DDW-2025-008636

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-
Telephone [phone] • Fax [phone] • T.D.D. (801) 903-
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

May 19, 2025

Kevin Mclaws
Zion Frontier Resort
Zion Land Holdings
1382 South 325 West
Hurricane, UT 84737

Subject: Notice of IPS Point Exceedance and Potential Water System Not Approved Rating
Change; Zion Frontier Resort, UTAH13039

Please be advised that a response is requested within 30 days of receiving this
certified mail.

Dear Kevin Mclaws:

This letter serves to inform you that the Zion Frontier Resort Water System, UTAH13039,
currently has 115 IPS points assessed. The Improvement Priority Systems (IPS) sets points for
compliance requirements based on the risk to public health and thresholds based on the type of
system. The Zion Frontier Resort Water System’s current score exceeds the 100 points for the
Transient Non-Community type as set in R309-400. The Division of Drinking Water (the
“Division”) intends to rate Zion Frontier Resort “Not Approved” if there is no response to the
Division within 30 calendar days of receiving this notice. Your response may include any of the
actions listed below to prevent a Not Approved Order:
1. Ask the Director for reconsideration by providing additional information to the Division
demonstrating the attached IPS report needs to be revised.
2. Correct any outstanding noncompliance items in the attached report and submit evidence
of its correction to the Division. This can include taking any missing chemical samples,
correcting any deficiencies, and/or submitting any evidence that violations or deficiencies
were issued in error.
3. Request a Corrective Action Plan (CAP) through requestcap.utah.gov. This informal
agreement between the System and the Division establishes a schedule to allow more time
to correct unresolved significant deficiencies in the attached report. A CAP is not available
for violations or minor deficiencies.
4. If the system has violations or has failed a previously executed CAP, the system must enter
into a Compliance Agreement/Enforcement Order (CA/EO). A CA/EO is formal
Zion Frontier Resort
Page 2
enforcement and establishes a schedule for systems to return to compliance. The System is
typically rated “Corrective Action” rather than “Not Approved” and has input on timelines
for meeting compliance deadlines. For inquiries regarding a CA/EO, please contact Colt
Smith at [phone] or [e-mail].
Failure to respond to the Division within 30 calendar days from the receipt of this notice may
result in the following:
1. The Director issuing a formal enforcement order rating your water system’s rating “Not
Approved.”
a. The Not Approved Order is a formal administrative notice and provides the
Director the ability to issue penalty amounts of up to $1,000 per violation per day.
b. This Not Approved Order, at a minimum, requires a system to issue public notice
every 90 days informing their customers of the “Not Approved” rating.
2. The Director may assess an additional 25 to 200 IPS points to your water system for
failing to protect public health.
3. The Division may refer the System to the Utah Attorney General for civil action in district
court, asking for an injunction to ensure compliance with the State and Federal Safe
Drinking Water Act.
4. Failure to respond may also result in the U.S. Environmental Protection Agency taking
federal enforcement action to address the noncompliance shown in the attached report.
This notice serves as a courtesy to your water system, allowing them to come into compliance
voluntarily. This notice is a compliance advisory, is not an agency action, and does not trigger any
legal rights and/or remedies for the System. Additionally, nothing in this notice prevents the
Director from initiating formal enforcement at any time in the process. We urge you to take
immediate action on this matter. Compliance with the standards and regulations for drinking
water, as outlined in the Utah Safe Drinking Water Act, the Utah Drinking Water Rules, and the
Federal Safe Drinking Water Act, is essential to ensure safe, reliable drinking water and to protect
public health. We are dedicated to working together with you to help you come into compliance.
If you require assistance in responding to this notice, please contact Brandi Smith at (385) 515-
1650 or [e-mail].
Sincerely,
Nathan Lunstad, Ph.D., P.E.
Director
Division of Drinking Water
,
Zion Frontier Resort
Page 3

Enclosure: May IPS Report

cc: Kevin Mclaws, Zion Land Holdings-Zion Frontier Resort, [e-mail]
Jeremy Roberts, Southwest Utah Health Department, [e-mail]
Paul Wright, P.E., District Engineer, Division of Drinking Water, [e-mail]
Bret F. Randall, Assistant Attorney General, [e-mail]
Brandi Smith, Division of Drinking Water, [e-mail]
EQDWMonitoring, EQDWCOA, and EQDWFS
Utah Department Of Environmental Quality
Division Of Drinking Water
Admin Contacts
IPS 2020 Report
IPS Report
ZION FRONTIER RESORT PWS ID: UTAH13039 Rating: Approved 10/02/2019 Active
Legal Contact
ZION LAND HOLDINGS
KEVIN MCLAWS
1382 S 325 WHURRICANE, UT 84737
Phone: [phone]
County: KANE COUNTY
System Type: Transient Non-Community
Population: 206
Site Updates
Last Inventory Update: 08/26/2021
Last Surveyor Update: 05/17/2022
Surveyor: MATTHEW DON HINCKLEY
Operating Period: 1/1 - 12/31
Last IPS Update: 05/22/2025 14:10:00
Consumptive Use Zone
Irrigation Zone: null
Date:
Name Title Office Emergency Email
MCLAWS, KEVIN 435-632-6310 [e-mail]
IPS Summary Total IPS Pts: 115
Admin & Physical Facilities Quality & Monitoring Significant Deficiency
65 50.0 0
DEQ | Drinking Water
Run Date: 05/22/2025 15:06:22 | Rating: Approved UTAH13039 ZION FRONTIER RESORT page 1 of 3
Physical Facility Points 2020 Total Pts: 65
Facility Facility Name Status Points Effective
DS001 UTAH13039 DISTRIBUTION SYSTEM A 30.0
Code Description Severity Comments Determined Date NotAssessed Assessed
M006 CCC-LACKS WRITTENRECORDS OF CCCACTIVITIES
MIN System lacks detail records ofcross connection activities.05/17/2022 15
M007 CCC-LACKS ON-GOINGENFORCEMENTIMPLEMENTATION
MIN System lacks records of on-going enforcement activities.05/17/2022 15
ST001 RESERVOIR A 15.0
Code Description Severity Comments Determined Date NotAssessed Assessed
V004 STORAGE TANKLADDERS IN EXCESSOF 20 FEET LACKSAFETY FEATURESUCH AS CAGE,HARNESS ORPLATFORM
MIN 07/23/2019 15
WS002 LODGE WELL A 20.0
Code Description Severity Comments Determined Date NotAssessed Assessed
S026 NO FLOW METER ONWELL DISCHARGEPIPING
MIN SOURCE 02 LACKS FLOWMEASURING DEVICE 06/25/2004 5
S015 WELL LACKS AMEANS TO MEASUREWATER LEVELSPERIODICALLY
MIN 09/23/2016 5
S023 NO SMOOTH NOSEDSAMPLING TAP ONDISCHARGE PIPING
MIN No smooth nose sampling tapwas present on dischargepiping.
05/17/2022 5
S027 NO SHUT OFF VALVEON WELL DISCHARGEPIPING
MIN There was not a shut offvalve present.05/17/2022 5
Microbial Rule Violations Total Pts: 50
Determined Compliance Period Code Violation Type Return ToCompliance Point Effective
12/24/2024 11/01/2024 - 11/30/2024 3A MONITORING, ROUTINE,MAJOR (RTCR)N 25.0
03/28/2025 02/01/2025 - 02/28/2025 3A MONITORING, ROUTINE,MAJOR (RTCR)N 25.0
Operator Certification
Type Level Required Highest Certificate
Distribution
Treatment
DEQ | Drinking Water
Run Date: 05/22/2025 15:06:22 | Rating: Approved UTAH13039 ZION FRONTIER RESORT page 2 of 3
Open Compliance Schedule
Type Required Activities Severity Created Due
Revised Total Coliform Rule SAMPLING SITE PLAN SUBMITTAL 01/01/2017 09/30/2017
DEQ | Drinking Water
Run Date: 05/22/2025 15:06:22 | Rating: Approved UTAH13039 ZION FRONTIER RESORT page 3 of 3