DDW-2025-004071

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, Ph.D., P.E.
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
March 17, 2025

Via Email: [e-mail]
Lester Dalton
Washington City
1305 East Washington Dam Road
Washington, Utah 84780

Subject: System-Specific Minimum Sizing Standards—Final Determination
Washington City, System #27021, File #11476

Dear Lester Dalton:

DETERMINATIONS

Based on the findings set forth below, the Division of Drinking Water (the Division) hereby
establishes the following system-specific minimum sizing standards for Washington City (the
System):

Peak Day Source Demand (gallons/day/ERC) – 822
Average Annual Demand (gallons/year/ERC) – 179,318
Equalization Storage (gallons/ERC) – 491
Fire Storage (gallons) – 360,000

Introduction

Pursuant to Utah Code Section 19-4-114, the Director of the Division (Director) is required to
establish system-specific minimum sizing standards based on, among other factors, water use data
submitted to the Division of Water Rights (DWRi). The Director’s determinations may also be based
on engineering analyses and other evidence if this is available. This final determination letter is
addressed to you in your capacity as the Administrative Contact for the System. The Director has
delegated the responsibility for making system-specific minimum sizing standards under Utah Code
Section 19-4-114 to the Engineering Manager for the Division.
Prior to issuing this final determination letter, the Division analyzed applicable DWRi water use data
and sent a draft summary of the Division’s proposed system-specific minimum sizing standards to the
System on March 12, 2025. The Division allowed for 30 days for the System to review the draft
system-specific minimum sizing. The System responded on March 12, 2025, concurring with the draft
Lester Dalton
Page 2 of 4
March 17, 2025

system-specific minimum sizing. A summary of the water use data and calculations the Division used
to make these determinations is attached as part of the administrative record.

Water Use Data Definitions

As used in this Final Determination, the following terms have the following meanings:
Peak Day Source Demand is the total flow into a public water system to meet the demand of the water
system on the day of the highest water consumption in a calendar year.

Average Annual Demand is the total quantity of drinking water flowing into a public water system
within a calendar year.

Total Equivalent Residential Connections (ERCs) term represents the number of residential service
connections and the number of equivalent residential connections for non-residential connections
(commercial, industrial, institutional connections).

Minimum Equalization Storage requirement is a volume that is equivalent to the amount of water
needed to meet the average day culinary demand for public water systems. Equalized storage per ERC
is calculated by dividing the Average Annual Demand per ERC data by the number of operational
days in a year.

Water System Background Facts

The System is a community water system in Washington County. The system currently has 15,187
residential connections serving an approximate population of 45,865 residents. Additionally, the
System provides water to 372 commercial, 57 industrial, and 114 institutional connections. The
System operates and maintains 14 active sources, 11 wells, two (2) consecutive connections to
WCWCD - Quail Lake (UTAH27094) and WCWCD - Sand Hollow (UTAH 27073), and one (1)
surface water treatment plant, and eight (8) storage tanks with the associated distribution lines.

System-Specific Minimum Sizing Standards—Background

Under Utah Code Section 19-4-114, the legislature required that the Director establish minimum
sizing standards on a system-specific basis instead of statewide, as the Division has done in the past.
System-specific determinations need to be based on system-specific information. The code allows the
Director to rely on water use data submitted to DWRi. Alternatively, a community water system may
perform and submit an engineering study to the Division if the water system’s water use data is not
representative of future use or the water system does not yet have actual water use data. In this matter,
actual water use data was available through DWRi, and an engineering study was not submitted to the
Division for review. Therefore, the Division has relied upon DWRi information and other relevant
data.

Additional System-Specific Basis for Determinations

The Division established Fire Storage requirements based on information from the City from teh
Washington City Fire Department on November 1, 2021.

Lester Dalton
Page 3 of 4
March 17, 2025

Storage Capacity

Based on the System’s storage facilities and the storage minimum sizing requirement established in
this letter, the Director hereby determines that the System is compliant with the minimum storage
capacity requirements.

The issuance of this letter resolves your water system’s deficiency of V031 due to lacking less than
20% of the required storage capacity. An updated IPS report is available at https:\\waterlink.utah.gov.
Please contact Jennifer Yee at [phone] or [e-mail] for questions related to the System’s
IPS report or deficiencies.

Source Capacity

The Division has adequate documentation of established safe yields (wells) and design capacities
(treatment plants) for all the System’s sources. Using total system-wide source capacity and the source
minimum sizing requirement established in this letter indicates that the System is compliant with
minimum source capacity requirements.

The issuance of this letter resolves the System’s deficiency of S091 related to lacking less than 20% of
the required source capacity. An updated IPS report is available at https:\\waterlink.utah.gov. Please
contact Jennifer Yee at [phone] or [e-mail] for questions related to the System’s IPS
report or deficiencies.

Effective Date

The determinations made in this letter are effective immediately and will become final 30 days from
the date of this letter unless the System files a contest as provided below.

Notice of Right to Contest

The Director has determined this determination made under Section 19-3-114 qualifies as a “permit
order” within the meaning of Utah Code Section 19-1-301.5(1)(f). See Utah Code § 19-1-301.5(1)(e)
(defining “permit” to include a “plan” or “other administrative authorization”).

The System may contest any determinations made herein by delivering a notice of contest to the
Director. The notice of contest must be in writing and must be delivered to the Director on or before
30 days after the date this letter is signed. There is no particular form for the notice of contest, but it
must include the System’s reasons and rationale for the contest. The Director’s address for purposes of
submitting a notice of contest is as follows:

U.S. Mail

Division of Drinking Water
Attention: Director
P.O. Box 144830
Salt Lake City, UT 84114-4830

Lester Dalton
Page 4 of 4
March 17, 2025

Email

A notice of contest may be submitted to the Director by email, provided, however, that the
Director confirms receipt of the email. The Director’s email address is: [e-mail].
The email submission must be received by the Director before the expiration of the contest
deadline.

If the System files a timely notice of contest, the Director will evaluate the matter and attempt to
resolve the matter through negotiations. If the Director is not able to resolve the matter, the Director
will issue a final agency action regarding the contest. At that point in the process, the System shall
have the right to seek further internal agency and judicial review pursuant to Utah Admin. Code R305-
7 and Utah Code Section 19-1-301.5.

Right to Request Reconsideration

The Director plans to evaluate the determinations made herein every three years. However, this
requirement is not mandatory. At any time, a water system whose system-specific minimum sizing
standards have been established by the Division under Section 19-4-114 may request reconsideration
of the Director’s determinations by submitting a written request. A request for reconsideration shall be
submitted to the Director in the same manner as a notice of contest provided above.

Conclusion

If the System management has any questions regarding this letter, please contact Dani Zebelean, P.E.,
of this office, at [phone], or me at [phone].

Sincerely,

Michael Newberry, P.E.
Permitting and Engineering Support Manager

DZ/mrn/mdb

Enclosures
1. 27021 11476 - Sizing Standard Renewal Calculation

cc: Jeremy Roberts, Southwest Utah Public Health Department, [e-mail]
Paul Wright, P.E., Southwest DEQ District Engineer, [e-mail]
Lester Dalton, Washington City, [e-mail]
Dani Zebelean, P.E., Division of Drinking Water, [e-mail]
Brent Arns, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Ted Black, Office of the State Fire Marshal, [e-mail]

DDW-2025-002465
Utah Department of Environmental Quality
Division of Drinking Water
Minimum Sizing Standards
Date Standard Effective: Wed Mar 12 15:49:58 MDT 2025
Peak Day Source Demand per ERC (gal/day): 822
Average Annual Demand per ERC (gal/year): 179,318
Equalization Storage per ERC (gal): 491
WASHINGTON CITY PWS ID: UTAH27021
Admin Name: LESTER CARL DALTON
Address: 1305 East Washington Dam Rd
City, State, Zip: Washington, UT 84780
Phone: [phone]
Email: [e-mail]
System Type: Community
Population: 38,015
MINIMUM SIZING STANDARD
MINIMUM SIZING STANDARD CALCULATIONS VARIABILITY
Data from these reporting years: 2022, 2023, 2024
Peak Day Source Demand per ERC (gal/day): 822
Average Annual Demand per ERC (gal/year): 179,318
Equalization Storage per ERC (gal): 491
x
x
x
(1 + 0.0)
(1 + 0.0)
(1 + 0.0)
=
=
=
822
179,318
491
DWRi WATER USE DATA REPORTED
Equalization per ERC (gal): 491
Existing Storage (gal): 12,128,932
ERCs: 19,999
Required Storage w/o Fire Flow: 9,819,509
Required Fire Storage (gal): 360,000
Required Storage w/Fire (gal): 10,179,509
Storage Deficiency: 0
Storage Deficiency (%): 0.0
No Storage Deficiency
Peak Day Source Demand per ERC (gpm):
0.57 Existing Source Capacity (gpm): 12,806
ERCs: 19,999
Required Source Capacity (gpm): 11,399
Source Deficiency: 0
Source Deficiency (%): 0.0
No Source Deficiency
Year Peak
Day
Source
Demand
(gal/day)
Average
Annual
Demand
(gallons)
ERCs Peak
Demand
per ERC
(gal/day)
Avg
Annual
Demand
per ERC
(gal/year
Equaliza
tion
Storage
per ERC
(gal)
OP
Days
2024 14,549,247 3,101,397,681.84 19,999 728 155,082 424 366
2023 13,405,510 2,779,574,200.2 17,044 787 163,083 447 365
2022 13,636,864 2,975,586,610.74 16,594 822 179,318 491 365
Variability:0.205 0.0 0.0 0.0
Year Peak Month Average
(gal/day)
Peak Month Average
per ERD (gal/day)
Ratio of PD/ERC to
Peak Month Avg/ERC
2024 12,867,225 643 1.13
2023 11,926,041 700 1.12
2022 12,236,756 737 1.11
CAPACITY CALCULATIONS FOR STORAGE
CAPACITY CALCULATIONS FOR SOURCES
SYSTEM STORAGE AND SOURCE INVENTORY
Storage ID Storage Name Effective Volume (GAL)
ST001 RED CLIFF TANK 1 MG 1,000,000
ST002 RED CLIFF TANK 2.3 MG 2,300,000
ST003 GRAPE VINE TANK 1 MG 1,000,000
ST004 WARNER VALLEY TANK 1,000,000
ST005 WASHINGTON DAM RD TANK 2 MG 2,000,000
ST006 WATER TREATMENT PLANT TANK 500K 328,932
ST007 RED CLIFFS 2 MG TANK 2,000,000
ST009 LONG VALLEY 2.5 MG TANK 2,500,000
Storage Totals: 12,128,932 GAL
Source ID Source Name Flow Rate (GPM)
WS007 WELL 2 600
WS008 WELL 3 180
WS009 WELL 4 650
WS010 WELL 5 750
WS011 WELL 6 600
WS012 GRAPEVINE WELL 1 180
WS013 GRAPEVINE WELL 2 90
TP014 WASHINGTON CITY MEMBRANE FILTRATION PLAN
WS015 UTAH27094 WCWCD-QUAIL LAKE 7,267
RW003 QUAIL CREEK SAND HOLLOW VIRGIN RIVER
WS016 UTAH27073 WASHINGTON CO WCD-SAND HOLLOW
WS017 GRAPEVINE #3 80
WS018 GRAPEVINE #4 100
WS019 GRAPEVINE #5 93
WS020 GRAPEVINE #6 133
Source Totals: 12,806 GPM
2,083