
Page 9 of 16
April 17, 2025
a) This system is subject to take monthly Escherichia coli (E. coli) samples at
Artesian Well (WS001) (assessment monitoring) during the operating
period and shall continue for a minimum of 18 months. This schedule will
begin June 2025.
b) This sample is in addition to the routine monthly distribution system
sample(s) (DS001). Please label the source sample as WS001 (for both the
facility ID and sample point ID) on all laboratory forms.
c) Please contact Sitara Federico for any positive samples that may occur at
the source at 385-515-1459 or sfederico@utah.gov. If any sample result
comes back as E. coli positive, the Supplier agrees to contact the Division
within 24 hours of being notified of the result.
35. 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.
36. The Supplier agrees to send all reporting and notifications required by this Order in writing
to:
Utah Division of Drinking Water
P.O. Box 144830
Salt Lake City, Utah
84114-4830
Email: eqdwvsa@utah.gov
GENERAL PROVISIONS
37. Based on this CA/EO, the Director hereby rates the System as “Corrective Action” status.
The “Corrective Action” rating is conditioned upon Supplier’s adherence to the
requirements of this CA/EO, 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 CA/EO,
the Act, or the Public Drinking Water Rules.
38. Upon satisfactory compliance with the requirements in the Enforcement Order Schedule,
the Director shall issue a subsequent administrative order closing out this CA/EO and rating
the System as “Approved” in accordance with UAC R309-100-7 and R309-400. Pursuant
to such subsequent order, the Director may also take other appropriate actions or impose
appropriate conditions, based on the facts presented.
Day Star Adventist Academy
Page 10 of 16
April 17, 2025
39. 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
CA/EO, 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
40. In the event of any violation of this CA/EO 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 CA/EO.
41. Nothing in this CA/EO 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 CA/EO, the Act, or the Utah Public Drinking Water Rules.
42. This CA/EO 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, the this CA/EO is without prejudice to, all rights against the Supplier that the
Director may have pertaining to matters not addressed in this CA/EO, including: (a)
violations of this CA/EO; (b) future violations of the Act or the Utah Public Drinking Water
Rules; and (c) criminal liability.
43. The Director has the jurisdiction and authority to make the findings set forth in this CA/EO
and to otherwise enforce the terms of this CA/EO.
44. The date of issuance shall be the date that this CA/EO is executed by the Director.
45. As of the date of issuance, this CA/EO 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 CA/EO 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 CA/EO or the
Director’s authority to enter it as a final administrative order under the Act.
46. The dates set forth in the Enforcement Order 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.
Day Star Adventist Academy
Page 11 of 16
April 17, 2025
47. This CA/EO is intended to satisfy the Director’s legal obligations under Utah Code Section
19-4-107(1) (“Upon discovery of any violation of this chapter 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 or the filing of a request for variance
or exemption by a specific date.”). Failure to comply with the requirements of this CA/EO
may result in legal enforcement action in district court for injunctive or other relief. See Utah
Code Section 19-4-107(2) (“The attorney general shall, upon request of the director,
commence an action for an injunction or other relief relative to the order.”).
48. In partial or full satisfaction of the Enforcement Order 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.
49. The person signing this CA/EO 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.
Day Star Adventist Academy
Page 12 of 16
April 17, 2025
COMPLIANCE NOTICE
Compliance with the provisions of this CA/EO is mandatory. All violations of the Utah Safe
Drinking Water Act, the Drinking Water Rules, and this CA/EO shall be strictly enforced during
the time that this CA/EO remains in effect.
IT IS SO ORDERED AND AGREED.
DIVISION OF DRINKING WATER
By:_________________________
Nathan Lunstad, Ph.D., P.E.
Director, Division of Drinking Water
DATE:_______________________
CASTLE VALLEY, INC.
By: ________________________
Name: ________________________
Title: ________________________
DATE: ________________________
Randall Ward (Apr 20, 2025 13:46 MDT)
Randall Ward
Randall Ward
President
04/20/2025
a/#an
0n./ad (Apr 21, 2025 14:21 MDT)
04/21/2025
Day Star Adventist Academy
Page 13 of 16
April 17, 2025
Enforcement Order Schedule UTAH10012
System Name: Day Star Adventist Academy
System Number: UTAH10012
Administrative Contact: Randy Ward
Email: randy@cva.school
Phone Number: 805-801-1687
Corrective Action Requirements and Due Dates
Date of Issuance:_____________
Distribution System, DS001
Item #1 Code Facility Deficiency Rule Citation
S001 DS001 Install Secondary Disinfection R309-215-13(2), R309-
515-6(5), R309-515-7(4),
R309-500-9(2) and (3)
Corrective Action Completion Due Date
Submit the plan as required in paragraph 27. Within 60 days of the Date of
Issuance of this Order.
Item #2 Code Facility Deficiency Rule Citation
M017 DS001 Water Stagnation, Biofilm Or
Sediments Contribute to
Drinking Water Contamination
R309-200-6, R309-105-18,
R309-215-4(3)
Corrective Action Completion Due Date
Submit the plan as required in paragraph 26. Within 60 days of the Date of
Issuance of this Order.
Artesian Well, WS001
Item #3 Code Facility Deficiency Rule Citation
S013 WS001 Well Lacks The Required Well
Seal
R309-515-6(6)(i)
Corrective Action Completion Due Date
Submit the plan as required in paragraph 26. Within 60 days of the Date of
Issuance of this Order.
Item #4 Code Facility Deficiency Rule Citation
SP04 WS001 Active Source lacks approved
updates to the DWSP Plan
R309-600-7(2)(e)
04/21/2025
Day Star Adventist Academy
Page 14 of 16
April 17, 2025
Corrective Action Completion Due Date
Submit an updated Drinking Water Source
Protection Plan.
Within 60 days of the Date of
Issuance of this Order.
Item #5 Code Facility Deficiency Rule Citation
S020 WS001 Well Head Or Well House Not
Protected From Flooding
R309-515-6(6)(b)(vi), R309-
515-6(12)(d)(iii), R309-515-
6(13)(a) to (d)
Corrective Action Completion Due Date
Submit the plan as required in paragraph 26. Within 60 days of the Date of
Issuance of this Order.
Item #6 Code Facility Violation Rule Citation
03 WS001 Monitoring, Routine Major R309-205-5(4)
Violation
Number
Period Analyte
2025-4032972 January 1, 2024- December 31,
2024
Nitrate
Corrective Action Completion Due Date
Collect a compliant nitrate sample and submit the
results to the Director.
Within 30 days of the Date of
Issuance of this Order.
Item #7 Code Facility Violation Rule Citation
3A DS001 Monitoring, Routine Major R309-210-8
Violation
Number
Period Analyte
2024-4032968 April 1, 2024-April 30, 2024 Total Coliform (RTCR)
Corrective Action Completion Due Date
Collect all required samples required by the
Revised Total Coliform Rule (RTCR)
Duration of this order
Item #8 Code Facility Violation Rule Citation
3A DS001 Monitoring, Routine Major R309-210-8
Violation
Number
Period Analyte
2024-4032969 May 1, 2024-May 31, 2024 Total Coliform (RTCR)
Corrective Action Completion Due Date
Day Star Adventist Academy
Page 15 of 16
April 17, 2025
Collect all required samples required by the
Revised Total Coliform Rule (RTCR)
Duration of this order
Item #9 Code Facility Violation Rule Citation
3A DS001 Monitoring, Routine Major R309-210-8
Violation
Number
Period Analyte
2024-4032973 December 1, 2024- December
31, 2024
Total Coliform (RTCR)
Corrective Action Completion Due Date
Collect all required samples required by the
Revised Total Coliform Rule (RTCR)
Duration of this order
Item
#10
Code Facility Violation Rule Citation
34 WS001 Monitor GWR
Triggered/Additional, Major
R309-215-15
Violation
Number
Period Analyte
2024-4032970 July 10, 2024- July 24, 2024 Total Coliform
Corrective Action Completion Due Date
Collect a triggered source total coliform sample
from Artesian Well WS001, as required by the
Groundwater Rule (GWR), and submit the results to
the Director.
Within 60 days of the Date of
Issuance of this Order.
Item
#11
Code Facility Violation Rule Citation
34 WS001 Monitor GWR
Triggered/Additional, Major
R309-215-15
Violation
Number
Period Analyte
2025-4032977 February 10, 2025 -February 24,
2025
Total Coliform
Corrective Action Completion Due Date
Collect a triggered source total coliform sample
from Artesian Well WS001, as required by the
Groundwater Rule (GWR), and submit the results to
the Director.
Within 60 days of the Date of
Issuance of this Order.
Day Star Adventist Academy
Page 16 of 16
April 17, 2025
IT IS SO ORDERED AND AGREED.
DIVISION OF DRINKING WATER
By:____________________________
Nathan Lunstad, Ph.D., P.E.
Director, Division of Drinking Water
DATE:_________________________
CASTLE VALLEY, INC.
By:____________________________
Name:__________________________
Title:___________________________
DATE:_________________________
Randall Ward (Apr 20, 2025 13:46 MDT)
Randall Ward
Randall Ward
President
04/20/2025
a/#an
0n./ad (Apr 21, 2025 14:21 MDT)
04/21/2025
Utah Department Of Environmental Quality
Division Of Drinking Water
Admin Contacts
Inventory Report
Service Connections
Storage
Sources
Site Visit History
DAY STAR ADVENTIST
ACADEMY
PWS ID: UTAH10012 Rating: Approved 12/13/2016 Active
Legal Contact
DAY STAR ADVENTIST ACADEMY
RANDY WARD
HC 64 BOX 2201
MOAB, UT 84532
Phone: 805-801-1687
County: GRAND COUNTY
System Type: Community
Population: 35
Site Updates
Last Inventory Update: 01/27/2023
Last Surveyor Update: 01/18/2023
Surveyor: RUSSELL SEELEY
Operating Period: 1/1 - 12/31
Last IPS Update: 04/18/2025 07:10:00
Consumptive Use Zone
Irrigation Zone: null
Date:
Name Title Office Emergency Email
WARD, RANDY 805-801-1687 randy@cva.school
Type Meter Type Meter Size # Of Connections
Residential Unmetered 0.000 15
Total Service Connections: 15
ID Name Type Effective Volume Material Status Status Reason
ST001 NOT A STORAGE TANK Standpipe 2,500 GAL Steel Inactive Abandoned
HD001 PSI TANK Hydropneu
matic
Active
Total Effective Volume: 0 null
ID Source Name OP Date Status Reason Source
Type Water Type Period Of
Op
WS001 ARTESIAN WELL Active Well Groundwater 1/1 - 12/31
Flow Flow Rate UOM
PUMP 30 GPM
Date Visited Survey Type Surveyor Notified Date Next Inspection
06/17/2002 Sanitary Survey, Finished SURVEYOR, DDW
DEQ | Drinking Water
Run Date: 04/18/2025 08:32:57 | Rating: Approved UTAH10012 DAY STAR ADVENTIST ACADEMY page 1 of 7
06/28/2011 Sanitary Survey, Finished KEERS, PETER T 07/28/2011 09/30/2014
11/03/2014 Sanitary Survey, Finished BRADFORD, BRADON 11/03/2014
09/25/2017 Sanitary Survey, Finished JENSEN, KIRT 12/01/2017
09/02/2020 Compliance Assessment 09/02/2020
09/17/2020 Sanitary Survey, Finished PETERSON, LEE RICHARD 10/05/2020
06/29/2021 Level 2 Assessment PATTEE, BRIAN H 07/29/2021
01/18/2023 Level 2 / Sanitary Survey SEELEY, RUSSELL 01/25/2023
09/25/2023 Wellhead Protection Program 09/25/2023
10/02/2024 Level 2 Assessment PATTEE, BRIAN H 12/12/2024
04/10/2025 Source Water Inspection 04/10/2025
DEQ | Drinking Water
Run Date: 04/18/2025 08:32:57 | Rating: Approved UTAH10012 DAY STAR ADVENTIST ACADEMY page 2 of 7
Bacterial Summary Report
Routine Bacteriological Sampling Requirements
Total Coliform Sample History
03/01/2024 - 04/30/2025
Sample Reuired Schedule Begin Schedule End Operation Begin Operation End
1/Monthly/Routine 02/01/2009 1/1 12/31
1/Monthly/Routine 01/01/1991 1/1 12/31
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
+
Mar-24 1 1 0 0 0 0 0 0 0 0 0 0
Apr-24 0 0 0 3 3 0 1 1 0 0 0 0
May-24 0 0 0 0 0 0 0 0 0 0 0 0
Jun-24 1 0 0 0 0 0 0 0 0 0 0 0
Jul-24 1 1 0 0 0 0 0 0 0 0 0 0
Aug-24 1 0 0 0 0 0 0 0 0 0 0 0
Sep-24 1 0 0 0 0 0 0 0 0 0 0 0
Oct-24 1 0 0 0 0 0 0 0 0 0 0 0
Nov-24 1 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 1 0 0 0 0 0 0 0 0 0 0 0
Feb-25 1 1 0 0 0 0 0 0 0 0 0 0
Mar-25 1 1 0 0 0 0 0 0 0 0 0 0
Apr-25 0 0 0 0 0 0 0 0 0 0 0 0
DEQ | Drinking Water
Run Date: 04/18/2025 08:32:57 | Rating: Approved UTAH10012 DAY STAR ADVENTIST ACADEMY page 3 of 7
Water Monitoring Report
BACTERIOLOGICAL MONITORING
Other Distribution Monitoring
MONITORING REQUIREMENTS BY FACILITY
Sample Count Type Frequency Schedule Begin Schedule End Analyte Name
1 Routine Monthly 02/01/2009 COLIFORM (TCR)
1 Routine Monthly 01/01/1991 COLIFORM (TCR)
Analyte Name ID Sample
Count Type Frequency Last Sampled Next Sample Due
LEAD AND COPPER DS001 5 Routine 3 Years 2024 06/01/2027-09/30/2027
ID NAME
WS001 ARTESIAN WELL
Name Sample
Count Type Frequency Last Sampled Next Sample Due
INORGANICS-COMPL 1 Routine 3 Years 04/25/2023 01/01/2026 - 12/31/2028
NITRATE 1 Routine Yearly 04/25/2023 01/01/2024 - 12/31/2024
PESTICIDES-COMPL 1 Routine 3 Years 04/25/2023 01/01/2026 - 12/31/2028
RADS - COMPLIANCE 1 Routine 6 Years 04/25/2023 01/01/2029 - 12/31/2034
SULFATE,SODIUM,TDS 1 Routine 3 Years 04/25/2023 01/01/2026 - 12/31/2028
VOC-COMPL 1 Routine 3 Years 04/25/2023 01/01/2026 - 12/31/2028
Open Compliance Schedule
Type Required Activities Severity Created Due
TEMPORARY EXCEPTION GWR CORRECT DEFICIENCY 120 DAYS SIG 10/05/2020 08/31/2027
Lead Consumer Notice SUBMIT LCN CERTIFICATE 01/01/2021 03/31/2022
Lead Consumer Notice SUBMIT LCN CERTIFICATE 06/01/2021 12/29/2021
Lead Consumer Notice SUBMIT LCN CERTIFICATE 06/01/2024 12/29/2024
Physical deficiency schedule WATER STAGNATION, BIOFILM OR
SEDIMENTS CONTRIBUTES TO
DRINKING WATER CONTAMINATION
SIG 12/12/2024 01/11/2025
Physical deficiency schedule WELL LACKS THE REQUIRED WELL SEAL SIG 12/12/2024 01/11/2025
Physical deficiency schedule WELL HEAD OR WELL HOUSE NOT
PROTECTED FROM FLOODING
SIG 12/12/2024 01/11/2025
SOURCE PROTECTION SOURCE PROTECTION PLAN- SUBMIT MIN 09/25/2023 12/24/2023
CCR SCHEDULES Submit Consumer Confidence Report 01/01/2025 07/01/2025
CCR SCHEDULES Submit CCR Certification Letter 01/01/2025 10/01/2025
ERROR:PFAS SUBMIT PFAS INITIAL MONITORING
SAMPLES
04/26/2024 04/26/2027
Physical deficiency schedule UNAPPROVED SOURCE IN SERVICE SIG 04/10/2025 06/09/2025
DEQ | Drinking Water
Run Date: 04/18/2025 08:32:57 | Rating: Approved UTAH10012 DAY STAR ADVENTIST ACADEMY page 4 of 7
IPS 2020 Report
IPS Report
IPS Summary Total IPS Pts: 335
Admin & Physical Facilities Quality & Monitoring Significant Deficiency
160 175 0
DEQ | Drinking Water
Run Date: 04/18/2025 08:32:57 | Rating: Approved UTAH10012 DAY STAR ADVENTIST ACADEMY page 5 of 7
Physical Facility Points 2020 Total Pts: 160
Facility Facility Name Status Points Effective
DS001 UTAH10012 DISTRIBUTION SYSTEM A 80.0
Code Description Severity Comments Determined Date Not
Assessed Assessed
M007 CCC-LACKS ON-
GOING
ENFORCEMENT
IMPLEMENTATION
MIN COMPLETE AND
DOCUMENT OTHER
ELEMENTS
06/28/2011 15
M006 CCC-LACKS WRITTEN
RECORDS OF CCC
ACTIVITIES
MIN 11/03/2014 15
V034 SYSTEM LACKS MORE
THAN 20% OF
REQUIRED STORAGE
CAPACITY (FIRE
DEMAND NOT
INCLUDED)
SIG TEMPORARY EXCEPTION
RENEWED 7/16/2024.
SYSTEM MUST CORRECT
DEFICIENCY OR RENEW
EXCEPTION BY 8/31/2027.
FILE #12677.
09/17/2020 50 0
M017 WATER STAGNATION,
BIOFILM OR
SEDIMENTS
CONTRIBUTES TO
DRINKING WATER
CONTAMINATION
SIG Artesian Well water floods
around well head and
fluctuates as well pumps on
and off
10/02/2024 50
WS001 ARTESIAN WELL A 80.0
Code Description Severity Comments Determined Date Not
Assessed Assessed
SP04 ACTIVE SOURCE
LACKS APPROVED
UPDATES TO DWSP
PLAN
MIN 09/25/2023 5
S013 WELL LACKS THE
REQUIRED WELL
SEAL
SIG Artesian Well water floods
around well head and
fluctuates as well pumps on
and off
10/02/2024 50
S020 WELL HEAD OR WELL
HOUSE NOT
PROTECTED FROM
FLOODING
SIG Artesian Well water floods
around well head and
fluctuates as well pumps on
and off
10/02/2024 25
S001 UNAPPROVED
SOURCE IN SERVICE
SIG SYSTEM MUST INSTALL
SECONDARY
DISINFECTION.
04/10/2025 200 0
Chemical Monitoring Rule Violations Total Pts: 50
Facility Violation
No.Period Violation Type Seasonality Point Effective
WS001 2025-
4032972
01/01/2024-12/31/2024
Determined: 01/22/2025
[03] MONITORING, ROUTINE MAJOR
Analyte/Group: NITRATE
P 50
DEQ | Drinking Water
Run Date: 04/18/2025 08:32:57 | Rating: Approved UTAH10012 DAY STAR ADVENTIST ACADEMY page 6 of 7
Microbial Rule Violations Total Pts:
125
Determined Compliance Period Code Violation Type Return To
Compliance Point Effective
05/31/2024 04/01/2024 - 04/30/2024 3A MONITORING, ROUTINE,
MAJOR (RTCR)
N 25
07/11/2024 05/01/2024 - 05/31/2024 3A MONITORING, ROUTINE,
MAJOR (RTCR)
N 25
09/17/2024 07/10/2024 - 07/24/2024 34 MONITOR GWR
TRIGGERED/ADDITONAL,
MAJOR
N 25
01/31/2025 12/01/2024 - 12/31/2024 3A MONITORING, ROUTINE,
MAJOR (RTCR)
N 25
03/28/2025 02/10/2025 - 02/24/2025 34 MONITOR GWR
TRIGGERED/ADDITONAL,
MAJOR
N 25
Operator Certification
Type Level Required Highest Certificate
Distribution Small System
Treatment
Open Compliance Schedule
Type Required Activities Severity Created Due
TEMPORARY EXCEPTION GWR CORRECT DEFICIENCY 120 DAYS SIG 10/05/2020 08/31/2027
Lead Consumer Notice SUBMIT LCN CERTIFICATE 01/01/2021 03/31/2022
Lead Consumer Notice SUBMIT LCN CERTIFICATE 06/01/2021 12/29/2021
Lead Consumer Notice SUBMIT LCN CERTIFICATE 06/01/2024 12/29/2024
Physical deficiency schedule WATER STAGNATION, BIOFILM OR
SEDIMENTS CONTRIBUTES TO
DRINKING WATER CONTAMINATION
SIG 12/12/2024 01/11/2025
Physical deficiency schedule WELL LACKS THE REQUIRED WELL SEAL SIG 12/12/2024 01/11/2025
Physical deficiency schedule WELL HEAD OR WELL HOUSE NOT
PROTECTED FROM FLOODING
SIG 12/12/2024 01/11/2025
SOURCE PROTECTION SOURCE PROTECTION PLAN- SUBMIT MIN 09/25/2023 12/24/2023
CCR SCHEDULES Submit Consumer Confidence Report 01/01/2025 07/01/2025
CCR SCHEDULES Submit CCR Certification Letter 01/01/2025 10/01/2025
ERROR:PFAS SUBMIT PFAS INITIAL MONITORING
SAMPLES
04/26/2024 04/26/2027
Physical deficiency schedule UNAPPROVED SOURCE IN SERVICE SIG 04/10/2025 06/09/2025
DEQ | Drinking Water
Run Date: 04/18/2025 08:32:57 | Rating: Approved UTAH10012 DAY STAR ADVENTIST ACADEMY page 7 of 7
The following secondary disinfection requirements must be met to ensure proper water quality and safeguard
public health.These outline the necessary chlorine levels and monitoring processes for maintaining effective
secondary disinfection in your water system.
Chlorine Residual Requirements ‒Point of Entry (POE)to Distribution System (EP00X)
●The POE location,designated as EP00X,must be confirmed with the system and identified in the
Division's database.
●A minimum chlorine residual of 0.2 mg/L (measured as free chlorine)must be continuously maintained
at this POE sampling location per Utah Administrative Code (UAC)R309-215-16(3)(b)(iii)(A)(I)and (II).
●Chlorine concentration at the POE must not exceed the Maximum Residual Disinfectant Level (MRDL)
of 4.0 mg/L,as per UAC R309-200-5(3)(c)(iv).
●Daily records of the lowest chlorine residual concentration (as free chlorine)at the POE must be
maintained and reported per UAC R309-210-8(3)(a)(ii).
Chlorinator Operational Report Requirements
●Water systems must complete monthly operational reports for each active chlorinator.
●The reports will include the POE residual values described above and operational data (e.g.,how much
water was treated and chlorine was used).The operational data collected will vary depending on the
type of chlorinator (e.g.,gas,liquid,or tablet).
●The operational reports are submitted quarterly and must be submitted by the 10th day after the end of
each quarter.
Chlorine Residual Requirements ‒Distribution System (DS001)
●A detectable residual must be maintained throughout the distribution system,with a recommended
minimum level of 0.1 mg/L per UAC R309-520-5.
●As with the POE,chlorine residual levels in the distribution system must not exceed the MRDL of 4.0
mg/L (free chlorine)[R309-200-5(3)(c)(iv)].
●To ensure consistency across the system,at least three chlorine residual samples must be collected
from various locations within the distribution system every week [UAC R309-105-10(1)(c)].
●Chlorine residual sampling must occur alongside total coliform sampling [R309-215-10(3)].
Reporting Requirements
●The chlorine residuals from the distribution system and the chlorinator operational reports (with the
POE residuals)must be submitted quarterly using the Division's online form found on mrdl.utah.gov.
System Malfunction Notification
●In the event of a disinfection facility malfunction where chlorine residuals cannot be maintained
throughout the system,the Supplier must notify the Division within eight hours by phone at (801)
560-8456,per UAC R309-105-18(1)(a).
By adhering to these requirements,you help ensure the safety of your community's drinking water.If you have
any questions or need further clarification,please contact the Division of Drinking Water.