J-1502000-27_Building_Water_Management_Plan.pdf

Final

BUILDING WATER

MANAGEMENT PLAN

Naval Support Activity

Orlando, Florida

Naval Facilities Engineering Systems Command Southeast Contract: N62470-19-D-4001 | Task Order: N6945020F0364

March 2021

Final

BUILDING WATER

MANAGEMENT PLAN

NAVAL SUPPORT ACTIVITY

ORLANDO, FLORIDA

Prepared For:

Naval Facilities Engineering Systems Command Southeast

Engineer in Charge: Jens Sapin, P.E.

Contract Number: N62470-19-D-4001 Task Order Number: N6945020F0364

March 2021

AH/BC Navy JV, LLC

11837 Rock Landing Drive Suite 300

Newport News, Virginia 23606-4493

(757) 873-4959

BUILDING WATER MANAGEMENT PLAN

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA TABLE OF CONTENTS

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ACRONYMS AND ABBREVIATIONS ............................................................ iii

EXECUTIVE SUMMARY .................................................................................. v

INTRODUCTION ................................................................................... 1-1

1.1 LEGIONELLA CONTROL GOAL ....................................................................1-2

1.2 BUILDING WATER MANAGEMENT TEAM ......................................................1-4

1.3 PLAN ORGANIZATION ................................................................................1-5

WATER SYSTEM DESCRIPTION ........................................................ 2-1

2.1 WATER SUPPLIER ....................................................................................2-2

2.2 BUILDING SYSTEM DESCRIPTION ...............................................................2-3

2.3 COOLING TOWERS ...................................................................................2-9

2.4 WATER USE ........................................................................................... 2-10

2.5 OTHER WATER SYSTEMS ........................................................................ 2-10

ANALYSIS OF HAZARD CONDITIONS ............................................... 3-1

3.1 LEGIONELLA .............................................................................................3-2

3.2 TEMPERATURE .........................................................................................3-3

3.3 OPERATIONAL CONDITIONS .......................................................................3-3

CONTROL MEASURES AND MONITORING....................................... 4-1

4.1 AUTOMATED FLUSHING .............................................................................4-5

4.2 SHOWERHEAD FILTERS.............................................................................4-5

VERIFICATION AND VALIDATION ...................................................... 5-1

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA TABLE OF CONTENTS

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APPENDICES

A. Water System Monitoring Standard Operating Procedure

B. Water System Flushing Standard Operating Procedure

C. Dead Leg Management Standard Operating Procedure

D. Miscellaneous Standard Operating Procedures

E. Cooling Towers Standard Operating Procedures

F. Building Water Management Plan Validation (Including Sampling) Standard Operating Procedure

FIGURES

Figure 1-1 Water Management Program Process .................................................1-2 Figure 2-1 Naval Support Activity Orlando Installation Layout ...............................2-1 Figure 2-2 Central Florida Research Park Water Treatment Plant Layout.............2-3 Figure 2-3 Naval Support Activity Orlando Domestic Water System Layout ..........2-5 Figure 2-4 Naval Support Activity Orlando Domestic Water System Process

Flow Diagram ......................................................................................2-6 Figure 2-5 Naval Support Activity Orlando Hot-Water Booster Heaters ................2-8 Figure 2-6 Naval Support Activity Orlando Cooling Towers ..................................2-9 Figure 3-1 Faucet Aerators ...................................................................................3-4

TABLES

Table ES-1 Summary of Potential Areas of Water Quality Concern........................... v Table 1-1 Action Levels Following Legionella Sampling ......................................1-4 Table 3-1 Summary of Potential Areas of Water Quality Concern........................3-1 Table 4-1 Summary of Control Measures ............................................................4-3

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA ACRONYMS AND ABBREVIATIONS

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ACRONYMS AND ABBREVIATIONS

% percent

°C degrees Celsius

°F degrees Fahrenheit

AH/BC AH/BC Navy JV, LLC

ANSI American National Standards Institute

ASHRAE American Society of Heating, Refrigerating, and Air-Conditioning Engineers

AST aboveground storage tank

BFP backflow preventer

BOS Base Operating Services

CDC Centers for Disease Control and Prevention

CFRP Central Florida Research Park

CO commanding officer

COVID-19 coronavirus disease 2019

HVAC heating, ventilation, and air conditioning

L. pneumophila Legionella pneumophila

MG million-gallon mg/L milligrams per liter

N/A not applicable

NAVFAC SE Naval Facilities Engineering Systems Command Southeast

NMCPHC Navy and Marine Corps Public Health Center

No. number

NSA Naval Support Activity

POE point of entry

POU point of use

PWD Public Works Department

RPZ reduced pressure zone

SOP standard operating procedure

US United States

WMP water management plan

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA ACRONYMS AND ABBREVIATIONS

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WTP water treatment plant

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY

Naval Facilities Engineering Systems Command Southeast contracted AH/BC Navy

JV, LLC (AH/BC) to provide a building water quality site assessment study and water management plan (WMP) at Naval Support Activity (NSA) Orlando, Florida, under Con-tract Number (No.) N62470-19-D-4001, Delivery Order No. N6945020F0364. This is in response to the detection of Legionella in the de Florez Complex (Building 1) and An-nex (Building 2) domestic water system during sampling events on 18 November 2019 and 12 February 2020. AH/BC published a water quality site assessment study report in December 2020 summarizing potential hazards identified and recommendations to consider when developing this WMP (summarized in Table ES-1).

Table ES-1 Summary of Potential Areas of Water Quality Concern

Hazard Potential Area(s) of Concern

Legionella present throughout system

The installation population is exposed to potential illness, including Legionnaires’ disease, from use of the system.

High cold-water temperatures (cross-connection)

A heated cold-water system improves conditions for Legionella growth and spread within the system.

Significant Legionella levels detected at points of use (POU)s1 with carbon filters installed (i.e., ice machines, water fountains)

Carbon filters provide a favorable substrate for bacterial growth, including Legionella when the bacterium is present in the system.

Low population conditions (i.e., coronavirus disease 2019 pandemic personnel restrictions)

Low water use allows for longer periods of stagnant water within the system, which leads to the decay of free chlorine disinfectant residual and amplifies the potential for microbial growth.

Low hot-water temperatures (upstream and separate from booster heaters)

Hot-water systems unable to maintain system temperatures above 108 degrees Fahrenheit (42 degrees Celsius) present optimal conditions for Legionella growth and spread within the system.

Spray aerators installed on majority of hand wash sinks

Spray aerator devices disperse aerosols into the air, increasing the susceptibility of Legionella inhalation when the bacterium is present in the system.

1 POU refers to any plumbing fixture that supplies potable water.

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA EXECUTIVE SUMMARY

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Table ES-1 Summary of Potential Areas of Water Quality Concern (continued)

Hazard Potential Area(s) of Concern

Lack of cold-water line insulation in areas with no temperature control

A lack of insulation makes the supply line susceptible to increased temperatures during warm weather, improving conditions for Legionella growth and spread within the system.

This is especially applicable to the supply line in the Mechanical Building.

Convective heat transfer to cold-water supply from booster heaters

Heating of the cold-water system improves conditions for Legionella growth and spread within the system.

Dead legs2 from removed POUs The potential for microbial growth is amplified by stagnant water conditions.

Electronic faucets with thermostatic mixing valves

The tempered water can provide ideal conditions for microbial growth on surfaces within POU fixtures.

Showerhead membrane filters The tempered water can provide ideal conditions for microbial growth on the filters if not maintained properly.

Hazards associated with building water systems can be managed through effective system operation. To assist building owners and operators, the Centers for Disease

Control and Prevention (CDC) created a standardized process that complies with

American National Standards Institute (ANSI)/American Society of Heating, Refrigerat-ing, and Air-Conditioning Engineers (ASHRAE) Standard 188 to identify risks and man-agement strategies to mitigate the risk of building water quality threats. AH/BC used the CDC process and the latest version of ANSI/ASHRAE Standard 188 (188-2018), in conjunction with ASHRAE Guideline 12-2020, as the main resources in developing this

WMP.

Section 4 summarizes recommended control measures, monitoring strategies, and cor-rective actions for identified hazards. Supporting these recommendations are standard operating procedures (SOPs) that provide more details on implementation for the NSA

Orlando building water management team.

The building water management team must establish procedures to confirm that this building WMP is being implemented as designed (verification) and whether the recom-mended control measures are successfully controlling the hazardous conditions iden-tified (validation).

2 Dead legs refer to water pipes that are no longer used but still connected to the active premise plumbing.

BUILDING WATER MANAGEMENT PLAN SECTION 1

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA INTRODUCTION

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INTRODUCTION

Hazards associated with building water systems are a leading cause of outbreaks and serious illnesses from exposure to potable drinking water. The most common microbial hazard associated with building water systems is Legionella pneumophila (L. pneu-mophila), the bacterium that causes Legionnaires’ disease.

Naval Facilities Engineering Systems Command Southeast (NAVFAC SE) contracted

AH/BC Navy JV, LLC (AH/BC) to provide a building water quality site assessment study and water management plan (WMP) at Naval Support Activity (NSA) Orlando, Florida, under Contract Number (No.) N62470-19-D-4001, Delivery Order No.

N6945020F0364. This is in response to the detection of Legionella in the de Florez

Complex (Building 1) and Annex (Building 2) domestic water system during sampling events on 18 November 2019 (two men’s restrooms) and 12 February 2020 (eighteen out of 40 locations after the application of shock chlorination). AH/BC personnel con-ducted two site visits. The initial site visit occurred from 31 August to 2 September 2020 and consisted of an assessment of the building plumbing system and water quality sampling. AH/BC published a water quality site assessment study report in December

2020 summarizing potential hazards identified and recommendations to consider when developing this WMP. The second site visit occurred from 5 to 7 January 2021 and consisted of meetings with key facility personnel to review the potential hazards iden-tified and determine which hazards require control or mitigation.

Hazards associated with building water systems can be managed through effective system operation. To assist building owners and operators, the Centers for Disease

Control and Prevention (CDC) created a standardized process3 that complies with

American National Standards Institute (ANSI)/American Society of Heating, Refrigerat-ing, and Air-Conditioning Engineers (ASHRAE) Standard 188 to identify risks and

3 CDC. Developing a Water Management Program to Reduce Legionella Growth & Spread in Buildings:

A Practical Guide to Implementing Industry Standards. Version 1.1. 5 June 2017. https://www.cdc.gov/le-gionella/downloads/toolkit.pdf. Accessed 19 January 2021.

https://www.cdc.gov/legionella/downloads/toolkit.pdf https://www.cdc.gov/legionella/downloads/toolkit.pdf

AH/BC Navy JV, LLC 1-2 Final, March 2021 134-014 management strategies to mitigate the risk of building water quality threats (Figure

1- 1). AH/BC used the CDC process and the latest version of ANSI/ASHRAE Standard

188 (188-20184), in conjunction with ASHRAE Guideline 12-2020,5 as the main re-sources in developing this WMP.

Figure 1-1 Water Management Program Process

1.1 LEGIONELLA CONTROL GOAL

Once this building WMP is in place and being implemented as designed, the validation process (see Section 5) will be used to determine when microbiological activity in the system is acceptable for no further remedial action.

4 ASHRAE. Legionellosis: Risk Management for Building Water Systems. ANSI/ASHRAE Standard 188- 2018. https://www.techstreet.com/ashrae/standards/ashrae-188-2018?product_id=2020895. Accessed 19 January 2021.

5 ASHRAE. Managing the Risk of Legionellosis Associated with Building Water Systems. ASHRAE Guideline 12-2020. https://www.techstreet.com/ashrae/standards/guideline-12-2020-managing-the-risk-of-legionellosis-associated-with-building-water-systems?product_id=2111422. Accessed 19 January 2021.

https://www.techstreet.com/ashrae/standards/ashrae-188-2018?product_id=2020895 https://www.techstreet.com/ashrae/standards/guideline-12-2020-managing-the-risk-of-legionellosis-associated-with-building-water-systems?product_id=2111422 https://www.techstreet.com/ashrae/standards/guideline-12-2020-managing-the-risk-of-legionellosis-associated-with-building-water-systems?product_id=2111422

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While no regulations exist in the United States (US) at the national level (or at state or local levels for NSA Orlando) for Legionella, other countries and some local US jurisdictions have developed guidance that recommend action levels when Legionella is detected in building plumbing.

The European Union has guidelines for acceptable levels of Legionella in building plumbing and bases remedial actions on detected levels. A modified version of these action levels was developed as part of the Navy and Marine Corps Public Health Center

(NMCPHC) Legionella Response Guidance for Navy Medicine.6 Table 1-1 summarizes these action levels, as presented in Table 4 of the NMCPHC guidance.

The action levels are based on analysis of sufficient samples to adequately represent the building water system. Section 2.4 of the NMCPHC guidance identifies representative sampling locations:

• Point of entry (POE)

• Storage tanks

• Hot-water supply (e.g., heat exchanger)

• Hot-water return

• At least 20 percent (%) of hot- and cold-water points of use (POUs)7

6 AH/BC; ESPRI, Inc.; and NMCPHC. Legionella Response Guidance for Navy Medicine. November 2020.

7 POU refers to any plumbing fixture that supplies potable water.

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Table 1-1 Action Levels Following Legionella Sampling

Legionella (colony-forming units per liter)

Sublevel Action Required

Not Detected

Not Applicable (N/A)

No action is required.

Less than 100 to 1,000

Refer to the responsible person and ensure that routine monitoring parameters are within target limits throughout the system.

Greater than 1,000 to <10,000

Less than 20% of samples are positive and not repeat positive

Resample the system. If a similar count is found again, conduct a review of the building WMP control measures and risk assessment to identify remedial actions.

Less than 20% of samples are positive and one or more are repeat positive

Resample the system.

For repeat positive sample locations, adjust the building WMP control strategy. For chronically positive locations, clean and disinfect to the origin of the branch.

For other sample locations, review the building WMP control measures, and conduct a hazard analysis to determine whether the building WMP control strategy must be changed.

20% or greater are positive

The system may be colonized, albeit at a low level.

Consider disinfection of the entire system; conduct an immediate review of the building WMP control measures and risk assessment to identify remedial actions.

Greater than or equal to 10,000

N/A

Resample the system. Conduct an immediate review of the building WMP control measures and risk assessment to identify remedial actions, including disinfection of the entire system or affected area(s).

1.2 BUILDING WATER MANAGEMENT TEAM

An imperative step in developing a building WMP is to establish an interdisciplinary team with expertise in building water management. Third-party team members with expertise on building water operations and quality management can add value in cre-ating the WMP. Implementation, however, incorporates steps and measures that fall upon staff to fully incorporate into their routine best practices.

The NSA Orlando WMP interdisciplinary development team included the team mem-bers listed below:

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• Jens Sapin, PE, NAVFAC SE Environmental Compliance Branch, Air and Wa-ter Section

• Lieutenant Brandon Roth, PE, Public Works Officer, NSA Orlando Public Works Department (PWD)

• Steven Wagner, Facilities Management Division Head/Energy Manager, NSA Orlando PWD

• Caleb Romero, PE, Facilities Management, NSA Orlando PWD

• William Holmgren, PE, NSA Orlando Project Management and Engineering Branch

The AH/BC team included the following:

• Peter Pommerenk, PhD, PE

• Richard Theiss, PE

• Robert Durso, PE

1.3 PLAN ORGANIZATION

This building WMP consists of the following sections:

• Section 1 (Introduction): Background and purpose of the project and WMP-development team

• Section 2 (Water System Description): Detailed description of the facility do-mestic water system and uses

• Section 3 (Analysis of Hazard Conditions): Summary of potential hazards identified during the building water quality site assessment study in August/Sep-tember 2020

• Section 4 (Control Measures and Monitoring): Recommendations for control measures, monitoring strategies, and corrective actions for each potential haz-ard identified and other recommendations per ANSI/ASHRAE Standard 188- 2018

• Section 5 (Validation Plan): Identification of validation efforts to ensure appli-cation of the recommended control measures

• Appendices: Standard operating procedures (SOPs) for water system moni-toring, water system flushing, dead leg8 management, cooling towers, building WMP validation, and other miscellaneous requirements per ANSI/ASHRAE Standard 188-2018

8 Dead legs refer to water pipes that are no longer used but still connected to the active premise plumbing.

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This page is left blank intentionally.

BUILDING WATER MANAGEMENT PLAN SECTION 2

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA WATER SYSTEM DESCRIPTION

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WATER SYSTEM DESCRIPTION

NSA Orlando consists of two administrative buildings, the de Florez Complex and An-nex, and a Mechanical Building (Building 3). Figure 2-1 shows an overall layout of the facility, including the domestic water POE and cooling towers.

The de Florez Complex has subareas designated as Zones A through D, running north to south in the building. The Annex is sometimes referred to as Zone E based on con-struction drawings provided to AH/BC.

Figure 2-1 Naval Support Activity Orlando Installation Layout

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2.1 WATER SUPPLIER

NSA Orlando receives finished water from Central Florida Research Park (CFRP) wa-ter treatment plant (WTP), located southwest of the facility at the southern dead end of

Technology Parkway. Figure 2-2 provides a layout of the facility. The WTP is sourced by groundwater from two on-site wells drawing from the Upper Floridan aquifer. The water is initially treated via aeration through cascade trays before entering a 2-mil-lion- gallon (MG) aboveground storage tank (AST). Inside the tank, the water is treated with sodium hypochlorite (tank contains a mixer) for disinfection.

The treated water is distributed to tenants of the business park, including NSA Orlando, via four high service pumps with variable frequency drives. According to the CFRP drinking water quality report for 2019 to 2020, the finished water is used by tenants for drinking water, irrigation, and fire protection purposes.9 There are no downstream stor-age tanks or booster pumps.

The WMP development team met with Thomas King, Director of Utilities and Infrastruc-ture for the CFRP WTP, on 6 January 2021 for a tour of the facility. According to Mr.

King, the free chlorine residual leaving the WTP is typically 2 to 3 milligrams per liter

(mg/L). Automatic flushing devices with timers are installed on the distribution network.

During the initial Legionella sampling events at NSA Orlando in November 2019 and

February 2020, free chlorine residual levels leaving the WTP ranged from 0.7 to

1.4 mg/L, and the automatic flushing devices were not yet installed.

There is one backup diesel pump on-site at the WTP. Polyphosphate addition was a previous component of the WTP treatment process but has since been discontinued.

Lead and copper monitoring is conducted every three years.

In case of an interruption of water supply to the CFRP WTP system, the distribution system has an emergency interconnection with the University of Central Florida water system, which has an emergency interconnection with the Orlando Utilities Commis-sion water system. During the January 2021 WTP tour, the team discovered that this

9 CFRP. Drinking Water Quality Information for CENTRAL FLORIDA RESEARCH PARK, Orlando, Flor-ida 32826, 2019 - 2020.

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Figure 2-2 Central Florida Research Park Water Treatment Plant Layout

2.2 BUILDING SYSTEM DESCRIPTION

Drinking water is supplied to NSA Orlando by a 6-inch pipe with a reduced pressure zone (RPZ) backflow preventer (BFP) at the Loop Road West entrance, located at the west corner of the Annex. From the BFP, the service line reduces to a 5-inch diameter and enters the south corner of the Mechanical Building. Figure 2-3 presents a layout of the system (based on 17 January 1990 revisions to the 30 May 1985 as-built drawings provided by NSA Orlando personnel), and Figure 2-4 presents a process flow diagram of the system.

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Figure 2-3 Naval Support Activity Orlando Domestic Water System Layout

DE FLOREZ COMPLEX

(BUILDING 1)

ANNEX

(BUILDING 2)

MECHANICAL BUILDING

(BUILDING 3)

ZONE A

ZONE B

ZONE C

ZONE D

ZONE E

POE

Legend

Cold Water

Hot Water

Hot-Water Return *Based on 17 January 1990 revisions to as-built drawings (subsequent modifications noted)

*Drawing not to scale

First-Floor

Restrooms Relocated

(Two Booster Heaters Installed, One Out of Service)

Booster Heater Installed at First-Floor Restrooms

Booster Heater Installed in

Food Preparation/Serving Area

Booster Heater Installed at First-Floor Restrooms

Hot-Water Storage

Tank Offline

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Figure 2-4 Naval Support Activity Orlando Domestic Water System Process Flow Diagram

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Once inside the building, the service line splits into a 2½-inch line and a 4-inch line.

The 2½-inch line delivers to two hose bibbs at the south corner of the building and a dual stacked pump/RPZ BFP setup that supplies the cooling towers. The 4-inch line splits to supply a heat exchanger and the cold-water service line entering the de Florez

Complex. Heated water from the heat exchanger supplies a 3-inch service line entering the de Florez Complex. The heat exchanger transfers heat from a closed-circuit, two- chiller system used for heating, ventilation, and air conditioning (HVAC) dehumidification. An electric boiler supplements heat whenever the chillers are off or the hot-water temperature is below 110 degrees Fahrenheit (°F) (43 degrees

Celsius [°C]).

The 4-inch cold- and 3-inch hot-water supply lines enter the de Florez Complex above the dropped ceiling for the food preparation/cooking (Room 1086) and serving (Room

1085) areas on the first floor in Zone C. The supply lines split upon entering the main corridor of the building and run along the corridor above the dropped ceiling to the ends of the building (hot-water line stops at the restrooms at the north end of Zone B).

There are three sets of restrooms (men’s room, women’s room, and janitor’s closet) on the first floor of the de Florez Complex: one at the north end of Zone B, one at the borders of Zones B and C, and one at the south end of Zone D. The supply line branches for these restrooms also supply similar restroom setups on the second and third floors above these restrooms via riser pipes. The first-floor restrooms in Zone D were relocated to the southeast corner of Zone D sometime in the mid- to late 1990s according to NSA Orlando personnel (no as-builts were provided to AH/BC), but the restrooms on the second and third floors in Zone D did not change. In addition to faucets and toilets, the first-floor restrooms in Zone D and at the Zone B/C border have showers.

Cold- and hot-water supply lines branch off from the main corridor supply line in Zone

C to transport water to the Annex. The lines travel above a covered exterior walkway connecting the buildings. The supply lines enter the southeast corner of the building above the dropped ceiling of the first floor and travel along the main corridor and split to support stacked restrooms (men’s room, women’s room, and janitor’s closet) on the

AH/BC Navy JV, LLC 2-8 Final, March 2021 134-014 first and second floors at the center of the building and the private restroom for the

Senior Executive Service Director (Room 2025) on the second floor at the northeast corner of the building.

Five in-line electric hot-water booster heaters have been installed (no as-builts were provided) throughout the facility. One was installed to support the food preparation/serving area, while the other four were installed to support shower areas

(plus some janitor’s closet mop sinks) throughout the installation. Two heaters were installed to support the showers at the first-floor restrooms in Zone D; however, one is inactive and tagged out due to insufficient demand. Figure 2-5 shows photos of two of the heaters. During the January 2021 site visit, it was determined that the hot-water booster pumps pushed heated water into the cold-water plumbing at various cross- connections, including at these heaters and potentially elsewhere (e.g., defective mixing valves) (see Section 3.2).

Annex, First Floor de Florez Complex, First Floor, Zone D

Figure 2-5 Naval Support Activity Orlando Hot-Water Booster Heaters

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Hot-water return lines start above the dropped ceiling on the first floor at the stacked restrooms in Zones B and D of the de Florez Complex and the Annex, retrace back to the food preparation/serving area, and enter the Mechanical Building via a 1-inch return line. These lines do not go above the first floor in either building. The return water passes through a RPZ BFP before rejoining the cold-water feed.

2.3 COOLING TOWERS

Three cooling towers are located southwest of the Mechanical Building (see Figure

2- 6) and are supplied by a 2½-inch line as mentioned above. They are used to remove heat from the installation HVAC system.

The water used in these towers is treated with Spectrus® NX1106 (5-chloro-2-methyl-

4-isothiazolin-3-one and 2-methyl-4-isothiazolin-3-one solution) as a biocide and

OX103 (bromo-chloro-dimethylhydantoin tablets) as a disinfectant.

Figure 2-6 Naval Support Activity Orlando Cooling Towers

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2.4 WATER USE

POUs at NSA Orlando include the following:

• Computer room air handling units (cold only)

• Hand wash sinks

− Breakrooms

− Food preparation/cooking

− Restrooms

• Hose bibbs (cold only, mainly external plus roof penthouses)

• Ice machines (cold only)

• Cafetorium

• Food preparation/cooking

• Janitor’s closet mop sinks

• Kitchen equipment (food preparation/cooking and serving)

− Bain-marie (cold only)

− Carbonator (cold only)

− Coffee and hot-water urn (cold only)

− Drink dispensers (cold only)

− Steam cabinet

− Trash can washer

− Water wash hoods (hot only)

• Showers

− First-floor restrooms in Zone D and at the Zone B/C border

− Private restrooms (e.g., commanding officer [CO])

• Toilets (cold only)

• Water fountains (cold only)

2.5 OTHER WATER SYSTEMS

The NSA Orlando fire suppression system consists of an internal suppression system

(sprinklers) and a fire loop (hydrants), which are both supplied with water by the CFRP

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WTP. Water enters the installation via an 8-inch pipe interconnection at the Loop Road

North entrance, located north of the de Florez Complex and exits the installation at the

Loop Road West entrance adjacent to the domestic water system interconnection. The system is connected to a fire pump on the east side of the Mechanical Building and is not part of the NSA Orlando domestic water system.

The installation also has an irrigation system that is supplied by an on-site well. NSA

Orlando has a consumptive use permit with the St. Johns River Water Management

District for use of the well for this system.

A cooling tower system is supplied via connection to the domestic water system (see

Section 2.2). There are no whirlpools, spas, ornamental fountains, misters, atomizers, air washes, humidifiers, or other non-potable water systems or devices that release water aerosols at the installation.

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BUILDING WATER MANAGEMENT PLAN SECTION 3

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA ANALYSIS OF HAZARD CONDITIONS

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ANALYSIS OF HAZARD CONDITIONS

Table 3-1 summarizes key hazardous conditions identified for the NSA Orlando do-mestic water system. For further details, please refer to the following sections and the building water quality site assessment study report developed by AH/BC.10

Table 3-1 Summary of Potential Areas of Water Quality Concern

Hazard Potential Area(s) of Concern

Legionella present throughout system The installation population is exposed to potential illness, including Legionnaires’ disease, from use of the system.

High cold-water temperatures (cross-connection)

A heated cold-water system improves conditions for Legionella growth and spread within the system.

Significant Legionella levels detected at POUs with carbon filters installed (i.e., ice machines, water fountains)

Carbon filters provide a favorable substrate for bacterial growth, including Legionella when the bacterium is present in the system.

Low population conditions (i.e., coronavirus disease 2019 [COVID-

19] pandemic personnel restrictions)

Low water use allows for longer periods of stagnant water within the system, which leads to the decay of free chlorine disinfectant residual and amplifies the potential for microbial growth.

Low hot-water temperatures (upstream and separate from booster heaters)

Hot-water systems unable to maintain system temperatures above 108 °F (42 °C) present optimal conditions for Legionella growth and spread within the system.

Spray aerators installed on majority of hand wash sinks

Spray aerator devices disperse aerosols into the air, increasing the susceptibility of Legionella inhalation when the bacterium is present in the system.

Lack of cold-water line insulation in areas with no temperature control

A lack of insulation makes the supply line in the Mechanical Building susceptible to increased temperatures during warm weather, improving conditions for Legionella growth and spread within the system.

Heat transfer to cold-water supply from booster heaters11

Heating of the cold-water system improves conditions for Legionella growth and spread within the system.

Dead legs from removed POUs The potential for microbial growth is amplified by stagnant water conditions.

10 AH/BC. Building Water Quality Site Assessment Study. NSA Orlando, Florida. December 2020. Pre-pared for NAVFAC SE under contract No. N62470-19-D-4001.

11 During the January 2021 site visit, it was determined that the hot-water booster pumps pushed heated water into the cold-water system through various cross-connections.

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Table 3-1 Summary of Potential Areas of Water Quality Concern (continued)

Hazard Potential Area(s) of Concern

Electronic faucets with thermostatic mixing valves

The tempered water can provide ideal conditions for microbial growth on surfaces within POU fixtures.

Showerhead membrane filters The tempered water can provide ideal conditions for microbial growth on the filters if not maintained properly.

3.1 LEGIONELLA

Legionella has been regularly detected within the NSA Orlando domestic water system since it was detected in November 2019. During the most recent sampling event on 1 and 2 September 2020 by AH/BC, L. pneumophila was detected in fourteen of the 40 samples collected, with the highest levels detected at the cooling towers and POUs with carbon filters (ice machine and water fountain). Two of those samples (both from the janitor’s closet mop sink at the first-floor restrooms in Zone D of the de Florez Com-plex) tested positive for L. pneumophila serogroup 1, which is responsible for most cases of Legionnaires’ disease.

During the September 2020 sampling, the system was observed to be continuously flushing from four POU fixtures:

• Cold-Water System

− Hose Bibb, de Florez Complex, Penthouse, Zone D, Room 4004

− Janitor’s Closet Mop Sink, Annex, Second Floor, Room 2045

• Hot-Water System

− Janitor’s Closet Mop Sink, de Florez Complex, Second Floor, Zone C, Room 2075

− Janitor’s Closet Mop Sink, de Florez Complex, Second Floor, Zone D, Room 2125

Although significant Legionella levels were detected throughout the water system, the rates were generally lower than those initially detected in November 2019, indicating that initial responses (i.e., shock chlorination, continuous flushing) were improving the situation (although further remedial action is still required).

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3.2 TEMPERATURE

According to ASHRAE Guideline 12-2020, the optimum temperature range for Le-gionella growth is between 85 and 108 °F (30 to 42 °C). Approximately half of the sam-ples collected in September 2020 (23 out of 40) had temperatures within this range.

Additionally, ASHRAE Guideline 12-2020 recommends maintaining hot-water temper-atures at or above 140 °F (60 °C) from water heaters and 120 °F (49 °C) throughout the entire system to control Legionella growth.

Several conditions are likely contributing to these inadequate temperature levels:

• There is a cross-connection between the cold- and hot-water systems at the Mechanical Building. During the January 2021 site visit, it was confirmed that the cold-water system heats up when hot-water booster pumps are in operation.

The pumps push heated water into the cold-water system at various cross-con-nections, which include the electric water heaters that are fed from the cold-water system without check valves. Other potential cross-connections may in-clude defective mixing valves.

• The heat exchanger in the Mechanical Building does not adequately increase the temperature of the hot-water system. While a supplemental electric boiler is installed to ensure that water temperature does not fall below 110 °F (43 °C), the system’s ability to reach sufficient hot-water temperatures is inadequate.

• The cold-water supply line entering and running through the Mechanical Build-ing is not insulated. The building does not have any air temperature controls (i.e., air conditioning). There may be other similar situations within the distribu-tion network (i.e., above the first-floor dropped ceiling).

• The in-line electric hot-water booster heaters with mixing valves are potentially causing convective heat transfer to the cold-water system during periods of low demand (i.e., COVID-19 population restrictions) and/or due to defective mixing valves.

3.3 OPERATIONAL CONDITIONS

There are several aspects of the current NSA Orlando domestic water system opera-tion that contribute to hazardous conditions:

• Significantly high levels of Legionella were detected downstream of carbon fil-ters (installed in ice machines, water fountains, and the CO lounge hand wash sink). The filters, which remove free chlorine residuals and serve primarily to improve water taste and odor, provide a favorable substrate for bacterial growth if not replaced frequently or removed altogether.

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• Significant periods of low water usage (i.e., COVID-19 population restrictions) increase the potential for stagnant water to be present throughout the system.

Under stagnant conditions, water temperatures adjust to ambient conditions (if not insulated) and free chlorine disinfectant residual begins to decay. This cre-ates favorable conditions for microbial growth and spread within the system.

• The majority of hand wash sinks in restrooms and lounges, as well as the food preparation/cooking area, have spray aerators installed. These devices dis-perse aerosols into the air, increasing the susceptibility of Legionella inhalation when present in the system. Figure 3-1 shows examples of faucet aerator de-vices and their impact on aerosol formation (from Figure 4-4 in Management of Legionella in Water Systems by the National Academy of Sciences, Engineer-ing and Medicine).12

− Most of these faucets are also electronic faucets with thermostatic mixing valves that provide water temperatures within the optimum growth range for Legionella. Additionally, they receive limited use and are difficult to flush.

• NSA Orlando personnel confirmed that there are dead legs throughout the sys-tem. This is due to capping of service lines during the removal of inactive POU fixtures instead of removing the service lines up to their connection with a main system line. These dead legs allow for stagnant water conditions.

Figure 3-1 Faucet Aerators

12 National Academy of Sciences, Engineering, and Medicine. Management of Legionella in Water Sys-tems. 2020. https://www.nap.edu/catalog/25474/management-of-legionella-in-water-systems. Accessed 3 February 2021.

https://www.nap.edu/catalog/25474/management-of-legionella-in-water-systems

BUILDING WATER MANAGEMENT PLAN SECTION 4

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA CONTROL MEASURES AND MONITORING

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CONTROL MEASURES AND MONITORING

Table 4-1 summarizes recommended control measures, monitoring strategies, and corrective actions for identified hazards. Supporting these recommendations are SOPs in Appendices A through C that provide more details on implementation for the NSA

Orlando building water management team. These SOPs cover the following:

• Cold- and hot-water system monitoring (Appendix A)

• Cold- and hot-water system flushing (Appendix B)

• Dead leg management (Appendix C)

Additional applicable SOPs are listed in Appendices D and E to cover all applicable preventive measures required per Section 7 of ANSI/ASHRAE Standard 188-2018, broken down into the following categories:

• System start-up and shutdown (Appendix D, Section 4)

• System maintenance (Appendix D, Section 5)

• Water treatment (Appendix D, Section 6)

• Contingency response plan (Appendix D, Section 7)

• Cooling towers (Appendix E)

Note that all of these measures must be considered where appropriate, even if they are not directly linked to the hazards identified in Table 4-1 and the appendices of this

WMP. Unless stated otherwise in Table 4-1 and/or the SOPs in the appendices, the responsible party for activities in this section will be the NSA Orlando PWD.

Some preliminary steps may be appropriate to facilitate the execution of this WMP:

• Ensure that hot-water source temperatures are at least 140 °F (60 °C)

• Eliminate cross-connections between the cold- and hot-water systems

• Install automated flushing equipment at cold- and hot-water system locations representative of both systems (see Appendix B)

− The setups shall consist of a water timer, flow meter, and dechlorination (cold only)

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− Discharges for the cold-water system setups in the roof penthouses shall be directed to stormwater drainage (i.e., roof drainage)

• Install temperature gauges at the booster heaters and hot-water return RPZ

BFP

• Remove and/or maintain (per manufacturers’ recommendations) carbon filters installed at ice machines and water fountains

• Insulate cold-water lines in areas with no temperature control

• Remove hand wash sink spray aerator devices and/or replace with laminar flow devices

• Replace electronic faucets with thermostatic mixing valves at hand wash sinks (preferably one per restroom at minimum)

• Ensure free chlorine residual levels at the POE are at least 0.5 mg/L

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Table 4-1 Summary of Control Measures

Hazard Control Measure(s) Control Location(s) Control Limit(s) Responsible

Party Monitoring Verification Frequency

Corrective Action(s)

SOP(s)

Legionella present throughout system

System flush (including installation of automated flushing equipment) and disinfection; review of temperature conditions throughout system

Throughout

Decreased Legionella conditions until no further action required per Table 1-1

NSA Orlando

PWD

Daily free chlorine measurements at the POE; weekly free chlorine measurements at the hot-water return RPZ BFP and cold-water POUs (janitor’s closet mop sinks) in Rooms 3012 and 3060 of the de Florez Complex and Room 2045 in the

Annex; daily temperature readings at the hot-water return RPZ BFP with newly installed gauge; weekly temperature readings at third-floor janitor’s closet mop sink at the north end of Zone B (Room 3012)

Log review by supervisor

Weekly reviews Flushing and disinfection; CFRP correspondence

Appendices A (monitoring) and B (flushing)

High cold-water temperatures (cross-connection)

Identify and remove cross-connections

Throughout No cross-connections NSA Orlando

PWD

Weekly readings at third-floor janitor’s closet mop sink at the north end of Zone B (Room 3012) Log review by supervisor Quarterly reviews

Removal of cross-connection

Appendix A (monitoring)

Flush all cold-water POU fixtures for 5 minutes

All cold-water POU fixtures

Cold-water temperature less than 25 °C (77 °F) at distal POU fixtures

Janitorial staff Weekly readings at third-floor janitor’s closet mop sink at the north end of Zone B (Room 3012) Log review by supervisor Quarterly reviews Flushing

Appendices A (monitoring) and B (flushing)

Significant Legionella levels detected at POUs with carbon filters installed (i.e., ice machines, water fountains)

Remove or replace carbon filters

All POU fixtures with carbon filters installed

No carbon filters or adherence to filter replacement schedule

Base Operating Services

(BOS)

contractor

Microbiological analysis at affected POUs Log review by supervisor Semiannual reviews

Removal or replacement of filters

Appendix F

(WMP

validation)

Low population conditions (i.e., COVID- 19 pandemic personnel restricitons)

Flush all POU fixtures for 5 minutes weekly (single flush for toilets) All POU fixtures

Free chlorine residual greater than 0.2 mg/L at distal POU fixtures

Janitorial staff

Daily free chlorine measurements at the POE; weekly free chlorine measurements at the hot-water return RPZ BFP and cold-water POUs (janitor’s closet mop sinks) in Rooms 3012 and 3060 of the de Florez Complex and Room 2045 in the

Annex

Log review by supervisor

Monthly reviews Flushing Appendices A (monitoring) and B (flushing)

Low hot-water temperatures (upstream and separate from booster heaters)

Raise hot-water source temperature at heat exchanger and booster heaters to 140 °F (60 °C)

Heat exchanger and booster heaters

Heat exchanger effluent water greater than 140 °C (60 °C)

BOS

contractor

Weekly temperature readings with existing and newly installed gauges

Log review by supervisor

Quarterly reviews Adjust heat exchanger temperature

Appendices A (monitoring) and B (flushing)

Flush the hot-water return line until it reaches 125 °F (52 °C) at the RPZ BFP

Hot-water return RPZ BFP at the

Mechanical Building

Hot-water temperature greater than 125 °F (52 °C) at the hot-water return RPZ

BOS

contractor

Daily temperature readings with newly installed gauge Log review by supervisor Quarterly reviews Flushing

Flush all hot-water POU fixtures for 5 minutes at least weekly during periods of low building occupancy

All hot-water POU fixtures

Hot-water temperature greater than 120 °F (49 °C) at distal POU fixtures

Janitorial staff Weekly temperature readings at third-floor janitor’s closet mop sink at the north end of Zone B (Room 3012) Log review by supervisor Quarterly reviews Flushing

Spray aerators installed on majority of hand wash sinks

Remove spray aerator devices and/or replace with laminar flow devices

All POU fixtures with device installed

No spray aerators

BOS

contractor Observe changes during removal/replacement

Work order review

Project initiation and completion

Removal or replacement of spray aerators

N/A

Lack of cold-water line insulation in areas with no temperature control

Install pipe insulation around cold-water lines

Mechanical Building and other areas with no temperature control

Insulated cold-water lines

NSA Orlando

PWD

Observe changes during installation Work order review Project initiation and completion

Installation of insulation

N/A

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Table 4-1 Summary of Control Measures (continued)

Hazard Control Measure(s) Control Location(s) Control Limit(s) Responsible

Party Monitoring Verification Frequency

Corrective Action(s)

SOP(s)

Heat transfer to cold-water supply from booster heaters

Install check valves on cold-water intake lines

Each booster heater

Check valves installed

BOS

contractor

Observe changes during installation Work order review Project initiation and completion

Installation of check valves

N/A

Flush all hot-water POU fixtures served by heaters for

5 minutes at least weekly during periods of low building occupancy

Cold-water supply temperature less than 25 °C (77 °F) Janitorial staff Weekly temperature readings at booster heater supply lines

Log review by supervisor

Quarterly reviews (monthly during extended low-population events)

Flushing N/A

Dead legs from removed POUs

Establish plan for decommissioning of dead legs and inactive POU fixtures

Areas with removed/inactive

POU fixtures No dead legs

NSA Orlando

PWD

Observe changes during removal Work order review Project initiation and completion

Removal of dead legs

Appendix C (dead leg management)

Electronic faucets with thermostatic mixing valves at hand wash sinks

Replace electronic faucets with two-handled faucets

All electronic faucet POU fixtures

No electronic faucets with mixing valves

BOS

contractor

Observe changes during replacement Work order review Project initiation and completion

Replacement of electronic faucets with mixing valves

N/A

Showerhead membrane filters

Replace filters regularly All showerhead POU fixtures Manufacturer’s recommendations

BOS

contractor Observe changes during replacement

Log review by supervisor

Quarterly reviews Replacement of filters Appendix D (Section 5.3)

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4.1 AUTOMATED FLUSHING

For the cold-water system automated flushing SOP listed in Appendix B, note that automated flushing equipment are to be installed and monitored to reduce sanitary service charges incurred by flushing activities. The equipment shall consist of a water timer, flow meter, and dechlorination. The CFRP sanitary sewer charges are based on metered water consumption.13 Flushed water from the penthouse hose bibbs

(cold- water system) will be discharged, after dechlorination, into the stormwater collection system. The recorded water consumption for flushing can then be deducted from the CFRP metered water use and would not incur sanitary service charges.

The automated flushing equipment setup for the hot-water system shall consist of a flow meter and solenoid valve connected to a timer. Flushed water from these setups will be discharged into the sanitary collected system (i.e., sink/floor drains).

4.2 SHOWERHEAD FILTERS

All showerhead POU fixtures that are part of the NSA Orlando domestic water system have membrane filters installed for removal of microorganisms such as Legionella. As discussed in the miscellaneous SOPs in Appendix D, these membranes should be replaced per manufacturers’ recommendations. These filters shall remain until the building WMP has been implemented, verified, and validated (see Section 5 and subsequent appendices).

13 $4.20 and $6.80 per 1,000 gallons for water and sewer, respectively

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BUILDING WATER MANAGEMENT PLAN SECTION 5

NAVAL SUPPORT ACTIVITY ORLANDO, FLORIDA VERIFICATION AND VALIDATION

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VERIFICATION AND VALIDATION

Per Section 6.2.8 of ANSI/ASHRAE Standard 188-2018, the building water manage-ment team must establish procedures to confirm that this building WMP is being imple-mented as designed (verification) and whether the recommended control measures listed in Section 4 are successfully controlling the hazardous conditions identified (val-idation).

Verification activities are detailed in Table 4-1 and the monitoring SOP in Appendix A.

Validation activities are detailed in…