DDW-2024-007281

April 23, 2024
Joette Marie Rex
Slot Canyons Inn
3680 West State Highway 12
Escalante, Utah 84726
Subject:Operating Permit, New Public Water System Engineering Review
Exception to R309-515-6(6)(i), Well Sealing Requirements for Slot Canyons Well (WS001)
Temporary Exception to R309-510-8, Storage Capacity Requirement
Slot Canyons Inn, System #09104, File #13384
Dear Joette Marie Rex:The Division of Drinking Water (the Division) sent you a New Public Water System Initial Order on April 19, 2021. This letter was sent to you as it was determined
that the water system that provides water to your business had met the threshold criteria to be identified as a Public Water System (PWS).Project HistoryA technical assistance site visit
was conducted by J. Paul Wright, DEQ Southwest District Engineer, on May 24, 2022. All of the information from the Initial Order letter was discussed with you at that time, an inspection
of the facilities was conducted, and a follow-up email was sent to you on May 25, 2022, summarizing the details of the site visit providing further information about the requirements
of being a Public Water System and the next steps you needed to take.An engineering evaluation report detailing the water system and its facilities was submitted to the Division by Devan
Shields, P.E., Sunrise Engineering, on May 16, 2023. An initial review of the evaluation report was conducted, and review comments were sent to you and your engineer on May 16, 2023.
A revised engineering evaluation report was submitted on July 31, 2023. Additional review comments were sent to you and your engineer on August 23, 2023. A final set of responses and
revisions to those comments were submitted to the Division on January 5, 2024.During this process, the Drinking Water Source Protection Plan for the well (described below) was also reviewed
by the Division with several drafts of the Preliminary Evaluation Report (PER) being submitted between May 19, 2022, and February 21, 2024. Review comments followed each time. A final
Drinking Water Source Protection (DWSP) Plan was concurred under a separate letter sent on March 7, 2024.Water System Description
Our understanding of the water system is that the Slot Canyons Inn provides water to five residential homes, some of which are used as nightly rentals; a bed and breakfast inn that has
10 rooms; and a restaurant with an 18-seat capacity. This business and water system was in existence before being identified as a PWS, therefore some of the facilities listed below have
been modified to meet current DDW construction requirements and where that was not possible, exceptions have been requested. A description is provided below for each of the drinking
water facilities included in the water system:
Slot Canyons Well (WS001) - The well was drilled in 2015 to a total depth of 85 feet and a surface (grout) seal was installed to a depth of 30 feet with another 20 feet of bentonite
down to 50 feet. As such, an exception has been requested for this surface seal since it does not extend to a depth of 100 feet. The exception is described below. The well is equipped
with a Flint & Walling Model No. 4F55S50, 5 HP submersible pump, and has a pumping capacity of about 60 gallons per minute (gpm). This well provides all of the water supply and pressure
(in conjunction with pressure tanks) for the water system. A 24-hour constant rate pump test was conducted at 90 gpm, which would allow for a safe yield of 60 gpm at ⅔ of the maximum
pump test rate. A Cummins RS20AC Generator has been installed to provide backup power for the well and treatment plant.
Iron Removal Treatment (TP001) - The Iron Removal Water Treatment Plant (TP001) uses media filtration to remove the high iron in the Slot Canyons Well (WS001). This facility consists
of a Nugen iron filter, using Clack Filter media, and a Nugen water softener. There is one train of treatment processes with a design capacity of 30 gpm and a continuous service flow
rate of 22 gpm.
Distribution System (DS001) - The Slot Canyons Inn distribution system consists of about 5,200 linear feet of 2-inch diameter HDPE pipe and 250 linear feet of 1-inch diameter HDPE pipe.
This pipe distribution system in conjunction with the well has been hydraulically modeled and it was determined that the minimum required pressures were achieved under the peak day demands
(40 psi) and peak instantaneous demands (30 psi). No fire hydrants were installed on this water system.
Cliff House Booster Pump (PF001) - This small booster pump was installed to make sure this one rental house at the upper end of the water system would have adequate water pressure.
The house is owned by the Slot Canyons Inn and as such, the booster pump is operated by them as well and is included as a facility. The booster pump is a ¾ HP Grundfos Scala2 3-45-1
pump and has a backup ready to install in the event this pump is out of service.
Three Pressure Tanks (HD001) - The pressure tanks all receive water from the well and keep the water system pressurized to reduce the cycling of the well submersible pump. All three
are State Pump Mate Diaphragm pump tanks, each with a 50-gallon capacity.
Operating Permit
We have received the following information for the Slot Canyons Inn Water System and its water system facilities described above:
An Engineering Evaluation report describing each facility’s details.
Documentation of valid water rights.
As-built or record drawings including photos of the water system facilities.
An approved Drinking Water Source Protection Plan for the Slot Canyons Well (WS001) and Land Use Agreements.
Satisfactory bacteriological results during the recent operation of the water system.
Complete New Source Chemistry data for the Slot Canyons Well (WS001).
We have determined that all conditions of operating permit issuance have been met. On this basis, an Operating Permit for the existing Slot Canyons Inn Water System (09104) and all of
its associated facilities described in this letter is hereby issued as constituted by this letter.
Please maintain a copy of this letter with your permanent records for future reference.
Permanent Exception to R309-515-6(6)(i), Well Sealing Requirements for the Slot Canyons Well (WS001)
Background Information Related to this Exception Request:
Slot Canyons Inn is a newly designated PWS and the Slot Canyons Well (WS001) was constructed before this designation. The well was constructed to a total depth of 85 feet. As part of
the Preliminary Evaluation Report, existing geologic information was researched. The only known aquifer at the well site and on the property owned by Slot Canyons Inn has a depth of
about 80 feet called the Straight Cliffs Sandstone aquifer and has a saturated interval of about 30 to 50 feet. Due to this, it is not possible to construct a well with a 100-foot grout
seal.
Beneath the Straight Cliffs Sandstone aquifer, geologic reports in the area indicate that the formation below that is Tropic Shale and is low permeability and has low water quality.
There are no known wells in the nearby vicinity drilled into this formation due to this. Underlying the Tropic Shale is the Navajo Sandstone aquifer starting at about 950 feet. A completed
well would likely have to be drilled to a depth of 1,100 feet to reach water. The cost to drill a well to this depth would be cost-prohibitive, especially considering that there are

no known wells within five miles of the site that have been drilled to this depth.
Exception Request
On April 30, 2022, as part of the first Preliminary Evaluation Report submission, the Division received your exception request to Rule R309-515-6(6)(i). The basis for your request for
an exception to Rule R309-515-6(6)(i), Well Sealing Techniques and Requirements is to allow the previously constructed grout seal to a depth of 30 feet with another 20 feet of bentonite
installed to a depth of 50 feet, instead of to a total depth of 100 feet. All other components of the well were drilled according to DDW rules.
To provide equivalent protection for public health and safety and to meet the intent of the rule, the following items are considered:
The DWSP has been concurred with and it was found that there are no uncontrolled potential contamination sources or pollution sources located in Zones 1 and 2, therefore there are no
potential issues of contamination to this shallow aquifer.
As a condition of allowing this exception, increased monitoring of the Slot Canyons well will be required as follows:
a.This water system is required to take monthly bacteriological samples of the Slots Canyon Well (WS001) before any treatment (at the well smooth-nosed sample tap), for the months the
well is in operation. The source sampling requirement shall begin with the 2024 operating season and last at least two operating seasons as long as the well is being used.
The purpose of the source sampling requirement is to gather data to evaluate the quality of the source water from Slots Canyon Well (WS001) and determine whether primary disinfection
treatment is required or not.
Label the source samples with WS001 as the sampling location. 
The required source bacteriological sampling is shown on your monitoring schedule for this sample site. Please note that the source sampling is in addition to the distribution system
bacteriological sampling already in place, which is labeled DS001. 
After two seasons of source sampling data become available, the Division will evaluate the results to determine whether primary disinfection is required for Slots Canyon Well (WS001).
Please contact Sitara Federico for any positive samples that may occur at the source at 385-515-1459 or [e-mail]. If any sample result comes back as E. coli positive, please
contact the Division within 24 hours of being notified of the result.
b. This water system is required to take one Nitrate sample representative of the Slots Canyon Well after it has undergone treatment at the Iron Removal Treatment Plant (TP001) each
quarter that the well is in operation. For a year-round system, this equates to four (4) Nitrate samples per year. Please label all post-treatment samples as TP001 as both the Facility
ID and Sample Point ID on laboratory paperwork.
c.All of this will be evaluated over time to determine if it is sufficient to protect public health.
On this basis, an exception to Rule R309-515-6(6)(i), Well Sealing Techniques and Requirements, is hereby granted for the Slot Canyons Well (WS001) to have a 30-foot cement surface seal
with 20 feet of bentonite to a depth of 50 feet in lieu of the required 100-foot surface seal.
Temporary Exception to R309-510-8, Storage Capacity RequirementThis Temporary Exception Expires on June 30, 2027.
On December 14, 2023, the Division received your request for an exception to Rule R309-510-8 regarding the storage capacity requirement for Public Water Systems. According to this rule,
“all public drinking water systems shall provide equalization storage.”
The basis for your request for an exception is that you do not have sufficient equalization storage as stated previously. According to your calculations, the water system would require
2,750 gallons of equalization storage. However, guidance in Rule R309-510-8(2) allows for transient non-community water systems to meet the intent of having equalization storage. The
configuration of the system is one of those items that meets the intent of equalization storage.
The Slot Canyons Well (WS001) has a 5 HP pump that can pump 60 gallons per minute (gpm). The well also has a generator hooked up in the event the power goes out. The peak day source
capacity requirement for the water system is about 4.5 gpm. The well pump capacity of 60 gpm far exceeds the peak day source capacity requirement. The water system also includes a series
of 3 hydropneumatic tanks (HD001) that have a total of 150 gallons of capacity for storage and that hold pressure in the system. The tanks hold pressure in the system at a minimum of
40 psi at which point the well automatically turns on to pressurize the hydropneumatic tanks again.
The configuration of the system described above meets all of the flow and pressure requirements needed to operate the water system safely and adequately for the Slot Canyons Inn. In
essence, the groundwater acts as storage in a system like this.
On this basis, an exception to R309-510-8, Storage Capacity Requirement, is hereby granted for the Slot Canyons Inn water system (09104).
This Temporary Exception expires onJune 30, 2027.
You must verify that the water system demands have not increased to the point that the well is not able to keep up with those demands and meet the intent of having equalization storage.

You will be required to re-submit an exceptionrequest and obtain an exception renewal prior to June 30, 2027.
Exceptions granted by the Division include an expiration date to ensure that the basis and conditions for granting the exception are verified periodically and that the drinking water
quality remains protected. After receiving your request, the Division will determine whether this exception can be re-issued.
This Temporary Exception may be rescinded at any time if new evidence indicates that the conditions of this exception are no longer being met or a public health risk exists due to this
exception.Source Monitoring Requirements
Issuance of this Operating Permit changes your water system’s monitoring and reporting
requirements. The monitoring requirements for this well are given below. An updated monitoring schedule can be viewed at any time at waterlink.utah.gov under the Water Monitoring section.Facility
with new requirementsAnalyte(s) Required# of samplesSampling FrequencyNext Due DateRule ReferenceTP001 Iron Removal TreatmentNitrate1Quarterly07/01/2024-09/30/2024R309-205-5(4)(b)Sulfate1Every
three years01/01/2023-12/31/2025R309-205-5(3)(a)Iron1Monthly06/01/2024-06/30/2024R309-215-6(2)(a)
The monthly Iron requirement will remain in place until six months of samples have been received. If treatment proves to be effective the monthly requirement will be reduced to one sample
per quarter. Please contact David Kruse at (385)-566-7789 or [e-mail] for questions regarding the source monitoring and reporting requirements for your water system.The issuance
of this Operating Permit resolves your water system’s deficiencies below:G001 – Unapproved Facilities in Service – 50 pointsS001 – Unapproved Source in Service – 200 pointsAn updated
IPS report isavailable at https://waterlink.utah.gov. Please contact Jennifer Yee at [phone] or [e-mail] for questions related to your water system’s IPS report or deficiencies.
If you have any questions regarding this Operating Permit, please contact J. Paul Wright, P.E., DEQ Southwest District Office, at [phone], or Michael Newberry, Permitting and
Engineering Manager, at [phone].
Sincerely,
Russell Seeley, P.E.
Assistant Director
JPW/mrn/mdb

Attachments - Addendum 1cc: Jeremy Roberts, Southwest Utah Public Health Dept., [e-mail]
J. Paul Wright, P.E., DEQ Southwest District Engineer, [e-mail]
Joette Marie Rex, Slot Canyons Inn, [e-mail]
Adam Rex, Slot Canyons Inn, [e-mail]
Kyler LaRose, Sunrise Engineering, [e-mail]
Devan Shields, P.E., Sunrise Engineering, [e-mail]
Danielle Zebelean, P.E., Division of Drinking Water, [e-mail]
Sitara Federico, Division of Drinking Water, [e-mail]
David Kruse, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Colt Smith, Division of Drinking Water, [e-mail] Smith, Division of Drinking Water, [e-mail]
Nagendra Dev, P.E., Division of Drinking Water, [e-mail] 09104 13384 System OP and EGADDENDUM 1Project OverviewSlot Canyons Inn Water System (UTAH#09104)Iron Removal Water
Treatment Plant (TP001)The Slot Canyons Inn (The System) is an existing water system that was issued a new system order (NSO) on April 19, 2021. As part of the NSO, The System is required
to obtain an operating permit for the existing water system facilities. One of the facilities is a Nugen iron filter, using Clack Filter media, and Nugen water softener to help filter
out the high iron in the Slot Canyons Well (WS001). The iron removal process does not use any oxidation to help remove the iron.Iron is not known to cause any health risks but does cause
discoloration in the water and premise plumbing which is why it is classified as a secondary contaminant for aesthetic purposes and is commonly filtered out of water.The iron removal
water treatment plant consists of a media absorption process. The Iron Removal Treatment Plant (TP001) has a plant design capacity of 30 gallons per minute (gpm) with a continuous service
flow rate of 22 gpm. The design includes 1 train of the media absorption process.The proposed treatment plant consists of the following processes in sequence:First-stage media adsorption
– Nugen Brand, Model BF-FUS-1.5-MMIR-1895; with garnet gravel, filter sand, filter ox, and filter ag plus; 1 train; 30 gpm per train. The Iron filter backwashes at 17 gpm and backwashes
every night.Second-stage media adsorption – Nugen Brand, Model LCS-FUS 1.5M-150; cation water softening resin; 1 train; 35 gpm per train. The water softener backwashes at 6.5 gpm and
also backwashes every night.