DDW-2025-004928

July 1, 2024

John Chartier
DEQ District Engineer – Central District
Division of Drinking Water
Utah Department of Environmental Quality
State Office Building
195 North 1950 West
Salt Lake City, Utah 84116

RE: IPP Renewed Potable Water Permit - Certification of Rule Conformance

Dear Mr. Chartier:
On behalf of Intermountain Power Service Corporation (System #14050), Kiewit Engineering
Group Inc. is providing a Certification of Rule Conformance for the IPP Renewed project Potable
Water System which is nearing construction completion in Delta, Utah.
This letter certifies the Potable Water System has been engineered, constructed, and tested in
accordance with the Plan Approval provided in Utah Division of Drinking Water letter DDW-2023-
008445 and DDW-2023-039814. This includes allowance to Exception to R309-550-7(1) and Rule
R309-545-14.

Sincerely,
Kiewit Engineering Group, Inc.

Paul Novogoratz, P.E.
Lead Mechanical Engineer

Enclosed: DDW-2023-008445
DDW-2023-039814

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-4830
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF DRINKING WATER
Tim Davis
Director

May 23, 2023

Jon Finlinson
Intermountain Power Service Corporation
850 West Brush Wellman Road
Delta, Utah 84624

Subject: Plan Approval, Renewed Units 3&4 Arsenic Treatment (TP005), Renewed Units 3&4
Storage Tank (ST005), and Renewed Units 3&4 Booster Pump (PF005); Exception to
Rule R309-545-14 Access Openings; Intermountain Power Service Corp, System
#14050, File #13356

Dear Jon Finlinson:

The Division of Drinking Water (the Division) received the plans and specifications for the
proposed Renewed Units 3&4 Arsenic Removal (TP005), Renewed Units 3&4 Storage Tank
(ST005), and the Renewed Units 3&4 Booster Pump (PF005) project from your consultant,
Patrick Jacobs with Kiewit on April 20, 2023.Written review comments were provided to your
consultant on May 9, 2023. The Division received the response to review comments and the
exception request to R309-545-14 on May 11, 2023.

Our understanding of the project is that Intermountain Power Service Corp is constructing two
new combined-cycle power trains to add natural gas and hydrogen as fuel sources. A 110-gallon
per minute (gpm) water treatment system is included in the project to remove arsenic from the
four existing wells that Intermountain Power Service Corp has. A liquid sodium hypochlorite
solution will be used to oxidize the water and provide residual disinfection. Aluminum
chlorohydrate will be used as a coagulant added after oxidation with chlorine. The water will
then pass through a Dupont ultrafilter with both NSF/ANSI 61 and 419 certifications. Detailed
project description and the Division’s decision to issue Plan Approval for the Renewed Units
3&4 Arsenic treatment plant are summarized in the Project Overview Addendum.

Jon Finlinson
Page 2 of 3
May 23, 2023

Exception Request

The basis for your request for an exception to R309-545-14, Access Openings, is a small,
prefabricated storage tank will be used for the that for the drinking water system at the Renewed
Units 3 & 4. This tank will only hold 14,440 gallons of water. The tank comes with a vent at the
top and an access opening at the base of the tank, above the outlet to the distribution system, that
can be used to clean out the tank when it is drained. The tank will be NSF/ANSI 61 certified.
However, to retrofit the tank, with a hatch that meets the rules, would be difficult given the small
size of the tank. The retrofit could also compromise the integrity of the storage tank. You
propose that the existing access at the base of the tank meets the intent of R309-545-14.

On this basis, an exception to R309-545-14, Access Openings, is hereby granted for the
Renewed Units 3&4 Storage Tank (ST005). This exception may be rescinded any time if
new evidence indicates that the conditions of this exception are no longer being met or a
public health risk exists due to this exception.

We have completed our review of the plans and specifications of the proposed Renewed Units
3&4 Arsenic Treatment Plant (TP005), stamped, and signed by Paul Novogoratz, P. E., and
dated April 19, 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
construction of the Renewed Units 3&4 Arsenic Treatment Plant (TP005), Renewed Units
3&4 Storage Tank (ST005), Renewed Units 3&4 Booster Pump (PF005), and associated
water lines are hereby approved.

This plan approval pertains to construction only. An Operating Permit must be obtained from
the Director before Renewed Units 3&4 Arsenic Treatment Plant 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, 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.

Jon Finlinson
Page 3 of 3
May 23, 2023

If you have any questions regarding this temporary exception, please contact Dani Zebelean, of
this office, at [phone], or Michael Newberry, Engineering Manager, at [phone].

Sincerely,

Nathan Lunstad, P.E.
Assistant Director

DZ/mrn/mdb

Enclosures
1. Operating Permit Checklist
2. Addendum – Project Overview

cc: Eric Larsen, Central Utah Health Department, [e-mail]
Patrick Jacobs, Kiewit, [e-mail]
Paul Novogoratz, Kiewit, [e-mail]
Logan Green, Kiewit, [e-mail]
Jon Finlinson, Intermountain Power Service Corp, [e-mail]
Dani Zebelean, Division of Drinking Water, [e-mail]
Tim Davis, Division of Drinking Water, [e-mail]
John Chartier, DEQ Central District Engineer, [e-mail]
Nagendra Dev, Division of Drinking Water, [e-mail]
Luke Treutel, Division of Drinking Water, [e-mail]
David Kruse, Division of Drinking Water, [e-mail]

DDW-2023-008445 

Utah Division of Drinking Water ― Checklist for Issuing Operating Permits
Water System Name: Intermountain Power Service Corp System Number: 14050
Project Description: Renewed Unite 3&4 Arsenic File Number: 13356
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 Mains
Two 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 Facilities
One or more samples, none positive
☐ ANSI/AWWA C653-13 AWWA Standard for Disinfection of Water Treatment
Plants
Two consecutive samples per unit, none positive, no less than 30 minutes apart
☐ ANSI/AWWA C654-13 AWWA Standard for Disinfection of Wells
Two consecutive samples, none positive, no less than 30 minutes apart
☐ 5. Water quality data — Four sets of raw and treated water samples will be analyzed for
arsenic, pH. Additionally, the chlorine residual of the treated water will be measured.
Each of the sets will be collected on separate calendar days.
☐ 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. Project Overview Page 2

ADDENDUM

Project Overview
Intermountain Power Service Corp Water System (UTAH#14050)
Renewed Units 3&4 Arsenic Treatment Plant (TP005)

Our understanding of the project is that the Intermountain Power Service Corp (the System) is adding
an additional two units to their power production. As a result, the System is installing a new water
treatment system for drinking water. This system will treat blended water from Intermountain Power
Service Corp’s four wells. The wells produce clean water except for elevated arsenic levels. Samples
came back at 0.0165 mg/L of arsenic which is just above the Environmental Protection Agency’s
Maximum Contaminant Limit of 0.01 mg/L.

The proposed Renewed Units 3&4 Arsenic Treatment Plant consists of pre-oxidation, a strainer
for a pre-filter, and ultra membrane filtration processes. The proposed Renewed Units 3&4
Arsenic Treatment Plant (TP005) has a plant design capacity of 110 gallons per minute (gpm).
The design includes only one (1) train.

The proposed treatment plant consists of the following processes in sequence:

 Pre-oxidation – by 12.5% sodium hypochlorite addition; dosing at 4.5 mg/L or ppm. With
a goal residual of 0.5 to 1 mg/L or ppm chlorine residual after the ultrafiltration
membrane. The chlorine residual will be monitored by an online analyzer post-
ultrafiltration.
 Coagulation – by 50% aluminum chlorohydrate. This is to help improve the removal of
oxidized arsenic.
 Ultrafiltration Membrane – Dupont Brand, Model IPD-51XP Modules, and Model IP51-14
Module Rack. The ultrafiltration membrane is both NSF/ANSI 61 and 419 certified. Eight
(8) total modules are included. There is one (1) train capable of treating 122 gpm per train.
o The ultrafiltration membrane can be backwashed and have clean in places (CIP)
performed. All chemicals used will be NSF/ANSI 60 certified. The CIP solution is
reused. The drain and overflow of the CIP containment go to the Backwash Sump.
This water is sent to the inlet of a separate industrial process water system.
 Finished Water Storage – a 14,440-gallon prefabricated tank, that is NSF 61 certified. The
pumps to pressurize the distribution system pull from this tank. The distribution system
cycles through and ends back up in the storage tank.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-4830
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF DRINKING WATER
Tim Davis
Director

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
October 24, 2023

Jon Finlinson
Intermountain Power Service Corporation
850 West Brush Wellman Road
Delta, Utah 84624

Subject: Exception to R309-550-7(1) Separation between Water and Sewer Piping as part of
Renewed Units 3&4 Arsenic Treatment (TP005), Renewed Units 3&4 Storage Tank
(ST005), and Renewed Units 3&4 Booster Pump (PF005); Intermountain Power Service
Corp, System #14050, File #13356

This letter is not Plan Approval for construction.

Dear Jon Finlinson:

On October 19, 2023, the Division of Drinking Water (the Division) received your request for an
exception to Rule R309-550-7(1), Separation of Water Mains and Transmission Lines from
Sewers and Other Pollution Sources for the Intermountain Power Service Corporation Renewed
Units Project. This rule states specifically that the horizontal distance between pressure water
mains and sanitary sewer lines shall be at least ten feet and that where a main and a sewer line
must cross, the water main shall be at least 18 inches above the sewer line.

Background Information

The submitted exception request included the following description of the situation where a 3-inch
diameter sewer force main will need to cross over the top of an existing 6-inch diameter culinary
water line.

It has come to our attention that a sanitary line size change is required for the IPP
Renewed facility. The originally sized sanitary lines (6”) have already been already
installed underground and backfilled. As Kiewit has evaluated the revised line sizing (3”)
and routing, the desired path forward is to abandon in place these already installed lines
(but not before disconnecting them from their respective source/destination at either end to
preclude sanitary waste from entering the pipe) and install new sanitary lines. With this
design, there will be a portion where the sanitary line is routed above the potable water
Jon Finlinson
Page 2 of 3
October 24, 2023

pipe in a crossing instance. Kiewit has reviewed Utah Administrative Rule R309-550-7
which offers guidance on the protection of potable water lines routed beneath sanitary
lines, but in this design instance, the sanitary pipe would cross above the potable water
pipe.

Kiewit would like to review for acceptance the following proposed design for the instances
in which the new underground sanitary line is routed above the previously installed
potable line.

Proposal: In the instances where a sanitary line is routed above the previously installed
potable water line, Kiewit would install a 6” PVC sleeve over the 3” sanitary pipe (HDPE
SDR 11) which shall extend no less than 10 feet beyond either side of the point of crossing.
Our preference would be to use a PVC sleeve for the installation for these lines, with a
secondary option being a 6” HDPE SDR 21 sleeve. The sanitary line will be a pressurized
pipe as it is being pumped from a lift station and the potable water pipe is a pressurized
line from the facility booster pump.

Exception Request

The basis for your request for an exception to R309-550-7(1) includes the following facts and
conditions:
o Due to existing site conditions and other utility conflicts, the 3-inch diameter sewer force
main cannot be routed beneath the existing potable water lines.
o The sewer force main and the potable water lines are all new and part of the current
Renewed Facility Project. The pipeline material for both the sewer and water is SDR 11
High-Density Polyethylene (HDPE) pipe, which is rated for 200 psi and has a substantial
wall thickness. The new HDPE pipelines do not have any fittings near the crossings and
the 3-inch diameter sewer force main will be encased in a 6-inch diameter PVC casing for
a minimum of 10 feet on either side of the crossing. The vertical distance between the
sewer force main and potable water lines is 4 feet.
o The IPSC site is a controlled environment and there may not be any need for future
digging in the area of these crossings, eliminating the potential for accidental ruptures of
either pipeline.
o IPSC will keep detailed as-built drawings of the crossings to aid them with any future
work that will take place in the area of the crossings.

On this basis, an exception to R309-550-7(1), Separation of Water Mains and Transmission
Lines from Sewers and Other Pollution Sources, is hereby granted for the locations
identified in the exception request. IPSC will maintain detailed as-built drawings of the
areas where the exception has been granted.

This exception may be rescinded any time if new evidence indicates that the conditions of
this exception are no longer being met or a public health risk exists due to this exception.

Jon Finlinson
Page 3 of 3
October 24, 2023

Please maintain a copy of this letter with your permanent records for future reference.

If you have any questions regarding this exception, please contact John Chartier, DEQ Central
District Engineer, at [phone], or me, at [phone].

Sincerely,

Michael Newberry, P.E.
Permitting and Engineering Support Manager

JLC/mrn/mdb

cc: Eric Larsen, Central Utah Health Department, [e-mail]
Patrick Jacobs, Kiewit, [e-mail]
Paul Novogoratz, Kiewit, [e-mail]
Logan Green, Kiewit, [e-mail]
Jon Finlinson, Intermountain Power Service Corp, [e-mail]
Dani Zebelean, Division of Drinking Water, [e-mail]
John Chartier, DEQ Central District Engineer, [e-mail]
Nagendra Dev, Division of Drinking Water, [e-mail]

DDW-2023-039814