DDW-2025-000163

January 8, 2025
Spencer Bateman
Bateman’s Mosida Farms
PO Box 119
Elberta, Utah 84626
Subject:Conditional Plan Approval, Arsenic Point-of-Use Compliance Plan (TPPOU);
Batemans Mosida Farms, System #25184, File #17663
Dear Spencer Bateman:On October 16, 2024, the Division of Drinking Water (the Division) received a revised submittal of information from your consultant, Scott Hendricks, P.E. and RB&G
Engineering on October 16, 2024,about the installation of Point-of-Use (POU) devices for the reduction of arsenic concentrations in the water supplied by the Batemans Mosida Farms water
system. The information submitted at that time included a revised schedule and specifications for the proposed individual reverse osmosis units. Additional information was requested
after reviewing your initial submittal and significant time passed while waiting for the requested information. Written review comments were provided to you (or your consultant) on October
9, 2024, and October 16, 2024. The Division received the revised plans and specifications on October 16, 2024. A meeting was held on November 15, 2024, to discuss the overall approach
for a compliance strategy. The original approved plan to install a new distribution system with a storage tank will be modified after the completion of arsenic treatment.
Our understanding of the project includes the following:
Groundwater sources with elevated levels of arsenic serve the water system. These sources are currently not approved. The levels exceed the maximum contaminant levels (MCLs).
The water system controls the service connections; therefore, access and maintenance agreements are unnecessary at each of the 14 locations.
The project includes potentially installing POU devices at each of the 14 locations. The device is the AquaSana AQ-SRFO Smartflow reverse osmosis filter. The POU device includes a carbon
block, Smartflow membrane, advanced carbon block, and remineralizer.
The POU devices will be installed at the kitchen sink for each of the 10 residences, all of which are owned and managed by Bateman's Mosida Farm, plus one at each of the drinking fountains
in the two milking barns, the office, and the Groviv building. Redundancy will not be provided due to space constraints, but additional filters will be available.
The POU device will be installed at one location and then verified with initial monitoring. The monitoring will include collecting a sample before and after the POU device. An additional
sample will be collected within 14 days of the initial sample to confirm the arsenic treatment. If satisfactory, then the remaining POU devices will be installed.
The Bateman’s Mosida Farms water system may install a Point of Connection (POC) device (i.e. AquaSana AQ-SRFO Smartflow reverse osmosis filter) as a whole-house filtration system where
appropriate.
Any wastes associated with the TPPOU, including reverse osmosis (RO) reject stream and spent filters, will be properly disposed of at an approved facility.
The treatment units are identified as TPPOU in the Division’s database.
We have completed our review of the plans and specifications of the proposed Arsenic POU devices (TPPOU), stamped and signed by Mathew Kimball Smith, P. E., and dated December 23, 2023,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 the construction of Arsenic
POU devices (TPPOU) are hereby approved subject to the following conditions:
If the Arsenic POU devices (TPPOU) do not meet the treatment requirements then centralized treatment or other appropriate treatment will need to be installed.
Verification that the County Fire Marshal has approved using the secondary irrigation system to satisfy fire flow and duration requirements.
A revised plan for achieving approved status shall be submitted 30 days after receiving an Operating Permit for arsenic treatment or if verification data show that treatment is ineffective.

The revised plan should include information on source, distribution, and storage considering existing wells, new wells, consecutive connections, water hauling, distribution piping, and
storage tanks.
The revised plan should include a verification and remediation plan, as appropriate, to ensure no cross-connection between the drinking water and secondary irrigation systems.
The original hydraulic model including system sizing should be reviewed and updated based on the revised plan.
Timeline for completing each major milestone proposed in the revised plan.
This plan approval pertains to construction only. An Operating Permit must be obtained from the Director before Arsenic POU devices (TPPOU) may be put into service. A checklist outlining
the items required for issuing an Operating Permit for this treatment plant is enclosed for your information.
Water Quality Data Requirements for Operating Permit Approval
Before an operating permit is issued, the Division requires the following water quality data to confirm the efficacy of each installed point-of-use (POU) device:
Initial Testing:
A total arsenic sample must be collected from each installed POU device.
A total arsenic sample must be collected from each active source feeding the distribution system.
Follow-Up Testing (Conducted within 14 days of initial testing):
A total arsenic sample must be collected from each active source feeding the distribution system.
An additional total arsenic sample must be collected from each installed POU device.
A bacteriological (BacT) sample must be collected from each installed POU device.
The results of these analyses should be sent directly to [e-mail] and [e-mail]. If the results are in compliance with applicable maximum contaminant levels (MCLs) and
an operating permit is issued, the routine monitoring requirements outlined in Addendum 1 will apply. Please contact David Kruse at [e-mail] or 385-566-7789 with any questions
about this system's source and treatment monitoring requirements. Approvals or permits by 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 and 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 the Division 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.
If you have any questions regarding this approval, please contact Chris Martin, P.E., of this office, at [phone], or Michael Newberry, P.E., Permitting Section Manager, at (385)
515-1464.
Sincerely,
Nathan Lunstad, Ph.D., P.E.
Division Director

CM/mrn/mdbEnclosuresOperating Permit ChecklistAddendum 1 – Routine Monitoring Requirements Upon issuance of an Operating PermitArsenic Reporting TemplateArsenic Reporting Template Guidance
Documentcc:Daymon Swensen, Utah County Health Department, [e-mail] Hendricks, P.E., RB&G Engineering, Inc., [e-mail] Bateman, Batemans
Mosida Farms, [e-mail]
Chris Martin, P.E., Division of Drinking Water, [e-mail]
Luke Treutel, Division of Drinking Water, [e-mail] (disinfection & DBP)
David Kruse, Division of Drinking Water, [e-mail] (arsenic, inorganics, organics, NO3, rads)
Colt Smith, Division of Drinking Water, [e-mail] (enforcement)
Brandi Smith, Division of Drinking Water, [e-mail] (CCR, UCMR, enforcement)
CMartin 25184 17663 TPPOU PA
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).☐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 (e.g., every 1,200 feet, end-of-line, each branch)☐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 — Complete initial and follow up testing as described above☐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 sourceADDENDUM
1Routine Monitoring Requirements Upon issuance of an Operating Permit
Bateman’s Mosida Farms Water System (UTAH#25184)
Arsenic POU Devices (TPPOU)
Following the issuance of an operating permit, the following routine monitoring requirements will apply. There will be a two-phased monitoring approach established to ensure effective
treatment at each point-of-use (POU) device while informing routine maintenance schedule timelines.
To fulfill the ongoing routine monitoring requirements given below, the system will need to purchase an approved field test kit for on-site arsenic analysis. Please contact David Kruse
at 385-566-7789 or [e-mail] for a list of approved field test kits. Should the system decide to not use a field test kit for ongoing monitoring, a modified version of the ongoing
routine monitoring schedule with more frequent samples submitted to a certified laboratory will apply.
Initial Monitoring Period (First Six Months)
During the first six months of operation, the following requirements will apply.
Monthly Arsenic Testing: Collect and analyze total arsenic samples from each of the 14 installed POU devices every month. These samples must be tested by a certified laboratory.
Monthly Bacteriological Testing: Collect and analyze bacteriological (BacT) samples from each of the 14 installed POU devices every month. These samples must also be tested by a certified
laboratory.
Ongoing Monitoring Requirements (After the Initial Period)
If during the first six months of operation, the sample results show effective arsenic removal and satisfactory bacteriological results, the system will be moved to a reduced monitoring
schedule in which arsenic and coliform presence will be evaluated at varying frequencies through a combination of in-field sampling conducted by the system and samples submitted to a
certified laboratory.
Arsenic Sampling:
Each calendar quarter, four (4) arsenic samples will be collected from various POU devices spread evenly across the system. Quarterly sampling can be performed using an approved field
test kit.
This requirement ensures that each POU device is tested for arsenic annually.
Each calendar year, at least two (2) arsenic samples will be collected from a rotating selection of POU devices. Yearly sampling must be performed using a certified laboratory.
This requirement ensures that the arsenic levels present at each POU device are professionally evaluated at least once every nine years.
Bacteriological Sampling
Installation of the described POU devices changes the water systems routine BacT monitoring requirements.
A condition of the operating permit will be that two (2) BacT samples are required to be collected, and analyzed by a certified laboratory, downstream of a rotating selection of POU
devices each calendar month.
To fulfill this requirement, an updated BacT sample site plan must be submitted to the Division.
This requirement ensures that coliform presence is evaluated at each POU device annually.
Reporting Requirement
It is the system’s responsibility to report all arsenic results obtained through in-field testing to the Division. This will be accomplished using the enclosed POU reporting template,
where the system will provide sample dates, sample locations, sample results, and any information about maintenance conducted during a calendar quarter.
The quarterly report is due 10 days after the end of each calendar quarter (i.e., January 10th, April 10th, July 10th, and October 10th). The report should be sent directly to David
Kruse at [e-mail]@utah.gov.