DDW-2025-002972

April 1, 2025
Scott Bradbury
Sunrock High Adventure Base
723 East 110 North
Heber City, Utah 84032
Subject:Plan Approval, Scout Lake Filter Plant (TP002) Membrane Change;
Sunrock High Adventure Base, System #22025, File #20336
Dear Scott Bradbury:This letter provides a summary of the Division of Drinking Water’s decision to issue Plan Approval for the Scout Lake Filter Plant (TP002) Membrane Change. The letter
includes the following sections and addenda:Plan Approval for Scout Lake Filter Plant (TP002) Membrane Change from Polymem UF120 to DuPont IntegraTec MB60 Module.Project Overview (Addendum
1), which provides detailed description of the proposed treatment plant design.Proposed Strategy for Achieving Surface Water Treatment Goals (Addendum 2), which describes the proposed
strategy for achieving the required treatment goals.Preliminary Summary of Surface Water Treatment Monitoring and Reporting Regulations (Addendum 3), which may be useful for this plant’s
PLC and SCADA programming.
We have completed our review of the new DuPont IntegraTec MB60 module specifications for the Scout Lake Filter Plant (TP002) received from you on March 21, 2025,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 switching to the DuPont IntegraTect MB60 Modules
for the Scout Lake Filter Plant (TP002)are hereby approved.
This plan approval pertains to construction only. An Operating Permit must be obtained from the Director before the Scout Lake Filter Plant (TP002) 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.Approvals or permits by local authority or 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.
If you have any questions regarding this approval, please contact Dani Zebelean, P.E., of this office, at [phone], or me at [phone].
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
DZ/mrn/mdbEnclosuresOperating Permit ChecklistAddendum 1. Project OverviewAddendum 2. Proposed Strategy for Achieving Surface Water Treatment GoalsAddendum 3. Preliminary Summary of
Surface Water Treatment Monitoring & Reporting Regulationscc:Joe Hadlock, Tri-County Health Department, [e-mail] Stevens, Sunrock High Adventure Base, [e-mail]
Bradbury, Sunrock High Adventure Base, [e-mail]
Dani Zebelean, P.E., Division of Drinking Water, [e-mail]
Nathan Lunstad, Ph.D., P.E., Division of Drinking Water, [e-mail]
Mark Berger, Division of Drinking Water, [e-mail]
Sarah Page, Ph.D., Division of Drinking Water, [e-mail]
Nathan Hall, P.E., TriCounty District Engineer, [e-mail] 22025 20336 PA TP002 Membrane Change
Utah Division of Drinking Water ― Checklist for Issuing Operating PermitsWater System Name: Sunrock High Adventure Base______System Number: 22025___________Project Description: Membrane
Change File Number: 22036______________
Items 1 through 11 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, nonpositive (e.g., every 1,200 feet, end-of-line, each branch)☐ANSI/AWWA
C652-11 AWWA Standard for Disinfection of Water-Storage Facilities (e.g., clearwell, storage tank).One or more samples, nonpositive☐ANSI/AWWA C653-13 AWWA Standard for Disinfection of
Water Treatment PlantsTwo consecutive samples per unit (filter), nonpositive, no less than 30 minutes apart☐ANSI/AWWA C654-13 AWWA Standard for Disinfection of WellsTwo consecutive samples,
nonpositive, no less than 30 minutes apart☐5.Water quality data — Required finished water and/or raw water data to demonstrate WTP performance before an OP can be issued
Paired raw and finished water new source chemistry data included in R309-515-4(5)
Operational data per item #7 below
☐6. If applicable, all other documentation that may have been required during the plan review process.☐7. SWTR monthly report with at least 5 days of operational data demonstrating SWT
has been achieved. The WTP does not have to operate at full capacity or continuously (but at least 4 hours per day) for the purpose of this demonstration.☐8. Confirmation of turbidimeter
calibration.☐9. For membrane treatment:a statement of knowledge that the facility startup of Subsection R309-530-8(9) have been completed.normalized operating flux range.normalized operating
flux per membrane unit.maximum operating differential pressure for a membrane unit.membrane unit backwashing frequency.minimum, verified, operation, direct integrity testing resolution.maximum,
verified, operational, direct integrity testing sensitivity.verified, operational, direct integrity control limit.verified, indirect integrity monitoring performance-based upper control
limit.☐10.If applicable, confirmation that the water system owner has received the O&M manual for the new facility.☐11.If applicable, the location data of the new storage tank, treatment
facility, or sourceADDENDUM 1Project Overview
Sunrock High Adventure Base Water System (UTAH#22025)
Scout Lake Filter Plant Surface Water Treatment Plant (TP002)
Project History
The Division of Drinking Water (the Division) received the specifications for the Scout Lake Filter Plant (TP002) received from Scott Bradbury on March 21, 2025. The Scout Lake Filter
Plantis identified as TP002 in the Division’s database.
Project Summary

Sunrock High Adventure Base (the System) used to be the Boy Scout camp of Camp Steiner. The Scout Lake Filter Plant (TP002) received an after the fact Plan Approval and Operating Permit
on April 16, 2015. The Division’s understanding is that Camp Steiner closed in 2019 and stored the water treatment plant in Midway. In 2024 the Sunrock Foundation renewed the special
use permit with the United States Forest Service and purchased the treatment plant equipment from the Boy Scouts of America. However, the membranes in the treatment plant were not adequately
stored and after five years were no longer serviceable to treat surface water. The decision was made to order new membranes for the facility in 2025. The Scout Lake Filter Plant (TP002)
surface water treatment plant consists of membrane and post-chlorination processes. The Scout Lake Filter Plant (TP002) has a plant design capacity of 70 gallons per minute (gpm). The
design includes 1train(s) of membrane filtration, with the design capacity for each train of 70 gpm. Since Sunrock High Adventure Base is a transient non-community system, according
to R309-530-8(8)(b)(ii) the treatment plant does not need to have a redundant train.The treatment plant consists of the following processes in sequence:Raw water is pumped from the Scout
Lake at the Scout Lake Intake (WS002).Raw water is filtered first by a 100-micron bag filter and into the raw water tank on the AltaPac APII skid. First-stage compliance filter – DuPont
Brand, Model IntegraTec MB60; 1 trains; 70 gpm per train.Post-chlorination – liquid hypochlorite; 70 gpm per train.Storage Tank for disinfection detention time – a 16,000-gallon concrete
tank for disinfection CT before releasing the finished water to the distribution system.ADDENDUM 2Proposed Strategy for Achieving Surface Water Treatment Goals
Sunrock High Adventure Base Water System (UTAH#03020)
Scout Lake Filter Plant Water Treatment Plant (TP002)Treatment Goals per Surface Water Treatment Rules
The Scout Lake Filter Plant (TP002) treatment plant consists of membrane filtration and post-chlorination processes. This plant shall be designed to meet the requirements of the surface
water treatment rules, as incorporated into Utah’s Rules in R309. These surface water treatment rules require removal and/or inactivation, expressed in terms of log10 credit, of Cryptosporidium,
Giardia lamblia, and viruses through treatment techniques. The Surface Water Treatment Rule (SWTR) requires:3-log removal/inactivation for Giardia lamblia, and4-log removal/inactivation
for virus.
The Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR) established four bin classifications for Cryptosporidium based on concentration in the source water. If a water system
has source water classified in Bin 1, LT2ESWTER requires 2-log removal forCryptosporidium. If a water system has source water in Bin 2, Bin 3, or Bin 4, LT2ESWTR requires additional
treatment, disinfection, or inactivation for Cryptosporidium, as outlined in EPA’s “Long Term 2 Enhance Surface Water Treatment Rule Toolbox Guidance Manual.”
The water source supplying this treatment plant is the Scout Lake Intake (identified as WS002). Per the Division’s letter issued on September 11, 2019, the raw water source for this
plant has been determined to be in Bin 1 based on the first round of sampling as stated in the Division letter dated September 11, 2019. The Scout Lake Filter Plant water treatment plant
is designed to meet the Bin 1 requirements, i.e., 2-log10 removal for Cryptosporidium.
In the event additional log removal credit is needed for a higher Bin classification, additional treatment will need to be installed. New Plan Approval would be required for any additional
treatment.Proposed Strategy to Comply with Surface Water Treatment RequirementsPrimary Filtration
The proposed DuPont IntegraTech MB60 membrane module will serve as the primary filtration process. According to the NSF/ANSI 419 product listing, the DuPont IntegraTech MB60 membrane
moduleis credited for providing a minimum of 6.41-log removal for Cryptosporidium with the maximum certified filtrate flux of 106 gallons per square foot per day (gfd). The Division
concurs with this determination. The transmembrane pressure and the membrane flux rate shall not exceed the manufacturer’s recommended maximums of 22 psi and 106 gfd, respectively. The
Division anticipates approving the DuPont IntegraTech MB60 membrane module as an alternative filtration technology for primary filtration under the surface water treatment rules. Upon
receiving water quality results that demonstrate the effective performance of the proposed treatment plant, the Division will grant (for membranes use required credit from SWTR and Bin
classification)3.0-log credit for Giardia lamblia removal, and 2.0-log credit for Cryptosporidium removal for the first stage compliance filter.
Please note that the turbidity performance standards for the proposed treatment plant will be less than 0.1 NTU 95% of the time, and shall not exceed 0.5 NTU (R309-200-5(5)(a)(ii) and
R309-215-9(1)).
Disinfection
Disinfection process will be installed following the membranefilters to provide additional treatment to meet the Bin 1 surface water treatment goals:
Post chlorination at a free chlorine residual of 0.5 ppm will be provided. The Scout Lake Filter Plant will provide disinfection through liquid sodium hypochlorite. A disinfection CT
(CT = Concentration × Contact Time) of 12 is needed for 4.0-log10 inactivation of virus. The estimated disinfection CT is 12.5, which will meet the 4.0-log Giardia/virus inactivation
requirement.
The CT calculations are based on the CT from the backwash tank and 16,000-gallon Storage Facility ST001 (ST001). The chlorination CT calculations are determined using a minimum free
chlorine residual of 0.5 ppm, minimum temperature of 0.5 degree C, maximum pH range of 6-9, a peak flow of 70 gpm, 560 gallons of effective storage volume (operationally) out of the
backwash tank with a baffle factor of 0.3, and 16,000 gallons of effective storage volume (operationally) of the 16,000-gallon Storage Facility ST001 (ST001) with a tank baffling factor
of 0.1.
The Point of Entry (POE) sampling location for the Scout Lake Filter Plant (TP002) will be a smooth nose sample tap after the Storage Facility ST001 (ST001).
Overall, the proposed design of the Scout Lake Filter Plant (TP002) is anticipated to meet the required treatment for Cryptosporidium for surface water classified as in Bin1 under R309-215-15
of Utah’s Rules. The processes of membrane filtration and post-chlorination together will achieve the treatment goals of:
3.0-log removal required for Giardia lamblia,
2.0-log removal required for Cryptosporidium (Bin 1 requirement), and,
4.0-log inactivation for virus.
ADDENDUM 3
Preliminary Summary of Surface Water Treatment Monitoring and Reporting Regulations
Sunrock High Adventure Base Water System (UTAH#22025)
Scout Lake Filter Plant Water Treatment Plant (TP002)
This addendum summarizes the monitoring and reporting regulations related to the Scout Lake Filter PlantSurface Water Treatment Plant (TP002). It is provided to you for informational
purposes only and may be helpful in PLC and SCADA programming after the plant is constructed.
The actual monitoring and reporting requirements for this treatment plant will be provided to the water system by staff of the Division of Drinking Water with the issuance of the Operating
Permit.
Monthly Report — General
The Sunrock High Adventure Basewater system (the System) is required to complete a monthly report for the Scout Lake Filter Plant surface water treatment plant using a template developed
by the Division of Drinking Water (the Division). As a minimum, the monthly surface water treatment plant report must include the following data and other applicable information.
Raw water pH, Temperature, turbidity, and flow rate. [R309-530-8(8)(p) and (q)]
Combined filter effluent (CFE) turbidity [R309-215-9(1)(a)]

Minimum chlorine residual of the treated water at the point of entry (POE)
Verification and calibration dates of turbidimeter(s)
Sufficient residual concentration, volume, flow, pH, and temperature readings in order to prove disinfection CT and/or Inactivation ratio demonstrating whether the log removal/inactivation
requirements are met
Summary of the daily direct integrity test, continuous indirect integrity test, and triggered direct integrity test results [R309-215-15(18)(b)]
The System will be required to submit the surface water treatment plant report for the entire month to the Division by the 10th of the following month. This report must be submitted
by e-mail as an Excel file [e-mail]. Please contact Sarah Page [phone] or [e-mail] to schedule training regarding proper reporting.
All operational records pertaining to the monthly surface water treatment plant reports shall be maintained for a minimum of 5 years [R309-105-17].
Treatment Adequacy [R309-200-5(7), R309-215-15(19) and (20)]
Water systems using surface water or groundwater under the direct influence of surface water must provide treatment consisting of both disinfection and filtration. [R309-200-5(5)(a)].
The surface water treatment plant monthly report must include both disinfectionand filtration processes. The monthly report shall contain sufficient information to indicate whether the
minimum surface water treatment requirements (i.e., log removal/inactivation of Giardia, virus, and Cryptosporidium) are met.
Required Treatments Credit — The treatment credits required and granted for the processes in the Scout Lake Filter Plant (TP002)are summarized below.
Sunrock High Adventure Base Water System (UTAH#22025)
Scout Lake Filter Plant Surface Water Treatment Plant (TP002)
Primary Treatment Technique: Membrane Filtration
Treatment Goals
(Minimum Treatment Requirements)
Giardia
Virus
Cryptosporidium
3.0 -log removal/ inactivation
4.0-log removal/ inactivation
2.0-log removal/ inactivation
(Bin 1)
Alternative Filtration1 (membrane filtration, DuPont IntegraTech MB60)
3.0-log removal
2.0-log removal
Chlorine2`
4.0-log inactivation
Total Treatment Credit
3.0-log removal / inactivation
4.0-log removal / inactivation
2.0-log removal / inactivation
Granted based on the NSF/ANSI 419 product listing.
Based on the CT calculation by Division Staff, Dani Zebelean, P.E., on March 25, 2025 during the plan review process
Disinfection
The System is required to continuously disinfect the treated water from this WTP.
The disinfection treatment shall be sufficient to ensure the total treatment processes of this WTP achieve at least 3.0-log inactivation/removal of Giardia lamblia, 4.0-log inactivation/removal
of virus, and a minimum of 2.0-log Cryptosporidium removal (for treating Bin1 source water). [R309-200-5(7)(a)(i); R309-215-15(12)].
The calculated disinfection CT for all processes shall be reported monthly to indicate the level of disinfection effectiveness. [R309-215-15(19)]
Disinfection at Point of Entry (POE)[R309-200-5(7), R309-215-15(19)]
The System is required to continuously disinfect the treated water from this WTP. [R309-200-5(7)]
The chlorine residual must not be below 0.2 milligram per liter (mg/L) free chlorine residual at the POE, where the treated water enters the distribution system, for more than four hours.
[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 [R309-215-10(1) Table 215-2].
Systems serving a population less than 500 shall either continuously monitor chlorine residuals at the POE or collect 1 grab sample per day.
The chlorine analyzer should be verified for accuracy or calibratedat least quarterly per 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 0.5NTU.
Turbidity Monitoring and Reporting — GeneralThe 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 no greater than every 15 minutes. [R309-215-9(1)(b)]The highest CFE turbidity reading at the end of eachfour-hour
(or shorter) intervalof operation must be included in the monthly surface water treatment plant report submitted to the Division, excluding data described in #5a. 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 (see #5e). 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 #5a.The date and value of any turbidity measurement taken during the month, which exceed 0.5NTU for a System using conventional
or direct filtrationIf there is a failure in continuous monitoring equipment, the System shall conduct grab sampling for turbidity every four hours. [R309-215-9(1)(b)]
The grab sampling, in lieu of continuous monitoring, cannot be more than five working days for water systems serving a population of 10,000 or more, following the failure of equipment.
The grab sampling, in lieu of continuous monitoring, cannot be more than fourteen days for water systems serving a population of less than 10,000, following the failure of equipment.
If the set turbidity limit for the approved treatment technology is exceeded, the System must comply with the re-sampling and notification requirements. [R309-215-9(2)]
Re-sample as soon as practicable and preferably within one hour.
If re-sampling confirms the exceedance of the turbidity limit —
The System shall collect at least one bacteriological sample near the first service connection from the WTP within 24 hours of the turbidity exceedance. This sample result shall be included
in determining bacteriological compliance for that month.
The System shall report this turbidity re-sampling exceedance to the Director as soon as practical, but no later than 24 hours after the turbidity exceedance is known. This reporting
is in addition to reporting the incident on any monthly WTP reports.
The System shall inform the Division as soon as possible, but no later than the end of the next business day if at any time the combined filter effluent (CFE) turbidity in representative
samples of filtered water exceeds the maximum level set by the Director, i.e., 0.5 NTU for the Scout Lake Filter Plant (TP002). [R309-215-9(6)(b)]
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 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 to primary standardsat least quarterly
It is not allowed to calibrate online 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 in 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 System based on the manufacturer’s recommendation or other testing.
The 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.
A direct integrity test must be conducted on each membrane unit no less than once each calendar day of operation.
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 greater 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)]
Source Water Bin Classification
The source water (Scout Lake Intake, WS002) of the Scout Lake Filter Plant (TP002) has been classified as Bin 1 with respect to R309-215-15 after an initial round of monitoring completed
September 11, 2019.
Per R309-215-15, a second round of monitoring must begin no later than 6 years after the initial bin classification. Thus, a second round of monitoring must begin no later than June
1, 2025. Please contact Sarah Page at [phone] or [e-mail] with questions about this monitoring requirement.