DDW-2025-005982

July 3, 2025
Sent via Email Only
Marjalee Smith
Highlands Water Company Inc
5880 North Highland Drive
Mountain Green, Utah 84050
[e-mail]
Subject:Plan Approval, Phosphate Injection System (TP006);
Highlands Water Company Inc, System #15005, File #22448
Dear Marjalee Smith:The Division of Drinking Water (the Division) received the plans and specifications for the proposed Phosphate Injection System from your consultant, Jacob Neilsen,
P.E. with Hansen, Allen & Luce Engineers on June 11, 2025. This project has met the conditions for receiving a plan approval.
Our understanding of the project is the construction of an orthophosphate injection system at the existing Gordon Creek Chlorinator (TP002). The dosing pump will be adjusted manually
on an as needed basis. The water from Gordon Springs group will pass through the existing chlorinator and proposed phosphate injection system and enter the storage tanks. The purpose
of the phosphate injection system is to coat the distribution system water lines to reduce the potential for copper to leach into the water supply. The estimated dosage of orthophosphate
is 0.08 gallons per hour (GPH). This phosphate injection system is listed in the Division database as the Phosphate Injection System (TP006).
We have completed our review of the plans and specifications, stamped and signed byJacob Nielsen, P.E., dated June 10, 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 Phosphate Injection System are hereby approved.
This approval pertains to construction only. An Operating Permit must be obtained from the Director before the Phosphate Injection System 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, 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.
Monitoring Requirement
A system that installs corrosion control treatment is required to conduct follow up lead and copper as well as applicable water quality parameter samples. The updated monitoring requirements
for this system are presented below. You will find a current copy of your complete monitoring schedule at waterlink.utah.gov. Distribution system water quality parameter samples (pH,
Alkalinity, Orthophosphate) can be collected from total coliform or lead and copper sample sites. SS164 is intended to represent the entry point to the distribution system where all
of the springs combine. Attached is a report template that can be used for this, though it is not required to use this format.
Starting now until the operating permit is granted for the phosphate injection system:Facility with new requirementsAnalyte(s) Required# Of samplesSampling FrequencyNext Due DateRule
ReferenceSS164 pH, Alkalinity2MonthlyJuly 31, 2025R309-210-6(3)(d)(iv)(G)DS001pH, Alkalinity2MonthlyJuly 31, 2025R309-210-6(3)(d)(iv)(G)
After the operating permit is granted for the phosphate injection system for the first year of operation:Facility with new requirementsAnalyte(s) Required# Of samplesSampling FrequencyNext
Due DateRule ReferenceTP006Reading of dosage rate of Orthophosphate2MonthlyTBDR309-210-6(3)(d)(iv)(G)SS164pH, Alkalinity2MonthlyTBDR309-210-6(3)(d)(iv)(G)SS164Orthophosphate2MonthlyTBDR309-210-6(3)(d)(iv)(G)DS001pH,
Alkalinity2MonthlyTBDR309-210-6(3)(d)(iv)(G)DS001Residual Orthophosphate2MonthlyTBDR309-210-6(3)(d)(iv)(G)DS001Lead & Copper20Every Six MonthsTBDR309-210-6(3)(d)(iv)(G)Note pH readings
should always be a field measure. If you have any questions about water quality parameters or lead and copper sampling, please contact the Division Lead and Copper Rule Manager, Dylan
Martinez, at [phone] or [e-mail].
If you have any questions regarding this approval, please contact Cameron Draney, P.E., of this office, at [phone], or me at [phone].
Sincerely,
Michael Newberry, P.E.
Permitting and Engineering Support Manager
CLD/mrn/mdbEnclosures –Operating Permit ChecklistCorrosion Control WQP Monthly Report Templatecc:Ryan Klinge, Weber-Morgan Health Department, [e-mail] Nielsen,
HAL Engineers, [e-mail] Smith, Highlands Water Company Inc, [e-mail] Draney, P.E., Division of Drinking Water, [e-mail] Martinez,
Division of Drinking Water, [e-mail] 15005 22448 PA Phosphate Injection System
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