Water Treatment Application MA DEP 110220.pdf

Water Treatment Application WS21B To Conduct Pilot Study = or >40,000 gpd and < 200,000 gpd

PWS ID # 3290051

TRANSMITTAL # X287151

FACILITY REQUIRING APPROVAL:

Saunders Building Tewksbury State Hospital Campus

APPLICANT:

Tewksbury State Hospital Scott Consaul, Chief Operating Of cer Department of Public Health 365 East Street Tewksbury MA, 01876

PREPARED BY:

GRAHAM/MEUS INC. ARCHITECTS (GMI)

DATE:

November 2, 2020

Tewksbury State Hospital Water Treatment Application To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

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To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

CONTRIBUTORS

The following individuals and rms contributed to this report:

TEWKSBURY STATE HOSPITAL

Scott Consaul, Esq.,CPHQ, CHSP, CSL, Chief Operating Of cer Don Prud’homme, CHSP, Interim Director of Facilities William Pellerin, Water Storage System Foreman III

WSP

Fernand Tomaz, Senior Associate Blair Chamberlain P.E., Plumbing and FP Department Head

CASSIDY WATER CONDITIONING INC.

Michael Boucher, Consultant

GRAHAM/MEUS INC ARCHITECTS (GMI)

Gary L Graham, FAIA, Principal in Charge Erich Friedrich, Project Coordinator

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

Executive Summary 6

Existing Water Quality 8

Options and Proposed System 12

Proposed System Precedent 24

Filtration System Speci cations 26

Estimated O&M 32

Pilot Study Duration 35

Proposed Study Testing 36

TABLE OF CONTENTS

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

Tewksbury Hospital campus water supply is from nearby Well #3, located 1/2 mile from the Saunders Building. Well water is pumped from the campus’s pump-house through approximately a mile or greater of the existing distribution system before being stored in two large (1 million gallon capacity each) water storage tanks located directly behind the Saunders building. Due to the vintage distribution piping throughout the campus and its buildings, Tewksbury Hospital treats the well water with a blended phosphate additive (to prevent the leeching of copper and iron), potassium hydroxide (KOH) (pH adjustment), and chlorine (disinfectant).

Due to current contaminant levels,Tewksbury Hospital is required to lter water in order to bring Iron and Manganese levels below the acceptable drinking water standard. In addition, both Arsenic and PFAS levels are at approximately 50% of the allowable limits. In a proactive effort, Tewksbury Hospital and MassDEP have agreed that ltration for Arsenic and PFAS will also be provided in case of an increase in levels within upcoming years that would exceed the MCL.

Based on the existing raw water quality present at Tewksbury Hospital, MassDEP requested a compliance action plan in 2018. The resulting compliance plan ultimately recommended Point of Entry (POE) ltration systems for each building on campus. After review, MassDEP requested a more thorough investigation including the analysis of four options to address the water quality issues. These options included supplying the campus with municipal water, blending municipal and well water, creation of a centralized water treatment plant, and the installation of POE ltration systems in each building.

Upon further investigation it was determined that municipal supplied water would not be a viable option due to multiple factors including the potential need to replace large sections of municipal water mains and annual cost of water. A ltration system was recommended that could be implemented for either a centralized water treatment plant or a POE ltration system. The equipment is able to be scaled in order to meet the required ow rate demand.

A similar ltration system has been used in Essex, MA for the ltration of Iron and Manganese which was installed in late 2017. The system used brought Iron levels from 10.9 mg/L to 0.008 mg/L after treatment and Manganese levels from 0.827 mg/L to an undetectable level after treatment. An identical system will be used at Tewksbury Hospital.

The proposed pilot study utilizes the above mentioned ltration system in the Saunders building to demonstrate the ltration capability. The ltration system will be sized for a ow rate of 230 gpm and will lter Iron, Manganese, Arsenic, and PFAS. The study will be conducted for 3 consecutive months in order to complete a comprehensive review and for all cyclic events to occur multiple times. Daily testing of raw and treated water will check for Iron, Manganese, and Turbidity. Weekly testing of raw and treated water will check for Arsenic and pH. Monthly testing of raw and treated water will check for Alkalinity, Carbon Dioxide, Coliform (Total), Color, and PFAS.

EXECUTIVE SUMMARY

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

At this time a nal decision to create a centralized treatment plant or install multiple POE systems has not been made pending the pilot study results and nal project funding. The following paragraphs outline the two available options to implement campus-wide water ltration.

If Tewksbury Hospital moves forward with the creation of a centralized treatment plant this pilot study will operate at approximately 75% of the nal ow rate. The pilot system and ltration results will be comparable to a full scale treatment plant. Please note that a central ltration plant alone would still utilize the vintage distribution system. If Tewksbury Hospital and MassDEP agrees that a creation of a centralized treatment plant is appropirate, the replacement of the distribution system is required in order to guarantee water quality at individual xtures on campus.

The proposed pilot study is also an accurate demonstration of a POE ltration system should Tewksbury Hospital and MassDEP decide to implement campus-wide POE ltration. The pilot study will install what would be the Saunders building’s POE system. This system is the largest one speci ed for the campus as it is the main hospital building. Successful ltration in the Saunders building will allow for additional systems to be sized according to other building ow rates.

Upon successful completion of the pilot study, consideration should be given to each option listed above for effectiveness nal project scope, and life-cycle costs. A centralized treatment plant and distribution system replacement will require a larger upfront capital cost however operation and maintenance costs will be relatively low since there will be a single system to service. A POE ltration system for each building will have a lower capital cost but the operation and maintenance of up to 22 systems will be greater. While both options are viable, GMI recommends the creation of a standalone centralized treatment plant close to the water storage tanks with a campus wide distribution system replacement; pending a successful pilot study.

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

The hospital campus water supply is from nearby Well #3, located 1/2 mile from the Saunders Building.

Well water is pumped from the campus’s pump-house through approximately a mile or greater of the existing distribution system before being stored in two large (1 million gallon capacity each) water storage tanks located directly behind the Saunders building. The hospital’s drinking water has historically tested from 1.1-1.4 mg/L Mn concentration which is above the MassDEP guideline of 0.3 mg/L Mn concentration.

Due to the vintage distribution piping throughout the campus and its buildings, Tewksbury Hospital treats the well water with a blended phosphate additive (to prevent the leeching of copper and iron), potassium hydroxide (KOH) (pH adjustment), and chlorine (disinfectant). These additives are introduced into the water main at the water stations.

The following pages provide water quality excerpts which highlight the contaminants present in Tewksbury Hospital’s water supply. The 2019 consumer con dence report shows Arsenic levels at 6.3 ppb (10 ppb MCL), Iron levels at 2.8 ppm (0.3 SMCL), and Manganese levels ranging from 810-1,100 ppb (50 ppb SMCL with a health advisory of 300/1,000 ppb). Water samples taken at Well #3 during October of 2020 show treated water levels of Arsenic levels at 14.49 ug/L, Iron levels at 4.97 mg/L, and Manganese levels at 1.24 mg/L. Lastly, water samples taken at Well #3 during September of 2020 show PFOA levels at 6.2 ng/L and PFOS levels at 2.4 ng/L. Currently, MassDEP has established a MCL of 20 ng/L for the sum of 6 particular PFAS (PFOS, PFOA, PFDA, PFHpA, PFHxS, and PFNA) to which Tewksbury Hospital’s current contaminate level of the speci c PFAS listed above is 8.6 nm/L.

The contaminate levels noted above require Tewksbury Hospital to lter water in order to bring the Iron and Manganese contaminate level below the acceptable drinking water standard. Currently, both Arsenic and PFAS levels are at approximately 50% of the allowable limits. In a proactive effort, Tewksbury Hospital and MassDEP have agreed that ltration for Arsenic and PFAS will also be provided in case of an increase in levels within upcoming years that would exceed the MCL.

EXISTING WATER QUALITY

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

EXERPTS FROM 2019 CONSUMER CONFIDENCE REPORT

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

SEPTEMBER 2020 PFAS TESTING RESULTS

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

OCTOBER 2020 WELL #3 TESTING RESULTS

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

The 2018 Compliance Action Plan, prepared by GMI Architects, recommended a Point of Entry (POE) ltration systems for each building on campus. In May of 2020 MassDEP requested a more thorough investigation including the analysis of four options to address the water quality issues. These options included supplying the campus with municipal water, blending municipal and well water, creation of a centralized water treatment plant, and the installation of POE ltration systems in each building.

Upon further investigation it was determined that municipal supplied water would not be a viable option due to multiple factors including the presence of Asbestos Cement Pipe within the municipal grid (which could require miles of municipal water main replacement), the estimated annual cost of $750k - $1 million for water, and the town’s uncertainty of reliably meeting the campus’s water demand.

The investigation revealed that a similar ltration system could be implemented for both a centralized water treatment plant and the POE ltration system. The equipment used is able to be scaled up or down in order to meet the required demand. As a result, this system has been chosen for the pilot study to be conducted in the Saunders building. A Culligan Depth Filter will be used to lter suspended particles. A modi ed Culligan Depth Filter which utilizes Activated Alumina will remove +3 and +5 Arsenic. A Culligan Water Softener will be used to removed dissolved hardness along with Iron and Manganese. A Culligan Carbon Filter will be used to lter PFOA and PFOS. Lastly, Harmsco Hurricane Filters will be used to remove colloidal iron, discoloration, and will act as a resin trip is the pre- lters bleed any material to service. These combined systems will be located in the Sub-basement of the Saunders building in proximity to the domestic water pumps and water heaters. A bypass as well as back- ow preventers will be installed with they system.

In comparison, the proposed system will operate at 75% of the expected centralized water treatment plant and will be the largest POE ltration system should the Hospital install the systems campus wide.

The following pages include product information. Please see the Filtration System Speci cations section for a quote and product cut sheets.

OPTIONS AND PROPOSED SYSTEM

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

CULLIGAN DEPTH FILTER AND ACTIVATED ALUMINA FILTER

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

ACTIVATED ALUMINA INFORMATION

ALCAN CHEMICALS

Product Data Activated Aluminas

Alcan Chemicals

Division of Alcan Aluminum Corporation A International Sales Brockville US Sales Cleveland Canadian Sales Montreal 400 Development Drive 3690 Orange Place, Suite 400 1188 Sherbrooke St. West Brockville, ON K6V 5V5 Cleveland, OH 44122-4438 Montreal, PQ H3A 3G2 Telephone: 613-342-7462 Telephone: 216-765-2550 Telephone: 514-848-1429 Fax: 613-342-6943 Fax: 216-765-2570 Fax: 514-848-1450

Toll Free: 800-321-3864 December 18, 1998

AAFS-50 ARSENIC REMOVAL GRADE

Activated Alumina AAFS-50 is promoted with a proprietary additive engineered to accomplish enhanced arsenic removal. Arsenic commonly occurs in two forms: As(V) (arsenate) and As(III) (arsenite).

To achieve maximum performance arsenite must be oxidized to arsenate which is easily accomplished by treatment with an oxidizing agent, such as chlorine. AAFS-50 has shown arsenic capacities up to five times greater than unpromoted activated alumina.

Alcan AAFS-50 effectively removes arsenic at a wider range of pH than unpromoted activated alumina, requiring little or no pH adjustment of the raw water. Both the activated alumina and proprietary promoter constituents of AAFS-50 are drinking water grade quality, suitable for potable water treatment. AAFS-50 is post treated for low aluminum leachability into treated water.

AAFS-50 is readily available in granular form in sizes 28 x 48 mesh, with other sizes being supplied on special request.

Comparative Adsorption Isotherms for Arsenic

10000

12000

14000

16000

0 200 400 600 800

Final Arsenic Concentration (µg/l)

A rs en ic

A d so rb ed (m g /g

M ed ia

AA-400G AAFS 50

Log. (AA-400G) Log. (AAFS 50)

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

ALCAN CHEMICALS

Product Data Activated Aluminas

Alcan Chemicals

Division of Alcan Aluminum Corporation A International Sales Brockville US Sales Cleveland Canadian Sales Montreal 400 Development Drive 3690 Orange Place, Suite 400 1188 Sherbrooke St. West Brockville, ON K6V 5V5 Cleveland, OH 44122-4438 Montreal, PQ H3A 3G2 Telephone: 613-342-7462 Telephone: 216-765-2550 Telephone: 514-848-1429 Fax: 613-342-6943 Fax: 216-765-2570 Fax: 514-848-1450

Toll Free: 800-321-3864 December 18, 1998

CHEMICAL ANALYSIS OF AAFS-50

Constituents Weight %

Al2O3 + proprietary additive 80-85

Soda Na 2O (total) 0.5

Silicon as SiO2 0.020

Titanium as TiO2 0.002

Loss on Ignition 15-20

PHYSICAL PROPERTIES OF AAFS-50

Bulk Density (g/cm 3) 0.91

BET Area (m 2/g) 200-250

Attrition (%) 0.3

Activated Alumina AAFS-50 is routinely packaged in 907 kg (2,000 lb.)

super bags, 158 kg (350 lb.), 45 kg (100 lb.), and 22 kg (50 lb.) drums.

Other forms of packaging can be considered on special request.

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

CULLIGAN WATER SOFTENER AND CARBON FILTER

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

HARMSCO HURRICANE FILTER

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

R

Certified to

ANSI-NSF 61

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150

HUR-40-HP

HUR-170-HP

HUR-90-HP

To ta l H ea d

L o ss p s i)

Flow Rate (GPM)

MEMBER

R

Certified to

ANSI-NSF 61

R

Certified to

HARMSCO HURRICANE FILTER CONT.

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

In late 2017 a similar ltration system was installed at Essex Woods Meeting and Retreat Center located in Essex, Ma. Raw water samples were taken on August 30, 2017 prior to installation of the ltration system at which Iron levels were at 10.9 mg/L and Manganese levels were at 0.827 mg/L. After installation Iron levels dropped 0.008 mg/L and Manganese was not detected.

The ltration system installed at Essex Woods for Iron and Manganese is identical to the one proposed for Tewksbury Hospital. The system utilizes a Culligan Automatic Depth Filter, Culligan Sater Softener, and a 1 micron post lter. Since installation the Meeting and Retreat Center has had no issues with water quality.

PROPOSED SYSTEM PRECEDENT

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

N ashoba Analytical, LLC 31A Willow Road, Ayer MA 01432 Website: http://www.NashobaAnalytical.com

Tel: 978-391-4428 Fax: 978-391-4643 LabNumber: 181581

Use this number with all correspondence

Client:

ReportDate: 9/5/2017Culligan Water Terry Cassidy

39 Chelmsford Street

Lowell, MA 01851

Parameter Date of AnalysisResult MRLMethod

Certificate of Analysis

AnalystMCL

1 Conomo Point Road, Essex, MA

Sampled: 8/30/2017 1:00:00 PM by M. Boucher

- Well Tank

ND 9/1/20170.001Arsenic, Total, MG/L SM 3113B M-MA11180.01

95.1 9/1/20170.2Calcium, MG/L EPA 200.7 M-MA1118Not Spec

0.008 9/1/20170.004Copper, MG/L EPA 200.7 M-MA11181.3

10.9# 9/1/20170.004Iron, MG/L EPA 200.7 M-MA11180.3

0.002 9/1/20170.001Lead, MG/L SM 3113B M-MA11180.015

30.8 9/1/20170.1Magnesium, MG/L EPA 200.7 M-MA1118Not Spec

0.827# 9/1/20170.004Manganese, MG/L EPA 200.7 M-MA11180.05

10.3 9/1/20170.1Potassium, MG/L EPA 200.7 M-MA1118Not Spec

75.6 9/1/20170.2Sodium, MG/L EPA 200.7 M-MA1118See Note

42 8/30/20171Alkalinity, MG/L SM 2320B M-MA1118Not Spec

ReportDate: 7/16/2018Culligan Water

39 Chelmsford Street

Lowell, MA 01851

Parameter Date of AnalysisResult MRLMethod

Certificate of Analysis

AnalystMCL

1 Conomo Point Road, Essex, MA

Sampled: 7/13/2018 7:20:00 AM by Michael Boucher

- SP-5

0.008 7/16/20180.004Iron, MG/L EPA 200.7 M-MA11180.3

ND 7/16/20180.004Manganese, MG/L EPA 200.7 M-MA11180.05

RAW WATER TEST PRIOR TO FILTRATION INSTALLATION:

WATER TEST AFTER FILTRATION SYSTEM INSTALLATION:

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

The following pages include a quote for the pilot study ltration system (with quantities) and product cut sheets. As mentioned in the previous section, this system is sized for a ow rate of 230 gpm. The product description includes model numbers which correspond with the product cut sheets. Please see the product information supplied in the previous section for additional information.

FILTRATION SYSTEM SPECIFICATIONS

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150

HUR-40-HP

HUR-170-HP

HUR-90-HP

To ta l H e a d L o s s p s i)

Flow Rate (GPM)

MEMBER

R

Certified to

ANSI-NSF 61

R

Certified to

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

The following is the expected operation and maintenance requirements for the pilot study ltration equipment. Life cycle costs can be found on the following pages along with more detailed information for each piece of ltration equipment.

Culligan CSM-362D Depth Filtration

• Cleaning cycle will take place twice a week

• Backwash will take 15 minutes at 105 GPM

• Media is expected to last 10-15 years

Culligan CSM-362-AA Activated Alumina Filter

• Cleaning cycle will take place twice a week

• Backwash will take 20 minutes at 50 GPM

• Activated Alumina will need to be replaced annually - water testing may show the need to replace sooner

Culligan CSM-300-2 Water Softener

• Cleaning cycle based on water usage (every 50,000 gallons)

• Backwash will take 15 minutes at 20 GPM and will require 200 lbs of salt per cleaning

• Softening resin is expected to last 10-12 years

Culligan CSM-422R Carbon Filter

• Cleaning cycle will take place twice a week

• Backwash will take 20 minutes at 95 GPM

• Calgon F600AW will need to be replaced annually - water testing may show the need to replace sooner

Harmsco Hurricane Filter HUR-90

• Filter will need to be replaced once a 10lb pressure difference is present from the incoming water - daily monitoring is suggested until regular intervals are established

ESTIMATED O&M

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

Cassidy Water Conditioning Inc.

39 Chelmsford Street, Lowell MA 01851

(978) 454-8896 (800) 428-8001 Fax (978) 453-1163

November 2, 2020

Tewksbury State Hospital Saunders Build Pilot System

Cassidy/Culligan water has designed a treatment system to remove Iron, Manganese, Arsenic, PFOA/PFOS and discoloration form the incoming water as it enters the Saunders Building. Below is a list of equipment, an explanation on how it works, the order of installation and maintenance.

1st Culligan CSM-362D Depth Filtration

System will remove sand, dirt and suspended partials This system will go into a cleaning cycle 2 times per week Backwash flowrate for this unit is 105 GPM for 15 min.

Depth filter media will last 10-15 years before needing replacement Estimated cost of replacing media plus labor $5,500.00 per tank

2nd Culligan CSM-362-AA Activated Alumina Filter

System will remove Arsenic +3 and +5 This system will go into a cleaning cycle 2 times per week Backwash flowrate for this unit is 50 GPM for 20 min.

Activated Alumina will need to be replaced yearly or based off of water test results.

Estimated cost of replacing Activated Alumina plus labor $6,250.00 per tank

3rd Culligan CSM-300 Water Softener

System will remove dissolved Hardness, Iron and Manganese This system will go into a cleaning cycle based on water usage Based off of the current water analysis the softeners will go into a cleaning every

50,000 gallons, backwash at 20 GPM for 15 min each and will use 200lbs of salt per cleaning

Softening resin will last 10-12 years before needing to be replaced Salt tank will hold 900lbs of salt (22.5 40lb bags) @ $9.00 per bag = $202.50 per salt fill.

Estimated cost of replacement resin plus labor $5,400.00 per tank

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd

4th Culligan CSM-422R PFOA/PFOS Carbon Filter

System will remove PFOA/PFOS This system will go into a cleaning cycle 2 times per week Backwash flowrate for this unit is 95 GPM for 20 min.

Calgon F600AW will need to be replaced yearly or based off of water test results.

Estimated cost of replacing Carbon, labor and disposal $14,000.00 per tank

5th HUR-90 Housings

System will remove Colloidal iron, discoloration and act as a resin trip if the pre filters bleed and material to service.

Filters will need to be replaced when there is a10lb difference on the pressure gauges from the incoming water.

Estimated cost of filter replacements $265.00 per housing each time

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

GMI Architects and Cassidy Water Conditioning Inc. recommends a pilot study duration of 3 months in order to demonstrate the ltration system’s ability to effectively lower Iron, Manganese, Arsenic, and PFAS level present in the current raw water. The three month period will allow for all cyclic events to occur numerous times and will allow the campus maintenance staff to familiarize themselves with the system and its operation.

Estimated Cyclic Events:

Depth Filter Cleaning:

Activated Alumina Filter Cleaning:

Water Softener Filter Cleaning:

Carbon Filter Cleaning:

Hurricane Filter Replacement:

PILOT STUDY DURATION

24 times

24 times

225 times

24 times

TBD based on water quality

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

After review of the required testing parameters for the pilot study, the following testing schedule is recommended. Each sampling will include both raw and nished water for comparison.

Daily Testing:

Iron Manganese Turbidity

Weekly Testing:

Arsenic pH

Monthly Testing:

Alkalinity Carbon Dioxide Coliform (Total) Color

PFAS

PROPOSED STUDY TESTING

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

To Conduct Pilot Study = or > 40,000 gpd and < 200,000 gpd Transmittal X287151

END OF DOCUMENT

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