47PB0024Q0001 RFQ Amendment 03 RFQ Attach 07 PWS Exhibit 17 GSA Order PBS 1000.7A Drinking Water Quality Management.pdf

GENERAL SERVICES ADMINISTRATION

Washington, DC 20405

PBS 1000.7A

November 16, 2023

GSA ORDER

SUBJECT: Drinking Water Quality Management

1) Purpose. This Order establishes national U.S. General Services Administration (GSA) Public Building Service (PBS) requirements for effectively managing and overseeing drinking water (DW) to help ensure the well-being of building occupants, contractors, and visitors in federally owned facilities and leased space under the jurisdiction, custody, or control of GSA (including federally owned facilities operating under a GSA delegation of operations and maintenance (O&M)).

2) Cancellations.

a) Drinking Water Quality Management, PBS 1000.7 (September 13, 2016;

Extended September 8, 2023).

b) Facilities Management Alert (FM-FY23-02) – Avoiding Water Stagnation, (August 4, 2023).

3) Authority.

a) Code of Federal Regulations: 41 C.F.R. § 102-80

b) United States (U.S.) Occupational Safety and Health Administration (OSHA):

29 C.F.R. § 1960, 29 C.F.R. § 1910.141, & General Duty Clause (Section 5(a)(1) of the Occupational Safety and Health Act) (29 U.S.C. § 654)

c) U.S. Environmental Protection Agency (EPA): Safe Drinking Water Act (42 U.S.C.§ 300f, et seq.)

d) EPA: National Primary Drinking Water Regulations (40 C.F.R.§ 141) including Lead and Copper Rule (40 C.F.R. § 141 Subpart I)

e) EPA: National Primary Drinking Water Regulations Implementation (40 C.F.R.

§ 142)

f) EPA: Other Safe Drinking Water Act Regulations (40 C.F.R. § 143) including Use of Lead-Free Pipes, Fittings, Fixtures, Solder, and Flux for Drinking Water (40 C.F.R. § 143 Subpart B)

g) Applicable state and local DW authorities

h) Applicable federal, state, and local plumbing codes

PBS 1000.7A

4) Organizations, Consensus Standards, and Guidelines Used in the Development of the Order.1

a) EPA: “3Ts for Reducing Lead in Drinking Water in Schools and Child Care Facilities”

b) U.S. Centers for Disease Control and Prevention (CDC): “Toolkit for Controlling Legionella in Common Sources of Exposure”

c) ASHRAE: Standard 514-2023 Risk Management for Building Water Systems:

Physical, Chemical, and Microbial Hazards

d) ASHRAE: Standard 188-2021 Legionellosis: Risk Management for Building Water Systems

e) ASHRAE: Guideline 12-2023 Managing the Risk of Legionellosis Associated with Building Water Systems

f) American Industrial Hygiene Association: Recognition, Evaluation, and Control of Legionella in Building Water Systems 2nd Edition

g) American Water Works Association: Responding to Water Stagnation in Buildings with Reduced or No Water Use

h) International Association of Plumbing & Mechanical Officials: Tips and Recommendations for the Safe and Efficient Flushing of Plumbing Systems in Buildings

5) Background. PBS is committed to providing safe and healthy spaces for building occupants, contractors and visitors in federally owned facilities and leased space under the jurisdiction, custody, or control of GSA (including federally owned facilities operating under a GSA delegation of O&M). Public water systems (PWS), usually municipality-owned and operated, are responsible for continuously providing safe DW to the public that meets the EPA’s National Primary Drinking Water Regulations (NPDWR) of the Safe Drinking Water Act (SDWA). However, a PWS may be publicly or privately owned. A PWS provides water for human consumption through pipes or other constructed conveyances to at least 15 service connections or serves an average of at least 25 people for at least 60 days a year. EPA has defined three types of PWS:

a) Community Water System (CWS): A PWS that supplies water to the same population year-round.

b) Non-Transient Non-Community Water System (NTNCWS): A PWS that regularly supplies water to at least 25 of the same people at least six months per year. Some examples are schools, factories, office buildings, and hospitals which have their own water systems.

c) Transient Non-Community Water System (TNCWS): A PWS that provides water in a place such as a gas station or campground where people do not remain for long periods of time.

Private water systems, such as private DW wells, serve individual households or small groups of people and are not regulated under the EPA SDWA. These

1 Links to these reference materials may be found in the accompanying desk guide.

systems usually serve fewer people and are often found in rural or remote areas.

However, in cases where the state has the primary authority to enforce regulations for PWS, the state’s definition of a PWS may differ from the EPA's definition and could include certain types of private water systems. It is also important to highlight that while the EPA sets federal DW standards and regulations, individual states or local authorities can also establish their own DW requirements, which may be more stringent than the federal standards. Water systems are obligated to comply with regulations at the federal, state, and local levels.

The quality of a facility’s DW can be influenced by various factors, including the design and condition of the building's plumbing system, maintenance and operational practices, construction and occupant activities, and issues related to the PWS.

Facilities often have limited control over water quality issues originating from the PWS and in those situations can only implement control measures in response to notifications from the appropriate authority. The primary responsibility for maintaining and delivering safe water lies with the PWS, which manages the water source, treatment, and distribution systems. Facilities rely on the PWS to provide clean and safe water for their operations.

Once a facility receives acceptable water from the PWS, it becomes the responsibility of the facility's controlling authority (whether it is PBS, a lessor, or an agency with delegated authority) to provide potable water at point-of-use outlets that meet EPA’s NPDWR per the OSHA Sanitation Standard (29 C.F.R. § 1910.141). The continued implementation of a national GSA Drinking Water Quality Management Order will help ensure that this occurs.

6) Scope and applicability. This Order, and the companion desk guide, apply to Federally owned facilities under the jurisdiction, custody, and control of the GSA, including facilities operating under a GSA delegation of authority. Limited aspects of this Order also apply to space leased by GSA and are dictated by the provisions of the lease.

7) Responsibilities.

a) PBS Office of Facilities Management (OFM) Facility Risk Management Division (FRMD). Central Office PBS OFM FRMD is responsible for:

i) Issuance of this Order and subsequent updates,

ii) Providing national guidance and training in support of this Order,

iii) Supporting regional environmental, health, safety, and fire protection (EHSF) program offices in DW program management activities.

b) PBS OFM Facilities Operations. Central Office PBS OFM Facilities Operations is responsible for:

i) Designing, implementing, and providing national program oversight for the PBS Guidance to Maintain or Restore Water Quality2, ensuring that it is effectively applied across Federally owned facilities to maintain water safety and prevent stagnation-related issues,

ii) Ensuring the O&M master specification incorporates the most current, applicable DW requirements.

c) PBS OFM Child Care Center (CCC) Center of Expertise. Central Office PBS OFM CCC Center of Expertise is responsible for:

i) Facilitating an understanding of state and local CCC DW requirements, coordinating with Regional EHSF program offices for CCC DW testing, and communicating with CCC providers regarding DW matters.

d) PBS Office of Architecture and Engineering (OAE). Central Office PBS OAE is responsible for:

i) Ensuring that updates to the P100 Facility Standards for the Public Buildings Service incorporate the most current, applicable DW requirements.

e) PBS Office of Leasing. Central Office PBS Office of Leasing is responsible for:

i) Ensuring that updates to the standard, national lease contracting language incorporate the most current, applicable DW requirements in leases.

f) PBS Regional EHSF Program Office. The PBS Regional EHSF program office is responsible for:

i) Overseeing compliance with the DW management program and this Order throughout the region,

ii) Providing technical DW program support and training to regional Facility Managers, Facility Operations Teams, Project Managers, Lease Administration Managers, and additional internal customers as needed,

iii) Reviewing DW reports and documentation for accuracy and completeness and providing recommendations to responsible offices as needed,

iv) Providing review and input on mitigation and corrective action efforts in buildings where sources of poor DW are identified, 2 Links to this guidance and other reference materials may be found in the accompanying desk guide.

v) Overseeing the conducting of CCC DW testing and documenting results in

IRIS OSH.

g) PBS Regional Design and Construction or Project Delivery Divisions.

Regional Design and Construction or Project Delivery Divisions3 are responsible for:

i) Ensuring post-installation DW testing is included in applicable projects, and the deliverables are received after construction and prior to use.

h) PBS Regional Building Operations Program Office. The PBS Regional Building Operations program office is responsible for:

i) Implementing and providing Regional program oversight for PBS Guidance to Maintain or Restore Water Quality, ensuring that it is effectively applied across Federally owned facilities in the region to maintain water safety and prevent stagnation-related issues.

i) PBS Regional Facility Management and Service Center (FM/SC) Divisions.

The Regional FM/SC Divisions are responsible for:

i) Ensuring post-installation DW testing is included in applicable projects, and the deliverables are received after construction and prior to use,

ii) Ensuring DW incidents, complaints, and emergencies are promptly investigated and reported to the regional EHSF Program Office,

iii) Documenting initial DW incidents, complaints, and emergencies submitted through the O&M Contractor and Facility Manager in the PBS NCMMS,

iv) Communicating to affected occupants any relevant information about DW-related incidents or emergencies per PBS 2400.1 Risk Management Notification (January 8, 2021),

v) Posting notifications at CCC related to DW testing,

vi) Ensuring the completion of mitigation and corrective action efforts in buildings where sources of poor DW are identified,

vii) Ensuring building systems, including backflow prevention devices, are maintained in accordance with the existing O&M specification, site-specific building operating plans, and preventive maintenance programs,

viii) Ensuring any federally owned or operated water systems (CWS, NTNCWS, TNCWS, or private water systems), under GSA’s jurisdiction, custody, or control, are maintained per applicable federal, state, or local regulations.

3 Regional organizational structures may dictate which office has certain responsibilities.

j) PBS Regional Leasing Specialists / Lease Contracting Officers / Lease Administration Managers (LS/LCO/LAM). Regional LS/LCO/LAMs are responsible for:

i) Ensuring the most updated DW clauses are added for new, replacing, succeeding, and superseding leases,

ii) Collaborating with the Lessor and, if necessary, escalating any issues to ensure that the lease provisions are applied in addressing DW concerns raised by GSA or other federal occupants in GSA-controlled leased space.

k) Delegated Agencies. Delegated Agencies must comply with this Order and the accompanying desk guide.

8) Policy.

a) Maintaining DW. The following items must be used to proactively reduce DW problems.

i) CWS, NTNCWS, or TNCWS. In federally owned and leased facilities under the jurisdiction, custody, or control of GSA (including facilities operating under a GSA delegation of authority) where the facility is also the operator of a CWS, NTNCWS, or TNCWS, it is the responsibility of the party or parties responsible for the water system to ensure compliance with applicable federal, state or local DW regulations. In cases where there is no separate party responsible for the water system, the obligation falls upon the controlling authority of the facility. Depending on the facility, this would be the responsibility of PBS, a lessor, or an agency with delegated authority to operate and maintain the facility.

ii) Private water systems. In federally owned and leased facilities under the jurisdiction, custody, or control of GSA (including facilities operating under a GSA delegation of authority) where DW is sourced from private water systems such as a private DW well, it is the responsibility of the party or parties responsible for the water system to ensure compliance with applicable state or local DW requirements. In cases where there is no separate party responsible for the water system, the obligation falls upon the controlling authority of the facility. Depending on the facility, this would be the responsibility of PBS, a lessor, or an agency with delegated authority to operate and maintain the facility.

For awareness, federally owned and leased facilities under the jurisdiction, custody, or control of GSA may own or operate CWS, NTNCWS, TNCWS, and private water systems in limited instances.

In addition to meeting the state or local DW requirements, proper documentation is essential. This includes, but is not limited to: sanitary surveys, operator certification, and drilling logs. It is the responsibility of the water system provider or controlling authority to maintain these documents.

iii) Consumer Confidence Reports (CCR). The EPA requires CWS to make a CCR, also known as an annual DW quality report, publicly available or to send it to their customers. These reports provide information about the local DW quality. The water system must publish these reports each year by July 1.

The O&M Contractor for all federally owned facilities under the jurisdiction, custody, and control of GSA (including facilities operating under a GSA delegation served by a CWS) must review these reports annually and, if any issues are noted, provide notification to the COR and document it in NCMMS. GSA or the agency with delegated authority to operate and maintain the facility must provide notification of the issues noted to each affected occupant agency point of contact.

iv) Guidance to Maintain or Restore Water Quality. Active federally owned facilities under the jurisdiction, custody, and control of GSA (including facilities operating under a GSA delegation of authority) must implement the PBS Guidance to Maintain or Restore Water Quality, as may be amended from time to time. Unless a building-specific ASHRAE 514 water management program or ASHRAE 188 water management plan has been implemented for the potable water system, this guidance applies in a facility that meets the following criteria, irrespective of occupancy: :

(1)Buildings over 50,000 square feet with one or more water booster pumps (both conditions must apply); or

(2)Buildings over six stories in height.

v) Routine Flushing of Focus Areas. Active Federally owned facilities under the jurisdiction, custody, and control of GSA (including facilities operating under a GSA delegation of authority) must conduct weekly flushing of specific areas of focus, and the aerators must be cleaned or replaced monthly if damaged. It's important to note that if aerators are replaced with laminar flow devices, monthly aerator maintenance will no longer be necessary. These areas are identified based on the populations they serve and the nature of their operations. These include:

(1) Health Units;

(2) Child Care Centers (as also noted below); and

(3) Building Common and Private Tenant Showers.

Additionally, if applicable and feasible, dead-end legs of domestic water systems identified during routine maintenance must be flushed monthly.

vi) Baseline Water Testing. In Fiscal Year 2024, an initial baseline DW quality testing by a qualified professional will be required for all active and occupied federally owned facilities that are greater than 1,000 square feet, have DW systems, and fall under the jurisdiction, custody, and control of GSA (including those operating with delegated authority from GSA).

Specifically, at least 10% of cold water outlets primarily designed for human consumption, such as drinking fountains, bottle fillers, and kitchenette faucets, must be tested for lead, copper, and total coliform bacteria [including Escherichia coli (E. coli)]. At a minimum, 5 outlets must be sampled. Test results that exceed the applicable federal, state, or local thresholds must result in remedial actions to reduce concentration levels.

It is essential to conduct post-remediation water testing on failed outlets by a qualified professional before resuming their use.

Additionally, a representative number of hot and cold water outlets must be tested for the presence of legionella as described in the accompanying desk guide. If systems are well controlled, as defined by CDC guidance, no further action is required. However, if systems are poorly controlled or uncontrolled, further response action is needed.

The regional EHSF program office responsible for DW will use their professional judgment to decide whether additional testing is required depending on the results of the baseline testing.

Similarly, an initial baseline DW quality testing by a qualified professional will be required for certain leased facilities under the jurisdiction, custody, or control of the GSA based on direction from the PBS Office of Leasing.

vii) Child Care Centers (CCC).

(1) Hot and cold water point-of-use outlets with the realistic potential to be used as a drinking water source must be flushed weekly, and the aerators must be cleaned or replaced monthly if damaged. This must be on the morning of the first regular business day of each week. It's important to note that if aerators are replaced with laminar flow devices, monthly aerator maintenance will no longer be necessary.

(2) In open CCCs: DW outlets must be sampled and evaluated for lead and copper by a qualified professional annually at a minimum. This testing must include all water outlets with the realistic potential to be used as DW sources, such as those used for human consumption and washing. Test results that exceed the applicable federal, state, or local thresholds must result in remediation actions to reduce concentration levels. It is essential to conduct post-remediation water testing on failed outlets by a qualified professional before resuming their use.

The regional EHSF program office responsible for DW will use their professional judgment to decide whether additional testing outside of the CCC is necessary based on the annual test results.

(3) In closed CCCs: Any CCC closed for 30 consecutive calendar days or more must be sampled and evaluated for lead and copper by a qualified professional approximately two to three weeks before reopening and with sufficient time for PBS to review the results and act on any issues before opening day.

This testing must include all water sources with the realistic potential to be used as DW sources, such as those used for human consumption and washing. Test results that exceed the applicable federal, state, or local thresholds must result in remedial actions to reduce concentration levels. It is essential to conduct post-remediation water testing on failed outlets by a qualified professional before resuming their use.

Additionally, all water outlets primarily designed for human consumption (such as drinking fountains, bottle fillers, and faucets in kitchenettes) must be tested by a qualified professional for the presence of legionella. If systems are well controlled, as defined by CDC guidance, no further action is required. However, if systems are poorly controlled or uncontrolled, further response action is needed.

(4) All newly installed outlets with the realistic potential to be used as a DW source must be thoroughly flushed for a minimum of 10 minutes.

(a) Use a detectable level of disinfectant residual to indicate that flushing has been successful for cold water.

(b) Use the maximum hot water temperature allowed by regulations and codes, or between 120°F (49°C) to 124°F (51°C) to indicate that flushing has been successful for hot water. For outlets with automatic mixing valves, flush until the water temperature stabilizes as the water will be premixed with cold water.

(5) All newly installed water outlets with the realistic potential to be used as a DW source, such as those used for human consumption and washing, must be tested for lead, copper, and total coliform bacteria (including E. coli) by a qualified professional before use. Test results that exceed the applicable federal, state, or local thresholds must result in remedial actions to reduce concentration levels. It is essential to conduct post-remediation water testing on failed outlets by a qualified professional before resuming their use.

viii) Water Testing After New Installations. All Federally owned facilities under the jurisdiction, custody, and control of GSA (including facilities operating under a GSA delegation) must conduct post-installation water testing when certain components of the water system are impacted during repair or renovation projects.

(1) All newly installed water outlets with the realistic potential to be used as DW sources, such as those used for human consumption and washing must be thoroughly flushed for a minimum of 10 minutes.

(a) Use a “detectable level of disinfectant residual” to indicate that flushing has been successful for cold water.

(b) Use the maximum hot water temperature allowed by regulations and codes, or between 120°F (49°C) to 124°F (51°C) to indicate that flushing has been successful for hot water. For outlets with automatic mixing valves, flush until the water temperature stabilizes as the water will be premixed with cold water.

(2) All newly installed water outlets primarily designed for human consumption (such as drinking fountains, bottle fillers, and faucets in kitchenettes) must be tested for lead, copper, and total coliform bacteria (including E. coli) by a qualified professional before use.

(a) Outlets primarily designed for washing (such as bathroom sinks) do not apply, except as outlined above in the CCC section.

(b) Only sample cold water outlets for metals, do not sample hot water outlets or outlets with automatic mixing valves.

(c) Test results that exceed the applicable federal, state, or local thresholds must result in remedial actions to reduce concentration levels.

(d) If applicable, post-remediation water testing on failed water outlets by a qualified professional is required before use.

(3) When replacing building service lines and primary pipes (such as riser and headers), comply with applicable plumbing code disinfection requirements. Adequately flush point-of-use water outlets served by the new portion of the system for a minimum of 10 minutes. Additionally, a representative sampling of at least 10% of total point-of-use water outlets served by the new portion of the system, must be tested for lead, copper, and total coliform bacteria (including E. coli) by a qualified professional before use.

(a) Prioritization must be given to water outlets primarily designed for human consumption (e.g., drinking fountains, bottle fillers, and faucets in kitchenettes) and then moving to water outlets used for human washing.

Only sample cold water outlets for metals, do not sample hot water outlets or outlets with automatic mixing valves.

(b) Test results that exceed the applicable federal, state, or local thresholds must result in remedial actions to reduce concentration levels.

(c) If applicable, post-remediation water testing on failed water outlets by a qualified professional is required before use.

(4) Any water system that plans to partially replace a lead service line must undertake specific actions per EPA’s Lead and Copper Rule. These actions encompass notifying customers with suitable response measures, furnishing pitcher or point-of-use filters, and extending the option for follow-up testing. Federally owned facilities are required to adhere to the instructions provided by the water system and take advantage of the offered testing when presented.

b) Incidents, Complaints, and Emergencies. In response to incidents, complaints, and emergencies related to DW, it is the responsibility of GSA, the Delegated Agency, or the Lessor (if a provision of the lease) to promptly investigate such complaints in federally owned and leased facilities under the jurisdiction, custody, or control of GSA (including facilities operating under a GSA delegation). The investigation process must include:

i) Efforts to identify the nature and source of the suspected DW issue, which may involve conducting confirmatory water testing by a qualified professional.

ii) If the investigation confirms the presence of a DW issue, appropriate corrective action must be initiated to address and remediate the source of the problem and notification to each affected occupant agency point of contact must occur per the requirements of PBS 2400.1 Risk Management Notification (January 8, 2021)

(1) Follow-up testing by a qualified professional must be conducted after implementing corrective actions to ensure the effectiveness of the measures taken.

(2) To ensure that the problem is confined to the original incident area, the regional EHSF program office responsible for DW will use their professional judgment to decide whether additional testing outside of the initial area of concern is required.

iii) In Federally owned facilities under the jurisdiction, custody, and control of GSA, initial DW incidents, complaints, and emergencies reported through the GSA O&M Contractor or GSA Facility Manager channels must be documented and maintained in NCMMS for record-keeping purposes.

9) PBS Desk Guide for Drinking Water Quality Management. The PBS Desk Guide for DW Quality Management serves as a practical resource for national and regional implementation of the PBS DW Quality Management Order. It provides additional guidance, procedures, and best practices for addressing specific DW issues and managing DW programs effectively and is linked below.

10) Signature.

/S/_________________

ELLIOT DOOMES

Commissioner Public Buildings Service

Attachment: PBS Desk Guide for Drinking Water Quality Management

Desk Guide for Drinking Water Quality Management

Companion to

GSA Order PBS 1000.7A

Public Buildings Service (PBS)

Office of Facilities Management

Facility Risk Management Division

November 16, 2023

Table of Contents

Introduction 3

Guidance 3

Water Systems 3

Types of Water Systems 3

Regulations 3

Proactively Maintaining DW 5

Privately Owned or Operated Water Systems 5

Consumer Confidence Reports (CCR) 7

PBS Guidance to Maintain or Restore Water Quality 7

Routine Flushing of Focus Areas 8

Baseline Water Testing 9

Water Testing After New Installation 10

Child Care Centers (CCC) 12

Use of Lead in Potable Water Systems 14

Utilizing Cold Water for Cooking and Drinking 15

Reactively Responding to Incidents, Complaints, and Emergencies 15

Legionella 16

DW Assessments 19

Other Considerations 20

Sampling Methodology & Protocols 20

Data Applicability 20

Associated Costs 21

Helpful Resources 21

Introduction

The Drinking Water (DW) Quality Management Desk Guide serves as a practical resource for national and regional implementation of the DW Quality Management Order. It provides additional guidance, procedures, and best practices for addressing specific DW issues and managing DW programs effectively.

Guidance

Water Systems

Types of Water Systems

The United States (U.S.) Environmental Protection Agency (EPA) outlines several primary types of water systems based on the population served and the type of users:

1) Public Water Systems (PWS): A PWS provides water for human consumption through pipes or other constructed conveyances to at least 15 service connections or serves an average of at least

25 people for at least 60 days a year. EPA has defined three types of PWS:

a) Community Water System (CWS): A PWS that supplies water to the same population year-round.

b) Non-Transient Non-Community Water System (NTNCWS): A PWS that regularly supplies water to at least 25 of the same people at least six months per year. Some examples are schools, factories, office buildings, and hospitals which have their own water systems.

c) Transient Non-Community Water System (TNCWS): A PWS that provides water in a place such as a gas station or campground where people do not remain for long periods of time.

2) Private Water Systems: Private Water Systems are water systems that are not subject to regulation under the EPA Safe Drinking Water Act (SDWA). These systems usually serve fewer people and are often found in rural or remote areas. Private wells and springs that serve individual households or small groups of people are typical examples of private water systems.

Regulations

The Safe Drinking Water Act, 42 U.S.C. § 300f, et seq., (SDWA) is a crucial federal law enacted by the EPA in 1974 to safeguard the nation's public DW supply. The SDWA establishes and enforces standards for the quality of DW provided by PWS to protect public health. It distinguishes between two types of standards:

primary standards and secondary standards. National Primary Drinking Water Regulations (NPDWR) set legally enforceable Maximum Contaminant Levels (MCLs) for specific contaminants known to pose significant health risks, such as microorganisms, disinfectants, disinfection byproducts, inorganic https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations chemicals, organic chemicals, and radionuclides. Compliance with these MCLs is mandatory for PWS. On the other hand, National Secondary Drinking Water Regulations (NSDWRs) are non-enforceable guidelines that address aesthetic properties of DW (like taste, odor, and color) which do not pose direct health risks but can affect the water's acceptability.

Below is a high-level summary of the DW regulations for each of the different types of water systems listed above:

1) PWS:

a) A CWS is subject to more comprehensive regulations under the SDWA. Some key components include:

i) MCLs: The EPA sets MCLs for various contaminants to establish the maximum allowable concentrations in DW. These include various microorganisms, disinfectants, disinfection byproducts, inorganic chemicals, organic chemicals, and radionuclides.

ii) Treatment Techniques: For certain contaminants where setting an MCL is not feasible, the EPA imposes treatment techniques to reduce the levels of those substances in DW.

iii) Monitoring and Reporting: CWS must regularly monitor and report the quality of their water to ensure compliance with the EPA's standards.

b) A NTNCWS is subject to similar regulations as CWS, with some specific considerations for non-residential facilities.

c) A TNCWS also adheres to the SDWA regulations, but it has monitoring and reporting requirements tailored to its transient nature.

2) Private Water Systems: Private water systems are not subject to the same federal regulations as

PWS under the SDWA. The EPA and the Centers for Disease Control and Prevention (CDC) recommend voluntary guidelines for private well owners to ensure the safety of their DW.

Additionally, states and local authorities may have specific regulations or requirements for private water systems.

In cases where the state has the primary authority to enforce regulations for PWS, its definition of a PWS may differ from the EPA's definition. However, it is essential to note that a state's definition must be at least as strict as the EPA’s definition. For example, the state might require a smaller number of service connections to classify as a PWS, but it cannot define a PWS as anything larger than 15 service connections or an average of 25 people served by the system. Alternatively, in some states, if a system is not considered a PWS according to the EPA but provides a DW fountain or has a bathroom open to the public, it would be considered a PWS according to the state's definition. Additionally, while the EPA sets federal DW regulations, individual states or local authorities can also establish their own DW https://www.epa.gov/sdwa/secondary-drinking-water-standards-guidance-nuisance-chemicals https://www.epa.gov/privatewells/protect-your-homes-water#welltestanchor https://www.cdc.gov/healthywater/drinking/private/wells/testing.html requirements which may be more stringent than the federal standards. Water systems are obligated to comply with regulations at the federal, state, and local levels.

As a final note, once a Federal facility receives acceptable water from the water system, it becomes the responsibility of the facility's controlling authority (whether it is PBS, a lessor, or an agency with delegated authority) to provide potable water at point-of-use outlets. OSHA 29 CFR 1910.141(b)(1)(i) mandates that potable water must be provided in all places of employment for various purposes, including: drinking, washing of individuals, cooking, washing of foods, cleaning cooking or eating utensils, washing food preparation or processing areas, and personal service rooms. OSHA defines potable water as water that meets the drinking standards set by the state or local authority with jurisdiction or water that complies with the quality standards prescribed by the EPA’s NPDWR.

The potable water system of a facility typically includes the point of entry service line(s), mechanical equipment (e.g., backflow preventers; in-line filtration including strainers; pressure/expansion tanks;

water treatment devices including softeners; boilers, hot water tanks, and other in-line water heating devices; hot water recirculation pumps and balancing valves; and other specialty equipment, if applicable), primary cold and hot water pipes, and point-of-use outlets.

Proactively Maintaining DW

Privately Owned or OperatedWater Systems

Ownership of a water system has no bearing on whether it is a PWS. As mentioned above, a PWS is defined by the number of people served and the number of connections. However, private water systems are almost exclusively privately owned, as the name implies. The controlling authority for federally owned and leased facilities under the jurisdiction, custody, or control of the U.S. General

Services Administration (GSA) (including facilities operating under a GSA delegation of authority) is responsible for ensuring compliance with applicable federal, state, and local DW regulations for the water systems they own or operate. Depending on the facility, this would be the responsibility of PBS, a lessor, or an agency with delegated authority to operate and maintain the facility.

A privately-owned PWS is regulated by federal, state, or local regulations as discussed above. These facilities are subject to a variety of requirements including but not limited to: system operator certification, routine testing, system preventative maintenance, recordkeeping, and periodic inspections by the authority having jurisdiction often called sanitary surveys. Check with the applicable authority to determine what is required for the specific system. Typical records to be maintained can include:

1) DW well construction logs and permits.

2) DW system operator training and certification records.

3) DW system permit and plans.

4) Sampling plan and results.

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.141

5) Preventive maintenance records.

6) System upset and repair records.

7) Records of required notifications, such as testing results, boil orders, and other required notices.

8) Copies of inspections and sanitary survey reports by the authority having jurisdiction, notices of violation, corrective action orders, etc.

Smaller private water systems that do not meet the definition of a PWS are often not fully regulated by federal, state, or local DW regulations. However, their DW wells are generally still required to meet specific well construction requirements and be installed by a certified or licensed DW well driller. If applicable, the well logs from these wells must be passed along to the state or local DW authority to be included in their well water databases. In the absence of federal, state, or local regulations, GSA requires the following sampling to be conducted to ensure the water is potable for federally-owned facilities under the jurisdiction, custody, and control of the GSA:

1) Initial Testing: After the installation of the well system, the owner or operator of the system must ensure compliance with state and local testing requirements for new well installation.

Additionally, the need for addressing other germs or harmful chemicals will depend on the well's location on the property, the state the property resides in, and whether it is located in an urban or rural area. To determine if any specific contaminants are a concern in the specific region, consult with the local health or environmental department or the EPA.

2) Routine Testing:

a) Weekly: Disinfectant and disinfectant byproduct, if applicable.

b) Monthly: Total coliform bacteria [including Escherichia coli (E. coli)]; one raw water sample from the wellhead and one water sample from the distribution system, rotated each month.

c) Annually: Nitrates, total dissolved solids, and pH.

Additional testing is required if:

1) There are known problems with well water in the area.

2) There are past problems near the well (i.e., flooding, land disturbances, or nearby waste disposal sites).

3) Replacement or repair of any part of the well system.

4) There is a change in water quality (i.e., taste, color, or odor).

Data management must be consistent with the state or local DW requirements. For systems that are not regulated by the state or locality, documentation must be uploaded to National Computerized

Maintenance Management System (NCMMS) for federally-owned facilities under the jurisdiction, custody, and control of the GSA.

If the testing results confirm the presence of a DW issue:

1) Notify the regional environmental, health, safety, and fire protection (EHSF) program office responsible for DW.

2) If applicable, notify affected occupants per PBS 2400.1 Risk Management Notification of DW concerns that could impact their health.

3) Initiate appropriate corrective action to address and remediate the source of the problem.

Consumer Confidence Reports (CCR)

CCR are an essential requirement mandated by the EPA that necessitates the annual dissemination of information regarding the quality and safety of DW supplied to building occupants. These reports play a crucial role in keeping consumers informed about the quality of their DW and ensuring transparency in water management practices. By providing comprehensive details on the sources of DW, any detected contaminants, and the measures taken to ensure water safety, CCRs empower individuals to make informed decisions about their water consumption. Furthermore, the reports highlight compliance with regulatory standards and outline any necessary actions taken to address water quality issues. By receiving CCRs annually, building occupants can gain confidence in their water supply, fostering trust and promoting a healthy and safe environment for all.

CCRs are published on an annual basis, usually by July 1st. Notifications regarding these releases are generally sent to the individual listed on the water bill or published on the Water System’s website. An easy way to locate these is by conducting an internet search for "City, State Water Quality Reports CCR", which often yields precisely the information you need. These must be reviewed annually by the operations and maintenance (O&M) contractor and, if any issues are noted, notification is to be provided to the COR and documented in the PBS NCMMS. As a result, GSA or the delegated agency must provide notification to each affected occupant agency point of contact. EPA has additional information available on CCR.

PBS Guidance to Maintain or RestoreWater Quality

The COVID-19 pandemic has significantly impacted how buildings are occupied and utilized for the foreseeable future. The adoption of remote work has been accelerated, leading to a change in building utilization. It has also highlighted the importance of managing buildings that prioritize the health and well-being of their occupants.

These changes in building utilization, combined with the best practices learned during the pandemic, necessitate the assurance that building potable water systems are providing fresh water at point-of-use outlets. Stagnation can occur within building water systems when water remains still within the plumbing network due to non-usage, leading to the development of water quality issues. Stagnation events can occur in buildings with an overestimated design capacity, during seasonal building use (e.g., schools during summer), construction activities, periods between occupancy, natural disasters, and https://insite.gsa.gov/directives-library/risk-management-notification https://www.epa.gov/ccr changes to building operations (e.g., "stay-at-home" orders during the COVID-19 pandemic or increased telework).

To address these concerns, all federally owned facilities, including facilities operating under a GSA delegation of authority, regardless of occupancy levels, must implement the PBS Guidance to Maintain or

Restore Water Quality if they meet the following criteria:

1) Buildings over 50,000 sqft. with water booster pumps (both conditions must apply); or

2) Buildings over six stories.

As part of the guidance, the O&M contractor must assess the building’s plumbing system and is responsible for developing a water sampling and flushing plan. Buildings will use this guidance, as may be amended from time to time, unless a building-specific ASHRAE 514 water management program

(WMP) or ASHRAE 188 water management plan has been implemented for the potable water system.

To the extent that compliance with the PBS Guidance to Maintain or Restore Water Quality is insufficient for the specific circumstances of the facility, such as a history of water issues involving opportunistic pathogens or facing challenges in maintaining consistent chlorine levels, hot water temperatures, or overall water quality, developing an ASHRAE 514 WMP or ASHRAE 188 water management plan that aligns with ASHRAE Guideline 12 for the potable water system is required. Moreover, facilities seeking a customized and holistic approach can benefit from an ASHRAE 514 WMP or ASHRAE 188 water management plan by implementing tailored strategies, advanced monitoring techniques, and preventive measures to mitigate risks and optimize water management practices. All contractors involved in the development of WMP must possess the ASSE 12080 Legionella Water Safety and Management Specialist

Certification or its equivalent.

Routine Flushing of Focus Areas

Active federally owned facilities under the jurisdiction, custody, and control of the GSA (including facilities operating under a GSA delegation of authority) must conduct weekly flushing of specific focus areas. These areas are identified based on the populations they serve and the nature of their operations.

These include:

1) Health Units;

2) Child Care Centers (as also noted below); and

3) Building Common and Private Tenant Showers.

For water outlets in Health Units and Child Care Centers, it is required to:

https://docs.google.com/document/d/18Q4c6ZmqNmwkjtFaL1w3viKXfKEgxFieE_wHweC64go/edit https://docs.google.com/document/d/18Q4c6ZmqNmwkjtFaL1w3viKXfKEgxFieE_wHweC64go/edit

1) Locate the furthest outlet from the incoming source in the focus area, run both the hot and cold water, and let the water run for 10 minutes.

2) Open the cold water at each outlet and let the water run for one minute or longer until it reaches the minimum cold water temperature.

3) Open the hot water at each outlet either simultaneously or independently from the cold water.

Allow the water to run for at least one minute or longer until it reaches its maximum hot water temperature.

4) Run all refrigerated water fountains for a minimum of 3-5 minutes.

For building common and private tenant showers, it is required to:

1) Flush hot and cold water until the temperatures stabilize or a disinfectant residual is detectable.

Furthermore, the aerators must be cleaned or replaced monthly if damaged.

1) An effective way to remove the need for monthly aerator maintenance is to replace aerators with laminar flow devices.

Additionally, if applicable and feasible, dead-end legs of domestic water systems identified during routine maintenance must be flushed monthly.

BaselineWater Testing

It is of significant importance that all active and occupied federally owned facilities under the jurisdiction, custody, and control of the GSA with drinking water systems that are over 1,000 SF (which also encompass facilities operating under a GSA delegation of authority) adhere to stringent drinking water testing requirements. Baseline DW quality testing will be required in FY24. Specifically, at least

10% of cold water outlets primarily designed for human consumption, such as drinking fountains, bottle fillers, and kitchenette faucets, must be tested for lead, copper, and total coliform bacteria (including E.

coli). Test results that exceed the applicable federal, state, or local thresholds, must result in remediation actions to reduce concentration levels. It is essential to conduct post-remediation water testing on failed outlets before resuming their use.

Additionally, there is a need to sample a representative number of hot and cold water outlets for the presence of legionella. Legionella sampling locations should encompass all of the following where applicable:

1) Incoming Municipal Water - 1 sample per service line.

2) Storage Tank(s) - 1 sample per tank.

3) Expansion tank(s) - 1 sample per tank.

4) Hot water circulation circuit(s) - 1 sample per plumbing riser.

5) Building common and private tenant showers - at least 1 sample for every 3 fixtures.

6) If applicable, all point-of-use outlets that are primarily designed for human consumption in a

Child Care Center for both hot (where applicable) and cold water.

7) If applicable, all point-of-use outlets that are primarily designed for human consumption or treatment of patients in a Health Unit for both hot (where applicable) and cold water.

8) 10% of all of the remaining point-of-use outlets primarily designed for human consumption, such as drinking fountains, bottle fillers, and kitchenettes focusing on distal locations for both hot

(where applicable) and cold water. In smaller facilities, this must include at least five outlets.

If systems are well controlled, as defined by CDC guidance, no further action is required. However, if systems are poorly controlled or uncontrolled, further response action is needed.

The regional EHSF program office responsible for DW will use their professional judgment to decide whether additional testing is necessary based on the baseline test results.

Water Testing After New Installation

Assessment of new point-of-use water outlets used for human consumption or washing purposes is a crucial step that ensures these systems' safe operation when certain components of the water system are impacted during repair or renovation projects. This involves an evaluation process to verify that these systems comply with regulatory standards after installation. By conducting this testing, any potential issues or deficiencies can be identified and addressed early on, reducing the risk of costly repairs, inefficiencies, or water quality problems in the future. It is required in these scenarios:

1) All newly installed outlets used for human consumption or washing purposes must be thoroughly flushed for a minimum of 10 minutes.

a) Use a detectable level of disinfectant residual to indicate that flushing has been successful for cold water.

b) Use the maximum hot water temperature allowed by regulations and codes, or between

120°F (49°C) to 124°F (51°C) to indicate that flushing has been successful for hot water.

For outlets with automatic mixing valves, flush until the water temperature stabilizes as the water will be premixed with cold water.

2) All newly installed water outlets primarily designed for human consumption (e.g., drinking fountains, bottle fillers, and faucets in kitchenettes) must be tested for lead, copper, and total coliform bacteria (including E. coli) by a qualified professional before use.

a) Outlets primarily designed for washing (e.g., bathroom sinks) do not apply, except as outlined above in CCC.

b) Test results that exceed the applicable federal, state, or local thresholds must result in remediation actions to reduce concentration levels.

c) If applicable, post-remediation water testing on failed water outlets is required before use.

3) When replacing building service lines and primary pipes (e.g., riser and headers), comply with applicable plumbing code disinfection requirements. Additionally, representative testing of at least 10% of total point-of-use water outlets served by the new portion of the system, must be tested for lead, copper, and total coliform bacteria (including E. coli) by a qualified professional before use.

a) Prioritization must be given to outlets primarily designed for human consumption (e.g., drinking fountains, bottle fillers, and faucets in kitchenettes) and then moving to outlets used for human washing. Only sample cold water outlets for metals, do not sample hot water outlets or outlets with automatic mixing valves.

b) Test results that exceed the applicable federal, state, or local thresholds must result in remediation actions to reduce concentration levels.

c) If applicable, post-remediation water testing on failed water outlets is required before use.

4) When a water system plans to partially replace a lead service line that provides DW to a facility, it's crucial to be aware of the…