DDW-2025-006651

July 25, 2025
Sent via Email Only
Randy Ward
Day Star Adventist Academy
HC 64 BOX 2201
Moab, Utah 84532
[e-mail]
Subject:ConditionalConcurrence of Interim Disinfection, Emergency Authorization to Disinfect, Artesian Well Chlorinator (TP001); Day Star Adventist Academy, System #10012, File #23306
This Concurrence Expires on January 31, 2026
Dear Randy Ward:The Division of Drinking Water (the Division) received the Notification of Interim Disinfection form from your consultant, Chad Bush, Rural Community Assistance Corporation
(RCAC) on May 9, 2025.Interim Disinfection Summary
Day Star Academy (Supplier) has been under an ongoing boil order issued on October 27, 2022. An April 17, 2025, Compliance Agreement / Enforcement Order and Stipulated Order to Disinfect
(CA/EO) letter was executed in order to address compliance issues affecting their drinking water system. The order requires the Supplier to install secondary disinfection to address
ongoing detections of total coliform bacteria, which indicate possible contamination pathways due to the deficiencies of their sole source Artesian Well (WS001) as described in the CA/EO.
The CA/EO directs the Supplier to install and operate temporary secondary disinfection until the Director provides written notification that the necessary modifications and corrections
to the Supplier’s drinking water source (Artesian Well, WS001) have been completed and disinfection is no longer required to protect public health. 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 (POE) into the distribution system and demonstrate a detectable chlorine
residual in the entire distribution system.
Our understanding of the interim disinfection plan includes the addition of a Stenner Peristaltic chlorine dosing pump (85MJH1A1S) capable of dosing up to 5 gallons of 12% sodium hypochlorite
solution per day with a maximum discharge pressure of 100 psi. The addition of a 15 Gallon Stenner STS Chemical Solution tank (STS15NC) with a ¼ inch Stenner Injection check valve (UCDBINJ).
The well pump is controlled by a pressure switch that is in line with the Hydropneumatic Tank (HD001). The dosing pump controls will be synchronized with the controls for the Artesian
Well, enabling simultaneous activation and deactivation.
The existing source sample tap location upstream of the flow meter will be used as the POE to inject chlorine into the system. The existing flow meter immediately downstream of the POE
will aid in the mixing of chlorine. A new sample tap will be installed downstream of the flow meter to serve as the POE sample location. A new sample tap will be installed upstream of
the POE for source sampling.
This facility will be identified as Artesian Well Chlorinator (TP001) in the Division’s database.
Conditional Concurrence for Interim Disinfection— Artesian Well Chlorinator (TP001)
We have completed our review of the information provided byChad Bush and concur with the proposal with the following conditions:
This Concurrence expires on January 31, 2026.
Notify the Division when you begin chlorinating. Please contact Luke Treutel at [e-mail], or [phone], within one business day of beginning chlorination.
The System must complete the following steps by January 31, 2026, to receive plan approval and an operating permit for a permanent disinfection facility, in accordance with the applicable
portions of Utah’s Administrative Rules for Public Drinking Water Systems in R309:
Submit a Project Notification Form.
Submit plans and specifications stamped and signed by a licensed professional engineer in the state of Utah that address the deficiencies identified in the April 15, 2025 CA/EO.
Obtain an Operating Permit.
Failure to comply with the conditions of this concurrence by January 31, 2026, will result in the activation of the deficiency related to having an unapproved facility in service in
your system (G001, 50 points). Approvals or permits from the local authority or the county may be necessary before beginning construction of this project. As the project proceeds, a
notice of any changes in the approved design, as well as any change affecting the quantity or quality of the delivered water, must be submitted to the Division. We may also conduct interim
and final inspections of this project. Please notify us when actual construction begins so that these inspections can be scheduled.
Secondary Disinfection Requirements
The Division issued a CA/EO on April 17, 2025. The Division has determined that theDay Star Advenstist Academymust provide continuous disinfection to maintain detectable chlorine residuals
throughout the distribution system. The Artesian Well Chlorinator (TP001)is intended for interim use to provide a detectable disinfectant residual in the distribution system for secondary
disinfection.
The review of the interim chlorinator, Artesian Well Chlorinator (TP001), is based on providing secondary disinfection. When this interim chlorinator is installed and placed in operation,
the water system will be required to demonstrate ongoing compliance with the secondary disinfection requirements that are outlined in Addendum 1 to this letter.
Please be aware if the Artesian Well (WS001) is found to require additional disinfection in the future per R309-200-5(7)(a)(i), further regulations will apply. For example, if primary
disinfection is required this will include submitting disinfection CT information showing compliance with 4-log virus inactivation in accordance with the Ground Water Rule in R309-215-16.
The Division shall be informed by telephone within 8 hours by a water supplier ofthe 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).
If you have any questions regarding this concurrence, please contact Curtis Page, P.E., of this office, at [phone], or me at [phone].
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
CMP/mrn/mdbEnclosures –Addendum 1- Future Monitoring and Reporting Requirements Attachment 1 - Chlorinator Operational Report Template Attachment
2 - DBP Sample Site Plan Templatecc:Orion Rogers, Southeast Utah Health Department, [e-mail] M. Page P.E., DEQ Southeast District Engineer, [e-mail] Ward, Day
Star Adventist Academy, [e-mail] Bush, RCAC, [e-mail] Treutel, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Colt Smith, Division of Drinking Water, [e-mail]
Brandi Smith, Division of Drinking Water, [e-mail]
VSA Team, Division of Drinking Water, [e-mail] CPage 10012 23306 Concurrence for Interim Disinfection

Addendum 1 - Secondary Monitoring and Reporting Requirements
Chlorine Monitoring & Reporting Requirements
The water system will be required to meet secondary disinfection requirements once this facility is installed and operating. As a part of these requirements, the water system will need
to continuously maintain a minimum free chlorine residual at each chlorinator Point of Entry (POE) into the system and demonstrate a detectable chlorine residual in the distribution
system.
Secondary Disinfection Requirements and Reporting
Chlorine Residual ‒ Point of Entry (POE) to Distribution System
The POE sampling location will be identified in the Division’s database as EP001. The location is the source sample tap location upstream of the flow meters. Maintain a minimum of 0.2
mg/L residual (measured as free chlorine) at the POE sampling location. [R309-215-16(3)(b)(iii)(A)(I) and (II)]
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)]Record
and report the lowest daily value of chlorine residual measured as free chlorine at the POE sampling location (EP001). [R309-215-10(1)]Our records show that your water system serves
35 people. Please be aware that R309-215-16(3)(b)(iii)(A)(II) requires water systems serving 3,300 people or fewer to monitor the POE chlorine residuals and take daily grab sample(s).
Alternatively, instead of taking daily grab samples, a groundwater system serving 3,300 or fewer people may choose to use an online analyzer to continuously monitor the POE chlorine
residuals entering the distribution system.
Chlorine Residual ‒ Distribution System (DS001)
This water system must maintain a detectable residualthroughout the distribution system. It is recommended to maintain the chlorine residual above 0.1 ppm in the distribution system.
[R309-520-5]
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)]
This water system must take a minimum of three (3) chlorine residual samples per weekat varying locations throughout its distribution system (DS001). [R309-105-10(1)(c)]
Distribution system chlorine residuals must be taken in conjunction with total coliform sampling. [R309-215-10(3)]
Disinfection Report Submission
To demonstrate ongoing compliance with secondary disinfection requirements, the water system must complete monthly operational reports for each active chlorinator using the template
attached to this letter.
The monthly operational reports are submitted quarterly. The reports are due to the Division by the 10th day following the end of each reporting quarter (i.e., January 10th, April 10th,
July 10th and October 10th). The reports can be submitted by hardcopy, fax, or by uploading them to the Division’s chlorine residual reporting form which can be found at MRDL.utah.gov.
Please contact Luke Treutel at [phone] or [e-mail] to schedule training regarding proper reporting.
In addition to monthly disinfection reporting, this water system must submit the monthly average of chlorine residual samples taken in the distribution system. Distribution system chlorine
residual monitoring results are due quarterly by the same compliance dates as the monthly disinfection report and can be submitted via an online form found at mrdl.utah.gov.
Records must be maintained for a minimum of 5 years. [R309-105-17(1)]
Disinfection Byproducts Monitoring & Reporting Requirements
In addition to the chlorine monitoring and reporting described above, the system will be required to monitor disinfection byproducts as a result of introducing disinfection to the system.
According to our records, the water system serves a population of approximately 35 people and serves groundwater from the system’s source. Based on this information, the water system
will be required to collect one sample from one (1) Disinfection Byproduct (DBP) sample site per year. The disinfection byproduct sample should be a paired sample of Total Trihalomethanes
(TTHM) and Haloacetic Acids (HAA5). The annual DBP sample set must be collected during the July 1 - September 30, 2025, monitoring period.
Water system staff will need to select one (1) site(s) to be sampled for DBPs. A sampling plan form is enclosed with this letter and will need to be completed and submitted to the Division
within 30 days from the date of this letter.