DDW-2024-006538

March 13, 2024
Raymond Garrison
South Jordan City
1600 Towne Center Drive
South Jordan, Utah 84095
Subject:Special Permit, Pure SoJo Direct Potable Reuse (DPR) Demonstration Facility Taste Test Phase 2 and Concurrence, Updated Pure SoJo DPR Demonstration Facility Testing and Monitoring
Plan; South Jordan City, System #18023, File #12554
Dear Raymond Garrison:This letter provides a summary of the Division of Drinking Water’s decision to issue phase two of the special permit for the Pure SoJo DPR demonstration facility
to include public taste testing and concurrence with the updated testing and monitoring plan for the Pure SoJo DPR demonstration pilot facility. Phase one of the special permit was issued
on February 2, 2022. The Division supports the following project goals:Continued demonstration after two years of operation that final effluent from a water reclamation facility can
meet drinking water quality regulations without the use of Reverse Osmosis.Estimate operating, monitoring and analytical, and construction costs of a full-scale water treatment plant.
Collaboration between South Jordan City and the Division that will help develop regulations for DPR in the state of Utah. Support public outreach efforts to gain public support in favor
of DPR efforts. The Division has completed reviews of four memorandums with testing results and analysis, submitted from November 2022 to September 2023, the request for Updated Log
Reduction Value Goals and Credits dated June 1, 2023, updated sampling plan, and monthly water reporting templates from December 2023 and January 2024 and concurs that an updated special
permit can be issued. This special permit and concurrence includes the public taste testing, with conditions and monitoring required based on the data collected during phase one of the
special permit. Enclosed please also find the following information related to this approval:Addendum 1. Project Overview, which provides detailed description of the treatment plant
design.Addendum 2. Compliance Strategy for Achieving Water Treatment Goals, which describes the approved strategy to meet Log Removal Value (LRV) Goals. Addendum 3. Summary of Water
Treatment Monitoring and Reporting RequirementsAttachment 1. Approved Taste Testing Checklist, which should be used and filled out prior to a taste testing event. South Jordan will be
required to keep records of the checklist but it is not required to submit to the Division.
If you have any questions regarding this Operating Permit, please contact Dani Zebelean, of this office, at [phone], or Michael Newberry, Permitting and Engineering Manager, at
[phone].
Sincerely,
Nathan Lunstad, P.E.
Director
DZ/mrn/mdbEnclosuresAddendum 1. Project OverviewAddendum 2. Compliance Strategy for Achieving Water Treatment GoalsAddendum 3. Summary of Water Treatment Monitoring and Reporting RequirementsAttachment
1 - Approved Taste Testing Checklistcc:Ron Lund, Salt Lake County Health Department Director, [e-mail] Ramsey, Mayor, South Jordan City, [e-mail] Garrison,
South Jordan City, [e-mail] Rasumussen, South Jordan City, [e-mail] Collins, South Jordan City, [e-mail] Rose, South Jordan City,
[e-mail] Lunstad, P.E., Director, Division of Drinking Water, [e-mail] Domonoske P.E., Carollo, [e-mail] Steinle-Darling Ph.D., P.E., Carollo,
[e-mail] Bassett, P.E., Carollo, [e-mail] Salveson P.E., Carollo, [e-mail] Seeley, P.E., Division of Drinking Water, [e-mail]
Newberry, P.E. Division of Drinking Water, [e-mail] Page, Ph.D., Division of Drinking Water, [e-mail] Zebelean, Division of Drinking Water, [e-mail]
Hoffman, P.E., Division of Water Quality, [e-mail] Hays, South Valley Sewer, [e-mail] White, South Valley Sewer, [e-mail]
DZebelean 18023 Taste Test PermitADDENDUM 1Project Overview
South Jordan City Water System (UTAH#18023)
Pure SoJo DPR Demonstration Facility
The understanding of the Division of Drinking Water (the Division) of the project thus far is South Jordan City (the System) is considering direct potable reuse (DPR) to expand its water
sources beyond its wholesale connection to Jordan Valley Water Conservancy District (JVWCD). The System has no water rights due to groundwater contamination in the local aquifers. After
spending several years looking for alternative water sources, the System decided to start working towards a full-scale DPR facility to produce potable water that would be blended with
the wholesale water from JVWCD. The first step was building and operating the Pure SoJo DPR Demonstration Facility. The system has operated the demonstration facility for the past two
years and collected data to show they can treat the water to meet Safe Drinking Water Regulations and more with the expanded sampling to cover Contaminants of Emerging Concern (CEC).
The System is now planning to offer public taste testing as part of its public outreach efforts. The Pure SoJo DPR Demonstration Facility is located at Jordan Basin Water Reclamation
Facility (JBWRF) which currently utilizes a membrane biological reactor (MBR) and ultraviolet (UV) disinfection to treat its water.
An initial meeting held in February 2019 with regulators from the Division and the Division of Water Quality (DWQ) introduced the DPR pilot treatment option. A meeting was held on December
10, 2020, presenting the finalized pre-design for the demonstration pilot facility. A follow-up meeting was held on February 12, 2021. After the February meeting, the Division provided
a response letter to the predesign report dated April 22, 2021, providing concerns of the Division. A meeting to discuss these concerns was held on May 21, 2021, with the Division, DWQ,
Carollo Engineers, Inc (Carollo), and the City. A site tour of the proposed demonstration facility was conducted on August 25, 2021, with representatives of the Division, DWQ, Carollo,
and the City present. A follow-up meeting held on September 22, 2021, with the Division, Carollo, and the City, discussed comments on the testing plan and introduction of a monthly reporting
template. The ozone and biologically active carbon unit was toured on October 25, 2021, with Division, Randy Zollinger from Carollo, Intuitech, and Suez Technologies representatives
present. A meeting to discuss comments on the Division’s special permit draft was held on December 7, 2021, with the Division, Carollo, and the City. The first phase of the special permit
was issued on February 2, 2022.
After the first phase of the permit was issued, the Division, the System, and Carollo held meetings to go over the first four quarters of operating data. The first quarterly meeting
was held on November 1, 2022, the second quarter was reviewed on February 15, 2023, the third quarter on May 4, 2023, and the fourth quarter was reviewed on August 17, 2023. There was
a delay in starting the quarterly reviews after the Pure SoJo DPR Demonstration Facility started operation due to the lead time to get all the sample results back from laboratories.
Additionally, the Request for Updated LRV Goals and Credits dated June 1, 2023, was reviewed and the Division concurred with the request on July 26, 2023, via email, this letter serves
as the formal acceptance of the updated LRV goals.
Project Summary
The Division’s understanding of the project is that the System built the Pure SoJo DPR Demonstration Facility inside of a future boiler room at JBWRF in the thermal drying facility.
The water is the final effluent taken downstream of JBWRF’s MBR and UV disinfection processes. The final effluent is non-chlorinated utility water pumped from a clearwell upstream of
JBWRF’s outfall and river discharge. Treated water from the Pure SoJo DPR Demonstration Facility is returned to headworks of JBWRF.
The Pure SoJo DPR Demonstration Facility process consists of ozone advanced oxidation, biologically active carbon filtration (BAC), ultrafiltration (UF), granular activated carbon (GAC),

UV disinfection, ion exchange (IX), post-chlorination processes. The Pure SoJo DPR Demonstration Facility has a design capacity of 8-12 gallons per minute (gpm), with a 0.5 gpm design
flow rate through the IX and post-chlorination processes for taste testing.
The treatment plant consists of the following processes in sequence:
Water is pumped from the clearwell after JBWRF’s MRB and UV disinfection processes.
Ozone - Ozonia Model TOGC -45 ozone generator with integrated Pressure Swing Adsorption (PSA) generator and air compressor. This unit is skid-mounted and includes a feed pump, a high
ozone concentration analyzer, direct injection type venturi injectors, an ozone contact tank, a break tank, an ozone destruction unit (Ozonia Model ODT-003), influent/effluent Total
Organic Carbon (TOC) analyzers, and off-gas analyzers to detect any leaks.
BAC - This gravity filter is mounted on the same skid as the ozone generator provided by Suez and Intuitech. It is provided with a feed pump, an air scour blower, a backwash pump, a
Dissolved Oxygen (DO) analyzer and a backwash tank. The BAC filter column contains carbon filter media with an underdrain below and several sampling points. The filter media is Calgon
Filtrasorb 820 activated carbon, with an effective size 1.0-1.2 mm and a uniformity coefficient of 1.5. The empty bed contact time is 15 minutes at 11 gpm. To limit direct large backwash
flowrates to the Pure SoJo DPR Demonstration Facility plant drain, a backwash flow equalization tank was added.
UF - The UF system is a WesTech Engineering, Inc. (WesTech) Model UFT11c, AltaPac System sized for a 10 to 12 gpm flow rate. It is supplied with one Toray HFU-1020 membrane module with
0.01 um nominal pore size and 312 square feet of membrane area. The AltaPac System includes a pre-strainer, a compressed air system, a Clean-In-Place (CIP) System, a turbidimeter, a
feed pump, feed and CIP backwash tanks, and an Integrity Test system.
GAC - The GAC system consists of two pressure vessels operated in lead-lag. The GAC media is Calgon Filtrasorb 400 activated carbon. A feed pump, supplied separately, supplies water
from the UF backwash tank. The minimum media depth is specified to be 39 inches, the effective media size is 0.55- 0.75 mm, the uniformity coefficient is 1.9, and the empty bed contact
time (EBCT) is 21 minutes at 8 gpm.
UV - the UV disinfection system was purchased from Evoqua Water Technologies (ATG UV Systems). Evoqua provided a single lamp reactor, model UVLX-1800-6, an online transmittance monitor
and a local control panel. The local control panel (microprocessor) monitors lamp status, UV transmittance (UVT), UV intensity, reactor temperature, and flowrate. The control panel controls
UV reactor start up and shut down, calculates UV dose delivery, operates the wiper system, and provides emergency shut down if necessary. The unit is designed to provide a target dose
of 276 mJ/cm^2 assuming a maximum of 15 gpm flowrate, 80% transmittance, and lamp aging and flowing factors of 0.85 and 0.9, respectively. This unit has undergone third party validation
testing per United States Environmental Protection Agency Ultraviolet Disinfection Guidance Manual (2006).
IX - Nitrates will be removed using a custom built 3-inch diameter by 30-inch tall IX column with Purolite A300E resin designed specifically for nitrate removal.
Post-chlorination - Liquid sodium hypochlorite will be injected downstream of the IX unit and a standpipe is used for disinfection chlorine contact time. A 12.5% sodium hypochlorite
solution, diluted to 1.25%, will be used. The disinfection CT (CT = Concentration × Contact Time) calculations were based on the CT from the Stand Pipe No. 3 with 12-inch diameter and
14-gallon volume. The disinfection CT calculations are also determined using a minimum free chlorine residual of 0.5 ppm, and peak flow of 0.5 gpm, and a tank baffling factor of 0.3.
ADDENDUM 2Compliance Strategy for Achieving DPR Water Treatment Goals
South Jordan City Water System (UTAH#18023)
Pure SoJo DPR Demonstration Facility Treatment Goals for DPR Water Treatment
The Pure SoJo DPR Demonstration Facility consists of ozone advanced oxidation, biologically active carbon (BAC) filtration, ultrafiltration (UF), granular activated carbon (GAC), ultraviolet
(UV) disinfection, ion exchange (IX), and post-chlorination processes. This pilot facility is designed to meet proposed direct reuse recommendations of removal and/or inactivation, expressed
in terms of log10 credit, of Cryptosporidium, Giardia lamblia, and viruses through treatment techniques.
The Request for Updated Log Reduction Values (LRVs) Goals and Credits dated June 1, 2023, summarized the source water characterization. The Division of Drinking Water (the Division)
concurs that the required treatment goals for the Pure SoJo DPR Demonstration Facility are:
8-log10 removal/inactivation for virus,
6-log10 removal/inactivation for Giardia lamblia, and
5.5-log10 removal/inactivation for Cryptosporidium.
The Division anticipates following the precedents Colorado and Texas established in their rule and guidance, respectfully, for LRV goals. A system has two options to follow in terms
of LRV goals. The first is to not characterize the effluent from the water reclamation facility and treat to 12- log10 removal/inactivation for virus, 10-log10 removal/inactivation for
Giardia lamblia, and 10-log10 removal/inactivation for Cryptosporidium. However, with effluent characterization, a water system would be able to lower the goals to a minimum of 8-log10
removal/inactivation for virus, 6-log10 removal/inactivation for Giardia lamblia, and 5.5-log10 removal/inactivation.
The Pure SoJo Demonstration Facility is supplied with water from the effluent of Jordan Basin Water Reclamation Facility (JBWRF). Samples were collected biweekly for characterization
of norovirus, adenovirus, enteric virus, Cryptosporidium, and Giardia lamblia. The samples from April 2022 to April 2023 were analyzed in the Request for Updated LRV Goals and Credits
dated June 1, 2023. Per the results in the letter, the Division concurred with granting the minimum required values of 8-log10 removal/inactivation for virus, 6-log10 removal/inactivation
for Giardia lamblia, and 5.5-log10 removal/inactivation for the Pure SoJo Demonstration Facility. Compliance StrategyPrimary FiltrationFour filtration processes are installed throughout
the Pure SoJo DPR Demonstration Facility treatment train. Biologically Active Carbon (BAC) FiltrationNo log removal credits are assigned to the BAC. The BAC serves to remove organic
carbon, stabilize the water post-ozone, and remove trace organics. Ultrafiltration (UF)The WesTech AltaPac ultrafiltration system employs a single Toray HFU-1020 membrane module with
0.01 um nominal pore size and 312 square feet of membrane area. It is operated at a maximum of 69.6 gallons per square foot per day (gfd) maximum flux rate (normalized at 20 oC), maximum
29 pressure per square inch - differential (psid) transmembrane pressure and maximum 43.5 pressure per square inch - gauge (psig) allowable module feed pressure. The ultrafiltration
skid employs automatic direct integrity testing where a Direct Integrity Test (DIT) is a Pressure Decay Test (PDT) that is used to verify membrane integrity and calculate an LRV based
on a PDT. The DIT is performed once per calendar day (daily) when operational and after any cleaning, maintenance, or emergency maintenance. A DIT can also be initiated manually.If the
LRV is below 4.0, the UF skid automatically shuts down. Diagnostic testing is pursued when the unit fails to pass a DIT. The UF skid also employs continuous indirect integrity testing
monitoring where effluent turbidity is continually monitored, and the unit is shut down if filtrate turbidity exceeds 0.15 NTU for greater than 15 minutes. Turbidimeters are calibrated
monthly. According to the State of Colorado acceptance of the Toray HFU-2020N letter, dated May 2014, the Toray HFU-2020N module is credited for providing 4-log10 removal for Giardia
lamblia and 4-log10 removal for Cryptosporidium if the system is operated within the maximum flow of 12 gpm and the maximum trans-membrane pressure of 29 psi is not exceeded. The Division
concurs with this determination. The Division grants 4-log10 credit for Giardia lamblia removal, and 4-log10 credit for Cryptosporidium removal for this first-stage compliance filter.

Per R309-200-5(5)(a)(ii) and R309-530-8(8)(s), the turbidity performance standard for this treatment process is that the turbidity shall be less than 0.1 NTU 95% of the time, and shall
not exceed 0.5 NTU.Granular Activated Carbon (GAC) FiltrationNo log removal credits are assigned to the GAC filtration process. GAC filtration removes bulk and trace organic compounds,
including taste and odor compounds and other chemicals through adsorption. Ion Exchange (IX)No log removal credits are assigned to the IX process. The IX treatment serves to remove nitrate

to achieve drinking water standards of nitrate less than 10 mg/L for taste testing. The IX will only be run during testing and for taste testing events at a reduced flow rate of 0.5
gpm.
Disinfection
Three disinfection processes are installed throughout the Pure SoJo DPR Demonstration Facility:
Ozone Advanced Oxidation Disinfection
No log removal credits are assigned to the Ozone system at this time. . The purpose of the ozone is to break down Total Organic Carbon and CECs and is dosed such that the ozone:TOC
ratio is greater than 0.8 to achieve these. The operational goal is to maintain an ozone residual entering the contactor.
Ultraviolet (UV) disinfection
Model UVLA-1800-6 UV reactor manufactured by Evoqua Water Technologies (ATG UV Systems) is installed immediately following GAC filtration. This UV reactor was validated by Carollo Engineers,
Inc. in a report dated February 2023. This February 2023 report adds to the report by Carollo Engineers dated April 2019 by expanding the validated flow rates of the UV reactor. The
UV reactor is designed to provide a minimum validated dose of 276 mJ/cm^2, which provides a minimum of 6-log10 inactivation for virus, 6-log10 inactivation for Giardia lamblia, and 6-log10
inactivation for Cryptosporidium, as granted in the EPA’s Innovative Approaches for Validation of Ultraviolet Disinfection Reactors for Drinking Water Systems dated April 2020. The Division
concurs with this validation report. Per R309-520-8(3),the Division accepts the minimum validated dose UV dose approach proposed by Carollo Engineers, Inc. This UV reactor is designed
to provide a minimum validated dose of 276mJ/cm2, which provides a minimum of 6-log10 inactivation for virus,6-log10 inactivation for Giardia lamblia and 6-log10 inactivation for Cryptosporidium.
Post chlorination
Chlorine will provide additional disinfection following UV treatment. The Pure SoJo DPR Demonstration Facility will provide additional disinfection through 12.5% liquid sodium hypochlorite,
diluted to 1.25%, during testing and taste testing events. A disinfection CT (CT = Concentration × Contact Time) of 12.0 is needed for 4-log10 inactivation for virus. The estimated
disinfection CT is 59.0, which meets the 4-log virus inactivation requirement.
The CT calculations were based on the CT from the Stand Pipe No. 3 with 12-inch diameter and 14-gallon volume. The chlorination CT calculations are also determined using a minimum free
chlorine residual of 0.5 ppm, and peak flow of 0.5 gpm, and a tank baffling factor of 0.3.
The design and LRV credits claimed for the Pure SoJo DPR Demonstration Facility are anticipated to exceed the treatment for virus, Giardia lamblia, and Cryptosporidium as required by
the Division. Utilizing ozone advanced oxidation, BAC filtration, UF, GAC, UV disinfection, ion exchange, and post-chlorination processestogether will achieve the total pathogen inactivations
of:
10-log10 inactivation for virus,
10.0-log10 removal and inactivation for Giardia lamblia, and
10.0-log10 removal and inactivation required for Cryptosporidium.
ADDENDUM 3
Summary of DPR Treatment Monitoring and Reporting Requirements
South Jordan City Water System (UTAH#18023)
Pure SoJo DPR Demonstration Facility
This Addendum summarizes the monitoring and reporting requirements related to the Pure SoJo Demonstration Facility.
Ongoing JBWRF Final Effluent Characterization and Reporting
The goal of the final effluent characterization is to continue to monitor the effluent for ongoing knowledge of the Jordan Basin Water Reclamation Facility (JBWRF).
Some of the data in the characterization will be collected from the EPA’s Enforcement and Compliance History Online (ECHO) database.
The proposed regulated and unregulated chemical monitoring for JBWRF final effluent characterization during the operation of the Pure SoJo DPR Demonstration Facility in addition to data
gathered from ECHO is shown below in Table 1.
With every sample, pH, and temperature will be collected.
Submit the results of the ongoing characterization to the Division of Drinking Water (the Division) semi-annually, on the 15th of June and December. This report can be submitted by email
to [e-mail] and [e-mail].
Table 1 - Final Effluent Characterization Plan
Sampling Point Number
SP Identification
1
JBWRF Final Effluent
Parameter
Sample Frequency
EPA Method (if applicable)
Pathogens
Bacteria (total coliform, E. coli, and heterotrophic plate count)
Monthly
1604, 9223B, and 9215
Virus (total culturable, entero-, noro-, and adeno-)
1615
Protozoa (Cryptosporidium and Giardia)
1623
Regulated
Nitrate and nitrite as N
Monthly
200.5
Ammonia as N

350.1
Minerals1, including TDS
300.1
Volatile Organic Compounds (VOCs)2
Semi-Annually
524.2
Metals not included in ECHO3
Annually
200.6
Semi Volatile Organic Compounds (SOCs)
Once during continued operation
525.3, 515.4, and 531.2
Other Pesticides4
504.1, 547, 1613, 459.2, and 548.1
Other Water Quality Parameters
TOC
Weekly
UV Transmittance (UV254)
Conductivity
Alkalinity, hardness
Quarterly
Fluorescence Emission Excitation Matrix (FEEM)
Total and Free Chlorine
Unregulated
Per- and polyfluoroalkyl substances (PFAS)
Monthly
537.1 or equivalent
1,4-dioxane
Quarterly
522 or equivalent
Nitrosamines, including NDMA and NPYR
521 or equivalent
Hormones
Semi-Annually
539 or equivalent
Pharmaceuticals and Personal Care Products (PCCP)5
See Note
1Bromide, Bromate, Chlorate, Chlorite, Fluoride, Sulfate, Perchlorate
2VOCs include the following: 1,1,1,2-Tetrachloroethane, 1,1,2,2-Tetrachloroethane, 1,1-Dichloroethylene, 1,2-dichloroethane, 1,2-dichloropropane, 1,2,4-trichlorobenzene, benzene, carbon
tetrachloride, cis-1,2-dichloroethylene, dichloromethane, ethylbenzene, monochlorobenzene, o-dichlorobenzene, para-dichlorobenzene,styrene, tetrachloroethylene, toluene, trans-1,2-dichloroethylene,
trichloroethylene, vinyl chloride, and xylenes.
3Antimony, Barium, Beryllium, Thallium, Aluminum, Iron, and Manganese
4Ethylene dibromide and 1,2-dichloro-3-propane (EDP/DBCP) by EPA 504.1, Glyphosate by EPA 547, Dioxin (2,3,7,8-TCDD) by EPA 1613, Diquat by EPA 459.2, and Endothall by EPA 548.1.
5Pharmaceutical and personal care products (Eurofins ESI+ and ESI- lists), which will include DEET, caffeine, gemfibrozil, iopromide, and sucralose as listed in the Table 2 of the DDW
Letter. The project team will consider those listed in Table 2 but may choose to consolidate down to a single PPCP method based on the lab’s ability
to provide them in one analysis.
Monitoring and Reporting
The following is the monitoring and reporting scheme proposed by Carollo for the sample points 2-6 along the Pure SoJo DPR Demonstration Facility treatment train.
The second phase of testing includes sampling conducted for process optimization and/or research purposes as proposed by Carollo and South Jordan City and does not represent what would
be required long-term if South Jordan moves to a full scale facility.
The proposed regulated and unregulated chemicals were proposed by Carollo in the sampling plan dated January 2022. Carollo proposed an updated schedule to the sampling plan on June 1,
2023. The Division concurs with the schedule as shown in the tables below.
With every sample at each sample point, pH and temperature will be collected.
Submit the results of the ongoing characterization to the Division semi-annually, on the 15th of June and December. This report can be submitted by email to [e-mail] and [e-mail].

Table 2 - Post Ozone Monitoring
Sampling Point Number
SP Identification
2
Post-Ozone

Parameter
Sample Frequency
EPA Method (if applicable)
Other Water Quality Parameters
UV Transmittance (UV254)
Weekly
Ozone Residual
Fluorescence Emission Excitation Matrix (FEEM)
Quarterly
Unregulated
1,4-dioxane
Quarterly
522 or equivalent
Nitrosamines, including NDMA and NPYR
521 or equivalent
Hormones
Semi-Annually
539 or equivalent
Pharmaceuticals and Personal Care Products (PCCP)5
See Note
Table 3 - Biologically Active Carbon Filtration
Sampling Point Number
SP Identification
3
BAC Filtrate
Parameter
Sample Frequency
EPA Method (if applicable)
Regulated
Nitrate and nitrite as N
Monthly
200.5
Ammonia as N
350.1
Other Water Quality Parameters
UV Transmittance (UV254)
Weekly
TOC
Turbidity
Conductivity
Fluorescence Emission Excitation Matrix (FEEM)
Quarterly
Unregulated
Per- and polyfluoroalkyl substances (PFAS)
Monthly
537.1 or equivalent
Nitrosamines, including NDMA and NPYR
Quarterly
521 or equivalent
Hormones
Semi-Annually
539 or equivalent
Pharmaceuticals and Personal Care Products (PCCP)5
See Note
Table 4 - Ultrafiltration
Sampling Point Number
SP Identification
4
UF Filtrate
Parameter

Sample Frequency
EPA Method (if applicable)
Other Water Quality Parameters
Turbidity
Weekly and Continuous Monitoring per R309-215-15
Table 5 - Primary Granular Activated Carbon
Sampling Point Number
SP Identification
5a
Primary GAC Filtrate
Parameter
Sample Frequency
EPA Method (if applicable)
Regulated
TTHM-FP/HAA-FP
Monthly
Other Water Quality Parameters
UV Transmittance (UV254)
Weekly
TOC
Fluorescence Emission Excitation Matrix (FEEM)
Quarterly
Unregulated
Per- and polyfluoroalkyl substances (PFAS)
Monthly
537.1 or equivalent
Table 6 - Secondary Granular Activated Carbon
Sampling Point Number
SP Identification
5b
Secondary GAC Filtrate
Parameter
Sample Frequency
EPA Method (if applicable)
Regulated
Nitrate and nitrite as N
Monthly
200.5
Ammonia as N
350.1
TTHM-FP/HAA-FP
300.1
Other Water Quality Parameters
UV Transmittance (UV254)
Weekly
TOC
Conductivity
Fluorescence Emission Excitation Matrix (FEEM)
Quarterly
Unregulated
Per- and polyfluoroalkyl substances (PFAS)
Monthly
537.1 or equivalent
1,4-dioxane
Quarterly
522 or equivalent
Nitrosamines, including NDMA and NPYR
521 or equivalent
Hormones
Semi-Annually

539 or equivalent
Pharmaceuticals and Personal Care Products (PCCP)1
See Note
1Pharmaceutical and personal care products (Eurofins ESI+ and ESI- lists), which will include DEET, caffeine, gemfibrozil, iopromide, and sucralose as listed in the Table 2 of the DDW
Letter. The project team will consider those listed in Table 2 but may choose to consolidate down to a single PPCP method based on the lab’s ability
to provide them in one analysis.
Table 7 - Post Ultraviolet Disinfection Monitoring
Sampling Point Number
SP Identification
6
Post UV
Parameter
Sample Frequency
EPA Method (if applicable)
Unregulated
Nitrosamines, including NDMA and NPYR
Quarterly
521 or equivalent
Table 8 - Finished Water
Sampling Point Number
SP Identification
6a
Product Water
Parameter
Sample Frequency
EPA Method (if applicable)
Regulated
TTHMs/HAA with SDS1
Monthly
524/552
Nitrate and nitrite as N
Monthly
200.5
Ammonia as N
350.1
Other Water Quality Parameters
UV Transmittance (UV254)
Weekly
TOC
Conductivity
Alkalinity, hardness
Quarterly
Total and Free Chlorine
With DBP Samples
Unregulated
Hormones
Semi-Annually
539 or equivalent
Pharmaceuticals and Personal Care Products (PCCP)2
See Note
1For samples collected at SP-6a, the chlorine system shall operate for a minimum of 1 hour prior to sampling. TTHMs and HAAs will be analyzed for samples collected directly from the
tap. In addition, a 7-day simulated distribution system (SDS) test will be completed by analyzing TTHMs and HAAs on a 50/50 blend with
distribution system potable water after a 7-day holding time at distribution system temperatures.
2Pharmaceutical and personal care products (Eurofins ESI+ and ESI- lists), which will include DEET, caffeine, gemfibrozil, iopromide, and sucralose as listed in the Table 2 of the DDW
Letter. The project team will consider those listed in Table 2 but may choose to consolidate down to a single PPCP method based on the lab’s ability
to provide them in one analysis.
Table 9 - Finished Water at Taste Testing Sample Tap
Sampling Point Number
SP Identification
6b

Taste Testing Tap
Parameter
Sample Frequency
EPA Method (if applicable)
Pathogens
Bacteria (total coliform and E. col)
Monthly
1604 and 9223B
Regulated
Nitrate and nitrite as N
Monthly
200.5
TDS
Other Water Quality Parameters
TOC
Weekly
Monthly Report - General
The Pure SoJo DPR Demonstration Facility is required to use a template approved by the Division. As a minimum, the monthly report must include the following data and other applicable
information:
Raw water pH, Temperature, turbidity, and flow rate.
Ultrafiltration filtrate turbidity
GAC filtrate turbidity
Verification and calibration dates of turbidimeter(s)
When chlorine is dosed, information to validate the disinfection CT and/or inactivation ratio demonstrating the log removal/inactivation requirements are met.
Summary of the daily direct integrity test, continuous indirect integrity test, and triggered direct integrity test results.
Submit the monthly surface water treatment plant report quarterly to the Division by the 15th of January, April, July, and October for the previous three months. For example, the submittal
in January should include October, November, and December. This report must be submitted by e-mail as Excel files to [e-mail] and [e-mail]. Please contact Sarah Page
at [phone] or [e-mail] to schedule training regarding proper reporting.
All operational records pertaining to the monthly DPR water treatment plant reports shall be maintained for a minimum of 5 years. [R309-105-17]
Taste Testing
South Jordan City, Carollo, and the Division worked together to agree upon a taste testing checklist (see Attachment 1) that South Jordan City can utilize prior to taste testing events
in order to determine whether a taste test can be conducted that day.
The Division recommends the city retain records of the checklists but does require copies to be provided to the Division.
Treatment Adequacy
Water systems practicing DPR must provide treatment consisting of both disinfection and filtration.
The DPR treatment plant monthly report must include both disinfectionand filtration processes. The monthly report shall contain sufficient information to indicate whether the minimum
DPR treatment requirements (i.e., log removal/inactivation of Giardia, virus, and Cryptosporidium) are met.
Required Treatments Credit — The treatment credits required and claimed by South Jordan City for the processes in Pure SoJo DPR Demonstration Facilityare summarized below.
South Jordan City Water System (UTAH#18023)
Pure SoJo DPR Demonstration Facility
Treatment Goals
(Minimum Treatment Requirements)
Virus
Giardia
Cryptosporidium
8.0-log inactivation
6.0-log removal and inactivation
5.5-log removal and inactivation
Processes
Credit Granted
Alternative Filtration1 (WesTech AltaPac, Model UFT11C using Toray HFU-2020N membrane module)
–
4.0-log removal
4.0-log removal
Ultraviolet2
6.0-log inactivation
6.0-log inactivation
6.0-log inactivation
Chlorine3
4.0-log inactivation

–
–
Total Treatment Credit
10.0-log inactivation
10.0-log removal and inactivation
10.0-log removal and inactivation
Granted based on State of Colorado Department of Public Health and Environment, Water Quality Control Division, letter dated May 2014.
Based on validation completed by Carollo onsite and summarized in the report dated February 2023.
Based on the CT calculation by Alan Domonoske, P.E, Inc of Carollo Engineers. However, the Division can currently only grant up to 4-log inactivation credit as of the date of this letter.

Disinfection at Point of Entry (POE)[R309-200-5(7), R309-215-15(19)]
For the Pure SoJo Demonstration Facility the POE is defined as the taste testing tap.
Chlorine disinfection is not required to be continuously operated. However, chlorine disinfection will be required to operate continuously during taste test events.
The chlorine residual must not be below 0.2 milligram per liter (mg/L) free chlorine residual at the point of entry (POE). [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 0.1NTU in at least 95% of the measurements taken each month. The treated water
or CFE turbidity shall at no time exceed 0.5 NTU.
The turbidity level of the treated water or the CFE shall not exceed 5.0 NTU for any treatment technique.
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 #8a. [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.
The number and percentage of 4-hour combined filter effluent (CFE) turbidity measurements reported during the month, which are less than or equal to 0.1 NTU, excluding data described
in#8a.
If there is a failure in continuous monitoring equipment, taste testing shall not be conducted.
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 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 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.
Membrane Filtration — Direct Integrity Testing [R309-215-15(18)(b)(iii)]
The direct integrity test must be independently applied to each membrane unit in service.
The direct integrity test must have a sensitivity sufficient to verify the log treatment credit awarded. This sensitivity level or pass/fail criteria should be agreed upon by the Division
and the water system based on the manufacturer's recommendation or other testing.
The water system must establish a control limit within the sensitivity limits of the direct integrity test indicative of an integral membrane unit capable of meeting the removal credit
awarded.
If the result of a direct integrity test exceeds the control limit, the System must remove the membrane unit from service. The System must conduct a direct integrity test to verify any
repairs and may return the membrane unit to service only if the direct integrity test is within the established control limit.
Within 24 hours of plant operation, a direct integrity test must be conducted. The System must conduct a direct integrity test on each membrane module no less than once each calendar
day that the membrane unit is in operation, excluding the data described in #8a.
The System must submit a monthly report to the Director summarizing all excursions above the established control limit, the triggered direct integrity testing, and the action taken in

each case. [40CFR 141.721(f)(10)(ii)(B)]
Membrane Filtration — Indirect Integrity Testing [R309-215-15(18)(b)(iv)]
The System must conduct continuous indirect integrity monitoring (i.e., continuous filtrate turbidity monitoring) of individual membrane units (IFE) and combined filter effluent (CFE).
Continuous filtrate turbidity monitoring must be conducted at a frequency of no less than once every 15 minutes. [40CFR 141.719(b)(4)(ii) and (iii)]
If the filtrate turbidity readings are above 0.15 NTU for a period greater than 15 minutes (i.e., two consecutive 15-minute readings above 0.15 NTU), excluding the data described in
#5a, direct integrity testing must immediately be performed on the associated membrane unit. [R309-215-15(18)(b)(iv)(D)]
UV Monitoring and Reporting [R309-215-15(19)(d) and R309-520-8]
UV Reactor Monitoring Requirements
To obtain disinfection credit for 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 Director as a part of the monthly 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 flow rate
Daily minimum UVT
Daily minimum validated dose
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)
Indications of whether or not 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 sensors 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 Director.
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.
The 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 Directorwhen 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.