32 ENVIRONMENT and ENERGY
<< Continued from page 31 presume that if sufficient treatment is provided to control for Giardia and viruses(( that is, 3-log( 99.9 %) inactivation of Giardia and 4-log( 99.99 %) inactivation of viruses)), then legionella risks will also be controlled. In addition, the Revised Total Coliform Rule( USEPA, 2013a) and the Ground Water Rule( USEPA, 2006a) have treatment technique requirements that address bacteria. Corrective actions related to treatment technique violations may provide some control of legionella. All of these rules apply to public water systems( PWS). Premise plumbing systems that do not meet all the exemption criteria in the Safe Drinking Water Act( SDWA) Section 1411 and 40 CFR 141.3, are subject to federal drinking water regulations under 40 CFR Part 141. Adding certain water treatment technologies in a premise plumbing system could impact the chemical and microbial quality of the water and change the regulatory status of the premise plumbing system. The criteria for being a regulated PWS are provided at 40 CFR 141.3.
Where there are questions about the application of these criteria, the primacy agency( for example, the state) typically makes the determination based on these criteria and any relevant site-specific considerations. EPA has issued guidance that primacy agencies may use as they make regulatory application decisions(( USEPA, 1976( revised in 1998); USEPA, 1990( revised in 1998)). States and / or local governments may have drinking water standards for such systems, even if federal regulations do not apply.
A determination of which technology is best suited for a particular premise plumbing system is case-specific in part due to the complex and diverse nature of premise plumbing systems and local water chemistry. This document does not specifically recommend the addition of treatment nor the installation of any of the technologies discussed herein; however, it does provide information regarding the operational requirements with which regulated PWSs must comply. This information is included only to provide the reader with a comprehensive understanding of the technologies.
Facility owners or operators who are considering adding treatment to their building’ s premise plumbing system may wish to consult with their water supplier( that is, PWS) to better understand any potential water quality issues before making treatment-related decisions. The installation of treatment may also trigger crossconnection control measures to protect the water supplier. If a decision to add treatment in the premise plumbing system seems likely, EPA advises facility owners or operators to consult with their primacy agency for any specific requirements that may apply before they add any treatment.
In addition to the drinking water regulations under SDWA, manufacturers of pesticidal treatment technologies used to control legionella and other microbial contaminants need to comply with the Federal Insecticide, Fungicide and Rodenticide Act( FIFRA) requirements, which are independent of the SDWA requirements. Under FIFRA, pesticide devices are regulated, and unless exempt, pesticide products that contain a substance or mixture of substances and that make a pesticidal claim, must be registered by EPA prior to sale or distribution. Registration of a pesticide product under FIFRA does not mean that it meets the requirements of SDWA or vice versa. PA
“… 26 %( positive tests) were from water systems, including 66 % hot water systems …”
February 2017 Volume 22 I Number 12 www. plumbingafrica. co. za