DDW-2024-014375

December 18, 2024
Melissa Hughes
Pinion Forest SSD
P.O. Box 38
Duchesne, Utah 84021
Subject: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
Dear Melissa Hughes:The Division of Drinking Water (the Division) received a request for a Permanent 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 14, 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. A temporary operating permit was issued on November 7, 2024.
This project has met all conditions for receiving an operating 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 Plant is identified as TP001
in 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 chlorinator treats 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.
Operating Permit
We have received the following additional information for the Water Hauling Station Treatment Plant (TP001) and Water Hauling Station 1 Tank (ST001) Modifications:
Record drawings.
We have determined that all conditions for operating permit issuance have been met. On this basis, an Operating Permit for Water Hauling Station Treatment Plant (TP001) and Water Hauling
Station 1 Tank (ST001) Modificationsis hereby issued as constituted by this letter.
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 SSD is 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 Reporting
Issuance 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 [phone] 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 System The issuance of this Operating Permit resolves your water system’s deficiency of 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 Dani Zebelean, P.E., of this office, at [phone], or Michael Newberry, P.E., Permitting and Engineering
Manager, at [phone].
Sincerely,
Russell Seeley, P.E.
Assistant Director
DZ/mrn/mdb
Enclosures:
Addendum 1 - Project Overview
Addendum 2 - Monitoring and Reporting Requirementscc:Joe Hadlock, Tri-County Health Department, [e-mail] Laurendeau, P.E., Jones and Demille Engineering, [e-mail]
Baker, Jones and Demille Engineering, [e-mail] Hughes, Pinion Forest SSD, [e-mail] Watkins, Pinion Forest SSD, [e-mail]
Hall, P.E., DEQ Tri-County District, [e-mail] Zebelean, P.E., Division of Drinking Water, [e-mail] Treutel, Division of Drinking Water, [e-mail]

Kruse, Division of Drinking Water, [e-mail] Spevak, Division of Drinking Water, [e-mail] Sitara Federico, Division of Drinking Water, [e-mail]
Jennifer Yee, Division of Drinking Water, [e-mail] Brandi Smith, Division of Drinking Water, [e-mail]
DZebelean 07073 13550 POP TP001
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 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 Water Hauling Station Treatment Plant consists of pre-oxidation, media absorption, and post-chlorination processes. The 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 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 as EP001 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. [R309-21516(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 Plant POE 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 [phone] or [e-mail] 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 [e-mail] for questions
regarding the source monitoring and reporting requirements for your water system or to request reduced monitoring.