HomeMy WebLinkAboutDWQ-2025-005500Date
Via Email
(Read Receipt Requested)
Mercer Owen
Lost Creek Park Manager
Dept. of Natural Resources, Division of State Parks
Lost Creek State Park
Croydon, Utah, 84018
Subject:GWPBR-24-003 –REVISED GroundWaterDischargePermit-By-RuleDeterminationandIssuanceofConstruction Permit for the Lost Creek State Park Culinary Well Water Reverse Osmosis Treatment
System Backwash EvaporationPonds
DearMr.Owen,
On August 22, 2024, the Division of Water Quality (DWQ) received construction documents and information concerning the drilling and completion of Well #2 (Well #2 Submittal) for use
at Lost Creek State Parkon behalf of the Department of Natural Resources, Division of State Parks (DNR-DSP). The documents were reviewed and it was determined that the proposed project
requires a Ground Water Discharge Permit by Rule (PBR) and Construction Permit. This letter serves as both the PBR and Construction Permit as documented herein.
The Well #2 Submittal included information about the well completion, lithology, pump testing, drawdown, and drinking water sampling. The sampling analysis showed that the water had
Total Dissolved Solids (TDS) of 1230 mg/L and Total Iron of 0.40 mg/L. The TDS values exceed the Primary Drinking Water Standards and the Total Iron exceed the Secondary Drinking Water
Standards. DNR-DSP plans to treat the water through a Reverse Osmosis (RO) system to provide culinary water for campground and other uses at Lost Creek State Park. The RO system would
have a waste streamwith higher concentrations of pollutants such as TDS, Iron, Sulfate, Sodium, Chloride, etc.These pollutants could infiltrate into the ground water system and over
time would further degrade that system. This discharge waste stream is required to be placed in lined evaporation ponds and be covered under a Groundwater Discharge Permit by Rule.
Therefore, the lined evaporation ponds required a Ground Water Discharge Permit by Rule and a Construction Permit.
The Construction Documents submitted on August 22, 2024, were a complete set of documents for all construction at Lost Creek State Park.The documents were all prepared by CivilScience
and signed by Cody C. Howick P.E., ProjectManager and Ryan Devitt P.E. Assistant Project Manager.Mr.Howick and Mr. DevittareaUtah Certified ProfessionalEngineers (P.E.). DWQ requested
updated Construction Documents that included only the water system, including the evaporation ponds, which were received on August 28, 2024.
The Construction Documents indicated that there would be six (6) Evaporation Ponds. Evaporation and precipitation rates were used to calculate the area required to evaporate the waste
stream. The calculations were based on 200 days of operation for the campground and year-round use for the Park Ranger Residence. The ponds were designed to fit in a certain area and
were sized so that a single flexible membrane liner could be installed in each pond without onsite seaming. The ponds are in series and pipes will allow flow from each pond consecutively.
To enhance evaporation the ponds are very shallow with a maximum depth of 3 feet. Solids would settle in Pond 1 which will help keep the other ponds cleaner. The ponds will be fenced
to help keep wildlife out which andprotect the liners.
Thewater system and evaporation ponds drawing set include the following:
Sizing and location of evaporation ponds;
Pump house and drain lines leading to evaporation pond: and
Well and pump house equipment: etc.
Revision
On Friday June 27, 2025, DWQ received an email from Ryan Devitt, P.E. Project Engineer Civil Science. Mr. Devitt explained that as part of the value engineering during the bidding process
there would be some changes to better fit the State Parks budget. A new set of drawings has been submitted and the following are the changes that will be made:
Removed the Ranger’s House from the plans;
Relocated the Concrete Water Tank from up on the hillside down to where the Ranger’s House was going to be built;
Construction of the main campground loop will stay as planned but the Group Campsite Area will be removed (30 campsites instead of 37). This also removes the 4-stall restroom building.;
These changes reduced the water needs and the calculations show that only 3 evaporation ponds will be required instead of the original 6 that were planned.
Ground Water Permit-By-Rule (PBR) Determination
The DWQ determined that the proposed project meets the requirements of PBR outlined in Utah Admin. Code R317-6-6. Below are the relevant factors evaluated in determining that the proposed
operation qualifies forPBRandthatdischargewillhaveademinimisactualorpotentialeffectongroundwaterqualityand beneficialuses of ground waterresources under Utah Admin. Code R317-6-6 (6.2)(A)(25).
The RO system waste stream will be contained in linedevaporation ponds.The Evaporation Ponds will be lined with a minimum 40-mil-thick Reinforced Polyethylene(RPE)liner and 8 oz Geotextile.The
lined evaporation ponds will minimize any infiltration of the RO system waste stream into the shallow aquifer system.The hydraulic head on the liner will only be 3 feet minimizing infiltration
in addition to the RPE liner.Placement of three down gradient piezometer to detect possible leakage from the evaporation ponds
PBR ConditionsofApproval
ThefollowingconditionsarerequiredunderthisPBR:TheEvaporationPondsmayonlybeusedforthe RO system waste streamandwell water.Nothingelsemaybeputin thepond.CeaseoperationsandnotifyDWQimmediatelyifasheenorodorisdetectedonanyofthewaterin
thepond.Ifanyofthefactors evaluated in determining the site qualifies for PBR changedue tooperational changesorfrom additionalknowledge of siteconditions including monitoring results
from the downgradient piezometers,thisPBRmaynotapplyandyoushouldinformDWQimmediately.If future project knowledge or experience indicates that a ground water quality is threatened bythis
operation, the Director may require that you apply for a Ground Water Discharge Permit inaccordancewithUtah Admin.CodeR317-6-6(6.2)(C).
ThisPBR determinationiseffectiveforaperiodof5yearsfromthedateofthisletter. A minimum of 6-months prior to the end of this 5-year period, DNR-DSP shall submit toDWQ written request to
renew the permit-by rule status.The request shall include a currentdescriptionoftheoperationandverificationoraffirmationthatsiteconditionshavenotchanged and include results from semi-annual
monitoring of the downgradient piezometers.
In evaluating the request, the Director may conduct a facility inspection and request additionalsamplesand informationasnecessary.
ConstructionPermit
On August 22, 2024, DWQ received the Construction Documents for the Lost Creek State Park. This was a complete set of documents for all construction at Lost Creek State Park. These
were all prepared by CivilScience and signed by Cody C. Howick P.E., Project Manager and Ryan Devitt P.E. Assistant Project Manager.Mr.Howick and Mr. Devitt areaUtah Certified ProfessionalEngineers
(P.E.).
On October 28, 2024, DWQ received a subset of documents concerning the water system including the evaporation ponds.Those drawings did not include any specifications (compaction, moisture
content, etc.) for the soils and berms of the evaporation ponds. This was communicated to Mr. Devitt and on November 9, 2024, DWQ received the drawing with those required changes.
REVISION
On Friday June 27, 2025, DWQ received an email from Ryan Devitt, P.E. Project Engineer Civil Science that contained a new set of drawings.
Thefollowingis asummaryoftheproposedmajorconstructionprojects for the water system and evaporation ponds:
Construction of a well and pump house including the RO equipment;
Placement of drain line to the evaporation ponds;
Construction of3newevaporationpondsthatwillbelinedwitha 40 mil Reinforced Polyethylene(RPE)liner and 8 oz Geotextile; and
Placement of three down gradient piezometer to detect possible leakage from the evaporation ponds.
This Construction Permit and PBR are issued for the RO wastewater and not for the drinking water. The attached plans and specifications may include part of the drinking water system
but those items are regulated by the Division of Drinking Water. For questions concerning the drinking water system you may contact Cameron Draney by email at cdraney@utah.gov or phone
at 385-271-7039. The file number is 13476.
Construction Permit Conditions of Approval
The plans and specifications, as submitted, comply with the Utah Water Quality Rules,(R317, Utah Administrative Code).A Construction Permit is hereby issued as constituted bythisletter,subject
to thefollowingconditions:
AnyrevisionsormodificationstotheapprovedplansandspecificationsmustbesubmittedtoDWQforreviewandapproval,beforeconstructionorimplementationthereof.Pleasesubmitanychangesforreviewandapprovaldirectly
to Woodrow Campbell, P.E., of the DWQ Ground Water ProtectionSection.
A written operations and maintenance manual, containing a description ofthefunctioningofthefacilities,anoutlineofroutinemaintenanceprocedures, and all checklists and maintenancelogs
needed for properoperation of the system, must be submitted and approved before the finalinspectionand operation ofthesystem.
The approved facilities must not be placed in service unless DWQ hasconductedafinalinspection,reviewedandapprovedtheAs-BuiltConstruction Certification Report, and provided written authorization
toplacetheconstructed facilities in service.
Construction activities that disturb one acre or more are required to obtain coverage under the Utah Pollutant Discharge Elimination System (UPDES) Storm Water General Permit for Construction
Activities. The permit requires the development of a storm water pollution prevention plan (SWPPP) to be implemented and updated from the commencement of any soil disturbing activities
at the site until final stabilization of the project. For more information, or to obtain permit coverage on-line, please go to: https://deq.utah.gov/water-quality/general-construction-storm-water-updes-permits
The plans and specifications for this project have been stamped and signed by a ProfessionalEngineer currently licensed to practice in the state of Utah.The construction design, inspectionsupervision,
and written construction certification of all work associated with this ConstructionPermitmustbeperformedbyaProfessional Engineerlicensedto practicein thestateofUtah.
This Construction Permit will expire one year from the date of its issuance, as evidenced by thedateofthisletter,unlesssubstantialprogressismadeinconstructingtheapprovedfacilitiesortheplansandspecificationshavebeenresubmittedandtheconstructionpermitisreissued.Thispermitdoes
not relieve you, in any way, of your obligations to comply with other applicable localrequirements. You may contact Scott Braeden, Weber-Morgan Health Department at801-399-7143 for further
assistanceregardinglocal matters.
Please contact Mr. Campbell at the beginning of construction to allow periodic inspections to bescheduled. Upon completion of the project, a final inspection and approval of the As-BuiltConstructionCertificationReportisrequiredbeforetheapprovaltooperatethecompletedfacilities
can be issued.Please remain in contact with Mr. Campbell to schedule the finalinspection.The Construction Certification Report with final as-built drawings must include testresultsforthefollowingconstructionqualityassurance
andqualitycontrol(CQA/QC)elements:
SoilSubgradeProctorCurves;SoilClassification;FieldCompactionTesting;andSubgradeAcceptanceCertification.
FlexibleMembraneLinerPanelPlacementLog;TrialSeamTest Log;SeamingRecord;SeamTestRecord;RepairLog;As-BuiltDrawing;ManufacturesCertificationincludingQA/QCTestingoftheRolls;andProfessionalEngineerCertification.If
you have any questions about the above correspondence, please contact Woodrow Campbell at wwcampbell@utah.govor(801)536-4353.
Sincerely,
JohnK.Mackey, P.E.
Director
JKM/WWC/DJH/Enclosures:ConstructionPlans and Specifications (DWQ-2024-007911)Revised Construction Plans (DWQ-2025-005499)CC:ViaEmail w/o AttachmentsRyan Devitt, Civil Science (rdevitt@civilscience.com)Cody
Howick, Civil Science (chowick@civilscience.com)Wendy Wilson, Regional Park Manager (wendywilson@utah.gov)Mercer Owen, Lost Creek Manager (mercerowen@utah.gov)Scott Braeden, Weber-Morgan
Health DepartmentCameron Draney, Division of Water Quality