DDW-2024-007862

May 30, 2024
Amy Rydalch
Oakley Town Water System
P.O. Box 129
Oakley, Utah 84055
Subject:Conditional Plan Approval, Cattail Well Equipping and Gas Chlorinator, (WS006, TP006); Oakley Town Water System, System #22010, File #12649
Dear Amy Rydalch:The Division of Drinking Water (the Division) received the plans and specifications for equipping the Cattail Well and installing a gas chlorinator from your consultant,
Michael Maughan, P.E. with Aqua Engineering on March 7, 2024. The Division issued Plan Approval for drilling the Cattail Well on November 2, 2021. Review comments were sent on March
27, 2024. A site visit was conducted by the Division on April 9, 2024. Revised plans were received on May 17, 2024. This project has met the conditions for receiving a plan approval.
The letter includes the following sections and addenda:

1.Project Summary for Cattail Well and Gas Chlorinator (WS006, TP006)    
2. Plan Approval for Cattail Well and Gas Chlorinator (WS006, TP006)
4.Operating Permit Checklist 
5.FutureMonitoring and Reporting Requirements (Addendum 1)
6.Estimated Disinfection CT & Summary Table (Attachment 1) 
Project Summary
The project involves equipping the Cattail Well (identified as WS006 in the Division’s database), construction of a well house building and installation of a gas chlorination facility
(TP007). The Cottonwood Spring (WS001), Cattail Well (WS006) and Spring Well (WS007) operations will be combined inside the building. The gas chlorinator will provide disinfection for
the Cottonwood Spring (WS001), Cattail Well (WS006) and Spring Well (WS007). The Spring Well (WS007) has been in operation since approximately 2011 but lacks Division plan approval and
an operating permit, which are currently being reviewed and processed under File #14065.
The Cattail Well (WS006) is an artesian flowing well. The constant rate pump test was performed at 2,250 gallons per minute (gpm). The well is also equipped with a 1,000-gpm submersible
pump. There are two discharge lines for operating the well through artesian flow or by using the submersible pump. Both discharge lines are equipped with a sample tap, check valve, flow
meter and shut off valve, with a common pump-to-waste line.
The Cattail Well House Chlorinator (TP006) will be completed according to the following:
The proposed Cattail Well House Chlorinator will be a Equavo V10K gas chlorinator and will replace the Cottonwood Springs Chlorinator (TP003).
This chlorinator will add chlorine to the water from Cottonwood Springs, Cattail Well and Spring Well (WS001, WS006, WS007).
This chlorinator is intended to provide secondary disinfection in the distribution system.
The chlorinated water will go to Spring Tanks #1 and #2 (ST001, ST002). Occasionally, the water will go through the bypass line which enters the Humbug Tank (ST003) or goes directly
to the distribution system.
The proposed gas chlorine for disinfection meets the ANSI/NSF 60 standard.
The proposed design target dose of 1.0 mg/L or ppm (measured as free chlorine) is based on a typical flow of 1,000 gpm from the Cattail Well (WS006). When the other sources are being
used (WS001, WS007) the flow rates will vary.
The chlorine dose will be adjusted by an automatic flow-paced control.
The Point of Entry (POE) sampling location will be a Hach Cl17sc continuous analyzer on the discharge line leaving the building.
Plan Approval for Cattail Well and Gas Chlorinator (WS006, TP006)
We have received the following information for Cattail Well and Gas Chlorinator (WS006, TP006):
Certification of well seal.
Well driller’s report (well log).
Aquifer drawdown test results (step drawdown test and constant-rate test).
New Source Chemical Analyses of the well water.
Plans and specifications for equipping the well.
Pump information
Well head discharge piping.
Well house design
Chlorinator design
We have completed our review of the plans and specifications, stamped, and signed by Michael Maughan, P. E., and dated May 17, 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 equipping the Cattail Well, construction of a well house and installation
of a gas chlorination facilityare hereby approved with the following conditions:
Complete the after-the-fact plan approval and operating permit process for the Spring Well (WS007).
Obtain concurrence of a Preliminary Evaluation Report and Drinking Water Source Protection (DWSP) plan for the Spring Well and provide confirmation of coverage under recorded land use
agreement(s) or a zoning ordinance in accordance with R309-600-13(2)(d).
You must fulfill and comply with all of the conditions of approval,or this approval is invalid.
This conditional approval pertains to construction only. An Operating Permit must be obtained from the Director before the Cattail Well and Chlorinator may be put in service. A checklist
outlining the items required for operating permit issuance is enclosed for your information.Approvals or permits from the local authority or county may be necessary before beginning
construction of this project. As the project proceeds, 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.
Secondary Disinfection Requirements

The Oakley Town Water System is not required to disinfect the Cottonwood Spring, Cattail Well and Spring Well (WS001, WS006, WS007) based on bacteriological source sample results currently
available. The water system proposes to electively install the Cattail Well House Chlorinator (TP006) to provide a detectable disinfectant residual in the distribution system for secondary
disinfection.
The plan review of the proposed Cattail Well House Chlorinator (TP006) is based on providing secondary disinfection. When this chlorinator is installed and placed in operation after
the Operating Permit issuance, the Oakley Town Water System will be required to demonstrate ongoing compliance with the secondary disinfection requirements that will be outlined in Addendum
1 to this letter.
The Division shall be informed by telephone within 8 hours by a water supplier ofthe malfunction of any disinfection facility such that a detectable residual cannot be maintained at
all points in the distribution system per R309-105-18(1)(a).
Cattail Well House Chlorinator (TP006) Disinfection CT Review
The Division received from your consultant, Michael Maughan of Aqua Engineering, the information of estimated worst-case scenario disinfection CT, which is described in the Addendum
to this conditional approval.The estimated worst-case scenario disinfection CT before the chlorinated water reaches the first connection on the bypass line is 10.9, which is not anticipated
to meet the 4-log virus inactivation goal.
Please be aware if Cottonwood Spring, Cattail Well or Spring Well (WS001, WS006, WS007) are found to requireadditionaldisinfection in the future per R309-200-5(7)(a)(i), further regulations
will apply. For example, if primary disinfection is required this will include submitting disinfection CT information showing compliance with 4-log virus inactivation in accordance with
the Ground Water Rule in R309-215-16.
If you have any questions regarding this approval, please contact Julie Cobleigh, of this office, at [phone], or me at [phone].
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
JJC/DLB/mrn/mdbEnclosures─ Well Approval Checklist; Operating Permit Checklist Estimated Worst-Case Disinfection CTcc:Nathan Brooks, Summit County Health Department, [e-mail]
Maughan, Aqua Engineering, [e-mail] Hawkes, Aqua Engineering, [e-mail] Raydalch, Oakley Town Water System, [e-mail] Beck, Division
of Drinking Water, [e-mail]
Julie Cobleigh, Division of Drinking Water, [e-mail]
Luke Treutel, Division of Drinking Water, [e-mail]
David Kruse, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail]
Rebecca Yoo, Division of Drinking Water, [e-mail] 22010 12649 WS006 TP006Division of Drinking WaterChecklist for New Public Drinking Water Wells
(Per Utah Administrative Code, Rule R309-515-6)
System Name:System Number:Well Name & Description:1.Approval to Drill the Well
☐Project Notification Form (PNF)
☐Preliminary Evaluation Report (PER) concurrence
☐Well drilling specifications and plans
☐Valid Start Card or authorization to drill letter from the Division of Water Rights2.Approval to Equip the Well
☐PNF (if the well drilling and well equipping are designed by different consultants)
☐Well location data
☐Certification of well seal
☐Well driller’s report (well log)
☐Aquifer drawdown test results (step drawdown test & constant-rate test) for well yield determination
☐Chemical analyses of the well water
☐Plans and specifications for equipping the well
☐Pump information (e.g., pump specifications, pump curve & operating point, motor information, etc.)
☐Well head discharge piping
☐Well house design3.Operating Permit to Introduce the Well Water
☐Documentation of valid water right(s)
☐Recorded land use agreements, or documentation that the requirements for coverage under the City/County source protection ordinance have been met
☐Design engineer’s certification of conformance with plan approval conditions
☐Design engineer’s certification of rule conformance for any deviation from approved plans
☐As-built or record drawings
☐Evidence of O&M manual delivery to system owner☐Satisfactory bacteriological results as evidence of proper flushing and disinfection
Utah Division of Drinking Water ― Checklist for Issuing Operating PermitsWater System Name:System Number: Project Description:File Number:
Items 1 through 8 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).
Distribution lines (not including in-line booster pump stations) requiring Plan Approval may be placed into service prior to submitting all of the following items and receipt of Operating
Permit if the water system has received items 1 and 4 below.☐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, none positive (every 1200 feet, end-of-line, each branch, etc.)☐ANSI/AWWA
C652-11 AWWA Standard for Disinfection of Water-Storage FacilitiesOne or more samples, none positive☐ANSI/AWWA C653-13 AWWA Standard for Disinfection of Water Treatment PlantsTwo consecutive
samples per unit, none positive, no less than 30 minutes apart☐ANSI/AWWA C654-13 AWWA Standard for Disinfection of WellsTwo consecutive samples, none positive, no less than 30 minutes

apart☐5.Water quality data, where appropriate ☐6.If applicable, all other documentation that may have been required during the plan review process☐7.If applicable, confirmation that
the water system owner has received the O&M manual for the new facility☐8.If applicable, location data of new storage tank, treatment facility, or source
Addendum 1 
Future Elective Monitoring and Reporting Requirements
Chlorine Monitoring & Reporting Requirements
The water system will be required to meet elective disinfection requirements once this facility is installed and operating. As a part of these requirements, the water system will need
to continuously maintain a minimum free chlorine residual at each chlorinator Point of Entry (POE) into the system and demonstrate a detectable chlorine residual in the distribution
system. 
Elective Disinfection Requirements and Reporting 
Chlorine Residual ‒ Point of Entry (POE) to Distribution System
The POE sampling location will be identified in the Division’s database. The location will be identified during the plan approval process. Maintain a minimum of 0.2 mg/L residual (measured
as free chlorine) at the POE sampling location. [R309-215-16(3)(b)(iii)(A)(I) and (II)]
The chlorine residual concentration measured at the POE sampling location shall not exceed the maximum residual disinfectant level (MRDL) of 4.0 mg/L (measured as free chlorine). [R309-200-5(3)(c)(iv)]
Record and report the lowest daily chlorine residual concentration, measured as free chlorine, at the chlorinator POE sampling location a minimum of three (3) times per week. [R309-210-
8(3)(a)(ii)]
Our records show that your water system serves 1,200 people. Please be aware that R309-215-16(3)(b)(iii)(A)(II) requires water systems serving 3,300 people or fewer to monitor the POE
chlorine residuals and take daily grab samples. Alternatively, instead of taking daily grab samples, a groundwater system serving 3,300 or fewer people may choose to use an online analyzer
to continuously monitor the POE chlorine residuals entering the distribution system.
Chlorine Residual ‒ Distribution System (DS001)
This water system must maintain a detectable residualthroughout the distribution system. It is recommended to maintain the chlorine residual above 0.1 ppm in the distribution system.
[R309-520-5]
The chlorine residual measured in the distribution system shall not exceed the maximum residual disinfectant level (MRDL) of 4.0 mg/L (measured as free chlorine). [R309-200-5(3)(c)(iv)]
This water system must take a minimum of three (3) chlorine residual samples per weekat varying locations throughout its distribution system (DS001). [R309-105-10(1)(c)]
Distribution system chlorine residuals must be taken in conjunction with total coliform sampling. [R309-215-10(3)]
Disinfection Report Submission
To demonstrate ongoing compliance with elective disinfection requirements, the water system must complete monthly operational reports for each active chlorinator using a template approved
by the Division. 
Operational reports are submitted quarterly. The reports are due to the Division by the 10th day following the end of each reporting month or quarter (i.e., January 10th, April 10th,
July 10th and October 10th for quarterly reports). The reports can be submitted by hardcopy, fax, or email at [e-mail]. Please contact Luke Treutel at [phone] or [e-mail]
to schedule training regarding proper reporting. 
In addition to monthly disinfection reporting, this water system must submit the monthly average of chlorine residual samples taken in the distribution system. Distribution system chlorine
residual monitoring results are due quarterly by the same compliance dates as the monthly disinfection report and can be submitted via an online form found at mrdl.utah.gov. 
Records must be maintained for a minimum of 5 years. [R309-105-17(1)]
Source Bacteriological Monitoring 
The operating permit will include requirements for monthly Escherichia Coli (E. Coli) sampling at Cattail Well (WS006) and Spring Well (WS007), prior to any treatment, for the months
the these wells are in operation or accessible for a minimum of two operating seasons. This monitoring is required to evaluate the quality of the water coming from Cattail Well (WS006)
and Spring Well (WS007) to determine whether primary disinfection treatment is required or not. Additional monitoring and/or disinfection requirements may be assigned depending on the
results of the assessment monitoring.
Monthly souce assessment monitoring of the Cattail Well (WS006) and Spring Well (WS007):
The source sampling requirement shall begin immediately for the Spring Well (WS007) and once the operating permit has been issued for the Cattail Well (WS006) and extend to cover the
duration of at least 18 months, sufficient to span two (spring/summer or peak season) cycles. 
The sampling location of the source water bacteriological samples needs to be labeled as WS006 and WS007. 
The source bacteriological sampling is in addition to the monthly total coliform sampling in the distribution system (DS001) that has been in place for your water system. 
In the result of an E. coli positive sample, please contact Sitara Federico at [e-mail] or [phone] within 24 hours of notification.