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HomeMy WebLinkAboutDDW-2024-013140 November 7, 2024 Melissa Hughes Pinion Forest SSD P.O. Box 38 Duchesne, Utah 84021 Subject:Temporary Operating Permit, Water Hauling Station Treatment Plant (TP001) and Water Hauling Station 1 Tank (ST001) Modifications; Pinion Forest SSD, System #07073, File #13550, SRF #3F1844 This Temporary Operating Permit Expires on November 1, 2025 Dear Melissa Hughes: The Division of Drinking Water (the Division) received a request for a Temporary Operating Permit for the Water Hauling Station Treatment Plant and Water Hauling Station 1 Tank Modifications from your consultant, Jeffrey Baker, P.E. of Jones & Demille Engineering on November 6, 2024. The Division issued Plan Approval for this project on November 15, 2023.Division staff, Dani Zebelean and Allyson Spevak, conducted a final inspection of this project on July 17, 2024. This project has met all conditions for receiving anoperating permit. This letter includes the following sections and addenda: Project Summary for the Water Hauling Station Treatment Plant (TP001) Operating Permit for the Water Hauling Station Treatment Plant (TP001) and Water Hauling Station 1 Tank (ST001) Modifications Treatment Project Overview (Addendum 1) Monitoring and Reporting Requirements (Addendum 2) Project Summary Our understanding of the project was to add chlorination and media filtration for the removal of iron, manganese, and turbidity at the Pinion Forest Well (WS001) as a result of the required disinfection – secondary (RTD) letter on June 14, 2022. The details of the treatment plant are included in Addendum 1. The Water Hauling Station Treatment Plantis identified as TP001in the Division’s database. The modifications made to the storage tank were made so the overflow and drain structure met state construction standards. The chlorinator included in the Water Hauling Station Treatment Plant (TP001) has been completed according to the following: The chlorinator in the Water Hauling Station Treatment Plant (TP001) is a liquid hypochlorinator to provide secondary disinfection. The chlorinatortreats water from the Pinion Forest Well (WS001). The liquid chlorine is added to the water on the well discharge piping before the static rapid mixers. The chlorinated water then enters the Water Hauling Station 1 Tank (ST001) and is available to the customers of Pinion Forest to haul water to their properties. The liquid sodium hypochlorite used for disinfection meets the ANSI/NSF 60 standard. The design target dose is 0.75 mg/L (ppm) of free chlorine. There is a recirculation line from the storage tank where more chlorine can be added to maintain residual. The Point of Entry (POE) sampling location for the chlorinator is the online chlorine analyzer located in the water treatment plant. (Temporary) Operating Permit We have determined that all conditions for issuing a Temporary Operating Permit have been met. On this basis, a Temporary Operating Permit for the Water Hauling Station Treatment Plant (TP001) is hereby issued as constituted by this letter contingent upon your compliance with the following conditions: This Temporary Operating Permit expires on November 1, 2025 The System must obtain a permanent operating permit for the Water Hauling Station Treatment Plant by November 1, 2025. We have received the following information for the Water Hauling Station Treatment Plant (TP001) and Water Hauling Station 1 Tank (ST001): Certification of Rule Conformance with plan approval conditions by a professional engineer. Satisfactory bacteriological results as evidence of proper disinfection and flushing. Water quality data — Four (4) pairs of raw and treated water analyzed for turbidity, iron, and manganese demonstrating the performance of the treatment plant. We have determined that all conditions for issuing an operating permit have been met. On this basis, a Temporary Operating Permit for the Water Hauling Station Treatment Plant(TP001)is hereby issued as constituted by this letter. You may now place the facility in service in your water system. Please maintain a copy of this letter with your permanent records for future reference. Secondary Disinfection Requirements Pinion Forest SSD is required to provide continuous disinfection to maintain detectable chlorine residuals from the Pinion Forest Well (WS001). From January 2019 through May 2022, Pinion Forest had sixteen total coliform present, Escherichia coli (E. coli) absent samples from the sample tap at the water hauling station. Further, there were multiple Level 2 Assessments conducted on the system within the past few years. Based on the number of total coliform present results, and the results of the Level 2 Assessments, the Division determined that Pinion Forest SSD does not consistently meet standards of bacteriologic quality within the distribution system. Because of this, the Division required the system to install and operate secondary disinfection, as described in the Letter dated June 14, 2022. The water system will be required to demonstrate ongoing compliance with the disinfection requirements described in Addendum 2 of this letter. As part of the required to disinfect designation, Pinion Forest shall not be allowed to operate the Pinion Forest Well (WS001) without a chlorinator. Please be aware that, if any water source of the Pinion Forest SSDis found to require primary disinfection in the future per R309-200-5(7)(a)(i), additional regulations will apply. 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. Monitoring and ReportingIssuance of this Operating Permit changes your water system’s monitoring and reporting requirements. The current monitoring and reporting requirements for this system are found in Addendum 2 of this letter and can be viewed anytime online at waterlink.utah.gov. Please contact Mark Berger, Water Quality/Monitoring and Standards Manager at (801) 641-6457 for questions regarding the monitoring and reporting requirements for your water system. There may be new changes in monitoring and reporting requirements in the future as the Division continues to improve the disinfection monitoring and reporting practices. Failure to adhere to required monitoring and reporting will result in violations and the assessment of IPS points. Improvement Priority SystemThe issuance of this temporary operating permit will make the S001, unapproved source in service, a deficiency dormant on the IPS report. This deficiency will be used to track the expiration date of this operating permit. An updated IPS report is available at https:\\waterlink.utah.gov. Please contact Jennifer Yee at (385) 515-1501 or jyee@utah.gov for questions related to your water system’s IPS report or deficiencies. If you have any questions regarding this Operating Permit, please contact Dani Zebelean, of this office, at (385) 278-5110, or Michael Newberry, Permitting and Engineering Support Manager, at (385) 515-1464. Sincerely, Russell Seeley, P.E. Assistant Director Enclosures: Addendum 1 - Project Overview Addendum 2 - Monitoring and Reporting Requirements DZ/mrn/mdbcc:Joe Hadlock, Tri-County Health Department, jhadlock@tricountyhealthut.govMatt Laurendeau, Jones and Demille Engineering, Matt.l@jonesanddemille.comJeffery Baker, Jones and Demille Engineering, jeff.b@jonesanddemille.comMelissa Hughes, Pinion Forest SSD, melissa.hughes@pfssd.usClyde Watkins, Pinion Forest SSD, clydedcwcd@gmail.comNathan Hall, DEQ Tri-County District, nhall@utah.govDani Zebelean, Division of Drinking Water, dzebelean@utah.govLuke Treutel, Division of Drinking Water, ltreutel@utah.gov David Kruse, Division of Drinking Water,dbkruse@utah.gov Allyson Spevak, Division of Drinking Water, allysonspevak@utah.govSitara Federico, Division of Drinking Water, sfederico@utah.govJennifer Yee, Division of Drinking Water, jyee@utah.govBrandi Smith, Division of Drinking Water, brandismith@utah.govDZebelean 07073 TP001 TOP ADDENDUM 1 Project Overview Pinon Forest SSD Water System (UTAH#07073) Water Hauling Station Treatment Plant (TP001) Our understanding of the project is that the proposed Water Hauling Station Treatment Plant will treat Pinon Forest Well 1(WS001) for secondary contaminants that could precipitate out of the water due to the water system adding chlorine to the water. Pinion Forest SSD was given a required to disinfect (RTD) letter on June 14, 2022. As part of the letter, the Division suggested looking into treatment options to help with turbidity and taste and odor concerns. The water from the Pinon Forest Well 1 (WS001) also has elevated levels of sulfate and total dissolved solids (TDS) that exceed the secondary maximum contaminant levels (SMCL). Turbidity is the only tested analyte with an MCL. While it does not directly have any health risks, higher levels of turbidity are often associated with higher levels of disease-causing microorganisms. Manganese, Iron, Sulfate, and TDS are all secondary contaminants. High levels of TDS and sulfate are often associated with gastrointestinal issues. Manganese over a long exposure time may cause problems with memory, attention, and motor skills. Conversely, Iron does not usually present other health risks, but it could be an indication of disease-causing microorganisms in the well water. As described in the pilot testing results report prepared by Matthe Laurendeau, P.E. of Jones and DeMille dated September 12, 2023, a Kinetico filtration unit capable of treating 5-8 gallons per minute (gpm) was used. The pre-chlorination and oxidizing media filtration reduced the turbidity below the MCL of 5 NTU, Iron below the detection limit, and Manganese below the SMCL of 0.05 mg/L. The report also evaluated the cost of installing reverse osmosis that would be needed to address sulfate and TDS. The proposed Water Hauling Station Treatment Plant consists of pre-oxidation, media absorption, and post-chlorination processes. The proposed Water Hauling Station Treatment Plant (TP001) has a plant design capacity of 76 gpm. The design includes 4 train(s) of the media absorption processes, and each train of 19 gpm. The proposed treatment plant consists of the following processes in sequence: Pre-oxidation – by liquid sodium hypochlorite addition. First-stage media adsorption – Fiberglass-wrapped polyethylene tanks with Catalytic Oxidation media; 4 trains; 19 gpm per train. Post-chlorination – sodium hypochlorite injection; dosed based on the online chlorine analyzer to reach a target dose of 0.75 ppm. Post Treatment Storage – the existing 45,000-gallon Water Hauling Station 1 Tank (ST001). Backwash Water – Each filter vessel will backwash with unfiltered water directly from the well. Each filter is internally controlled to backwash and prevent cross-connections. The filters will backwash at 8 gpm which is enough to achieve 50% bed expansion. The backwash water is discharged into a collection box shared with the pump to waste. ADDENDUM 2   Secondary Monitoring and Reporting Requirements  Chlorine Monitoring & Reporting Requirements The water system is required to meet 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 asEP001 in the Division’s database. This location has been identified as the online chlorine analyzer in the Water Hauling Station Treatment Plant (TP001). 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 value of chlorine residual measured as free chlorine at the Water Hauling Station Treatment PlantPOE sampling location (EP001). [R309-210- 8(3)(a)(ii)] Our records show that your water system serves 640 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. 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.  The monthly operational reports are submitted quarterly. The reports are due to the Division by the 10th day following the end of each reporting quarter (i.e., January 10th, April 10th, July 10th, and October 10th). The reports can be submitted by hardcopy, fax, or by uploading them to the Division’s chlorine residual reporting form which can be found at MRDL.utah.gov. Please contact Luke Treutel at (385) 258-6084 or ltreutel@utah.gov to schedule training regarding proper reporting. Records must be maintained for a minimum of 5 years. [R309-105-17(1)] Source and Treatment Plant Monitoring Requirements The water quality from Pinion Forest Well 1 (WS001) will be evaluated through post treatment samples collected from the Water Hauling Station Treatment (TP001). These requirements are given below. The post treatment sampling location is identified as TP001 in the Division’s database. Please label the samples accordingly. After six months of turbidity, iron and manganese sampling, the monitoring frequencies for these parameters can be reduced to quarterly. An updated monitoring schedule can be viewed any time at waterlink.utah.gov under the Water Monitoring section. Please contact David Kruse at (385)-566-7789 or dbkruse@utah.gov for questions regarding the source monitoring and reporting requirements for your water system or to request reduced monitoring.Facility with new requirementsAnalyte(s) Required# of samplesSampling FrequencyNext Due DateRule ReferenceTP001 Water Hauling Station TreatmentTurbidity1Monthly09/01/2024-09/30/2024R309-215-6(2)(a)Iron1Monthly09/01/2024-09/30/2024R309-215-6(2)(a)Manganese1Monthly09/01/2024-09/30/2024R309-215-6(2)(a)Nitrate1Yearly01/01/2025-12/31/2025R309-205-5(4)(a)Volatile Organic Contaminants1Yearly01/01/2025-12/31/2025R309-205-6(2)Inorganics & Metals1Every three years01/01/2026-12/31/2028R309-205-5(3)(a)Sulfate, Sodium, TDS1Every three years01/01/2026-12/31/2028R309-205-5(3)(a)Pesticides1Every three years01/01/2026-12/31/2028R309-205-6(1)(f)Radionuclides1Every six years01/01/2026-12/31/2031R309-205-7(1)(c)