DDW-2024-007568

May 13, 2024
Mike Lee
Bull Moose Waterworks
524 West 350 South
Layton, Utah 84041
Subject:Plan Approval, Upper Springs Surface Water Treatment Plant (TP002); Exception to Rule R309-525-5; Bull Moose Waterworks, System #22114, File #13575
Dear Mike Lee:This letter provides a summary of the Division of Drinking Water’s decision to issue Plan Approval for Upper Springs Surface Water Treatment Plant (identified as TP002
in the Division’s database). The letter includes the following sections and addenda:Plan Approval for Upper Springs Surface Water Treatment Plant Surface Water Treatment Plant (TP002).Exception
to Rule R309-525-5.Project Overview (Addendum 1) provides a detailed description of the proposed treatment plant design.Proposed Strategy for Achieving Surface Water Treatment Goals
(Addendum 2) describes the proposed strategy for achieving the required treatment goals.Preliminary Summary of Surface Water Treatment Monitoring and Reporting Regulations (Addendum
3) may be useful for this plant’s PLC and SCADA programming.
We have completed our review of the plans and specifications of the proposed Upper Springs Surface Water Treatment Plant (TP002) stamped and signed by Michael Chambers, P. E., and dated
May 5, 2024, and find they basically comply with the applicable portions of Utah’s Administrative Rules for Public Drinking Water Systems in R309. On this basis, the plans for the construction
of Upper Springs Surface Water Treatment Plant (TP002) are hereby approved.
This plan approval pertains to construction only. An Operating Permit must be obtained from the Director before Upper Springs Surface Water Treatment Plant may be put into service. A
checklist outlining the items required for issuing an Operating Permit for this treatment plant is enclosed for your information.Approvals or permits by local authority or 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.
This approval must be renewed if construction has not begun or if substantial equipment has not been ordered within one year of the date of this letter.Exception to R309-525-5 The Division
received your request for an exception to Rules R309-525-5. This rule indicates that a minimum of two units for filtration are typically provided for surface water treatment and that
the degree of backup required in a water treatment plant varies with the number of connections served, the availability of other acceptable water sources, and the ability to control
water consumption. Bull Moose Waterworks is a transient-noncommunity system with less than 10 year-round connections. Most of the connections are sporadically and infrequently inhabited
for recreational purposes. You have indicated that you will have two (2) extra filtration cartridges for each filter housing on hand for changing out as needed, meeting the intent of
the redundancy requirement. On this basis, an exception to R309-525-5 is hereby granted for Upper Springs Surface Water Treatment Plant (TP002) to allow a single train process for surface
water treatment. The Division considers the proposed design of the Upper Springs Surface Water Treatment Plant (TP002) acceptable with only one treatment train.
If you have any questions regarding this approval, please contact Julie Cobleigh, P.E., of this office, at [phone], or me at [phone].
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
JJC/mrn/mdbEnclosuresOperating Permit ChecklistAddendum 1. Project OverviewAddendum 2. Proposed Strategy for Achieving Surface Water Treatment GoalsAddendum 3. Preliminary Summary of
Surface Water Treatment Monitoring & Reporting Regulationscc:Nathan Brooks, Summit County Health Department, [e-mail] Neilsen, Hansen, Allen and Luce, [e-mail]
Lee, Bull Moose Waterworks, [e-mail]
Julie Cobleigh, P.E., Division of Drinking Water, [e-mail]
Nathan Lunstad, P.E., Division of Drinking Water, [e-mail]
Mark Berger, Division of Drinking Water, [e-mail]
Sarah Page, PhD, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Nagendra Dev, P.E., Division of Drinking Water, [e-mail]
Colt Smith, Division of Drinking Water, [e-mail]
Utah Division of Drinking Water ― Checklist for Issuing Operating PermitsWater System Name: ______________________________System Number: _______________Project Description: _______________________________File
Number: __________________
Items 1 through 11 below must be submitted to the Division and found to be acceptable prior to operating permit issuance (unless a water line project meets the requirements of R309-500-7
and is not required to obtain an Operating Permit).☐1.Certification of Rule Conformance by a professional engineer (P.E.) that all conditions of Plan Approval were accomplished, and
if applicable, changes made during construction were in conformance with rules R309-500 through 550☐2.As-built or record drawings incorporating all changes to approved plans and specifications
(unless no changes were made to the previously approved plans during construction)☐3.Confirmation that as-built or record drawings have been received by the water system☐4.Satisfactory
bacteriological samples as evidence of proper disinfection and flushing in accordance with the appropriate ANSI/AWWA standards:
☐ANSI/AWWA C651-14 AWWA Standard for Disinfecting Water MainsTwo consecutive sample sets at least 16 hours apart, nonpositive (e.g., every 1,200 feet, end-of-line, each branch)☐ANSI/AWWA
C652-11 AWWA Standard for Disinfection of Water-Storage Facilities (e.g., clearwell, storage tank).One or more samples, nonpositive☐ANSI/AWWA C653-13 AWWA Standard for Disinfection of
Water Treatment PlantsTwo consecutive samples per unit (filter), nonpositive, no less than 30 minutes apart☐ANSI/AWWA C654-13 AWWA Standard for Disinfection of WellsTwo consecutive samples,
nonpositive, no less than 30 minutes apart☐5.Water quality data — New source chemistry data on finished waterCFE turbidity (highest reading at 4-hour intervals for a minimum of 7 days)
Minimum chlorine residual, pH and temp, min. volume for detention time calculations (daily for a minimum of 7 days)
☐6. If applicable, all other documentation that may have been required during the plan review process.☐7. SWTR monthly report with at least 7 days of operational data demonstrating SWT
has been achieved. The WTP does not have to operate at full capacity or continuously (but at least 4 hours per day) for the purpose of this demonstration.☐8. Confirmation of turbidimeter
calibration.☐9.If applicable, confirmation that the water system owner has received the O&M manual for the new facility.☐10.If applicable, the location data of the new storage tank,
treatment facility, or sourceADDENDUM 1Project Overview
Bull Moose Waterworks Water System (UTAH#22114)
Upper Springs Surface Water Treatment Plant (TP002)
Project History

The Division of Drinking Water (the Division) received the plans and specifications for the proposed Upper Springs Surface Water Treatment Plant from your consultant, Lance Nielsen,
P. E. on November 20, 2023. Review comments were provided on November 30, 2023. The final revised plans were received on May 5, 2024. The Upper Springs Surface Water Treatment Plant
is identified as TP002 in the Division’s database.
Project Summary
Our understanding of the project is that the proposed Upper Springs Surface Water Treatment Plant (TP002) will treat Upper Spring source (WS001). The Upper Spring (WS001) was determined
to be under the direct influence of surface water (UDI) by the Division in a letter dated June 15, 2022. The UDI designation was based on the results of a microscopic particulate analysis
(MPA) test conducted on May 16, 2022. This test scored 22, indicating high risk of Upper Spring (WS001) being UDI. The System has been operating the existing disinfection facility (TP001)
to achieve a 3-log inactivation of Giardia as a temporary solution. The proposed Upper Springs Surface Water Treatment Plant (TP002) will consist of cartridge filtration and post-chlorination
processes. The proposed Upper Springs Surface Water Treatment Plant (TP002) has a plant design capacity of 25 gallons per minute (gpm). This is based on the pump capacity supplying the
filters from the spring; however, the filters are rated up to 65 gpm. The storage tank will have a level transducer that will call on the pump when the level reaches a certain set point.
When the pump is not running, the spring will overflow from the spring box. The plant will be powered by a solar-powered battery with a backup generator for redundancy. The design
includes a single train of pre-filtration and two compliance cartridge filters in series.The proposed treatment plant consists of the following processes in sequence:First-stage pre-filter
– Harmsco, Model Muni 90-MP, .35 micron Harmsco cartridge filter; 1 train; 25 gpm per train
First-stage compliance filter – Harmsco, Model Muni 90-MP, HC/90 -LT2 cartridge filter; 1 train; 25 gpm per train.
Second-stage compliance filter – Harmsco, Model Muni 90-MP, HC/90 -LT2 cartridge filter; 1 train; 25 gpm per train.
Post-chlorination – liquid sodium hypochlorination; 25 gpm per trainStorage tank and pipe segments used for disinfection detention time – three CT segments which include 310 feet of
3-inch diameter water line, 10,000 gallon low-level set point for tank (ST001), and 2,100 feet of 6-inch diameter water line to the POE. Monitoring and Reporting locations:Raw water
sample tapAfter the two Harmsco, Model Muni 90-MP, HC/90 -LT2 cartridge filters in series there is a HACH TU5 Turbidimeter that will be the combined filter effluent (CFE) compliance
location along with a pH sensor. Additionally, a Rosemont Flow Meter will measure the filtered flow rate. Analyzers for the primary disinfection and POE chlorine residual are located
at one of the cabins, approximately 2,200 feet from the chlorinator and 200 feet beyond the first connection. ADDENDUM 2Proposed Strategy for Achieving Surface Water Treatment Goals
Bull Moose Waterworks Water System (UTAH#22114)
Upper Springs Surface Water Treatment Plant (TP002)Treatment Goals per Surface Water Treatment Rules
The Upper Springs Surface Water Treatment Plant consists of pre-filtration, cartridge filtration, and post-chlorination processes. This plant shall be 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-log removal/inactivation for Giardia lamblia,
and4-log 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, LT2ESWTER requires 2-log 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.”
The water source supplying this treatment plant is the Upper Spring (identified as WS001). The Bulll Moose Waterworks water system is currently completing sampling requirements as outlined
in the LT2ESWTR. The Upper Springs Surface Water Treatment Plant is designed to meet the Bin 1 requirements, i.e., 2-log10 removal for Cryptosporidium. It will be confirmed after the
first round of sampling if the bin is appropriate.
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.Proposed Strategy to Comply with Surface Water Treatment RequirementsPrimary Filtration
According to the Conditional Acceptance of the Harmsco Potable Water Cartridge Filtration System as an Alternative Filtration Technology by the California State Water Resources Control
Board, Division of Drinking Water, dated June 2015, the Harmsco, Muni-90-MP, HC/90 -LT2 cartridge filter treatment process is credited for providing 3.0-log removal for Giardia lamblia
and 2.5-log removal for Cryptosporidium if two filters are installed in series with a maximum flow of 65 gpm and the maximum trans-membrane pressure of 30 psi is not exceeded. The first-stage
filter is awarded 2.5-log and 2.0-log removal for Giardia lamblia and Cryptosporidium, respectively. The second-stage filter is awarded an additional 0.5-log and 0.5-log removal for
Giardia lamblia and Cryptosporidium, respectively. The Division concurs with this determination.The Division anticipates approving the cartridge filtration process using the Harmsco
Model Muni-90-MP, HC/90-LT2 filter as an alternative filtration technology for primary filtration under the surface water treatment rules. Upon receiving water quality results that demonstrate
the effective performance of the proposed treatment plant, the Division will grant 3.0-log credit for Giardia lamblia removal, and 2.5-log credit for Cryptosporidium removal for the
first and second-stage compliance filter.
Please note that the pressure differential performance standards for the proposed treatment plant will be the manufacturer’s recommended maximums for cartridge filtration, and the differential
pressure of the filtration units shall not exceed the manufacturer’s recommended maximum differential pressure.
The turbidity performance standards for the proposed treatment plant will be less than 0.3 NTU 95% of the time, and shall not exceed 1.0 NTU (per R309-200-5(a)(ii) and R309-530-9).
Disinfection
The disinfection processwill be installed following the cartridge filters to provide additional treatment to meet the Bin 1surface water treatment goals:
Post chlorination at free chlorine residual of approximately 1.0 ppm will be provided for additional disinfection following the compliance filters. The Upper Spring Surface Water Treatment
Plant (TP002) will provide disinfection by adding sodium hypochlorite. A disinfection CT (CT = Concentration × Contact Time) of 12 is needed for 4-log10 inactivation for virus. The estimated
disinfection CT is 106, which will meet the 4-log virus inactivation requirement.
The CT calculations are based on the CT from the pipe segments and Storage Tank (ST001). The chlorination CT calculations are determined using a minimum free chlorine residual of 1.0
ppm and a peak flow of 25 gpm, 310 feet of 3-inch diameter water line, low tank level volume of 10,000 gallons (ST001), and 2,100 feet of 6-inch diameter water line to the POE, and a
tank baffling factor of .1. The estimated CT without considering the tank volume is 66, which also meets the 4-log virus inactivation requirement; therefore, effective storage volume
will not be taken away for achieving CT.
The Point of Entry (POE) sampling location for the Upper Spring Surface Water Treatment Plant (TP002) will be the continuous analyzer located at one of the first cabins.
Overall, the proposed design of the Upper Springs Surface Water Treatment Plant 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 processes of pre-filtration, two Harmsco cartridge filtration processes in series, and the post-chlorination together will achieve the treatment
goals of:
3.0-log removal required for Giardia lamblia,
2.0-log removal required for Cryptosporidium (Bin 1 requirement)

4.0-log inactivation for virus.
ADDENDUM 3
Preliminary Summary of Surface Water Treatment Monitoring and Reporting Regulations
Bull Moose Waterworks Water System (UTAH#22114)
Upper Springs Surface Water Treatment Plant (TP002)
This addendum summarizes the monitoring and reporting regulations related to the Upper Springs Surface Water Treatment Plant (TP002). It is provided to you for informational purposes
only and may be helpful in PLC and SCADA programming after the plant is constructed.
The actual monitoring and reporting requirements for this treatment plant will be provided to the water system by staff of the Division of Drinking Water with the issuance of the Operating
Permit.
Monthly Report — General
The Bull Moose Waterworks water system (the System) is required to complete a monthly report for Upper Springs Surface Water Treatment Plant using a template developed 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 effluent (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 met [R309-200-5(7), R309-215-15(19)];
The System will be required to 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 [e-mail]. Please contact Sarah Page [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 Upper Springs Surface Water Treatment Plant (TP002) are summarized below.
Bull Moose Waterworks Water System (UTAH#22114)
Upper Springs Surface Water Treatment Plant (TP002)
Primary Treatment Technique: Cartridge Filtration
Treatment Goals
(Minimum Treatment Requirements)
Giardia
Virus
Cryptosporidium
3.0-log removal / inactivation
4.0-log removal / inactivation
2.0-log removal
(Bin 1 source water)
Processes
Credit Granted
Alternative Filtration First Stage (Harmsco, MUNI 90-MP, HC/90-LT2 cartridge filter)
2.5-log removal
0.0-log removal
2.0-log removal
Alternative Filtration Second Stage (Harmsco, MUNI 90-MP, HC/90-LT2 cartridge filter)
0.5-log removal
0.0-log removal
0.5-log removal
Chlorine2
0.0-log inactivation
4.0-log inactivation
0.0-log inactivation
Total Treatment Credit
3.0-log removal
4.0-log inactivation
2.5-log removal
Granted based on the State of California Conditional Acceptance of the Harmsco Potable Water Cartridge Filtration System as an Alternative Filtration Technology by the California State
Water Resources Control Board, Division of Drinking Water, dated June 2015.
Based on the CT calculation by DDW during the plan review process
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 3.0-log inactivation/removal of Giardia lamblia, 4.0-log inactivation/removal
of 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 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 [R309-215-10(1) Table 215-2].
Systems serving a population less than 500 shall either continuously monitor chlorine residuals at the POE or collect 1 grab sample per day.
The chlorine analyzer should be verified for accuracy or calibratedat least quarterly per 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 — GeneralThe 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 no greater than every 15 minutes. [R309-215-9(1)(b)]The highest CFE turbidity reading at the end of eachfour-hour
(or shorter) intervalof operation must be included in the monthly surface water treatment plant report submitted to the Division, excluding data described in #5a. 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 If there is a failure in continuous
monitoring equipment, the 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 of 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 WTP 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 shall inform the Division as soon as possible, but no later than the end of the next business day if at 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 Upper Springs Surface Water Treatment Plant. [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 re-calibrated at a minimum
frequency of monthly. [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 to primary standardsat least quarterly.
It is not allowed to calibrate online 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 in the monthly report.
Source Water Bin Classification
The source water (Upper Spring, WS001) of the Upper Spring Surface Water Treatment Plant (TP002) has not yet received a Bin classification. Bin sampling is required to determine if the
source water is classified as Bin 1 with respect to R309-215-15.
Bull Moose Waterworks must conduct an initial and a second round of source water monitoring for the Upper Spring (WS001) source. This monitoring may include sampling for Cryptosporidium,
E. coli, and turbidity as described in R309-215-15(2) through R309-215-15(7), to determine what level, if any, of additional Cryptosporidium treatment that must be provided. Please contact
Sarah Page at [phone] or [e-mail] as soon as possible to begin this monitoring requirement.