DDW-2024-007470

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

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF DRINKING WATER
Nathan Lunstad, P.E.
Director

April 29, 2024

Vern Rosenstiel
Pinecliff Camp
11052 South Grapevine Cove #S204
Sandy, UT 84070

Subject: NOTICE OF VIOLATION – Failure to Monitor Distribution System Chlorine Residuals,
Pinecliff Camp (UTAH22078)

Dear Vern Rosenstiel:

Our records indicate that Pinecliff Camp is in violation of the State of Utah Public Drinking Water Rules as
follows:

As a system that disinfects or purchases disinfected water, Pinecliff Camp is required to take a minimum of
12 chlorine residuals per month in the distribution system per Rule R309-105-10(1)(c). Disinfectant
residual results for this system were not reported to the Division of Drinking Water (DDW) for the January
1st, 2024, to March 31st, 2024, compliance period.

In accordance with Rule R309-400, failure to take these samples and report them to DDW has resulted in
the addition of 15 Improvement Priority System (IPS) points to this water system’s IPS report for every
month that the Division did not receive chlorine residual data. These violations and associated points can
be resolved by collecting and reporting the required residual data in a future quarter.

Pinecliff Camp staff must notify all the water system’s consumers of this violation within one year after
notification of this violation (see R309-220-7). Refer to the enclosed example of a public notice. A copy of
the notice sent to the system’s consumers must be forwarded to the Division of Drinking Water
Vern Rosenstiel
Page 2 of 18
April 29, 2024

([e-mail]) within ten days after issuing the notice (see R309-105-16(2). Failure to provide the
required public notification within one year will result in the addition of five points to this system’s IPS.
report.

If the distribution system chlorine residual sampling has been completed for the compliance period above,
please contact the Division to resolve this issue. Attached is an informational sheet that describes how
water system staff can submit chlorine residual data online. Please contact Luke Treutel at [phone]
or [e-mail] if you have any questions or need assistance regarding this notice. Thank you for your
efforts to maintain safe drinking water.

Sincerely,
Mark Berger
Rules Section Manager

Enclosure –
3-Quarterly Notice-Chlorine Monitoring
Distribution System Chlorine Residuals

cc: Vern Rosenstiel, Pinecliff Camp, [e-mail]
Nathan Brooks, Summit County Health Department Luke Treutel, Utah Division of Drinking Water, [e-mail]
Instructions for Monitoring Violations Annual Notice – Chemical Monitoring (Tier 3)

Template on Reverse

Since most monitoring violations are included in Tier 3, you must provide public notice to persons served
within one year after you learn of the violation (R309-220-7(2)). Multiple monitoring violations can be
serious, check with the Division of Drinking Water (801-536-4200) to make sure you meet the public
notification requirements.

Community systems must use one of the following (R309-220-7(3)(a)):

Χ Hand or direct delivery
Χ Mail, as a separate notice or included with the bill

Non-community systems must use one of the following (R309-220-7(3)(b)):

Χ Posting in conspicuous locations
Χ Hand delivery
Χ Mail

In addition, both community and non-community systems must use another method reasonably
calculated to reach others if they would not be reached by the first method (R309-220-7(3)). Such
methods could include newspapers, e-mail, or delivery to community organizations. If you post the
notice, it must remain posted until the violation is resolved. If the violation has been resolved, you must
post the notice for at least one week (R309-220-7(2)). If you mail, post, or hand deliver, print your notice
on letterhead, if available.

The notice on the reverse is appropriate for insertion in an annual notice or the CCR, as long as public
notification timing and delivery requirements are met (R309-220-7(4)). You may need to modify the
template for a notice for individual monitoring violations. This example presents violations in a table;
however, you may write out an explanation for each violation if you wish. For any monitoring violation for
volatile organic compounds (VOCs) or other groups, you may list the group name in the table, but you
must provide the name of every chemical in the group on the notice, e.g., in a footnote.

You may need to modify the notice if you had any monitoring violations for which monitoring later showed
a maximum contaminant level or other violation. In such cases, you should refer to the public notice you
issued at that time.

Include in your notice the standard language for monitoring and testing procedure violations in italics
(R309-220-8(4)(b)). If you modify the notice, you may not alter this mandatory language.

Corrective Actions

In your notice, describe corrective actions you took or are taking. Listed below are some steps commonly
taken by water systems with monitoring violations. Choose the appropriate language, or develop your
own:

Χ We have since taken the required samples, as described in the last column of the table above.
The samples showed we are meeting drinking water standards.
Χ We have since taken the required samples, as described in the last column of the table above.
The sample for [contaminant] exceeded the limit. [Describe corrective action; use information
from public notice prepared for violating the limit.]
Χ We plan to take the required samples soon, as described in the last column of the table above.

After Issuing the Notice

Make sure to send the Division of Drinking Water (PO Box 144830, SLC, UT 84114-4830) a copy of each
type of notice and a certification that you have met all the public notice requirements within ten days after
issuing the notice (R309-105-16(3)).

IMPORTANT INFORMATION ABOUT YOUR DRINKING WATER
Monitoring Requirements Not Met for [System]

Our water system violated several drinking water standards over the past year. Even though
these were not emergencies, as our customers, you have a right to know what happened and
what we did to correct these situations.

We are required to monitor your drinking water for specific contaminants on a regular basis.
Results of regular monitoring are an indicator of whether or not our drinking water meets health
standards. During [compliance period] we ['did not monitor or test' or 'did not complete all
monitoring or testing'] for [contaminant(s)] and therefore cannot be sure of the quality of our
drinking water during that time.

What should I do?

There is nothing you need to do at this time.

The table below lists the contaminant(s) we did not properly test for during the last year, how
often we are supposed to sample for this contaminant and how many samples we are supposed
to take, how many samples we took, when samples should have been taken, and the date on
which follow-up samples were (or will be) taken.
Contaminant Required
sampling
frequency
Number of
samples
taken
When all samples
should have been
taken
When samples
were or will be
taken Chlorine Residual Levels
in Distribution system
12 readings
every month

0 January – March,
2024
PWS EDIT THIS
FIELD

What happened? What is being done?

[Describe corrective action.]

For more information, please contact [name of contact] at [phone number] or [mailing address].

Please share this information with all the other people who drink this water, especially those who
may not have received this notice directly (for example, people in apartments, nursing homes,
schools, and businesses). You can do this by posting this notice in a public place or distributing
copies by hand or mail.

This notice is being sent to you by [system]. Water System ID#: __________. Date distributed:

7/30/2021 - This is a brief overview of the rule and does not serve as a substitute for actual rule language.
DISTRIBUTION SYSTEM
CHLORINE RESIDUALS
Quarterly Treatment Reports are required to be sent to the Division of
Drinking Water (DDW), per R309-105-10(1).

The quarterly report provides DDW with three main components:
1. DBP Results
2. Chlorine Residual Results from the distribution system
3. Operational Data
(rotameter/pump settings, volume of water treated, etc.)

A template for these reports was provided in 2005 to all public systems
in Utah. We have updated and simplified this report, now available on
the DDW Website.
OLD WAY NEW WAY
Disinfection
By-Products
CHLORINE
RESIDUALS
OPERATIONAL
DATA
Disinfection
By-Products
CHLORINE
RESIDUALS
OPERATIONAL
DATA
Record, track,
and report
data on old
form
Send all individual
residuals on old
form
Record detailed
operations on old
form
Ask your lab to
send us the data
electronically
Submit averages online at
https://MRDL.utah.gov
Download Quarterly
Chlorination Report
online under Forms,
Disinfection By-Products
(DBP) Rule
*** Systems purchasing chlorinated water DO NOT need to report operational data.

Failure to submit your quarterly data will result in a violation. Each month is worth 10 IPS points (R309-400-3).
Applies
to:
Systems That Chlorinate or Purchase
Chlorinated Water
How many residuals should I be taking?
All disinfecting systems, or systems purchasing disinfected
water, must sample a minimum of 3 chlorine residuals within
the distribution system per week, which equates to at least 12
per month.

Each time you sample for coliform bacteria you should also
be taking a chlorine residual test. The coliform sample re-
siduals can count towards your system ’s total distribution
residual requirement.
When do I submit?
10 days after every calendar quarter a system is
in operation.
Qtr 1 Qtr 2 Qtr 3 Qtr 4
April 10th July 10th October
10th
January
10th
How do I report monthly chlorine residuals?
Navigate to https://MRDL.utah.gov in your web browser.

A link to report chlorine residuals online can also be
found on our website (https://drinkingwater.utah.gov)
under Chlorine Reporting
These reports provide DDW more information than needed to confirm compliance with regulation. In order to make these easier
for systems and DDW, we have a new way you can submit that information.

Here is the Old Way vs. the New Way:
For more information, or to answer questions, please contact the DBP Rule Manager, Morgan Vinyard at [phone]
[e-mail]

7/30/2021 - This is a brief overview of the rule and does not serve as a substitute for actual rule language.
The link or web address will take you to this page:

1. Enter your Email Address
When you’ve finished submitting your residuals this address
will receive a confirmation email.

2. Enter your System #: UTAH#####
No spaces between UTAH and your FIVE DIGIT number.

3. Choose the Reporting Year:
This is important to indicate if you’re submitting old data or
new data.

4. Select the Reporting Quarter:
Click to indicate which quarter the data was collected.
5. Enter the number of samples taken
for each month (minimum of 12).

6. Enter the average sample results of
the chlorine residuals taken for each
month.

7. Enter your name, email address,
and confirm the information provided is
correct.

8. Click Submit.
A confirmation will be sent to the provided email
address to ensure your system ’s compliance for
the quarter, and your residual information will be
uploaded into the state database in a timely
manner.