KCAB_Water_Management_Program.pdf
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This is a Water Management Program document prepared by the Kenton County Airport Board (KCAB) for Cincinnati/Northern Kentucky International Airport that outlines a comprehensive waterborne pathogen management program based on ASHRAE 188-2015 and CDC toolkit standards. The program establishes procedures for monitoring and controlling Legionella and other opportunistic premise plumbing pathogens across 17 airport buildings and facilities through a cross-departmental water management team including the KCAB Utility Supervisor, Facilities Department Head, Environmental Compliance Manager, Asset Manager, Senior Manager of O&M Contracts, and external support from Weas Engineering. The program encompasses monitoring of potable water systems, cooling towers, HVAC systems, ice machines, irrigation systems, emergency eyewashes and showers, and fire protection systems, with buildings classified into three risk levels (Level 1: high risk with 24/7 occupancy and high aerosolization; Level 2: low risk with limited occupancy or aerosolization; Level 3: minimal risk with infrequent occupancy). Critical control points include monthly temperature and chlorine checks for Level 1 cold water outlets (maintaining <5°F difference from incoming supply and >0.75 ppm free chlorine) and hot water outlets (maintaining 110°F-120°F and >0.25 ppm free chlorine), quarterly checks for Level 2 facilities, and annual checks for Level 3 facilities, with service reports maintained electronically.
Validation of the water management program includes Legionella testing at frequencies determined by building risk level—quarterly for Level 1 buildings, semi-annually for Level 2 buildings, and only upon potential case notification for Level 3 buildings—with documented corrective actions corresponding to contamination concentration levels ranging from flushing affected devices for concentrations of 10-100 CFU/mL to complete device replacement and system draining for concentrations exceeding 100 CFU/mL. Cooling towers require monthly bacterial level dip slide testing maintaining <10,000 CFU/mL and annual cleaning and disinfection, while ice machines require semi-annual cleaning, disinfection, and filter replacement. Irrigation systems operate on timers from 2 am to 6 am to minimize human exposure, and emergency eyewashes and showers require weekly flushing per ANSI standards. The program includes quarterly team meetings to review microbiological test results and remedial actions, with meeting notes distributed to all team members, ensuring ongoing verification and evolution of the program as industry standards and facility assessments change.
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| Notice_to_Bidders.pdf | ||
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Text version
Waterborne Pathogen Management Program
Cincinnati/Northern Kentucky International Airport
Kenton County Airport Board
77 Comair Boulevard
Burlington, KY 41018
March 2019
Table of Contents Introduction
Water Management Team
Assessment of Building Water Systems
Process Flow Diagrams
Monitoring of Critical Control Points & Corrective Actions
Validation of the Water Management Program
Verification of the Water Management Program
Appendix A: Process Flow Diagrams
Main Terminal
Concourse A
Concourse B
Parking Garage
Airport Police Department
Sign Shop Builiding
Facility Maintenance
CVG Centre
ARFF Station North
ARFF Station South
Meyer Tool Hangar
Air Field Maintenance Building #3
ARFF Training Center
Central Warehouse
Glycol Processing Building
Ball Fields
Fire Arms Training Building
Electric Vault West
Appendix B: Supporting Information
Introduction We have elected to have a waterborne pathogen management program because cases of disease caused by waterborne pathogens have continued to increase. The goal of this program is to reduce the risk and spread of Legionella and other opportunistic premise plumbing pathogens. The basis of our program is a number of industry best practices, including ASHRAE 188-2015 and the CDC toolkit. In keeping with best practices, our program will have the following components:
- Water Management Team
- Assessment of Building Water Systems
- Process Flow Diagrams
- Monitoring of Critical Control Points
- Corrective Actions
- Validation of the Program
- Verification of the Program
- Documentation
The creation of the water management team allows for identification of the people responsible for the development and implementation of the WMP. The assessment of the building water allows for recognition and evaluation of potentially hazardous conditions that may lead to the growth and dissemination of waterborne pathogens. The process flow diagrams will describe the potable water systems, along with any systems that are connected to the potable water. Once our critical control points are determined using the assessment and flow diagram, we will implement a monitoring schedule to minimize any risks associated with these points. For each of these control points, corrective actions will be established in the case where control measures are outside of the established limits. In order to confirm that our program is mitigating the risk of waterborne pathogens, we will regularly validate the program. We will also verify our program to confirm that all the proper actions are being taken. Lastly, we will ensure that proper documentation of the program is occurring.
It is important to note that our waterborne pathogen management program will evolve over time, as industry continues to identify new hazards and risks. Furthermore, validation of our program will determine whether any necessary changes needed to be made.
Water Management Team One of the requisites for a waterborne pathogen management program is a cross-departmental team.
Per ASHRAE Standard 188, members of the team could include the owners of the building, those with knowledge of the facility’s water systems, those with knowledge of waterborne pathogens, or those responsible for the safety of others in the building.
Typically, the following responsibilities are filled by the members of the internal team:
- Overall program compliance and reporting to other parties within or outside of the organization
- Overall implementation of the program, including daily operation, maintenance, and monitoring of the program
- Responsible for determining the high-risk populations and areas
The members of the KCAB water management team include the KCAB Utility Supervisor, the KCAB
Facilities Department Head, the KCAB Environmental Compliance Manager, the KCAB Asset Manager, and the Senior Manager of O&M Contracts. Outside support include people from Weas Engineering.
Assessment of Building Water Systems An assessment of the various building water systems managed by the Kenton County Airport Board was conducted. The following water systems were determined to be addressed by this Water Management
Program:
• Potable Water Systems • Cooling Towers
• HVAC Systems • Ice Machines
• Irrigation Systems • Emergency Eyewashes & Showers
• Fire Protection Systems
While these water systems can harbor biofilm that can allow for waterborne pathogens to proliferate, the risk of each of these systems is also dependent on the building in which it is present. Therefore, a table was created identifying the risk level of each of the KCAB buildings. The risk levels are as follows:
• Level 1 – high risk of exposure to waterborne pathogens due to high frequency of aerosolization and high level of occupancy
• Level 2 – low risk of exposure to waterborne pathogens due to limited opportunities of aerosolization or less frequent occupancy
• Level 3 – limited risk of exposure to waterborne pathogens due to minimal aerosolization or infrequent occupancy
The following table contains a list of buildings that are maintained by KCAB and fall under this waterborne pathogen management program with the associated risk level:
Building Occupancy Aerosolization Risk
Main Terminal 365 Days/24 Hours High Level 1
Concourse A 365 Days/24 Hours High Level 1
Concourse B 365 Days/24 Hours High Level 1
Terminal Parking 365 Days/24 Hours None Level 3
Airport Police Department 365 Days/24 Hours High Level 1
Sign Shop Building 5 Days per Week/8 Hours Low Level 2
Facility Maintenance 365 Days/24 Hours High Level 1
CVG Centre 5 Days per Week/8 Hours High Level 2
ARFF North Fire House 365 Days/24 Hours High Level 1
ARFF South Fire House 365 Days/24 Hours High Level 1
Meyer Tool Hangar 5 Days per Week/8 Hours Low Level 2
Air Field Maintenance Building #3 365 Days/24 Hours High Level 1
ARFF Fire Training Limited Low Level 3
Central Warehouse 5 Days per Week/8 Hours Low Level 2
Glycol Building Limited Low Level 3
Ball Fields 7 Days/Seasonal Low Level 2
Fire Arms Training Building 5 Days per Week/8 Hours Low Level 2
Electric Vault West 5 Days per Week/8 Hours Low Level 2
Process Flow Diagrams The next pages contain the written descriptions of the building water systems managed by Kenton County
Airport Board. The visual representations of each of these systems can be seen in Appendix A.
Terminal The Terminal has its own incoming main that feeds an irrigation system, a fire suppression system, a chilled loop, a hot water boiler system, and cooling towers. It also serves as the cold water for the sinks and showers in both the east and west end, along with the ice machines in the east and west end and the janitor closets in both ends. This incoming main serves as the make-up to the tank-style water heater that then serves the east end sinks/showers and janitor closets. The Terminal Building incoming main also serves as the make-up to the tank-style water heaters that serve the west end sinks/showers and janitor closets. The domestic hot water systems do have their own separate recirculating loops.
Concourse A Concourse A has four separate incoming mains: Area 3 Incoming Main, Area 4 Incoming Main, Area 5
Incoming Main, and Area 7 Incoming Main.
The Area 3 Incoming Main is the make-up for the fire suppression system that serves Areas 1, 2, and 3. It is also the make-up for the hot water boiler system that serves the entirety of Concourse A. The Area 3
Incoming Main is the make-up to the Concourse A Cooling Towers. It also serves as the cold water for any sinks/showers, ice machines, and janitor closets that are present in Areas 1, 2, and 3. The Area 3 Incoming
Main serves as the cold water make-up to the tank-style water heater present in the Area A Hub. This water heater serves hot water to any sinks/showers and janitor closets that are present in Areas 1, 2, and
3. The domestic hot water system does have a recirculating loop.
The Area 4 Incoming Main is the make-up for the fire suppression system that serves Area 4. It also serves as the cold water for any sinks/showers, ice machines, and janitor closets that are present in Area 4. The
Area 4 Incoming Main serves as the cold water make-up to the tank-style water heater present in Area 4.
This water heater serves hot water to any sinks/showers and janitor closets that are present in Area 4.
The domestic hot water system has its own recirculating loop.
The Area 5 Incoming Main is the make-up for the fire suppression system that serves Area 5. It is also the cold water for any sinks/showers, ice machines, and janitor closets that are present in Area 5. The Area 5
Incoming Main serves as the cold water make-up to the tank-style water heater present in this area. This heater serves hot water to any sinks/showers and janitor closets that are present in Area 5. The domestic hot water system does have its own recirculating loop.
The Area 7 Incoming Main is the make-up for the fire suppression system that serves Areas 6 and 7. It is also the cold water for any sinks/showers, ice machines, and janitor closets that are present in Areas 6 and 7. The Area 7 Incoming Main also serves as the cold water make-up to the tank style water heater present in Area 7. This water heater serves the hot water to any sinks/showers and janitor closets that are present in Areas 6 and 7. The domestic hot water system has its own recirculating loop.
Concourse B Concourse B has four separate incoming mains: Area 1 Incoming Main, Area 7 Incoming Main, Area 10
Incoming Main, and Area 12 Incoming Main.
The Area 1 Incoming Main is the make-up for the fire suppression system that serves Areas 1, 2, 3, 4, and
5. It is also the make-up for the hot water boiler system that serves the entirety of Concourse B. The Area
1 Incoming Main is the make-up to the Concourse B Cooling Towers. It also serves as the cold water for any sinks/showers, ice machines, and janitor closets that are present in Areas 1, 2, 3, 4, and 5. The Area
1 Incoming Main serves as the cold water make-up to the tank-style water heater present in Area 1. This water heater serves hot water to any sinks/showers and janitor closets that are present in Areas 1, 2, 3, 4, and 5. The domestic hot water system does have a recirculating loop.
The Area 7 Incoming Main is the make-up for the fire suppression system that serves Areas 6, 7, 8, and 9.
It also serves as the cold water for any sinks/showers, ice machines, and janitor closets that are present in Areas 6, 7, 8, and 9. The Area 7 Incoming Main serves as the cold water make-up to the tank-style water heater present in Area 7. This water heater serves hot water to any sinks/showers and janitor closets that are present in Area 6, 7, 8, and 9. The domestic hot water system does have a recirculating loop.
The Area 10 Incoming Main is the make-up for the fire suppression system that serves Areas 10 and 11.
It also serves as the cold water for any sinks/showers, ice machines, and janitor closets that are present in Areas 10 and 11. The Area 10 Incoming Main serves as the cold water make-up to the tank-style water heater present in Area 10. This water heater serves hot water to any sinks/showers and janitor closets that are present in Area 10 and 11.
The Area 12 Incoming Main is the make-up for the fire suppression system that serves Areas 12 and 13.
It also serves as the cold water for any sinks/showers, ice machines, and janitor closets that are present in Areas 12 and 13. The Area 12 Incoming Main serves as the cold water make-up to the tank-style water heater present in Area 12. This water heater serves hot water to any sinks/showers and janitor closets that are present in Area 12 and 13.
Parking Garage The Parking Garage Incoming Main is the make-up for the fire suppression system that serves the Terminal
Parking Area. It is also the make-up for the hot water boiler system that serves the entirety of the Terminal
Parking Area.
Airport Police Department The Airport Police Department Incoming Main is the make-up for the fire suppression system that serves the Police Station. It is also the make-up for the hot water boiler system that serves the entirety of the
Police Station. The Police Station Incoming Main serves as the make-up to the irrigation system that is present near the Police Station and as the cold water make-up to the chilled loop. This main also serves cold water to any sinks/showers, ice machines, and janitor closets that are present on the 1st and 2nd floors. The Police Station Incoming Main is the cold water make-up for the tank-style water heater present on the 1st Floor. This water heater serves hot water to any sinks/showers, ice machines, and janitor closets that are present on the 1st and 2nd floors.
Sign Shop Building The Sign Shop Incoming Main is the make-up for the fire suppression system that serves the Sign Shop.
This main also serves cold water to any sinks/showers, ice machines, and janitor closets that are present on the 1st floor. The Sign Shop Incoming Main is the cold water make-up for the tank-style water heater present on the 1st Floor. This water heater serves hot water to any sinks/showers, ice machines, and janitor closets that are present on the 1st floor.
Facility Maintenance The Facility Maintenance Incoming Main is the make-up for the fire suppression system that serves the
Facility Maintenance and the irrigation system that is present outside this building. This main also serves cold water to any sinks/showers, ice machines, and janitor closets that are present on the 1st floor. The
Facility Maintenance Incoming Main is the cold water make-up for the tank-style water heater present on the 1st Floor. This water heater serves hot water to any sinks/showers, ice machines, and janitor closets that are present on the 1st floor.
CVG Centre The CVG Centre has its own incoming main that feeds an irrigation system, a fire suppression system, a chilled loop, a hot water boiler system, and cooling towers. It also serves as the cold water for the sinks and showers on the 1st through 6th floors, along with the ice machines and the janitor closets on the 1st through 6th floors. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st through 6th floors. The domestic hot water system has its own recirculating loop.
ARFF Station North The ARFF Station North has its own incoming main that feeds an irrigation system and a hot water boiler system. It also serves as the cold water for the sinks and showers on the 1st and 2nd floors, along with the ice machines and the janitor closets on the 1st and 2nd floors. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st and 2nd floors. The domestic hot water system has its own recirculating loop.
ARFF Station South The ARFF Station South has its own incoming main that feeds an irrigation system, fire suppression system, and a hot water boiler system. It also serves as the cold water for the sinks and showers on the 1st floor, along with the ice machines and the janitor closets on the 1st floor. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st floor. The domestic hot water system has its own recirculating loop.
Meyer Tool Hangar The Meyer Tool Hangar has its own incoming main that feeds fire suppression system. It also serves as the cold water for the sinks and showers on the 1st floor, along with the ice machines and the janitor closets on the 1st floor. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st floor. The domestic hot water system has its own recirculating loop.
Air Field Maintenance Building #3 The Air Field Maintenance Building #3 has its own incoming main that feeds a fire suppression system and a hot water boiler system. It also serves as the cold water for the sinks and showers on the 1st floor, along with the ice machines and the janitor closets on the 1st floor. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st floor. The domestic hot water system has its own recirculating loop.
ARFF Training Center The ARFF Training Center has its own incoming main that feeds a fire suppression system. It also serves as the cold water for the sinks and showers on the 1st floor, along with the ice machines and the janitor closets on the 1st floor. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st floor. The domestic hot water system has its own recirculating loop.
Central Warehouse The Central Warehouse has its own incoming main that feeds a fire suppression system. It also serves as the cold water for the sinks and showers on the 1st floor, along with the ice machines and the janitor closets on the 1st floor. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st floor. The domestic hot water system has its own recirculating loop.
Glycol Processing Facility The Glycol Processing Facility has its own incoming main that feeds a fire suppression system and a boiler hot water system. It also serves as the cold water for the sinks and showers on the 1st floor, along with the ice machines and the janitor closets on the 1st floor. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets on the 1st floor. The domestic hot water system has its own recirculating loop.
Ball Fields The Ball Fields has its own incoming main that serves as the cold water for the sinks and showers on the
1st floor, along with the ice machines and the janitor closets. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets.
Fire Arms Training Building The Fire Arms Training Building that serves as the cold water for the sinks and showers on the 1st floor, along with the ice machines and the janitor closets. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets. The domestic hot water system has its own recirculating loop.
Electric Vault West
The Electric Vault West has its own incoming main that serves as the cold water for the sinks and showers on the 1st floor, along with the janitor closets. This incoming main serves as the make-up to the tank-style water heater that then serves the sinks/showers and janitor closets. The domestic hot water system has its own recirculating loop.
Monitoring of Critical Control Points & Corrective Actions Potable Water Systems Potable water, both hot and cold, are considered critical control points for our facility, as they can aerosolize water containing waterborne pathogens that can then be inhaled by immunocompromised visitors and staff. However, this risk can be mitigated by preventing stagnation. In order to verify that water is kept moving, we will perform regular checks of both the chlorine and temperature in the hot and cold water. How often these checks are performed will be based on the risk level of a specific building, which can be seen below.
For these checks, the incoming water at one of the backflow preventers will provide the reference amount of chlorine and temperature that is being supplied by the city. The checks of the cold water and hot water outlets will be conducted at the far point of the system, as determined by CVG personnel. Service Reports will be kept electronically.
Level 1:
Includes Terminal, Concourse A, Concourse B, Airport Police Department, Facility Maintenance, ARFF Station North, ARFF Station South, Air Field Maintenance Building #3, and Ball Fields (seasonal)
Cold Water Outlets:
Strategy Method Frequency Control Limit
Check temperature Thermometer Monthly < 5oF different from incoming
Check free chlorine DPD field test Monthly > 0.75 ppm
Hot Water Outlets:
Strategy Method Frequency Control Limit
Check temperature Thermometer Monthly 110oF to 120oF
Check free chlorine DPD field test Monthly > 0.25 ppm
Water Heaters with Mixing Valves:
Check heater temperature Temperature gauge Monthly > 130oF
Check supply temperature Temperature gauge Monthly 110oF to 120oF
Check return temperature Temperature gauge Monthly < 10oF different from supply
Water Heaters without Mixing Valves:
Check heater temperature Temperature gauge Monthly 110oF to 120oF
Check return temperature Temperature gauge Monthly < 10oF different from supply
Level 2:
Includes Sign Shop, CVG Centre, Meyer Tool Hangar, Central Warehouse, and Fire Arms Training Building
Cold Water Outlets:
Strategy Method Frequency Control Limit
Check temperature Thermometer Quarterly < 5oF different from incoming
Check free chlorine DPD field test Quarterly > 0.75 ppm
Check temperature Thermometer Quarterly 110oF to 120oF
Check free chlorine DPD field test Quarterly > 0.25 ppm
Check heater temperature Temperature gauge Quarterly > 130oF
Check supply temperature Temperature gauge Quarterly 110oF to 120oF
Check return temperature Temperature gauge Quarterly < 10oF different from supply
Check heater temperature Temperature gauge Quarterly 110oF to 120oF
Check return temperature Temperature gauge Quarterly < 10oF different from supply
Level 3:
Includes Parking Garage, ARFF Training Center, Electric Vaand Glycol Building
Cold Water Outlets:
Strategy Method Frequency Control Limit
Check temperature Thermometer Annually < 5oF different from incoming
Check free chlorine DPD field test Annually > 0.75 ppm
Check temperature Thermometer Annually 110oF to 120oF
Check free chlorine DPD field test Annually > 0.25 ppm
Check heater temperature Temperature gauge Annually > 130oF
Check supply temperature Temperature gauge Annually 110oF to 120oF
Check return temperature Temperature gauge Annually < 10oF different from supply
Check heater temperature Temperature gauge Annually 110oF to 120oF
Check return temperature Temperature gauge Annually < 10oF different from supply
If the control limit is not met, the root cause will be determined through discussions with both KCAB and Weas personnel. Some of the responses may include establishing a flushing protocol for a particular system or increasing a heater set-point temperature. However, the response will ultimately depend on the root cause of control limit failure.
Cooling Towers Cooling towers are one of the highest risk systems, as the majority of Legionnaires’ disease outbreaks can be attributed to them. However, with proper maintenance, this risk can be properly mitigated. Because towers can spread aerosols over a wide area, there is no varying risk level associated with them; therefore, they will all be treated as high-risk systems. Service Reports will be kept electronically.
Check water quality Routine maintenance Continuously Normal operating parameters
Check bacteria levels Dip slide Monthly < 10,000 CFU/mL
Clean & disinfect Routine maintenance Annually Minimal growth & sediment
If the control limit is not met, the root cause will be determined through discussions with both KCAB and Weas personnel. Some of the responses may include increasing the feed rate of one of the biocides or an online disinfection. However, the response will ultimately depend on the root cause of control limit failure.
HVAC Systems Air handler units, when not properly maintained, can allow for bacteria proliferation, particularly in the pan. However, the risk of aerosolization of bacteria can be limited if the units are properly maintained.
Furthermore, because the risk associated with these systems is minimal, the building does not have an impact.
General inspection Visual analysis Monthly Normal operating parameters
Replace filters Routine maintenance As Required Normal pressure differential
Clean cooling coils Routine maintenance As Required Minimal growth & sediment
Ice Machines Ice machines have been associated with a few outbreaks of Legionnaires’ disease, making them a critical control point. Filters, especially those with carbon, can both remove the disinfectant and provide an environment for bacteria to proliferate. The risk is not dependent on the building.
Clean & disinfect Routine maintenance Semi-annually No scale or build-up
Change filters Routine maintenance Semi-annually Rated for 6 months
Irrigation Systems Traditional irrigation systems result in the aerosolization of water. By running these systems during times in which few people are present, the risk of exposure can be decreased. These systems use cold domestic water, which should have a chlorine residual that prohibits the proliferation of bacteria.
Irrigate to minimize exposure
Timer When in use Irrigate from 2 am to 6 am
Emergency Eyewashes & Showers Emergency eyewashes and showers can result in aerosolization. However, the ANSI standard requires that these be flushed weekly, so stagnation is minimal. Furthermore, these are not widely used by visitors and staff, so the risk of exposure to waterborne pathogens is small.
Flush device ANSI Standard Weekly Normal operating parameters
Fire Protection Systems When they are required to run, fire protection systems aerosolize water. There have not been any documented cases attributed to these systems, and the risk of fire is considered greater than the risk of developing disease due to waterborne pathogens.
General system inspection
Manufacturer’s specs Annually Normal operating parameters
Validation of the Water Management Program Potable Water Systems Because of the risk associated with domestic water, the cold and hot water systems will be tested for the presence of Legionella on a regular basis. The frequency of testing will be dependent on the risk level assigned to the building, as seen below. Representative samples from various fixtures will be taken from both the hot and cold water. Results will be kept electronically.
Risk Level Legionella Testing Frequency
Level 1 Quarterly
Level 2 Semi-Annually
Level 3 Only upon potential case
Potential responses to positive Legionella results can be seen in the table below. It is important to note that all responses should be discussed with the team. If positive results continue, secondary disinfection may be a necessary step.
Percent Positivity
< 30% Positivity ≥ 30% Positivity
Concentration
> 0 but < 10 CFU/mL
- Consult with WMP team
- Flush affected devices simultaneously with hot and cold water for 30 minutes
- Replace supply lines and disinfect aerators
- Retest within one week of corrective action
- Consult with WMP team
- Flush all devices simultaneously with hot and cold water for 30 minutes
- Replace supply lines and disinfect aerators
- Retest within one week of corrective action
≥ 10 but < 100 CFU/mL
- Consult with WMP team
- Flush affected devices simultaneously with super-heated hot water and cold water for 30 minutes
- Replace supply lines and disinfect aerators
- Retest within one week of corrective action
- Consult with WMP team
- Flush all devices simultaneously with super-heated hot water and cold water for 30 minutes
- Replace supply lines and disinfect aerators
- Retest within one week of corrective action
≥ 100 CFU/mL
- Consult with WMP team
- Replace device
- Replace supply lines
- Retest within one week of corrective action
- Consult with WMP team
- Replace affected devices
- Replace supply lines
- Retest within one week of corrective action
Cooling Towers Because cooling towers are commonly sited as sources of Legionella outbreaks, they will be tested quarterly to validate that the program is working correctly. Potential responses to positive Legionella results can be seen in the table below. Results will be kept electronically.
Biocide
Oxidizing Non-Oxidizing
Concentration
> 0 but < 100 CFU/mL
- Shock feed system to achieve 5 to 10 ppm of chlorine for one hour using oxidizer
OR
- Feed oxidizer to achieve 1 to 2 ppm of chlorine for one hour daily
- Feed non-oxidizer to establish 200 to 300 ppm for 8 hours
Retest within one week of corrective action
≥ 10 but < 1000 CFU/mL
- Feed oxidizer to maintain 10 ppm of chlorine for at least 6 hours
- Feed non-oxidizer to establish 200 to 300 ppm for 8 hours
Retest within one week of corrective action
≥ 1000 CFU/mL
- Shock system with 25 to 50 ppm of chlorine using oxidizer
- Drain, fill, and repeat
- Mechanically clean tower
- Re-fill and maintain 10 ppm free chlorine for 24 hours
- Drain and refill and repeat above steps
- Repeat shock using oxidizer to establish 10 ppm of chlorine for one hour
- N/A
Retest within one week of corrective action
HVAC Systems Because there have not been any documented cases attributed to HVAC systems and they are not considered a source of disease caused by waterborne pathogens by various technical manuals, these systems will not be tested for Legionella on any regular frequency. If a situation arises that calls for testing, we will only check systems that are potentially involved with the case.
Ice Machines Since there have been cases of Legionnaires’ disease traced back to ice machines, we will run Legionella tests on the ones that KCAB is responsible for maintaining. If there is a positive result, the ice machine will be disinfected, and the filter analyzed to ensure that it is not a carbon filter. Results will be kept electronically.
Irrigation Systems Irrigation systems pose a minimal risk, as they are run at a time in which there is limited exposure to both employees and visitors. Therefore, they will not be routinely tested for Legionella. If a situation arises that suggests that this system was involved with a potential case, we will test for Legionella.
Emergency Eyewashes & Showers Emergency eyewashes and showers have not been involved in any documented cases. They have also been deemed low risk by technical manuals, so they will not be routinely tested for Legionella.
Fire Protection Systems Fire protection systems have not been cited as the cause in any documented cases. They have also been deemed low risk by different technical manuals, so they will not be routinely tested for Legionella.
Verification of the Water Management Program In order to verify our program and ensure that everything is running smoothly, the team will meet quarterly. At this meeting, any microbiological tests will be discussed, along with any other remedial actions that have been taken. If there are any changes required or any new water systems that have been identified, steps will be taken to both determine and mitigate any risks associated with them.
Efforts will be made to ensure that the team in its entirety is present.
Following the meeting, notes summarizing the discussion will be sent out to all members of the team.
Appendix A: Process Flow Diagrams The next pages will show the various process flow diagrams for the building water systems managed by the Kenton County Airport Board.
Each of the visual representations has pictograms that show what checks are being performed on that particular water system. The check points are based on the risk that the specific device poses. For example, a cooling tower has an elevated risk due to the aerosolization of water. Therefore, the chemistry is regularly checked. The legend is as follows:
= regular chemistry (i.e. chlorine) checks, with frequency determined by the assessment
= regular temperature checks, with frequency determined by the assessment
If a particular water system has elevated risk that requires validation of mitigation by Legionella testing, the system has a red box around it. The frequency of the Legionella testing will be determined by the risk assessment.
Main Terminal
Concourse A Concourse A, Area 3 Incoming Main:
Concourse A, Area 4 Incoming Main:
Concourse A, Area 5 Incoming Main:
Counsourse A, Area 7 Incoming Main:
Concourse B Concourse B, Area 1 Incoming Main:
Concourse B, Area 7 Incoming Main:
Concourse B, Area 10 Incoming Main:
Concourse B, Area 12 Incoming Main:
Parking Garage
Airport Police Department
Sign Shop Builiding
Facility Maintenance
CVG Centre
ARFF Station North
ARFF Station South
Meyer Tool Hangar
Air Field Maintenance Building #3
ARFF Training Center
Central Warehouse
Glycol Processing Building
Ball Fields
Fire Arms Training Building
Electric Vault West
Appendix B: Supporting Information The following is a list of documents that were utilized in order to create our program:
CMS (Centers for Medicare & Medicaid Services). 2017.
Requirement to Reduce Legionella Risk in Healthcare Facility Water Systems to Prevent Cases and Outbreaks of Legionnaires’ Disease (LD).
https://www.cms.gov/Medicare/Provider-Enrollment-and- Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-17-30.pdf
Allegheny County Health Department. 2014.
Approaches to Prevention and Control of Legionella Infection in Allegheny County Health Care Facilities.
http://www.achd.net/infectd/pubs/pdf/2014_FINAL_Legionella_Guidelines_for_Western_PA.pdf
VHA (Veterans Health Administration). 2014.
VHA Directive 1061: Prevention of Healthcare-Associated Legionella Disease and Scald Injury from Potable Water Distribution Systems https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=3033
New York State. 2015.
New York Protection Against Legionella Title: Part 4 – Protection Against Legionella https://www.health.ny.gov/environmental/water/drinking/legionella/index.htm
Centers for Disease Control and Prevention. 2004. Guidelines for Preventing Health-Care Associated Pneumonia, 2003. Morb Mort Wkly Rep 2004; (53):(No. RR-3)1-36.
https://www.cdc.gov/mmwr/preview/mmwrhtml/rr5303a1.htm
Centers for Disease Control and the Healthcare Infection Control Practices Advisory Committee (HICPAC).
2003. Guidelines for Environmental Infection Control in Health-Care Facilities. Morb Mort Wkly Rep 2003;
(52):No. RR-10.
https://www.cdc.gov/mmwr/preview/mmwrhtml/rr5210a1.htm
Centers for Disease Control and Prevention. 2016. Investigation Tools for Single Cases of Legionnaires’ disease https://www.cdc.gov/legionella/health-depts/inv-tools-single/index.html
Centers for Disease Control and Prevention. 2016.
Legionella (Legionnaires’ Disease and Pontiac Fever) Environmental Investigation Tools https://www.cdc.gov/legionella/health-depts/inv-tools-cluster/environmental-inv-tools.html
Centers for Disease Control and Prevention. 2017 Water Management Program Toolkit https://www.cdc.gov/legionella/maintenance/wmp-toolkit.html
Centers for Disease Control and Prevention. 2017 CDC Legionella VitalSigns Article https://www.cdc.gov/vitalsigns/pdf/2017-06-vitalsigns.pdf https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-17-30.pdf https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-17-30.pdf http://www.achd.net/infectd/pubs/pdf/2014_FINAL_Legionella_Guidelines_for_Western_PA.pdf https://www.va.gov/vhapublications/ViewPublication.asp?pub_ID=3033 https://www.health.ny.gov/environmental/water/drinking/legionella/index.htm https://www.cdc.gov/mmwr/preview/mmwrhtml/rr5303a1.htm https://www.cdc.gov/mmwr/preview/mmwrhtml/rr5210a1.htm https://www.cdc.gov/legionella/health-depts/inv-tools-single/index.html https://www.cdc.gov/legionella/health-depts/inv-tools-cluster/environmental-inv-tools.html https://www.cdc.gov/legionella/maintenance/wmp-toolkit.html https://www.cdc.gov/vitalsigns/pdf/2017-06-vitalsigns.pdf
Association of Water Technologies (AWT). 2003.
Legionella 2003: An Update andStatement by the Association of Water Technologies (AWT). Association of Water Technologies, McLean, VA.
https://www.awt.org/pub/0165C705-00C2-B8FF-10E0-A5A6EBDC9021
Cooling Technology Institute (CTI). 2006.
Legionellosis Guideline: Best Practices for Control of Legionella. CTI Guide http://www.cti.org/downloads/WTP-148.pdf
Department of Labor, Occupational Safety and Health Administration (OSHA). 1999.
OSHA Technical Manual. Legionnaires’ Disease. Section III: Chapter 7.
https://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_7.html#1
AIHA (American Industrial Hygiene Association). 2015.
Recognition, Evaluation, and Control of Legionella in Building Water Systems https://www.aiha.org/about-aiha/Press/2015PressReleases/Pages/AIHA-Provides-Preventative-Guidance-in- New-Legionella-Guideline.aspx
WHO (World Health Organization). 2007.
Legionella and the Prevention of Legionellosis.
Published by the World Health Organization ISBN 92 4 156297 8 http://www.who.int/water_sanitation_health/emerging/legionella.pdf
WHO (World Health Organization). 2011. Fourth Edition Guidelines for Drinking-Water Quality http://apps.who.int/iris/bitstream/10665/44584/1/9789241548151_eng.pdf
WHO (World Health Organization). Davison A, Howard G, Stevens M, et al. 2005.
Water Safety Plans: Managing drinking-water quality from catchment to consumer. Geneva, World Health Organization.
http://apps.who.int/iris/bitstream/10665/75141/1/9789241562638_eng.pdf
WHO (World Health Organization). 2009.
Water Safety Plan Manual http://apps.who.int/iris/bitstream/10665/75141/1/9789241562638_eng.pdf
HSE (Health and Safety Executive). 2013 L8 Legionnaires’ Disease http://www.hse.gov.uk/pUbns/priced/l8.pdf
ANSI/ASHRAE Standard 188-2015 Legionellosis: Risk Management for Building Water Systems https://www.ashrae.org/standards-research--technology/standards--guidelines/guidance-on-reducing-the-risk-of-legionella
EPA (Environmental Protection Agency) 1974-2004 Safe Drinking Water Act https://www.epa.gov/sdwa https://www.awt.org/pub/0165C705-00C2-B8FF-10E0-A5A6EBDC9021 http://www.cti.org/downloads/WTP-148.pdf https://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_7.html#1 https://www.aiha.org/about-aiha/Press/2015PressReleases/Pages/AIHA-Provides-Preventative-Guidance-in-New-Legionella-Guideline.aspx https://www.aiha.org/about-aiha/Press/2015PressReleases/Pages/AIHA-Provides-Preventative-Guidance-in-New-Legionella-Guideline.aspx http://www.who.int/water_sanitation_health/emerging/legionella.pdf http://apps.who.int/iris/bitstream/10665/44584/1/9789241548151_eng.pdf http://apps.who.int/iris/bitstream/10665/75141/1/9789241562638_eng.pdf http://apps.who.int/iris/bitstream/10665/75141/1/9789241562638_eng.pdf http://www.hse.gov.uk/pUbns/priced/l8.pdf https://www.ashrae.org/standards-research--technology/standards--guidelines/guidance-on-reducing-the-risk-of-legionella https://www.ashrae.org/standards-research--technology/standards--guidelines/guidance-on-reducing-the-risk-of-legionella https://www.epa.gov/sdwa
ASHRAE Guideline 12-2000 & ASHRAE 12-2000R (July 2017) Minimizing the Risk of Legionellosis Associated with Building Water Systems https://www.ashrae.org/standards-research--technology/standards--guidelines/guidance-on-reducing-the-risk-of-legionella https://osr.ashrae.org/sitepages/showdoc2.aspx/ListName/Public%20Review%20Draft%20Standards/ItemID/
1722/IsAttachment/N/Gdl12-2000R_1stPPRDraft+July+2017.pdf
AWWA (American Water Works Association). 2014 AWWA C651-14 Disinfecting Water Mains https://www.awwa.org/store/productdetail.aspx?productId=45320336
State of Maryland Department of Health & Mental Hygiene. 2000.
Report of the Maryland Scientific Working Group to Study Legionella in Water Systems in Healthcare Institutions.
https://phpa.health.maryland.gov/IDEHASharedDocuments/Legionella-Scientific-Working-Group-
Guidance.pdf
Joint Commission. 2016 Environment of Care, EC.02.05.01 EP14 https://www.jointcommission.org/assets/1/6/PrePub_LifeSafetyCode_Disposition_HAP_v2.pdf
EPA (Environmental Protection Agency). 2016.
Technologies for Legionella Control in Premise Plumbing Systems, EPA810-R-16-001 https://www.epa.gov/sites/production/files/2016-
09/documents/legionella_document_master_september_2016_final.pdf
Legionella Risk Management. 2005 Guidelines for Control of Legionella in Ornamental Water Features http://www.legionellae.org/guidelines/ControlofLegionellainWaterFeatures.pdf
ASHE (American Society for Healthcare Engineering). 2017.
Water Management in Health Care Facilities: Complying with ASHRAE Standard 188 http://www.ashe.org/management_monographs/mg2017platt_et_al.shtml
NSF (National Sanitation Foundation). 2017.
Cooling Towers – Treatment, Operation and Maintenance to Prevent Legionnaires’ Disease, NSF 453-2017 http://standards.nsf.org/apps/group_public/download.php/36391/NSF%20453-2017%20-%202-13-17.pdf https://www.ashrae.org/standards-research--technology/standards--guidelines/guidance-on-reducing-the-risk-of-legionella https://www.ashrae.org/standards-research--technology/standards--guidelines/guidance-on-reducing-the-risk-of-legionella https://osr.ashrae.org/sitepages/showdoc2.aspx/ListName/Public%20Review%20Draft%20Standards/ItemID/1722/IsAttachment/N/Gdl12-2000R_1stPPRDraft+July+2017.pdf https://osr.ashrae.org/sitepages/showdoc2.aspx/ListName/Public%20Review%20Draft%20Standards/ItemID/1722/IsAttachment/N/Gdl12-2000R_1stPPRDraft+July+2017.pdf https://www.awwa.org/store/productdetail.aspx?productId=45320336 https://phpa.health.maryland.gov/IDEHASharedDocuments/Legionella-Scientific-Working-Group-Guidance.pdf https://phpa.health.maryland.gov/IDEHASharedDocuments/Legionella-Scientific-Working-Group-Guidance.pdf https://www.jointcommission.org/assets/1/6/PrePub_LifeSafetyCode_Disposition_HAP_v2.pdf https://www.epa.gov/sites/production/files/2016-09/documents/legionella_document_master_september_2016_final.pdf https://www.epa.gov/sites/production/files/2016-09/documents/legionella_document_master_september_2016_final.pdf http://www.legionellae.org/guidelines/ControlofLegionellainWaterFeatures.pdf http://www.ashe.org/management_monographs/mg2017platt_et_al.shtml http://standards.nsf.org/apps/group_public/download.php/36391/NSF%20453-2017%20-%202-13-17.pdf
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