DDW-2024-013058

November 5, 2024
David Law
Penneys Grill
29 North Main Street
Tooele, Utah, 84074
Subject:Operating Permit, Penney’s Grill Chlorinator (TP001);
Penneys Grill, System #23075, File #13047
Dear David Law:
The Division of Drinking Water (the Division) received a request for an Operating Permit for the Penney’s Grill Chlorinator (TP001) from your consultant, Robert Rousselle, and Ensign
Engineering on September 27, 2024. The Division issued Plan Approval for this project on October 16, 2023. Division staff, Brent Arns conducted a final inspection of this facility September
18, 2024. This project has met all conditions for receiving an operating permit.
The letter includes the following sections and addenda:

Project Summary for Penney’s Grill Chlorinator (TP001) 
Operating Permit for Penney’s Grill Chlorinator (TP001)
Primary Monitoring and Reporting Requirements (Addendum 1)
Estimated Disinfection CT (Addendum 2)
Project Summary
Our understanding of the project is the installation of a liquid sodium hypochlorite chlorinator
system (identified as TP001 in the Division’s database). Two (2) 5-gallon liquid chlorine storage tanks, two (2) 80-gallon MixMaster Model BAF 80 disinfection tanks, used to obtain the
required chlorine contact time, and a Stenner S3001 peristaltic chemical metering pump. All valves, fittings, pumps, and mechanical equipment installed are rated for a minimum pressure
rating of 150 psi.
The Penneys Grill Chlorinator (TP001)included in this project has been completed according to the following:
The Penneys Grill Chlorinator (TP001) is designed to provide primary disinfection of the water from Penneys Grill Well (WS001).
The Penneys Grill Chlorinatoris a sodium hypochlorite solution chlorinator.
The Penneys Grill Chlorinatortreats water from the Penneys Grill Well (WS001). The sodium hypochlorite solutionis added to the water at the well house.
The chlorinated water then flows into the distribution system.
The sodium hypochlorite solution used for disinfection meets the ANSI/NSF 60 standard.
A design target dose of 2.8 mg/L (measured as free chlorine) is based on a typical flow of 22 gallons per minute (gpm) from Penneys Grill Well.
The chlorine dose is adjusted by a manually adjusted rotometer set for the constant flow from Penneys Grill Well
The Point of Entry (POE) sampling location will be in the well house after the (2) 80 gallon disinfection tanks.
Operating Permit for Penneys Grill Chlorinator (TP001)
We have received the following information for Penneys Grill Chlorinator (TP001):
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 operation and maintenance manual delivery.
We have determined that all conditions for issuing an operating permit have been met. On this basis, an Operating Permit for Penneys Grill Chlorinatoris hereby issued as constituted
by this letter. You may now place Penneys Grill Chlorinator (TP001) in service in your water system.
Please maintain a copy of this letter with your permanent records for future reference.
Primary and Secondary Disinfection
The Division issued a “Required to Disinfect” notice to Penney’s Grill on July 5, 2022. In August 2021, Penneys Grill LLC took a total of sixteen bacteriological distribution samples.
Of the sixteen samples that were taken, three samples were total coliform positive and E. coli positive. Seven samples came back total coliform positive and E. coli absent. In addition,
nine samples were taken at the Penney Well (WS001). Of the nine samples taken from the well, three samples were total coliform positive and E. coli positive. Four samples came back total
coliform positive and E. coli absent. Two samples were total coliform absent.
The positive sample results indicate that Penney Well (WS001) source is a low-quality ground water source that does not consistently meet standards of bacteriologic quality. Based on
the sample history, the Division requires Penneys Grill LLC to provide continuous primary disinfection of the Penneys Grill Well (WS001) and continuous secondary disinfection of the
entire distribution system.
Penneys Grillis required to demonstrate ongoing compliance with the primary and secondary disinfection requirements found in Addendum 1.
Penneys Grill Chlorinator (TP001) Disinfection CT
The Division received the information of the worst-case scenario disinfection CT estimated by your consultant, which is described in the Addendum to this letter.The estimated worst-case
scenario disinfection CT before the chlorinated water reaches the point-of-entry to the distribution system (POE) is 2.8, which meets the 4-log virus inactivation goal.The issuance of
this Operating Permit resolves your water system’s deficiency related to S001 UNAPPROVED SOURCE IN SERVICE. An updated IPS report isavailable at https://waterlink.utah.gov. Please contact
Jennifer Yee at [phone] or [e-mail] for questions related to your water system’s IPS report or deficiencies.
If you have any questions regarding this Operating Permit, please contact Brent Arns, of this office, at [phone], or Michael Newberry, P.E., Permitting and Engineering Support
Manager, at [phone].
Sincerely,
Russell Seeley, P.E.
Assistant Director
BA/LT/mrn/Admin (processing)/Admin (mailing) [Initials]

Enclosure:Addendum 1- Primary Monitoring and Reporting Requirements
Addendum 2- Estimated Disinfection CTcc:Bryan Slade, Tooele County Health Dept., [e-mail] Law, Penneys Grill, [e-mail] Rousselle, P.E., Ensign Engineering,
[e-mail] Kruse, Division of Drinking Water,[e-mail] Yee, Division of Drinking Water, [e-mail] Smith, Division of Drinking Water, [e-mail]
Smith, Division of Drinking Water, [e-mail] Treutel, Division of Drinking Water, [e-mail] Federico, Division of Drinking Water, [e-mail] Martin,
P.E., Division of Drinking Water, [e-mail] Arns, Division of Drinking Water, [e-mail] Arns 23075 13047 OP Penneys Grill Chlorinator TP001
ADDENDUM 1 
Primary Monitoring and Reporting Requirements 
Chlorine Monitoring & Reporting Requirements
The water system is required to meet primary and secondary disinfection requirements. As a part of these requirements, the water system is required 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. 
Secondary Disinfection Requirements and Reporting 
Chlorine Residual ‒ Point of Entry (POE) to Distribution System
The POE sampling location is identified as EP001 in the Division’s database. This location has been identified as the well house after the (2) 80-gallon disinfection tanks. Maintain
a minimum of 2.8 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 value of chlorine residual measured as free chlorine at the Penneys Grill ChlorinatorPOE sampling location (EP001). [R309-210- 8(3)(a)(ii)]
Our records show that your water system serves 27 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 sample(s). 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 secondary disinfection requirements, the water system must complete monthly operational reports for each active chlorinator using a template approved
by the Division. 
Operational reports for primary disinfection must be submitted monthly. The reports are due to the Division by the 10th day following the end of each reporting month. 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)]
ADDENDUM 2
Information of Estimated Disinfection CT 
Penneys Grill LLC (UTAH #23075)
Penneys Grill Chlorinator (TP001)
A system’s pathogen treatment effectiveness is typically expressed in terms of log10 removal or inactivation. For example, primary disinfection of a groundwater source is demonstrated
by meeting a 4-log10 inactivation for virus. The level of inactivation by disinfection is calculated by taking the disinfection residual (Concentration) multiplied by the contactTime,
or is referred to in terms of CT. For groundwater sources that must have continuous disinfection, a minimum CT of 12 is required for 4-log virus inactivation for water pH ranges between
6 and 9 and a worst-case scenario of water temperature of 0.5°C. 
Please note that the Division’s review of estimated CT information is limited to the disinfection CT that can be achieved in a worst-case scenario based on the current system configuration.
The worst-case scenario disinfect CT estimate does not reflect the actual CT achieved during ongoing operation. The water system is required to monitor and report the actual CT achieved
when Penneys Grill Chlorinator (TP001)is in operation. The actual CT values are compared to the CT associated with the required log treatment to determine compliance. 
The Division received the following information of the worst-case scenario disinfection CT estimated by your consultant. 
The estimated worst-case scenario disinfection CT before the chlorinated water reaches the point of entry to distribution system (POE) sampling location is 2.8, which meets the 4-log
virus inactivation of groundwater sources (a minimum CT of 6).
POE Sampling Location: The POE sampling location was specifically identified as in the well house after the (2) 80-gallon disinfection tanks. 
Chlorine Residual at POE: The CT estimate is based on chlorine residual at POE at 0.2mg/L (measured as free chlorine) as the worst-case scenario.
pH: The CT estimate is based on water pH ranging between 6 and 9.
Temperature: The CT estimate is based on the worst-case scenario of winter water temperature of 0.5°C.
Disinfection CT: The estimated worst-case scenario disinfection CT of 2.8 encompasses the CT segments described in the attached CT summary table. Also attached is the CT calculation
sheet.