DDW-2024-007479

May 7, 2024
Clint McAffee
Park City Water System
PO Box 1480
Park City, Utah 84060
Subject:ConditionalOperating Permit, 3 Kings Water Treatment Plant (TP015) and Finished Water Pump Facility (PF018); Park City Water System, System #22011, File #10433
Dear Clint McAffee:This letter provides a summary of the Division of Drinking Water’s (the Division) decision to issue a Conditional Operating Permit for 3 Kings Water Treatment Plant
(identified as TP015 in the Division’s database). The letter includes the following sections and addenda:ConditionalOperating Permit for 3 Kings Water Treatment Plant (TP015) and Finished
Water Pump Facility (PF018)Project Overview (Addendum 1)Compliance Strategy for Achieving Surface Water Treatment Goals (Addendum 2)Metals Removal Water Treatment –Monitoring and Reporting
Regulations (Addendum 3)Summary of Surface Water Treatment Monitoring and Reporting Regulations (Addendum 4)Conditional Operating Permit for 3 Kings Water Treatment Plant (TP015) and
Finished Water Pump Facility (PF018)We have received the following information prior to issuing the ConditionalOperating Permit for3 Kings Water Treatment Plant(TP015) and Finished Water
Pump Facility (PF018):
Certification of Rule Conformance with plan approval conditions by a professional engineer.
As-built or record drawings.
Satisfactory bacteriological results as evidence of proper disinfection and flushing.
Evidence of O&M manual delivery.
Water quality data —
7 days of operational data including:
IFE, CFE and clearwell turbidity (highest reading at 4-hour intervals)
Minimum chlorine residual, pH and temperature
Minimum volume and peak flow for detention time calculations
UV data: minimum validated dose, UVT%,
New source chemistry results on the combined raw water (including recycled water) and finished water at the following locations:
Raw water at rapid mix influent, a blend of Judge and Spiro Tunnels (WS001 and WS006) and recycled water
Thiriot Springs (WS001)
Point of Entry after all treatment (TP015)
Demonstration of Performance (DOP) Framework as approved by the Division on June 21, 2023.
Documentation of Best Management Practices (BMPs) developed to provide additional protection of the water quality throughout the treatment plant processes until the DOP has been completed
and the final log removal value (LRV) credits have been established.
We have determined that all conditions for a conditionaloperating permit issuance have been met. On this basis, aConditionalOperating Permit for 3 Kings Water Treatment Plant(TP015),
as a metals removal and surface water treatment plant, andFinished Water Pump Facility (PF018), is hereby issued as constituted by this letter with the following conditions:
The Division temporarily grants 3 Kings Water Treatment Plant (TP015)LRV credits for the pre-treatment processes and Pyrolusite (manganese dioxide) pressure filters of 2:1.5:1.5 (Giardia,
Crypto, virus). The balance will be achieved through UV and chlorine disinfection to achieve full surface water treatment requirements for a Bin 1 source of 3:2:4.
ADOP will be conducted to determine the LRV credits for the Pyrolusite media pressurefiltration process.
The results of the DOP must be submitted to the Division and a permanent Operating Permit must be requested. The request will include a summary of the LRV credits determined by the DOP
and thefinal operational strategy for achieving surface water treatment requirements.
The established BMPs must be used to protect the integrity of the groundwater sources until the DOP has determined that the pyrolusite media filtration can be approved as an alternative
filtration process for surface water treatment.
Please maintain a copy of this letter with your permanent records for future reference.
The issuance of this Conditional Operating Permit changes your water system’s monitoring and reporting requirements. Please see the enclosed addendumsfor the details of these changes.
An updated monitoring schedule can be viewed at any time at waterlink.utah.gov under the Water Monitoring section. If there are any additional changes to your system’s monitoring requirements,
the staff of the Water QualityMonitoring and Standards Section will follow up to provide an updated monitoring scheduleto you. Please contact Mark Berger, Water Quality Monitoring and
Standards Manager, at(801) 641-6457 for assistance regarding the monitoring and reporting requirements for your watersystem.
If you have any questions regarding this Conditional Operating Permit, please contact Julie Cobleigh, of this office, at [phone], or Michael Newberry, Permitting and Engineering
Manager, at [phone].
Sincerely,
Russell Seeley, P.E.
Assistant Director
JJC/DM/ DK/ SEP/mrn/mdbEnclosuresAddendum 1. Project OverviewAddendum 2. Compliance Strategy for Achieving Surface Water Treatment GoalsAddendum 3. Metals Removal Treatment- Monitoring
and Reporting Requirements and Antimony Blending PlanAddendum 4. Summary of Surface Water Treatment Monitoring and Reporting Regulationscc:Nathan Brooks, Summit County Health Department,
[e-mail] Zalla, Jacobs Engineering, [e-mail] McAffee, Park City Water System, [e-mail] DeHaan, Park City Water System,
[e-mail] Cobleigh,P.E., Division of Drinking Water, [e-mail]
Sitara Federico, Division of Drinking Water, [e-mail]
Luke Treutel, Division of Drinking Water, [e-mail]
David Kruse, Division of Drinking Water, [e-mail]
Sarah Page, Ph.D., Division of Drinking Water, [e-mail]
Dylan Martinez, Division of Drinking Water, [e-mail] 1Project Overview
Park City Water System (UTAH#22011)
3 Kings Water Treatment Plant (TP015)

The Division of Drinking Water (the Division) received a request for a Conditional Operating Permit for the 3 Kings Water Treatment Plant (WTP) project from you on April 23, 2024. The
Division issued a Conditional Plan Approval on July 6, 2020, Unconditional Plan Approval on April 14, 2021,to include approval of the UV validation report, andan Amended Plan Approval
on June 30, 2021, to correct the source water facility names that the plant is treating. The3Kings WTP is identified as TP015 in the Division’s database.
Our understanding of the project is that the 3Kings WTP (TP015) will treat the Judge Tunnel (WS001)and Spiro Tunnel (WS006) for metals removal and surface water treatment. Thiriot Spring
(WS003) is combined to the filtered Judge and Spiro Tunnels flows ahead of UV and chlorine disinfection. The Park City Water System(the System) is required to treat Mine Impacted Water
(MIW) according to the City’s Amended Stipulated Compliance Order (ASCO) by the Division of Water Quality (DWQ) to reduce metals in the locally impacted streams. The DWQ ASCO requires
the System treat to DWQ standards, which are lower than drinking water maximum contaminant levels (MCLs), for Antimony (found in the Judge Tunnel(WS001) and the Spiro Tunnel (WS006))
and Cadmium (Judge Tunnel(WS001)). Drinking water primary and secondary MCLs dictate the following metals removal: Arsenic (Spiro), Thallium (Spiro), lead (Spiro), and Zinc (Judge).
A full-scale pilot plant operated at the site from April 2016 until October 2016 to demonstrate proof of performance and validate the treatment technology effectiveness to treat mine
influenced water from the Judge and Spiro Tunnel (WS001 and WS006). The Division concurred with the Pilot Test Protocol on October 12, 2016. The System continued to operate the adsorption
testing on Spiro Water Treatment plantuntil the plant was demolished in late 2019.
The Division originally approved the 3Kings WTP (TP015) as a metals removal plant with an option for operating as a conventional surface water treatment plantin the event the Judge and
Spiro Tunnel groundwater sources (WS001 and WS006) were classified as under the direct influence (UDI) of surface water. The approval as a conventional surface water treatment plant
was based on piloting results for the pressurized Pyrolusite media filters with turbidity as the basis of the study. However, during a site visit conducted by the Division on February
15, 2022, concerns were brought up regarding the open basins throughout the treatment process inside the building and recycled flows. It was concluded that the treatment plant should
operate as a surface water treatment plant and comply with the monitoring and reporting requirements. It was also determined that the original piloting performed on the Pyrolusite media
filters did not comply with EPA’s requirements for demonstration of effective performance by alternative filtration.The Division requested additional testing, in the form of a Demonstration
of Performance (DOP) to determine the effectiveness of the alternative filtration technology.
On April 7, 2022, the Division sent an email regarding the intent to issue a Conditional Operating Permit for 3Kings WTP (TP015) to operate as a groundwaterUDI water treatment plant
and issue conditional log reduction value (LRV) credits while conducting a DOP. On June 21, 2023, the Division issued concurrence for the Revised Framework for DOPtesting. The DOP will
be conducted to determine the LRV credits assigned to the pretreatment and Pyrolusite filtration processes. Upon completion of the DOP, 3Kings WTP (TP015) will receive a final Operating
Permit.
On November 29, 2023, Division staff conducted an operating permit inspection and emphasized the need for Best Management Practices (BMPs) to protect the integrity of the water in the
open basins while under the Conditional Operating Permit period.
Project Design
The 3Kings WTP (TP015) provides a multiple barrier approach designed to treat mine impacted groundwater from Judge Tunnel (WS001) and Spiro Tunnel (WS006) through metals water treatment
technologyand to meet surface water treatment requirements.
The 3Kings WTP (TP015)consists of pre-oxidation, rapid mix, flocculation, and sedimentation at elevated pH for optimized metals removal, pressurized granular media filtration through
Pyrolusite (manganese dioxide)media, and post-filter titanium dioxide adsorption, pH adjustment for the distribution system, UV disinfection, and free chlorine contact time. Water from
the blended adsorber treated water may also be dechlorinated and discharged to the local stream system. The design also includes amicro hydro facility and raw water mix basin to allow
the System to have the ability tomanage the blending of flows from Judge Tunnel (WS001) and Spiro Tunnel(WS006).Thiriot Spring (WS003)is pumped from the existing springbox to tie into
the 3Kings WTP (TP015)downstream of adsorption for UV, chlorine disinfection, and pH adjustment before sending thecombined treated flow to the distribution system.Thiriot Spring (WS003)
is currently classified as agroundwatersource and the plant includes space for a future addition of pre and final cartridge filter units in the event the spring is classified as UDI
in the future.
The3Kings WTP (TP015) has a finished water capacity of 5,000 gallons per minute (gpm) or 7.2 million gallons per day (MGD) and a peak filtration rate of 5,507 gpm. The additional flow
over 5,000 gpm is required for backwash supply water. The design includes redundant trains for each treatment process. Thiriot Spring (WS003) has a yield of 1,500 gpm and is combined
with the 3Kings WTP (TP015) flows ahead of the UV and chlorine disinfection.The blended flows from the filters and Thiriot Spring (WS003) will not exceed 5,507 gpm and will vary in specific
source quantities set by the System based on operational strategies.
The combined flows are pumped from the 3Kings WTP (TP015) clearwell through the 3Kings WTP Finished Water Pump Facility (PF018). The Flowserve vertical turbine pumps deliver water from
the clearwell to the Thaynes Tanks (ST005 and ST006) and Boothill Tanks (ST004 and ST017) and consist of three (3), 100 HP, 2,250 gpm pumps going to the Boothill Tanks and three (3),
100 HP, 250 gpm pumps going to Thaynes Tanksthrough dedicated lines.  
Treatment Plant Processes Summary
Treatment Process
Treatment Goals
Key Information
Pre-treatment
Metals-Pre-oxidation to precipitate metals cadmium and zinc removal
Surface Water - Pre-chlorination to target metals removal, limit softening, and accumulation of calcium particles through plant.
pH elevation goal of 8.2 (8-1 to 8.3) with sodium hydroxide
Target free chlorine residual of 0.3 mg/L (as NaOCl) to meet the target oxidation reduction potential of 500 mV required for partial metals removal
Rapid Mix
Metals-Addition of primary coagulant to aid flocculation to remove arsenic, cadmium, lead, and zinc
Surface Water - Addition of primary coagulant to aid flocculation to remove suspended solids, organics, microbiological materials, and colloidal matter
Dosing ferric sulfate (10-12% Fe) as primary coagulant
Two Rapid Mix trains that operate in a duty-standby orientation, with jet injection lines designed to achieve turbulent flow, and meeting mixing requirements
Flocculation
Metals-Removal of arsenic, cadmium, lead, and zinc through flocculation and sedimentation
Surface Water–Removal of suspended solids, organics, microbiological materials, and colloidal matter
Three flocculation trains
Single train total volume of 7,312 cubic feet

Minimum detention time of 30 minutes (approximately 1,850 gpm per train
Peak flow rate influent of 5,551 gpm (7.99 MGD) including recycle flows
Staged velocity gradients of 60, 40 and 20 per second
Sedimentation
Metals-Removal of arsenic, cadmium, lead, and zinc
Surface Water-Removal of suspended solids including metals
Three sedimentation basins with lamella plate settlers
See Division File #12020 for exception granted R309-525-13 (3)(d)
All trains used in normal operation with peak operation capacity of 5,551 gpm (7.99 MGD)
Filtration
Metals-Removal of manganese, and thallium
Surface Water– Removal of suspended solids, organics, microbiological materials, and colloidal matter
Eight filters total with six active filters and two filters on standby during peak flow to achieve MCL removal of metals.
Mono media bed of pyrolusite (manganese dioxide) that is NSF/ANSI 61 certified
Peak operation flow rate at 5,507 gpm (7.93 MGD)
See Division File #12020 for exception granted for Filtration Rule R309-525-15 (4)(a-d) for a filter media type, bed depth, and loading rate.
Adsoprtion
Metals-Removal of antimony and a secondary barrier for all metals with a titanium dioxide media.
Surface Water–Additional filtration but no credit given due bypass options/blending plan
Six adsorber vessels, with number of online adsorbers depending on plant flowrate and water quality with a blending plan option to either partially or totally bypass.
Vessels utilize MetSorb® HMRG titanium dioxide media, supplied by Graver Technologies that is NSF/ANSI Standard 61 certified.
Peak operation flow rate at 5,507 gpm (7.93 MGD)
See Division File #12020 Exceptions to R309-525-14 Adsorber media type, depth and loading and R309-525-15 for backwash rate
Blending is controlled to meet the primary MCL for antimony. Bypassing or blending will allow the City to extend the life of the expensive media.
Finished water is analyzed to determine the LSI (Langelier Saturation Index), which provides an indication of the corrosivity of the finished water.
UV Disinfection
Metals-Provide voluntary primary disinfection with pathogen inactivation
Surface Water – Provide required primary disinfection with pathogen inactivation
Three UV disinfection trains (two duty one standby).
Treat water from all sources [Judge Tunnel (WS001), Spiro Tunnel Bulkhead (WS006), and Thiriot Spring (WS003)]
Trojan 2L12 medium pressure reactors.
UV facility meets R309-520(2) and (3) validation and design criteria
The goal of the UV disinfection system is to achieve at least 1.0-log Giardia inactivation with a validated UV dose of 2.1mJ/cm2 per Table 1.4 in the UV Design Guide Manual.
UV reactors are capable of treating up to 6.4 MGD per reactor.
Primary Disinfection Clearwell
Metals-provide voluntary pathogen inactivation
Surface Water – provide required pathogen inactivation
Finished water adjusted pH with either Sulfuric Acid (93%) or sodium hydroxide (25%) as needed.
The 3KWTP will include a chlorinator according to the following:
An onsite generation process that converts brine solution to sodium hypochlorite solution (0.8%).
Add sodium hypochlorite to the UV treated water
CT calculations summarized in Addendum 2.ADDENDUM 2Compliance Strategy for Achieving Surface Water Treatment Goals
Park City Water System (UTAH#22011)
3 Kings Water Treatment Plant (TP015)Treatment Goals per Surface Water Treatment Rules
The 3 Kings Water Treatment Plant (WTP) (TP015)is analternative surface water treatment and metals removal plant. Treatment technologies consists of pre-oxidation, rapid mix, flocculation
and sedimentation at elevated pH for optimized metals removal, pressurized granular media filtration through Pyrolusite (manganese dioxide) media, and post-filter titanium dioxide adsorption,
pH adjustment for the distribution system, UV disinfection, and free chlorine contact time. This plant was designed to meet the requirements of the surface water treatment rules, as
incorporated into Utah’s Rules in R309. These surface water treatment rules require removal and/or inactivation, expressed in terms of log10 credit, of Cryptosporidium, Giardia lamblia,
and viruses through treatment techniques.
The Surface Water Treatment Rule (SWTR) requires:
3-log10 removal/inactivation for Giardia lamblia, and
4-log10 removal/inactivation for virus.
The Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) established four bin classifications for Cryptosporidium based on concentration in the source water. If a water system
has source water classified in Bin 1, LT2ESWTR requires 2-log10 removal forCryptosporidium. If a water system has source water in Bin 2, Bin 3, or Bin 4, LT2ESWTR requires additional
treatment, disinfection or inactivation for Cryptosporidium, as outlined in EPA’s “Long Term 2 Enhance Surface Water Treatment Rule Toolbox Guidance Manual.”
Since all water sources being treated at TP015 are currently designated as groundwater sources, the monitoring requirements of the LT2ESWTR do not apply. If in the future any water source
being treated at TP015 is designated as being groundwater under direct influence of surface water (GUDI), the monitoring required in the LT2ESWTR must be completed.
In the event additional log removal credit is needed for a higher Bin classification, additional treatment will need to be installed. New Plan Approval would be required for any additional
treatment.Compliance StrategyPrimary Filtration
3Kings WTP (TP015) will operate pressurized granular media filtration through Pyrolusite media with a maximum filtration rate of 5,507 gpm (6 of 8 filters online)and a hydraulic loading

rate between 5.21 to 9.66 gpm/sf, per approved exception (File #12020).Upon completion of the Demonstration of Performance (DOP), the Division will determine if the Pyrolusite media
can be approved as an alternative filtration method and the final log removal value (LRV) credits granted.The Division temporarily approvesthe pressurized Pyrolusite media filtration
for primary filtration under the surface water treatment rules. The Division temporarily grants2.0-log10 credit for Giardia lamblia removal,1.5-log10 credit for Cryptosporidium removaland
1.5-log10 credit for virus inactivationfor the compliance filter. Best Management Practices will be implemented to protect the integrity of the groundwater sources throughout the treatment
process while the DOP is being performed to determine the LRV credits granted to the alternative filtration process.
Per R309-200-5(a)(ii) and R309-530-9, the turbidity performance standard for this treatment plant is that the turbidity shall be less than 0.3 NTU 95% of the time and shall not exceed
1.0 NTU.
Disinfection
Two disinfection processeswill be installed following the granular media filters to provide additionaltreatment to meet surface water treatment disinfection requirements:
Ultraviolet (UV) disinfection(Trojan UV Swift Model 2L12) UV reactor manufactured by Trojan installed immediately following the metals adsorption filter.
The System provided the goals of the UV process as part of a comprehensive disinfection strategy including target pathogens, target log inactivation and corresponding required UV does
that is required.
This UV reactor was validated by Harold Write, P.E., with Carollo Engineers, in the validation report dated March 7, 2008.
The Division concurs with this validation report. Per R309-520-8(3), the Division accepts the calculated dose (or single set point) UV dose approach proposed by Trojan UV Swift. 1.0-log10Giardia
lamblia and 0.5-log inactivation for Cryptosporidiumwith a validated UV dose of 2.1mJ/cm2 per Table 1.4 in the UVDGM) through the 3Kings WTP (TP015). UV reactors can treat up to 6.4
MGD per reactor, to achieve a design minimum UVT of 95% with turbidity less than 0.3 NTU more than 95% of the time and always less than 0.1 NTU.Three reactors are installed (two duty,
one standby).Post chlorination at free chlorine residual of 1.00 ppm will be provided for additional disinfection following the UV treatment. The 3Kings WTP (TP015) will provide disinfection
through onsitesodium hypochlorite generation. Free chlorine inactivation through a clearwell will provide the remaining required 2.5 log10 virus inactivation credit.Jacobs completed
a Computational Fluid Dynamics (CFD) model of the clearwell inlet hydraulics and efficiency of the clearwell design configuration and determined the following:A baffle factor of 0.59A
T10, or time for the outlet concentration to reach 10 percent of the inlet tracer concentration, of 8.01 minutes.Worst case: flow rate 5,507 gpm (7.93 MGD), pH of 8, clearwell depth
of 15 feet and volume of 74,786 gallons, temperature of 4 °C, and residual of 1 mg/L.The CT required to achieve 2.5 log10 virus inactivation credit at a pH of 8.0 and water temperature
of 4 °C is 5.56 mg-min/L. A chlorine residual of 1.00 mg/L at a flow rate of 5,507 gpm will result in an actual CT achieved of 8.01 mg-min/L and a CT ratio of 1.44.The Point of Entry
for the chlorination system is the exit weir of the clearwell.
All water sources being treated at TP015 are currently designated as groundwater sources, the monitoring requirements of the LT2ESWTR do not apply. If in the future, any water source
being treated at TP015 is designated as being groundwater under direct influence of surface water (GUDI), the monitoring required in the LT2ESWTR must be completed.
In the event additional log removal credit is needed for a higher Bin classification, additional treatment will need to be installed. New Plan Approval would be required for any additional
treatment.
Overall, the design of the 3Kings WTP (TP015) is anticipated to meet the required treatment for Cryptosporidium for surface water classified as in Bin 1 under R309-215-15 of Utah’s Rules.
The System will need to conduct Bin classification monitoring once the plant is in operation for determination of Surface Water Treatment. The processes of granular media filtration,
UV reactor, and the post-chlorination together will achieve the treatment goals of:
≥3.0-log removal/inactivation required for Giardia lamblia,
≥2-log removal/inactivation required forCryptosporidium (Bin 1 requirement), and,
≥4-log removal/inactivation for virus.ADDENDUM 3
Metals Removal Water Treatment and Antimony Blending Plan
Summary of Monitoring and Reporting Regulations
Park City Water System (UTAH#22011)
3 Kings Water Treatment Plant (TP015)
Metals Treatment Monitoring and Reporting Requirements
Issuance of this Operating Permit changes your water system’s monitoring and reporting
requirements. The monitoring requirements for this facility are given below. An updated monitoring schedule can be viewed any time at waterlink.utah.gov under the Water Monitoring section.

Facility ID
Sample Point ID
Analyte
# of Samples
Sampling Frequency
Next Due Date
Rule Citation
TP015
TP015
Antimony
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
Arsenic
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)

Iron
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
Lead
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
Manganese
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
Thallium
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
Zinc
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
Cadmium
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
Nitrate
1
Quarterly
07/01/2024-09/30/2024
R309-205-5(4)(a)
Pesticides
1
Quarterly
07/01/2024-09/30/2024
R309-205-6(1)(d)
Volatile Organics
1
Quarterly
07/01/2024-09/30/2024
R309-205-6(2)
Radionuclides
1
Quarterly
07/01/2024-09/30/2024
R309-205-7(1)(c)
Inorganics and Metals*
1
Yearly
01/01/2024-12/31/2024
R309-205-5(3)(a)
Sodium, Sulfate and TDS
1
Yearly
01/01/2024-12/31/2024
R309-205-5(3)(a)

TP015
UP001
Antimony
1
Monthly
06/01/2024-06/30/2024
R309-215-6(2)(a)
DS001
DS001
Lead and Copper
40
Every Six Months
07/01/2024-12/31/2024
R309-210-6(3)(d)(iv)(G)
*Yearly Inorganics and Metals sample does not include Antimony, Arsenic, Iron, Lead, Manganese, Thallium, Zinc and Cadmium. These analytes shall be monitored at the frequencies given.

It is the Divisions understanding that the 3Kings WTP (TP015) will reduce Antimony levels using blending. Sample Point ID “UP001” represents the combined effluents of the Judge Tunnel
(WS001) and the Spiro Tunnel (WS06) after they have undergone filtration, prior to the introduction of the Thiriot Spring (WS003). Sample Point “UP001” will represent the Antimony concentrations
of the largest contributors before it is diluted/blended with the Thiriot Spring (WS003). Blending efficacy and compliance with the Antimony MCL will be determined through routine sampling
at the 3Kings WTP point of entry (sample point ID TP015).
Monthly sampling has been applied to the contaminants for which the treatment plant was designed in accordance with R309-215-6(2)(a). After six months of monthly sampling, the system
may apply to have these frequencies reduced from monthly to quarterly, provided that the results demonstrate concentrations reliably and consistently below the MCLs.
Please contact David Kruse [e-mail] or (385)-566-7789 with any questions regarding the monitoring and reporting requirements given above, or to request reduced monitoring following
six months of operation. Please contact Dylan Martinez at [e-mail] or [phone] with any questions regarding the lead and copper monitoring schedule.
ADDENDUM 4
Summary of Surface Water Treatment Monitoring and Reporting Regulations
Park City Water System (UTAH#22011)
3 Kings Water Treatment Plant (TP015)
This Addendum summarizes the monitoring and reporting regulations related to the 3 Kings Water Treatment Plant (WTP)(TP015). Park City water system has agreed to comply with all surface
water treatment requirements for the 3 Kings WTP.
Monthly Report — General
The Park City water system (the System) is required to complete a monthly report for 3Kings WTPusing a template approved by the Division of Drinking Water (the Division). As a minimum,
the monthly surface water treatment plant report must include the following data and other applicable information.
Combined filter treated water (CFE) turbidity [R309-215-9(1)(a)]
Minimum chlorine residual of the treated water at the point of entry (POE)
Verification and calibration dates of turbidimeter(s)
Sufficient residual concentration, volume, flow, pH, and temperature readings in order to prove disinfection CT and/or Inactivation ratio demonstrating whether the log removal/inactivation
requirements are R309-215-15(19)(d) and R309-520-8]
Disinfection CT and/or Inactivation ratio demonstrating whether the log removal/inactivation requirements are met R309-200-5(7), R309-215-15(19); R309-215-15(19)(d) and R309-520-8]
Submit the surface water treatment plant report for the entire month to the Division by the 10th of the following month. This report must be submitted by e-mail as an Excel file at [e-mail].
Please contact Sarah Page at [phone] or [e-mail] to schedule training regarding proper reporting.
All operational records pertaining to the monthly surface water treatment plant reports shall be maintained for a minimum of 5 years. [R309-105-17]
Treatment Adequacy [R309-200-5(7), R309-215-15(19) and (20)]
Water systems using surface water or groundwater under the direct influence of surface water must provide treatment consisting of both disinfection and filtration. [R309-200-5(5)(a)].
The surface water treatment plant monthly report must include both disinfectionand filtration processes. The monthly report shall contain sufficient information to indicate whether the
minimum surface water treatment requirements (i.e., log removal/inactivation of Giardia, virus, and Cryptosporidium) are met.
Required Treatments Credit — The treatment credits required and granted for the processes in 3KWTP (TP015) are summarized below.
Park City Water System (UTAH#22011)
3 Kings Surface Water Treatment Plant (TP015)
Primary Treatment Technique: Alternative Filtration
Treatment Goals
(Minimum Treatment Requirements)
Giardia
Virus
Cryptosporidium
3-log removal / inactivation
4-log removal / inactivation
2-log removal
(Bin 1 source water)
Processes

Credit Granted
Alternative Filtration1 pressure filtration with Pyrolusite granular media
2.0-log removal
1.5-log removal
1.5-log removal
Chlorine2
2.5-log inactivation
Ultraviolet3
1.0-log inactivation
0.5-log inactivation
Total Treatment Credit
3-log removal / inactivation
4-log removal / inactivation
2-log removal / inactivation
Temporarily granted by the Division as alternative filtration, pending results of DOP
Based on the CT calculation by Jacobs during the plan review process
Based onNSF validation per the Environmental Technology Verification Report dated May 2013 (NSF 13/38/EPADWCTR, EPA/600/R-13/096)
Disinfection
The System is required to continuously disinfect the treated water from this WTP.
The disinfection treatment shall be sufficient to ensure the total treatment processes of this WTP achieve at least 3-log inactivation/removal of Giardia lamblia, 4-log inactivation/removal
virus, and a minimum of 2.0-log Cryptosporidium removal (for treating Bin 1 source water). [R309-200-5(7)(a)(i); R309-215-15(12)].
The calculated disinfection CT for all processes shall be reported monthly to indicate the level of disinfection effectiveness. [R309-215-15(19)]
Disinfection at Point of Entry (POE)[R309-200-5(7), R309-215-15(19)]
The System is required to continuously disinfect the treated water from this WTP. [R309-200-5(7)]
The chlorine residual must not be below 0.2 milligram per liter (mg/L) free chlorine residual at the point of entry (POE), where the treated water enters the distribution system, for
more than four hours. [R309-200-5(7)(a)(ii)]
The chlorine residual must not exceed the maximum residual disinfectant level (MRDL) of 4.0 mg/L free chlorine residual. [R309-200-5(3)(c)(iv) Table 200-5]
Lowest Daily POE chlorine residual readings shall be collected and recorded on the monthly report.
Systems serving a population greater than 3,300 shall continuously monitor chlorine residuals at the POE
The chlorine analyzer should be verified for accuracy or calibratedat least quarterlyper Standard Method 334.0 Determination of Residual Chlorine in Drinking Water Using an Online Chlorine
Analyzer. [EPA 815-B-09-013 September 2009 11.1.1.2 Page 13]
A Hach Pocket Colorimeter DPD colorimetric method (e.g. Method 8021) is an acceptable method for verifying on-line chlorine residual analyzers (e.g. for Hach Cl17 online analyzer). If
the verification fails, online analyzer adjustments will be made until the accuracy is achieved. A calibration will be conducted if verification testing cannot be accomplished successfully.
Turbidity Limit Issues
Filtration Technologies Other Than Conventional Filtration, Direct Filtration, Slow Sand Filtration, or Diatomaceous Earth Filtration [R309-200-5(5)(a)(ii); R309-215-9(1)]
The turbidity of the treated water or the combined filter effluent (CFE) shall be less than or equal to 0.3 NTU in at least 95% of the measurements taken each month. The treated water
or CFE turbidity shall at no time exceed 1.0 NTU.
Turbidity Monitoring and Reporting — General
The turbidity readings during the operation and maintenance procedures, such as plant start-up, clean in place, enhanced flux maintenance, air scrub, integrity tests, etc., can be excluded
from the report. Operational logs and/or SCADA shall reflect the conditions causing false turbidity readings.
If a data recording delay is programmed into SCADA after plant start-up, the delay shall not exceed 15 minutes and the System shall inform the Division of the programming details.
Signal averaging is not allowed.
The turbidity of the combined filter effluent (CFE) and each individual filter effluent (IFE) shall be continuously monitored. [See R309-215-9(1)(a) for CFE monitoring, and R309-525-15(4)(b)(vi)
and (4)(c)(vii) for IFE monitoring.]
The turbidity of the combined filter effluent (CFE) and each individual filter effluent (IFE) shall be continuously recorded. [R309-215-9(1)(b)]
The System shall monitor the turbidity results of each IFE at a frequency of no greater than every 15 minutes. [R309-215-9(1)(b)]
The highest CFE turbidity reading at the end of eachfour-hour (or shorter) interval of operation must be included in the monthly surface water treatment plant report submitted to the
Division, excluding data described in #5a. [R309-215-9(1)(b)] Data must be sufficient to determine the information outlined below. [R309-215-9(1)(b); R309-215-9(1)(c), R309-215-9(4)(a)
and R309-215-9(5)(a)]
Total number of the 4-hour combined filter effluent (CFE) turbidity measurements reported during the month (see #5e)
The number and percentage of 4-hour combined filter effluent (CFE) turbidity measurements reported during the month, which are less than or equal to 0.3 NTU, excluding data described
in #5a.
The date and value of any turbidity measurement taken during the month, which exceed 1.0NTU for a System using conventional or direct filtration.
If there is a failure in continuous monitoring equipment, the water system shall conduct grab sampling for turbidity every four hours. [R309-215-9(1)(b)]
The grab sampling, in lieu of continuous monitoring, cannot be more than five working days for water systems serving a population of 10,000 or more, following the failure of equipment.
The grab sampling, in lieu of continuous monitoring, cannot be more than fourteen days for water systems serving a population less than 10,000, following the failure of equipment.
If the set turbidity limit for the approved treatment technology is exceeded, the System must comply with the re-sampling and notification requirements. [R309-215-9(2)]
Re-sample as soon as practicable and preferably within one hour.
If re-sampling confirms the exceedance of the turbidity limit —
The System shall collect at least one bacteriological sample near the first service connection from the source within 24 hours of the turbidity exceedance. This sample result shall be

included in determining bacteriological compliance for that month.
The System shall report this turbidity re-sampling exceedance to the Director as soon as practical, but no later than 24 hours after the turbidity exceedance is known. This reporting
is in addition to reporting the incident on any monthly WTP reports.
The System using a filtration technology other than conventional filtration, direct filtration, slow sand filtration, or diatomaceous earth filtration shall inform the Division as soon
as possible, but no later than the end of the next business day if any time the combined filter effluent (CFE) turbidity in representative samples of filtered water exceeds the maximum
level set by the Director, i.e., 1.0 NTU for 3KWTP (TP015). [R309-215-9(6)(b)]
Turbidity Equipment Verification and Calibration
Continuous turbidity monitoring equipment for the combined filter effluent (CFE) and each individual filter effluent (IFE) shall be checked for accuracy and/or re-calibrated at a minimum
frequency ofmonthly. [R309-215-9(1)(d)]
The turbidimeter shall be calibrated andthe accuracy verified at least once per month.
The turbidimeters should be thoroughly cleaned and calibrated with primary standardsat least quarterly.
It is not allowed to calibrate on-line instruments by comparison with a bench-top turbidimeter.
The most recent verification/calibration date for the CFE turbidimeter and each IFE turbidimeter shall be reported on the monthly report.
UV Monitoring and Reporting [R309-215-15(19)(d) and R309-520-8]
UV Reactor Monitoring Requirements:
To obtain disinfection credit of UV disinfection, the System shall monitor the parameters used as part of the dose monitoring algorithm continuously, i.e. at least once per minute. For
example, UV reactors validated using the Calculated Dose Approach must monitor the following parameters continuously for each UV reactor that is in use, including flow rate, UVT, UV
intensity sensor reading, lamp status, number of lamp rows on, calculated or validated dose, power ballast setting, and off-specification time.
Other parameters that are essential to operation and maintenance shall be monitored at the frequency recommended by the UV manufacturer or per EPA’s 2006 Final UVDGM. Examples of these
operational parameters:
Reactor status and run time.
Water temperature
Lamp hours
Lamp sleeve cleaning records
Cumulative number of the lamp on/off cycles
Calibration and verification of UV sensors
Calibration of online UVT analyzers
Date (or frequency) and type of maintenance/replacement of UV reactor components.
Additional UV Reporting Requirements:
Compliance reporting for approved UV disinfection credit shall be submitted to the State as a part of the surface water treatment rule compliance report on a monthly basis. The recording
frequency shall be at least every 4 hours. The minimum validated dose recording is the lowest validated dose reading within a period of 4 hours. The daily minimum validated dose is the
lowest value among the four-hour minimum values for each day.
As a minimum, the following parameters shall be included in the UV monthly compliance report:
Daily minimum and maximum flow rate.
Daily minimum UVT.
Daily minimum validated dose (This depends on the dose monitoring approach. Use UV intensity in case of UV Intensity Setpoint Approach).
Daily minimum ballast power setting.
Daily production volume for off-specification events.
Total production volume through UV system in a month.
Total production volume for off-specification events in a month.
Total off-specification percentage (based on monthly volume).
Target pathogen (Cryptosporidium, Giardia, and Virus).
Target log disinfection.
Actual log disinfection.
Date of monthly verification of duty UV sensor calibration and date of yearly calibration of the reference UV sensor.
Total number of UV sensors per reacto.
Number of UV sensors per reactor in service that were verified for calibration.
Number of verified sensors that were withing the acceptable range of toleranc.
Reactor number and UV intensity sensor correction factor (if any UV sensor does not meet the calibration criteria and remains in service in a particular reactor).
Date of the weekly calibration of online UVT analyzers.
Indications of whether the UV facility met the following criteria:
Total log disinfection greater than target log disinfection.
Flow rates less than the maximum validated flow rate.
At or above validated minimum UVT (if using the calculated does approach as monitoring strategy).
At or above validated power ballast minimum setting.
At or above the required does or UV intensity.
Within the 5% off specification limit of the total volume of treated water each month.
Off Specification Reporting. The requirements of off-specification reporting in this section are largely based on Section 6.4.1.3 of the 2006 Final UVDGM
The calculated off-specification percentage is based on the volume of water treated through the UV system. The off-specification percentage must be no more than 5% of the monthly total
production. The off-specification total volume should be calculated by totaling the off-specification time and the associated volume released during those periods for each UV reactor

(see Section 6.5.1 of the 2006 Final UVDGM).
Five factors shall be considered contributing to off-specification events:
The UV facility operates outside of the validated limits, for example, the validated dose is below the required dose, the flow rate is greater than the maximum validated flow rate,
UVT is below the minimum validated value, the ballast setting is below the validated power setting, etc
A UV sensor is not in calibration. For example, any of the duty sensors did not meet the calibration criteria, the failed duty sensors were not replaced with calibrated duty sensors,
or a UV sensor correction factor was not applied.
The UVT analyzer, which is part of the dose monitoring strategy, is found to be out of calibration and the remedial actions are not completed per the protocol prescribed in 6.4.1.2
of the 2006 Final UVDGM.
UV equipment and replaced components are not equivalent to or better than the equipment components validated. This UV equipment remains off specification until a proper replacement
takes place.
Failure of flow meters or missing data necessary for dose calculation.
UV Sensor Calibration and Reporting
The monthly compliance report shall contain:
Total number of UV sensors per reactor.
Number of UV sensors per reactor in service that were verified for calibration.
Number of verified sensors that were within an acceptable range of tolerance.
The System shall have an adequate inventory of duty UV sensors to allow immediate replacement of a failed duty UV sensor.
Re-calibrate or replace duty UV sensors if excessive drift or error occurs (i.e. greater than 20%).
Reference UV sensor shall be calibrated at least once a year at a qualified facility (such as the manufacturer). The date of the most recent UV reference sensor calibration shall be
included in the compliance report to the State.
Duty sensors shall be verified for calibration at least monthly by verifying with at least two (2) reference sensors. All UV sensors in operation that month shall be verified for calibration.
Date of the UV duty sensor verification shall be reported in the monthly report.
The System shall follow the verification protocol of duty UV sensors specified in Section 6.3 of the EPA Ultraviolet Disinfection Guidance Manual for the Final Long Term 2 Enhanced
Surface Water Treatment Rule (2006 Final UVDGM). UV sensor correction factor shall be included in the compliance report if a failed duty UV sensor is not replaced with a calibrated duty
UV sensor. However, this approach shall not be used for long-term operation and the UV sensor problem should be resolved as quickly as possible.
If a UV sensor correction factor (CF) is applied to allow a UV duty sensor that failed the UV sensor verification criteria to remain in service on an interim basis, the reactor number,
the UV sensor number, and its UV sensor correction factor must be reported.
UVT Analyzer Calibration and Reporting. 
UVT analyzer calibration is required for the UV reactor validated based on the Calculated Dose Approach, because UVT is an integral part of the dose monitoring strategy.
The online UVT analyzers should be calibrated at least weekly by comparing the on-line UVT measurement using a bench-top spectrophotometer.
The UVT calibration frequency can be reduced to once a month if approved by the Executive Secretary when sufficient data (a minimum of a one-year period) indicate that the UVT analyzer
is consistently within the allowable calibration error without adjustment for more than a month.
Source Water Bin Classification
The Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) established four bin classifications for Cryptosporidium based on concentration in the source water. If a water system
has source water classified in Bin 1, LT2ESWTR requires 2-log10 removal for Cryptosporidium. If a water system has source water in Bin 2, Bin 3, or Bin 4, LT2ESWTR requires additional
treatment, disinfection or inactivation for Cryptosporidium, as outlined in EPA’s “Long Term 2 Enhanced Surface Water Treatment Rule Toolbox Guidance Manual.”
Since all water sources being treated at TP015 are currently designated as groundwater sources, the monitoring requirements of the LT2ESWTR do not apply. If in the future any water source
being treated at TP015 is designated as being groundwater under direct influence of surface water (GUDI), the monitoring required in the LT2ESWTR must be completed.
In the event additional log removal credit is needed for a higher Bin classification, additional treatment will need to be installed. New Plan Approval would be required for any additional
treatment.