Attachment A - Legionella Sampling Plan rev 1-14-2026 02.docx

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B533--Potable Water Testing
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36C25926Q0307
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This is an Environmental Testing Protocol attachment that establishes the Legionella Detection Program procedures for the George E. Wahlen VA Medical Center. The document outlines a quarterly rotating sampling schedule for routine legionella testing at distribution endpoints in patient care areas (Buildings 1, 3, and 14) and non-patient buildings (27, 32, 42, and 43). Testing is conducted monthly on a quarterly basis, with each quarter beginning October 1st, January 1st, April 1st, and July 1st. The sampling plan includes core testing sites such as Building 1's cold tank room, Building 27's cooling tower, and Building 42's three units, with approximately 14-16 sites and 33-36 tests conducted per month depending on the quarter. Each site requires two tests—one from hot and one from cold water sources—with samples collected as "first draw" approximately 125 ml from standard outlets and 1000 ml from hot and cold only sources.

Engineering Service staff are responsible for collecting water samples and transporting them immediately to a certified testing contractor for laboratory analysis. The contractor must possess specific certifications (detailed in the associated Statement of Work) and will deliver test results in writing to Engineering Service, which forwards copies to the Infection Preventionist to minimize patient exposure risk. All environmental testing results are tracked in the VASLCHCS Water Safety Committee Environmental Sampling Spreadsheet and logged quarterly into the VHA Water Safety Management Tool. The protocol also addresses post-construction testing requirements, recovery procedures following water line disturbances (requiring chlorine dioxide concentration of 0.06 ppm), and procedures for documenting positive test results through formal VHA Issue Briefs—with the latter being VA responsibility rather than contractor responsibility.

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September 17, 2025 MCP 138.73

ATTACHMENT A

GEORGE E. WAHLEN VA MEDICAL CENTER

ENVIRONMENTAL TESTING PROTOCOL (Legionella Detection Program)

1. The determination of the sampling sights is controlled by the VASLCHCS Water Safety Committee with the support of the Infection Preventionist, and Engineering Service as needed.

1. Water testing frequency for Legionella is controlled by Directive 1061, the VASLCHCS, and with the advisement of the Infection Preventionist.

2. The water sampling, lab testing, and result documentation for Legionella is the responsibility of the Engineering Service. Comment by O'Bryan, Jacqueline L.: VA or contractor? Comment by Keene, Joshua R.: Its engineering's responsibility, but it’s the VA’s decision whether we will be doing this with a contractor or on our own. This is just saying the testing of legionella is our domain.

3. Routine testing for Legionella at distribution endpoints in patient care areas of buildings 1, 3, and 14, and non-patient building 27, 32, 42, and 43 will be performed monthly by Engineering Service with the assistance of the Infection Preventionist. The VASLCHCS Environmental Sampling Plan is as follows: Comment by O'Bryan, Jacqueline L.: Tests are conducted monthly, but only 3 months listed in the table. Are bldg 27 and 42 not monthly? The structure of this table should be revised to reflect all twelve months or one month with all bldgs and tests, Comment by Keene, Joshua R.: There is only three months because this is a rotating schedule for the quarter. SO Month 1 is the first month of the quarter.

VASLCHCS Environmental Sampling Plan outline monthly testing for each quarter. This schedule restarts at the start of each quarter. The beginning of each quarter is the first of October, January, April, and July, Each Quarter:Comment by O'Bryan, Jacqueline L.: Is there particular months you want the sampling to occur?Comment by Keene, Joshua R.: Now outlined above.
Month
BuildingComment by O'Bryan, Jacqueline L.: Every building listed is not identified in the map provided. That must be addressed.Comment by Keene, Joshua R.: They are in the map. We talked about this over teams.
Sites
TestsComment by O'Bryan, Jacqueline L.: Is this number of samples?Comment by Keene, Joshua R.: Yes
1
3
4
10
1
1
4
10
1
32
3
9
1
14
1
2
1
42Comment by O'Bryan, Jacqueline L.: This and 43 aren’t listed in para 3 above.Comment by Keene, Joshua R.: Fixed
1
1
1
43
1
1
TOTAL
14
33
Month
Building
Sites
Tests
2
1
5
15
2
3
5
10
2
32
3
7
2
27
1
1
TOTAL
14
33
Month
Building
Sites
Tests
3
1
6
16
3
32
2
6
3
3
5
12
3
27
1
1
3
42
1
1
TOTAL
16
36

*Note: for each site there are two tests – one hot, and one cold

a. Core Testing Sites:

Building 1 – Cold Tank Room Building 27 – Cooling Tower Building 42 – Unit 1 Soft Comment by O'Bryan, Jacqueline L.: Not listed in para 3 above Comment by Keene, Joshua R.: Fixed Building 42 – Unit 2 Hard Building 42 – Unit 3 Hard Building 43 – Pumphouse

5.New outlets will be chosen for each testing period. Any sites that were positive during the previous testing will be re-tested the next time testing is conducted.
6. Water samples will be tested by a certified testing contractor.Comment by O'Bryan, Jacqueline L.: What is the exact cert requirement?Comment by Keene, Joshua R.: Outlined in SOW.

7. Engineering Services staff will collect the water samples and transport them to the testing lab immediately after collection. Water samples from outlets will be collected as follows:

a. Samples must be “first draw”.

b. Fill the specimen container provided by the testing laboratory with approximately 125 (ml) of water. Comment by O'Bryan, Jacqueline L.: VA or Contractor? Comment by Keene, Joshua R.: It’s a contract, but really its just whatever lab recieves it. This isnt going to a VA lab. No VA has the ability to test this.

c. Label the container with the sample number.

d. Two water samples from hot only source:

(1) Open the drain valve and immediately fill one specimen container with 1000 ml of water. Label the container with the sample number. Comment by O'Bryan, Jacqueline L.: Is this industry standard or VASLCHSC preference? Comment by Keene, Joshua R.: Industry standard

e. Two water samples from cold only source:

(1) Open the drain valve and immediately fill one specimen container with 1000 ml of water. Label the container with the sample number.

8. Engineering Service staff will receive written laboratory results and forward copies to the Infection Preventionist as soon as possible to minimize exposure risk to patients.

9. Tested site areas and environmental results for the Medical Center will be tracked in VASLCHCS Water Safety Committee Environmental Sampling Spreadsheet reflecting environmental testing results from core test sites, active test sites, and cleared test sites.

10. Tested site areas and environmental results for the Medical Center will be logged into the VHA Water Safety Management Tool each quarter following receipt of test results.

5. Post-Construction Legionella testing will be conducted per the requirements of the Infection Control Risk Assessment conducted by the Infection Control Preventionist for each applicable project.

6. Following any disturbance to the water line, recovery procedures will be performed to ensure chlorine dioxide is present at the distal most site affected by the disturbance. This includes flushing the line until a chlorine dioxide concentration of 0.06 ppm is reached.

7. Upon receipt of any positive environmental sample result, the Chair of the VASLCHCS Water Safety Committee will write a VHA Issue Brief detailing the following: Comment by O'Bryan, Jacqueline L.: Is this pertinent to the contract/contractor or is this simply VA procedures after contractor performance? Comment by Keene, Joshua R.: VA procedure after contractor performance.

a. Issue Title: Legionella Water Test Results

b. Date of Report

c. Brief Statement of Issue and Status

d. Actions, Progress, and Resolution Date

e. Public Affairs Contacts

f. Contact for Further Information

(1) Issue Brief will be sent via email to the Issue Brief Approval Group VHASLCIssueBriefApprovalGroup@va.gov, who will in turn send it via email to VISN 19 Leadership. Comment by O'Bryan, Jacqueline L.: Is this contractor or VA responsibility? If VA, is it pertinent to this contract? Comment by Keene, Joshua R.: VA responsibility. Remove.

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