DDW-2024-006984

April 2, 2024
Amanda Buhler
Clark Bench Water Company
725 EastKaneplex Drive
Kanab, Utah 84741
Subject:Plan Approval, Clark Bench Water Company 2024 Improvements, 200K Tank (ST002), Booster Pumps Modifications (PF001), Clark Bench Chlorinator (TP001), and Water Line Improvements
(DS001);
Clark Bench Water Company; Water System #13060, File #13037, SRF #3F1853
Dear Amanda Buhler:The Division of Drinking Water (the Division) received the plans and specifications for the proposed Clark Bench Water Company 2024 Improvements from John Jacobsen
and Dustyn Shaffer, Sunrise Engineering, on December 19, 2023. Additional information regarding the proposed chlorinator and hydraulic modeling was requested on that same day. A hydraulic
modeling report was received by the Division on January 10, 2024. However, it was not complete as it did not include all the required modeling scenarios. A completed hydraulic modeling
report was received by the Division on January 23, 2024. A review of the entire project was completed, and review comments were sent to you and your consultant on February 22, 2024.
Revised plans and a response to the comments were received by the Division on March 1, 2024. This project has met the conditions for receiving a plan approval.
The Kane County Water Conservancy District is taking over the operation of this water system. This project is intended to bring the water system up to current standards with regard to
operational pressures and fire flows. Our understanding of the project is detailed below for each component of the project.
Distribution System Improvements
The new water lines for this project include adding new and replacement water lines to improve hydraulic capacity and service to the southeast part of the water system. This includes
installing 1,000 linear feet of 4-inch PVC C900 DR18; 2,200 linear feet of 8-inch PVC C900 DR18; and 700 linear feet of 10-inch PVC C900 DR18 pipe.
200K Tank (ST002)
A new 200,000-gallon reinforced concrete tank will be constructed and will replace the existing 20,000-gallon tank referred to as Clark Bench Tank (ST001). This will increase water system
storage, resolve deficiencies related to the existing storage tank, and will add fire suppression storage. This tank meets all of the required elements including an air vent, access
hatch, overflow, and drain.
Booster Pumps Modification (PF001)
This existing booster pump station will be constructed in a new building and is planned to have 2 3 HP pumps that can supply 20 gallons per minute (gpm) of water each at operating pressures.
In addition, the biggest modification is that a 100 HP pump will be installed that can supply 1,000 gpm of fire flow.
Clark Bench Well Improvements(WS001)
Some discharge piping, including a flow meter and sample tap, and valving will be modified to resolve deficiencies related to this well source.
Clark Bench Chlorinator (TP001)
For this chlorinator, this letter includes the following section and addenda:

1.Summary for the Clark Bench Chlorinator (TP001)    
2.FutureMonitoring and Reporting Requirements (Addendum 1)
The plan review of the proposed Clark Bench Chlorinator (TP001) has been completed according to the following:
The proposed Clark Bench Chlorinator (TP001) will be a Regal Model 216 gas chlorinator. 
This chlorinator will add chlorine to the water from the existing Clark Bench Well (WS001).
This chlorinator is intended to provide secondary disinfection in the distribution system. 
The chlorinated water will go into the new 200K tank (ST002). After that, it will go through the Booster Pumps (PF001) and into the distribution system.
Chlorine gas, which will be used for disinfection, meets the ANSI/NSF 60 standard.
The proposed design target dose of 0.3 mg/L or ppm (measured as free chlorine) is based on a typical flow of 80 gallons per minute (gpm) from the existing Clark Bench Well (WS001).
The chlorine dose will be adjusted by an automatic flow-paced control.
The Point of Entry (POE) sampling location will be in the new Booster Pumps (PF001) before the first customer.
Plan Approval for the New Paria Subdivision 2024 Water System Improvements
We have completed our review of the plans and specifications, stamped, and signed byDustyn W. Shaffer, P.E., dated February 29, 2024, and found 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 Clark Bench Water Company 2024 Water System Improvements and each
of the facilities described above are hereby approved.
This approval pertains to construction only. An Operating Permit must be obtained from the Director before each of these facilities may be put in service. A checklist outlining the items
required for operating permit issuance is enclosed for your information.Approvals or permits from the local authority or the county may be necessary before beginning construction of
this project. As the project proceeds, a notice of any changes in the approved design, as well as 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 us 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.
Secondary Disinfection Requirements for the Clark Bench Chlorinator
The water system proposes to electively install the Clark Bench Chlorinator (TP001) to provide a detectable disinfectant residual in the distribution system for secondary disinfection.
The plan review of the proposed Clark Bench Chlorinator (TP001) is based on providing secondary disinfection. When this chlorinator is installed and placed in operation after the Operating
Permit issuance, the Clark Bench Water Company will be required to demonstrate ongoing compliance with the secondary disinfection requirements that will be outlined in Addendum 1 to
this letter.
The Division shall be informed by telephone within 8 hours by a water supplier ofthe malfunction of any disinfection facility such that a detectable residual cannot be maintained at
all points in the distribution system per R309-105-18(1)(a).
Please be aware if any source in this water system is found to requireadditionaldisinfection in the future per R309-200-5(7)(a)(i), further regulations will apply. For example, if primary
disinfection is required 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.State
SRF FundingThe project, as described herein, is generally eligible for assistance under the Drinking Water Construction Assistance Program. All change orders must be reviewed and approved

for compliance with the Drinking Water Rules and the conditions of this construction approval. The project may now be advertised for bids. But, as a condition of the project funding,
you must not award the contract or proceed with construction until the Division of Drinking Water has authorized you to do so. This is necessary to comply with applicable requirements
and to protect you, as the funding recipient, by ensuring that the contract meets the requirements for funded projects.
If you have any questions regarding this approval, please contact J. Paul Wright, P.E., DEQ Southwest District Office, at [phone], or me at (385) 515‑1464.
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
JPW/mrn/mdbEnclosures –Operating Permit ChecklistAddendum 1- Future Monitoring and Reporting Requirementscc:Jeremy Roberts, Southwest Utah Health Department, [e-mail]
Shaffer, P.E., Sunrise Engineering, [e-mail] Jacobsen, Sunrise Engineering, [e-mail] Buhler, Clark Bench Water Company, [e-mail]
Fisher, Clark Bench Water Company, [e-mail]. Paul Wright, P.E., DEQ District Engineer, [e-mail] Spevak, Division of Drinking Water, [e-mail]
Treutel, Division of Drinking Water, [e-mail]
Sitara Federico, Division of Drinking Water, [e-mail] 13060 13037 ST002 Mods PF001 TP001 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).
Distribution lines (not including in-line booster pump stations) requiring Plan Approval may be placed into service prior to submitting all of the following items and receipt of Operating
Permit if the water system has received items 1 and 4 below.☐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, where appropriate [For example, include raw and finished water data that demonstrate satisfactory performance of the treatment facility; sample should be
taken from a storage tank for residual volatile organic compounds after tank interior re-coating; etc.]☐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 source
Addendum 1 
Future Elective Monitoring and Reporting Requirements
Chlorine Monitoring & Reporting Requirements
The water system will be required to meet elective disinfection requirements once this facility is installed and operating. As a part of these requirements, the water system will need
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. 
Elective Disinfection Requirements and Reporting 
Chlorine Residual ‒ Point of Entry (POE) to Distribution System
The POE sampling location will be identified in the Division’s database. The location will be identified during the plan approval process. 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 chlorine residual concentration, measured as free chlorine, at the chlorinator POE sampling location a minimum of three (3) times per week. [R309-210-
8(3)(a)(ii)]
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 elective disinfection requirements, the water system must complete monthly operational reports for each active chlorinator using a template approved
by the Division. 
Operational reports are submitted quarterly. The reports are due to the Division by the 10th day following the end of each reporting month or quarter (i.e., January 10th, April 10th,
July 10th and October 10th for quarterly reports). 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)]
Disinfection Byproducts Monitoring & Reporting Requirements
In addition to the chlorine monitoring and reporting described above, the system will be required to monitor disinfection byproducts as a result of introducing disinfection to the system.
According to our records, the water system serves a population of approximately 45 people and serves groundwater from the system’s source(s). Based on this information, the water system
will be required to collect samples from two (2) Disinfection Byproduct (DBP) sampling sites. Each disinfection byproduct sample should be a paired sample of Total Trihalomethanes (TTHM)
and Haloacetic Acids (HAA5).

Water system staff will need to select two (2) site(s) to be sampled for DBPs. A sampling plan form will be enclosed with the operating permit letter and will need to be completed and
submitted to the Division within 30 days from the date of the operating permit letter. The specifics relating to the number and frequency of required samples will be provided in the
operating permit letter.
Source Bacteriological Monitoring 
The operating permit will include requirements for monthly Escherichia Coli (E. Coli) sampling at Clark Bench Well (WS001), prior to any treatment, for the months the Clark Bench Well
(WS001)  is in operation or accessible for a minimum of two operating seasons. This monitoring is required to evaluate the quality of the water coming from Clark Bench Well (WS001) to
determine whether primary disinfection treatment is required or not. Additional monitoring and/or disinfection requirements may be assigned depending on the results of the assessment
monitoring.
The source sampling requirement shall begin no later than May 2024 and extend to cover the duration of at least 18 months, sufficient to span two (spring/summer or peak season) cycles.

The sampling location of the source water bacteriological samples needs to be labeled as WS001.
The source bacteriological sampling is in addition to the monthly total coliform sampling in the distribution system (DS001) that has been in place for your water system. 
The required source sampling data must be submitted to the Division for evaluation before a permanent operating permit can be issued for Clark Bench Chlorinator (TP001).
In the result of an E. coli positive sample, please contact Sitara Federico at [e-mail] or [phone] within 24 hours of notification.