DDW-2025-003044

April 2, 2025
Robert Craig Hawkes
Howell Town Water System
P.O. Box 1011
Howell, Utah 84316
Subject:Plan Approval, 2000 Well Gas Chlorinator (TP001);
Howell Town Water System, System #02017, File #19478
Dear Robert Hawkes:The Division of Drinking Water (the Division) received the plans and specifications for the 2000 Well Gas Chlorinator from your consultant, Jacob Nielsen, P.E. with
Hansen, Allen, and Luce on February 12, 2025. Written review comments were provided to your consultant on February 28. 2025. The Division received the revised plans and specifications
on March 19. 2025. This project has met the conditions for receiving a plan approval.
The letter includes the following sections and addenda:

1.Project Summary for the 2000 Well Gas Chlorinator (TP001)    
2. Plan Approval for the 2000 Well Gas Chlorinator (TP001)
3.Operating Permit Checklist 
4.FutureMonitoring and Reporting Requirements (Addendum 1)Project Summary
Our understanding of the project includes the addition of a new gas chlorination facility within a separate room in the 2000 Well (WS005) well house. The chlorinator will consist of
two (2) 150-pound chlorine gas cylinders installed on a scale. The chlorination equipment will consist of a Superior Water Solutions Model CL-2/5 chlorinator, and automatic switchover,
a manually controlled rotometer, and a 0.75 horsepower, 3.5 gallon per minute (gpm) booster pump. The 2000 Well Gas Chlorinator is identified as TP001in the Division’s database.
The plan review of the proposed 2000 Well Gas Chlorinatorhas been completed according to the following:
The proposed 2000 Well Gas Chlorinator is a gas chlorinator.
This chlorinator will add chlorine to the water from the 2000 Well (WS005).
This chlorinator is intended to provide voluntary secondary disinfection.
The disinfected water will flow directly into the distribution system.
The proposed chlorine gas to be used for disinfection meets the ANSI/NSF 60 standard.
The proposed design target dose of 1.0 mg/L or ppm (measured as free chlorine) is based on a typical flow of 230 gallons per minute (gpm) from the 2000 Well (WS005).
The chlorine dose will be adjusted by a manually adjusted rotometer set for the constant flow from the 2000 Well.
The Point of Entry (POE) sampling location will be the home located at 17210 W Blue Creek Dr, Howell, UT, which is the first service connection downstream of the chlorinator.
Plan Approval for 2000 Well Gas Chlorinator (TP001)
We have completed our review of the plans and specifications, stamped, and signed byJacob K. Nielsen, P.E., dated March 19, 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 for the 2000 Well Gas Chlorinator are hereby approved.
This approval pertains to construction only. An Operating Permit must be obtained from the Director before the 2000 Well Gas Chlorinator 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
The Howell Town Water Systemis not required to disinfect the 2000 Well (WS005) based on bacteriological source sample results currently available. The water system proposes to voluntarily
install the 2000 Well Gas Chlorinator (TP001) to provide a detectable disinfectant residual in the distribution system for secondary disinfection.
The plan review of the proposed 2000 Well Gas Chlorinator (TP001) is based on providing secondary disinfection. When this chlorinator is installed and placed in operation after the Operating
Permit issuance, the Howell Town Water System will be required to demonstrate ongoing compliance with the secondary disinfection and disinfection byproduct (DBP) monitoring requirements
that are 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 the 2000 Well Gas Chlorinator is found to require additional disinfection 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.
If you have any questions regarding this approval please contact Hunter Payne, of this office, at [phone], or me at [phone].
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
HP/mrn/mdbEnclosures –Operating Permit ChecklistAddendum 1- Future Monitoring and Reporting Requirementscc:Grant Koford, Bear River Health Department, [e-mail] Nielsen,
P.E., Hansen, Alle, & Luce, [e-mail] Hawkes, Howell Town Water System, [e-mail] Payne, P.E., Division of Drinking Water, [e-mail]
Luke Treutel, Division of Drinking Water, [e-mail]
Sitara Federico, Division of Drinking Water, [e-mail]
hpayne 02017 19478 PA TP001
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 as EP001 and is located at 17210 W Blue Creek Drive. 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 value of chlorine residual measured as free chlorine at the POE sampling location (EP001). [R309-215-10(1)]Our records show that your water system serves
260 people. Please be aware that R309-215-10(1) 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.
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.
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.
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 (DBP) as a result of introducing disinfection to
the system. According to our records, the water system serves a population of approximately 260 people and serves groundwater from the system’s source(s). Based on this information,
the water system will be required to collect samples from one (1) DBP sampling site per year. Each disinfection byproduct sample must be a paired sample of Total Trihalomethanes (TTHM)
and Haloacetic Acids (HAA5).
Water system staff will need to select one (1) site 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 2000 Well (WS005), prior to any treatment, for 12 months. This monitoring is required
to evaluate the quality of the water coming from 2000 Well (WS005) 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 June 2025 and extend to cover the duration of at least 12 months.
The sampling location of the source water bacteriological samples needs to be labeled as WS005. 
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 2000 Well Gas 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.