&EPA
United States	Office of Water
Environmental Protection	epasio-r-16-ooi
Agency	September 2016
Technologies for Legionella Control in Premise
Plumbing Systems:
Scientific Literature Review

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Office of Water (4607M)
EPA 810-R-16-001
September 2016

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Disclaimer
The U.S. Environmental Protection Agency (EPA) prepared this document to serve as a technical
resource for primacy agencies, facility operators and facility owners to use as they evaluate
technologies to respond to the risks associated with Legionella growth in premise plumbing
systems. This document summarizes peer-reviewed scientific literature, reports from nationally
and/or internationally recognized research organizations, and guidelines and standards from
nationally and/or internationally recognized organizations on the characterization of the
effectiveness against Legionella of different technologies that may be used to control Legionella
growth in premise plumbing systems. The document provides information about water quality
issues that could result when using the various technologies and summarizes operational
conditions for each technology. It also discusses critical risk management approaches to address
microbial (including Legionella), physical and chemical risks in various parts of the premise
plumbing system, such as water management programs (WMPs), hazard analysis and critical
control point (HACCP), water safety plans (WSPs) and industrial hygiene principles. This
document provides an overview of other strategies that can be used to control Legionella growth
when addressing a public health threat such as a Legionella outbreak. It does not apply to
households but rather to commercial and institutional facilities.
This document is not a regulation; it is not legally enforceable; and it does not confer legal rights
or impose legal obligations on any party, including EPA, states or the regulated community.
While EPA has made every effort to ensure the accuracy of any references to statutory or
regulatory requirements, the obligations of the interested stakeholders are determined by statutes,
regulations or other legally binding requirements, not by this document. In the event of a conflict
between the information in this document and any statute or regulation, this document would not
be controlling.
Although this document describes technologies for controlling Legionella growth in premise
plumbing systems, the information presented may not be appropriate for all situations and
alternative approaches may be applicable.
Mention of trade names or commercial products does not constitute an EPA endorsement or
recommendation for use.

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Table of Contents
Table of Contents	i
Table of Exhibits	iv
Abbreviations and Acronyms	v
Acknowledgements	vii
Preface	ix
Executive Summary	1
1	Background	5
1.1	Purpose and Scope	5
1.2	Legionella. Overview	5
1.2.1	General Information	5
1.2.2	Epidemiology and Pathogenesis	6
1.2.3	Ecology and Physiology	8
1.3	Legionella Occurrence and Risk from the Distribution Systems and Premise Plumbing
Systems	 10
1.4	Regulatory Context	13
2	Risk Management Approaches and Technologies to Control Legionella	15
2.1	Overview of Current State of Knowledge	15
2.2	Risk Management Approaches	17
2.2.1	Background	17
2.2.2	Applications of Risk Management Approaches	18
2.2.2.1 Temperature Approach for Legionella Control	20
2.2.3	Environmental Testing	22
2.3	Technologies	25
2.3.1	Chlorine	25
2.3.1.1	Background	25
2.3.1.2	Characterization of Effectiveness against Legionella	26
2.3.1.3	Potential Water Quality Issues	32
2.3.1.4	Operational Conditions	33
2.3.2	Monochloramine	34
2.3.2.1	Background	34
2.3.2.2	Characterization of Effectiveness against Legionella	35
2.3.2.3	Potential Water Quality Issues	41
2.3.2.4	Operational Conditions	43
2.3.3	Chlorine Dioxide	45
2.3.3.1	Background	45
2.3.3.2	Characterization of Effectiveness against Legionella	45
2.3.3.3	Potential Water Quality Issues	48
2.3.3.4	Operational Conditions	49
2.3.4	Copper-Silver Ionization	51
2.3.4.1	Background	51
2.3.4.2	Characterization of Effectiveness against Legionella	52
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2.3.4.3	Potential Water Quality Issues	55
2.3.4.4	Operational Conditions	56
2.3.5	Ultraviolet Light Disinfection	58
2.3.5.1	Background	58
2.3.5.2	Characterization of Effectiveness against Legionella	59
2.3.5.3	Potential Water Quality Issues	60
2.3.5.4	Operational Conditions	61
2.3.6	Ozone	62
2.3.6.1	Background	62
2.3.6.2	Characterization of Effectiveness against Legionella	63
2.3.6.3	Potential Water Quality Issues	64
2.3.6.4	Operational Conditions	65
3	Other Strategies Used to Control for Legionella	67
3.1	Emergency Remediation	67
3.1.1	Superheat-and-Flush Disinfection	67
3.1.1.1	Background	67
3.1.1.2	Characterization of Effectiveness against Legionella	67
3.1.1.3	Potential Water Quality Issues	70
3.1.1.4	Operational Conditions	70
3.1.2	Shock Hyperchlorination	71
3.1.2.1	Background	71
3.1.2.2	Characterization of Effectiveness against Legionella	72
3.1.2.3	Potential Water Quality Issues	73
3.1.2.4	Operational Conditions	73
3.2	Point-of-Use Filtration	74
3.2.1	Background	74
3.2.2	Characterization of Effectiveness against Legionella	76
3.2.3	Potential Water Quality Issues	77
3.2.4	Operational Conditions	78
4	Questions and Answers on Legionella Control in Premise Plumbing Systems	79
4.1	Public Health Concerns	79
4.2	Potential Regulatory Requirements	79
4.3	Control Measures	81
4.4	New Technology Approval	83
4.5	Permitting	83
4.6	Sampling and Monitoring	84
4.7	Operator Certification	85
4.8	Unintended Consequences	85
4.9	Additional Sources of Information	85
5	References	87
Appendices	117
A. 1 Types of Studies by Technology	 117
A.2 Elements of Hazard Analysis and Critical Control Points	 122
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A. 3 Elements of a Water Management Program	 123
A.4 Water Safety Plan Modules	124
A. 5 Elements of the American Industrial Hygiene Association Assessment Approach	125
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Table of Exhibits
Exhibit 1-1: Legionella transmission	7
Exhibit 2-1: UV doses (mJ/cm2) for inactivation of L. pneumophila	60
Exhibit 3-1: Membrane filtration guide for removal of microbial contaminants	75
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Abbreviations and Acronyms
AIHA
American Industrial Hygiene Association
ASTM
American Society for Testing and Materials
ANSI
American National Standards Institute
AOC
Assimilable organic carbon
ASHRAE
American Society of Heating, Refrigerating and Air-Conditioning Engineers
ATP
Adenosine triphosphate
AWWA
American Water Works Association
C
Celsius
CDC
Centers for Disease Control and Prevention
CFR
Code of Federal Regulations
CFU
Colony-forming units
CSI
Copper/silver ionization
CT
Disinfectant residual concentration "C" multiplied by the contact time "T"

(Cxi)
DBP
Disinfection byproduct
D/DBPR
Disinfectants and Disinfection Byproducts Rule
DPD
N,N-di ethyl -p-phenyl enedi amine
DNA
Deoxyribonucleic acid
DS
Distribution system
ECDC
European Centre for Disease Prevention and Control
ELITE
Environmental Legionella Isolation Techniques Evaluation
EP
Entry point to the distribution system
EPA
United States Environmental Protection Agency
EPDM
Ethylene-propylene diene-monomer
F
Fahrenheit
FIFRA
Federal Insecticide, Fungicide and Rodenticide Act
GWR
Ground Water Rule
HAA
Haloacetic acid
HACCP
Hazard analysis and critical control points
HDPE
High density polyethylene
HPC
Heterotrophic plate count
HOC1
Hypochlorous acid
HSE
Health and Safety Executive of the United Kingdom
ICP/MS
Inductively coupled plasma/mass spectrometry
ICU
Intensive care unit
km
Kilometers
LP
Low pressure
MCL
Maximum contaminant level
MF
Microfiltration
mg/L
Milligrams per liter
mJ/cm2
Millijoule per square centimeter
mM
Millimolar
MP
Medium pressure
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MRDL
Maximum residual disinfectant level
NDMA
jV-nitrosodimethyl amine
NF
Nanofiltration
NSF
NSF International
ocr
Hypochlorite ion
OSHA
Occupational Safety and Health Administration
PCR
Polymerase chain reaction
POE
Point-of-entry
POU
Point-of-use
PWS
Public water system
qPCR
Quantitative polymerase chain reaction
RO
Reverse osmosis
rRNA
Ribosomal ribonucleic acid
SDWA
Safe Drinking Water Act
SMCL
Secondary maximum contaminant level
spp.
Plural of species
SWTR
Surface Water Treatment Rule
THM
Trihalomethane
TTHM
Total trihalomethanes

Micron (millionth of a weight, distance and/or volume unit)
^g/L
Micrograms per liter
|im
Micrometer
UF
Ultrafiltration
U.S.
United States
UV
Ultraviolet
UVT
UV transmittance
VBNC
Viable but non-culturable
VHA
Veterans Health Administration
WHO
World Health Organization
WMP
Water management program
WSG
Water supply guidance
WSP
Water safety plan
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Acknowledgements
EPA's Office of Ground Water and Drinking Water would like to thank the Association of State
Drinking Water Administrators; the States of Maryland, Minnesota, Nevada, New York, Ohio, and
Pennsylvania; and the U.S. Centers for Disease Control and Prevention for their contributions to this
document. EPA thanks these participants for their input, which was critical for the development of
this document.
The following individuals helped to develop and/or review this document:
Darrell Osterhoudt (Association of
State Drinking Water
Administrators)
Laurel Garrison (CDC)
Natalia A. Kozak-Muiznieks (CDC)
Claressa Lucas (CDC)
Philip Berger (U.S. EPA)
Cesar Cordero (U.S. EPA)1
Leslie Darman (U.S. EPA)
Michael Elovitz (U.S. EPA)
Michael Finn (U.S. EPA)1
John Hebert (U.S. EPA)
Darren Lytle (U.S. EPA)1
Thomas Grubbs (U.S. EPA)1
Hannah Holsinger (U.S. EPA)1
Jingrang Lu (U.S. EPA)
Emily Mitchell (U.S. EPA)
Pritidhara Mohanty (U.S. EPA)1
Mark Perry (U.S. EPA)
Stacy Pfaller (U.S. EPA)1
Jonathan Pressman (U.S. EPA)
Stig Regli(U.S. EPA)
Mark Rodgers (U.S. EPA)1
Crystal Rodgers-Jenkins (U.S. EPA)1
Kenneth Rotert (U.S. EPA)
Nicole Shao (U.S. EPA)
Alysa Suero (U.S. EPA)
Lili Wang (U.S. EPA)1
Saeid Kasraei (Maryland Department
of the Environment)
Jerry Smith (Minnesota Department
of Health)
Jennifer Carr (Nevada Division of
Environmental Protection)1
Ross Cooper (Nevada Division of
Environmental Protection)1
Neculai Codru (New York State
Department of Health)
David Dziewulski (New York State
Department of Health)1
Lloyd Wilson (New York State
Department of Health)
Lisa Daniels (Pennsylvania
Department of Environmental
Protection)
Elizabeth Messer (Ohio EPA)
Samuel Perry (Washington State
Department of Health)1
1 Lead author
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Preface
This document summarizes peer-reviewed scientific literature, reports from nationally and/or
internationally recognized research organizations, and guidelines and standards from nationally
and/or internationally recognized organizations. The reviewed literature characterizes the
effectiveness of different technologies that may be used to control Legionella growth in premise
plumbing systems of large buildings (e.g., hospitals, hotels, schools). The U.S. Environmental
Protection Agency (EPA) developed this document because the agency recognizes that many
species of the genus Legionella are a public health threat. While EPA is not promoting or
endorsing the use of any of the treatment technologies described in this document as a preferred
means of Legionella control, EPA recognizes that many facility managers are choosing to install
treatment systems to prevent or mitigate Legionella growth in premise plumbing systems. The
target audience for this document includes, but is not limited to, primacy agencies, facility
operators, facility owners and technology developers and vendors. EPA expects this document
will improve public health protection by helping the target audience make better informed
science-based, risk management decisions to control Legionella growth in buildings.
The scientific information presented in this document comes from published literature related to
six technologies used for Legionella control (chlorine, monochloramine, chlorine dioxide,
copper-silver ionization (CSI), ultraviolet (UV) disinfection and ozone). The document provides
information about water quality issues that could result when using the various technologies and
summarizes operational conditions for each technology. It also discusses risk management
approaches for addressing microbial, physical and chemical risks in various parts of the premise
plumbing system, such as water management programs (WMPs), hazard analysis and critical
control point (HACCP), water safety plans (WSPs) and industrial hygiene principles. This
document provides an overview of other strategies that can be used to control Legionella growth
when addressing a public health threat such as a Legionella outbreak.
EPA developed this document in collaboration with state drinking water program
representatives. Legionella experts at the U.S. Centers for Disease Control and Prevention
(CDC) reviewed and provided feedback on portions of the document. State drinking water
program representatives and CDC helped to compile the peer-reviewed scientific literature,
reports from nationally and/or internationally recognized research organizations, and guidelines
and standards from nationally and/or internationally recognized organizations. The scientific
information in this document spans from circa 1970 to 2016. Information published in trade
journals or popular magazines is not included in this document.
There is not a single one-size-fits-all approach to addressing Legionella concerns in premise
plumbing systems. A determination of which strategy is best suited for a particular premise
plumbing system is case-specific due in part to the complex and diverse nature of premise
plumbing systems.
EPA does not recommend the addition of treatment nor the installation of any of the technologies
discussed herein, but rather provides technical information regarding the effectiveness of
technologies and other approaches for controlling Legionella and other microbial contaminants.
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In some buildings, risks associated with premise plumbing systems (including Legionella) may
be addressed without additional treatment.
Stakeholders (e.g., primacy agencies, technology developers and vendors) who are interested in
information about the approval process for a new or alternative drinking water treatment
technology are advised to consult EPA's Water Supply Guidance (WSG) 90, the State
Alternative Technology Approval Protocol (USEPA, 1996). The goal of WSG 90 is to provide a
streamlined and consistent protocol to facilitate state approval of new drinking water treatment
technologies. WSG 90 is not meant to replace current state plan review and approval processes.
Stakeholders (e.g., primacy agencies, technology developers and vendors) should be aware that
pesticide products or devices for drinking water treatment must be in compliance with the
Federal Insecticide, Fungicide and Rodenticide Act (F1FRA). EPA's Pesticide Registration
Manual (USEPA, no date) provides guidance for applicants seeking to register pesticide products
for sale or distribution in the United States and for those interested in selling or distributing
pesticides or pesticide devices.
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Executive Summary
The U. S. Environmental Protection Agency (EPA) developed this document because it
recognizes that many species of the genus Legionella are a public health threat. EPA recognizes
that many facility managers are choosing to install treatment systems to prevent or mitigate
Legionella growth in their premise plumbing systems. The target audience for this document
includes, but is not limited to, primacy agencies, facility operators, facility owners, technology
developers and vendors.
This document summarizes peer-reviewed scientific literature, reports from nationally and/or
internationally recognized research organizations, and guidelines and standards from nationally
and/or internationally recognized organizations. The reviewed literature characterizes the
effectiveness of different technologies that may be used to control Legionella growth in premise
plumbing systems. Particularly, it focuses on premise plumbing systems of large buildings, such
as hotels, hospitals, schools and other buildings with complex plumbing infrastructure.
EPA expects this document will improve public health protection by helping the target audience
make better informed science-based risk management decisions to control Legionella growth in
buildings.
BACKGROUND
Legionella is a bacterium that can be found throughout the world, mostly in aquatic and moist
environments (e.g., lakes, rivers, groundwater and soil). The infection caused by Legionella is
known as legionellosis and occurs primarily in two forms:
1.	Legionnaires' disease, which is a type of pneumonia (Fraser et al., 1977).
2.	Pontiac fever, which is a milder flu-like illness without pneumonia (Kaufmann et al.,
1981; Glick et al., 1978).
The disease can be acquired by inhaling or aspirating aerosolized water or soil (potting soil,
compost soil) contaminated with Legionella (Travis et al., 2012). No infection associated with
animal-to-person contact, consumption of contaminated food or ingestion of contaminated water
has been reported. Only one probable case of person-to-person transmission has been reported; it
occurred in Portugal (Correia et al., 2016).
While anyone can develop Legionnaires' disease, some common risk factors for developing an
infection include age (>50 years), gender (male), smoking habits, existing lung conditions (e.g.,
asthma, chronic obstructive pulmonary disease), previous use of beta-lactam antibiotics,
immunosuppressed or immunocompromised status (e.g., persons receiving transplants or
chemotherapy; those with kidney disease, diabetes or AIDS) and recent surgery or intubation
(Health Canada, 2013; Viasus et al., 2013; Newton et al., 2010; WHO, 2007; Stout and Yu,
1997). The percentage of fatalities from reported cases of Legionnaires' disease increased with
age (> 50 years) and showed a similar pattern for males and females (ECDC, 2016).
Hospitalization costs due to legionellosis in the United States are estimated at $433 million per
year (Collier et al., 2012). Fatality rates are estimated to be 5-30 percent (Kutty, 2015). The
costs associated with loss of productivity and death are not included in these estimates and are
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likely to be significant. Between 3,000 and 4,000 cases of legionellosis are reported to the U.S.
Centers for Disease Control and Prevention (CDC) each year; however, the actual number of
hospitalized cases is estimated to be between 8,000 and 18,000 (Kutty, 2015; CDC, 2012;
Marston et al., 1997), since many cases of pneumonia are empirically treated with antibiotics and
never tested fox Legionella (CDC, 2011; Marston et al., 1997).
Legionella has been found in public water systems. Environmental conditions and processing of
the water once it enters a building can lead to the growth of Legionella, which could result in
increased risks of infection. The CDC has identified environmental conditions within premise
plumbing as the leading cause of the Legionella outbreaks reported between 2009 and 2012
(CDC, 2015; CDC, 2013).
SCOPE OF rill DOCUMENT
The purpose of this document is to summarize the current body of knowledge on the
effectiveness of different approaches to control Legionella growth in large buildings.
As a result of Legionella outbreaks and the potential for Legionella to grow in premise plumbing
of buildings, many facility owners or operators have decided to take measures to control or
mitigate Legionella growth. This document summarizes information on several Legionella
control technologies, including:
•	Risk management approaches (including temperature control)
•	Chlorine
•	Monochloramine
•	Chlorine dioxide
•	Copper-silver ionization
•	Ultraviolet light
•	Ozone
This document provides information on other control technologies that are often used for
emergency remediation: superheat-and-flush, shock hyperchlorination and point-of-use filtration.
This document provides a summary of the literature for each technology. The summary includes
information about the effectiveness of the technology against Legionella, potential water quality
impacts that may result from using the technology and operational considerations.
This document describes different types of studies, which include: laboratory, field, premise
plumbing and distribution system-based studies. The results from the different types of studies
may not be directly comparable to one another given the differences in experimental conditions.
Appendix A. 1 includes a table that identifies the types of studies conducted for each of the
technologies presented in Section 2.3 and Section 3 of this document.
Discussions of Legionella control issues related to cooling towers and other systems within the
building that do not deliver water for human consumption are not within the scope of this
document. The EPA defines "human consumption" as "drinking, bathing, showering, hand
washing, teeth brushing, food preparation, dishwashing and maintaining oral hygiene" (40 CFR
141.801 and 63 FR41940. Aug. 5. 1998).
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APPROACH
EPA developed this document in collaboration with state drinking water program
representatives. Legionella experts at CDC reviewed and provided feedback on portions of this
document. State drinking water program representatives and CDC helped to compile the
literature referenced in the document, which spans from circa 1970 to 2016. EPA's main
criterion for including studies in the "Characterization of Effectiveness against Legionella"
subsections of Sections 2.3 and 3 was publication in a peer-reviewed document. A draft of this
document was released for public review and comment in October 2015. In November 2015,
EPA held a public meeting and webinar to seek public input on the draft document. EPA revised
the document based on input received during the public comment period. The document was also
revised based on input from an independent expert peer review.
SUMMARY OF FINDINGS/CONCLUSIONS
•	There is no one-size-fits-all approach to addressing Legionella concerns in premise
plumbing systems.
•	In some buildings, risks associated with premise plumbing (including Legionella) in large
buildings may be addressed without additional treatment by implementing appropriate
risk management approaches (CDC, 2016).
•	Facility owners or operators who are considering adding treatment to their building's
premise plumbing system may wish to consult with their primacy agency for any specific
requirements that may apply before they add any treatment.
•	Facility owners or operators may also wish to consult with their water supplier (i.e.,
public water system (PWS)) to better understand any potential water quality issues before
making treatment-related decisions.
•	Avoiding dead ends and stagnation and optimizing thermal control of hot and cold water
loops in the design of a premise plumbing system could help to mitigate growth of
Legionella.
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1 Background
1.1	Purpose and Scope
The purpose of this document is to characterize the current body of knowledge regarding the
effectiveness of available technologies for the control of Legionella growth in premise plumbing
systems.1 The National Research Council (NRC) defines "premise plumbing" as that portion of
the distribution system from the water meter to the consumer's tap in homes, schools and other
buildings (NRC, 2005). This document focuses on premise plumbing systems of large buildings,
such as hotels, schools, hospitals and other similar buildings with more complex plumbing
infrastructure. Premise plumbing is used to deliver water intended for human consumption. The
U.S. Environmental Protection Agency (EPA) defines water "intended for human consumption"
as water used for drinking, bathing, showering, hand washing, teeth brushing, food preparation,
dishwashing and maintaining oral hygiene (40 CFR 141.801 and 63 FR 41940. Aug. 5. 1998).
Discussions of Legionella control issues related to cooling towers are not within the scope of this
document. EPA developed this document in collaboration with state drinking water program
representatives. Legionella experts at the U.S. Centers for Disease Control and Prevention
(CDC) reviewed and provided feedback on portions of the document. State drinking water
representatives and CDC helped to compile the literature that is summarized and referenced in
this document.
The EPA expects this document will improve public health protection by helping the primacy
agencies,2 facility operators, facility owners, technology developers and vendors make science-
based risk management decisions to control Legionella growth in buildings. It is not EPA's goal
to make recommendations for or against the use of any of the technologies discussed in this
document.
1.2	Legionella: Overview
1.2.1 General Information
The genus Legionella currently includes more than 50 bacterial species (abbreviated as "spp")
and approximately 70 distinct serogroups, many of which are considered pathogenic (DSMZ,
2014; LPSN, 2014; Pearce et al., 2012; WHO, 2007; Fields et al., 2002). Legionella spp. are
gram-negative, rod-shaped bacteria. Legionella pneumophila (L. pneumophila) was the first
species to be described following an outbreak of pneumonia in 1976 among members of the
American Legion, who were attending a convention in Philadelphia, Pennsylvania (Fields et al.,
2002; McDade et al., 1979). Approximately half of the Legionella species described to date have
been associated with clinical cases of legionellosis (disease caused by Legionella), but it is likely
that most legionellae can cause human disease under the appropriate conditions (Borella et al.,
2005a; Fields, 1996; Fang et al., 1989). There are several EPA regulations that provide some
degree of protection against Legionella (see Section 1.4 for additional information).
1	For the purposes of this document, the term "Legionella" refers to the genus Legionella (any species). The plural
form legionellae and Legionella spp. are also used to denote the genus Legionella.
2	Primacy - States and Indian Tribes are given primary enforcement responsibility (e.g., primacy) for public water
systems in their jurisdictions if they meet certain requirements.
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Legionellosis is acquired by inhaling or aspirating aerosolized water or soil (potting soil,
compost soil) contaminated with Legionella (Travis et al., 2012), as opposed to ingestion of
contaminated water. Though animals can be infected by legionellae and develop disease, they
have not been identified as carriers of legionellae, nor has transmission from animals to humans
been documented (Cunha, 2006; USEPA, 1999a). Only one probable case of person-to-person
transmission has been reported; it occurred in Portugal (Correia et al., 2016).
1.2.2 Epidemiology and Pathogenesis
Legionellosis includes Legionnaires' disease, characterized by pneumonia (Fraser et al., 1977),
and Pontiac fever, a milder flu-like illness without pneumonia (Kaufmann et al., 1981; Glick et
al., 1978). Hospitalization is common among Legionnaires' disease patients; inpatient costs in
the United States are estimated at $433 million per year (Collier et al., 2012), with a case fatality
rate of 5-30 percent (Kutty, 2015). The economic costs associated with loss of productivity and
death are not included in these estimates and are likely to be significant.
Legionellosis is a nationally notifiable disease, which means that state health departments report
any case that is confirmed by a laboratory to CDC (CDC, 2005). However, many cases of
pneumonia that could be Legionnaires' disease are empirically treated with antibiotics and never
tested for Legionella, so the incidence could be much higher than reported (CDC, 2011; Marston
et al., 1997). Between 3,000 and 4,000 cases of legionellosis are reported to CDC each year
(Kutty, 2015; CDC, 2012); however, the actual number of hospitalized cases in the United States
is estimated to be between 8,000 and 18,000 annually, based on actual cases in two Ohio
counties in 1991 (Marston et al., 1997). The wide range in the estimated number of cases is due
to inaccuracies in diagnostic testing (Marston et al., 1997).
In the United States, waterborne disease outbreaks associated with Legionella have been tracked
through the Waterborne Disease and Outbreak Surveillance System since 2001 (Craun et al.,
2010). Between 2009 and 2012, CDC reported that Legionella accounted for 40 of the 65
drinking water-related waterborne disease outbreaks in the United States, causing 72 illnesses
and 8 deaths. CDC identified environmental conditions within premise plumbing systems as the
deficiency that caused 32 of the 40 Legionella outbreaks (CDC, 2015; CDC, 2013).
Strains of L. pneumophila belonging to serogroup 1 are responsible for most cases of
Legionnaires' disease in the United States and Europe (Borella et al., 2005a; Yu et al., 2002;
Fields et al., 2002; Marston et al., 1994). L. pneumophila serogroup 6 may be the second most
common serogroup, based on the frequency with which it is isolated from clinical samples
(Marston et al., 1994).
Although L. pneumophila causes most cases of Legionnaires' disease, other species can also
cause the disease, particularly in hospital-acquired cases. Of the reported non-A. pneumophila
infections, the most common causes of infection are L. micdadei, L. bozemanii, L. dumoffii and
L. longbeachae (Fang et al., 1989; Reingold et al., 1984).
While anyone can develop Legionnaires' disease, factors associated with an increased risk of
developing infection include age (>50 years), gender (male), smoking habits, existing lung
conditions (e.g., asthma, chronic obstructive pulmonary disease), previous use of beta-lactam
antibiotics, immunosuppressed or immunocompromised status (e.g., persons receiving
transplants or chemotherapy, those with kidney disease, diabetes or AIDS) and recent surgery or
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intubation (Health Canada, 2013; Viasus et al., 2013; Newton et al., 2010; WHO, 2007; Stout
and Yu, 1997).
Exhibit 1-1 shows different factors and events that could affect the transmission of Legionella in
environmental and clinical settings. Legionella outbreaks can occur when legionellae multiply
under particular conditions in water systems and the water is then aerosolized and subsequently
inhaled or aspirated by susceptible persons (Donohue et al., 2014; Fields et al., 2002; Blatt et al.,
1993; Stout et al., 1985; Fliermans et al., 1981). For these reasons, the presence of Legionella is
a particular concern in large buildings that house susceptible populations, such as facilities in the
healthcare and hospitality industries (Health Canada, 2013; Williams et al., 2013; Buse and
Ashbolt, 2012; CDC, 2008; Rusin et al., 1997; Colbourne and Dennis, 1989).
Exhibit 1-1: Legionella transmission
KnviniiiriH'.nfal
Clinical
Factors
Temp,, pH,
Nutrients
Microbial Associations
Microbial Associations
Nutrients
ฃw#ifs
1
Survival in
{Nature}
I
Events
Diagnosis of
3'S
Amplication
Risk
Minimization
(Prevention)
I
Factors
Symptoms
Lab Tests
Surveillance
Virulence
System Cleanliness
Temp., Humidlly,
Droplet Production
Multiply in
Susceptible Host
(Aerosotization)
Age
Disease
Immunodeficiency
Transmission
Humidity
Droplet Size
Distance
Source: ASHRAE, 2000
Premise plumbing systems can be colonized with Legionella and transmit the bacteria through
aerosols generated from showers, humidifiers and spas associated with hot water distribution
systems, as well as from respiratory therapy devices, ultrasonic mist machines, decorative
fountains and industrial-use water (Haupt et al., 2012; WHO, 201 la; Carducci et al., 2010; HSE,
2009; Edelstein, 2007; Benin et al., 2002; Stout and Yu, 1997; CDC, 1997; Blatt et al., 1993;
Addiss et al., 1989; Muder et al., 1986; Bollin et al., 1985; Dondero et al., 1979; Glick et al.,
1978). Aspiration of contaminated aerosols has also been associated with contaminated water
and ice (WHO, 2011).
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Waterborne disease outbreaks have demonstrated that Legionella infections are not limited to
premise plumbing systems. Cases have also been linked to ice machines and birthing pools
(Public Health England, 2014; Nagai et al., 2003; Franzin et al., 2001; Graman et al., 1997). In
addition, several infections have been linked to exposures to potting soil (Whiley and Bentham,
2011; CDC, 2000). Water used in horticultural irrigation is a potential occupational risk (Stojek
and Dutkiewicz, 2002). A study by Wallensten et al. (2010) suggests water used instead of
windshield washer fluid as another potential route of transmission.
1.2.3 Ecology and Physiology
Fresh water is the major natural reservoir for legionellae. The bacteria are found worldwide in
many different natural aquatic environments (e.g., lakes, rivers and groundwater); however,
exposure to these sources typically does not result in legionellosis. Legionella spp. have also
been found to occur in natural soil, potting soil and compost samples (van Heijnsbergen et al.,
2014; Travis et al., 2012; CDC, 2000).
Legionellae exhibit several properties that allow them to persist in environmental conditions such
as low and high temperatures, presence of disinfectants, low pH, low nutrients and high salinity
(Health Canada, 2013; Borella et al., 2005a; Kuchta et al., 1983; Fliermans et al., 1981). Ideal
growth conditions are in warm water between 35 and 46 degrees Celsius (C) (95-115 degrees
Fahrenheit (F)) (Buse and Ashbolt, 2011; Katz and Hammel, 1987; Wadowsky et al., 1985; Yee
and Wadowsky, 1982; Dondero et al., 1979; Glick et al., 1978). High relative humidity increases
the viability of Legionella spp. in contaminated aerosols (Heng et al., 1995). Legionella spp. are
considered thermotolerant bacteria, able to withstand temperatures of 50 degrees C (122 degrees
F) for several hours (WHO, 2007). This characteristic allows Legionella spp. to occur frequently
in heated water systems (Taylor et al., 2009). Legionella spp. can also survive at temperatures
below 20 degrees C (68 degrees F) and even below freezing (Borella et al., 2005a).
Legionella spp. are often found to be protected from adverse environmental conditions as a result
of their association with biofilms, as well as their symbiotic and parasitic interactions with other
microorganisms. Association with biofilms appears to increase Legionella's resistance to
disinfectants (Falkinham et al., 2015; USEPA, 2002). Declerck (2010) reported that L.
pneumophila are associated with biofilms at the air-water interface (i.e., floating biofilms) in
addition to the solid-water interface, and these associations can allow L. pneumophila to
aerosolize and be transmitted over large distances. The association of L. pneumophila with many
different microorganisms in aqueous environments has been widely demonstrated. Stewart et al.
(2012), for instance, demonstrated that A. pneumophila could persist in biofilms dominated by
other pathogens, such as Klebsiella pneumoniae, Flavobacterium and Pseudomonas fluorescens.
Solimini et al. (2014) noted that the addition of P. aeruginosa to a biofilm eliminated L.
pneumophila in a laboratory co-culture study. They noted that in the absence of P. aeruginosa,
the addition of heterotrophic plate count bacteria allowed L. pneumophila to increase in the
biofilm. Although Legionella spp. are themselves heat-tolerant, thermotolerant amoebae living in
biofilms may provide further protection from heat (Abdel-Nour et al., 2013). However,
temperatures greater than 55 degrees C (131 degrees F) may decrease biofilm formation, as other
species making up the biofilm cannot survive (van der Kooij et al., 2005; Martinelli et al., 2000).
Conditions that allow growth of Legionella in biofilms include long water residence time, the
presence of iron (although too much iron can inhibit biofilm formation); the presence of cations
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such as calcium, magnesium, zinc and manganese, which facilitate attachment; and temperature.
Factors which increase the likelihood of biofilm formation include the presence of nutrients,
scale and corrosion, warm water temperatures and long water residence time as occurs in the
dead ends of distribution systems and in storage tanks (WHO, 2007). The presence of corrosion
and scale increases both the available surface area and the concentration of nutrients and growth
factors, such as iron, in the water system. Bacterial systems for attachment (i.e., production of
proteins and other substances) are affected by temperature (Abdel-Nour et al., 2013). Of eight
Legionella species tested, only L. pneumophila produces Lcl (protein that contributes to biofilm
production), and only L. pneumophila was shown to be capable of auto-aggregation (Abdel-Nour
et al., 2014). These results support the role of auto-aggregation in the formation of L.
pneumophila biofilms. Lcl may also contribute to the attachment of L. pneumophila to amoebae,
facilitating infection of the protozoa.
L. pneumophila also excretes a surfactant that is toxic to other Legionella spp., which may
prevent or reduce the presence of these species when L. pneumophila is present; the surfactant
did not affect non-Legionella species (Abdel-Nour et al., 2013).
Studies have shown the ability of Legionella to parasitize and multiply in several species of
protozoa including amoebae and ciliated protozoa (Springthorpe et al., 2014; Cervero-Arago et
al., 2014; Escoll et al., 2013; Buse et al., 2013; Buse and Ashbolt, 2011; Taylor et al., 2009;
Fields, 1996), as well as establish symbiotic interactions with other bacteria (Taylor et al., 2009;
Rowbotham, 1986; Wadowsky et al., 1985; Bohach and Snyder, 1983; Wadowsky and Yee,
1983; Fliermans et al., 1981). The ability of Legionella to parasitize certain protozoa that are
commonly found to graze on biofilms in distribution systems is considered particularly important
in their ability to survive and grow under adverse environmental conditions (Hoffmann et al.,
2014; Escoll et al., 2013; Richards et al., 2013; WHO, 2007; Molmeret et al., 2004; Storey et al.,
2004a; Storey et al., 2004b; Thomas et al., 2004; Fields et al., 1984). Legionella can parasitize
alveolar macrophages (white blood cells that are part of the immune system) in human lungs the
same way it parasitizes protozoa (Hoffmann et al., 2014).
Protozoan hosts may be necessary for Legionella growth in biofilm in many circumstances.
Murga et al. (2001) noted that /.. pneumophila in a biofilm of P. aeruginosa, K. pneumoniae and
a Flavobacterium species did not divide unless the amoeba Vermamoeba vermiformis was
present. This study was conducted using a continuous flow chamber in which the presence of V.
vermiformis was not required for survival of L. pneumophila but was required for growth. Based
on a literature review, Springthorpe et al. (2014) concluded that V. vermiformis seems to be the
most important amoeba influencing Legionella amplification in the field. Although protozoans
may be necessary for Legionella growth in many cases, Pecastaings et al. (2010) developed a
growth medium that allowed growth of monospecies L. pneumophila biofilm without the
presence of protozoans and without producing free-floating bacterial cells. Andreozzi et al.
(2014) suggested that L. pneumophila in biofilm may be able to switch to a transmissible or
virulent form without the presence of amoebae or other hosts.
Multiple studies suggest that protozoa play a major role in the transmission of L. pneumophila
and subsequently, legionellosis. For example, there is strong evidence that V. vermiformis is
associated with Legionella outbreaks and helps transmit Legionella (Springthorpe et al., 2014).
Studies indicate that infectivity may be substantially increased if amoebae infected by Legionella
are inhaled, as opposed to individual free-living Legionella cells (Richards et al., 2013; Newton
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et al., 2010; Borella et al., 2005a; Cirillo et al., 1999; Brieland et al., 1996). Infected amoebae
may contain hundreds of Legionella cells. When these cells are released from the amoebae they
could allow a large number of bacteria to reach the lungs (Buse and Ashbolt, 2012; Ohno et al.,
2008; Berk et al., 1998; Kwaik et al., 1998; O'Brien and Bhopal, 1993). A study by Berk et al.
(1998) also showed that protozoa can release vesicles (membrane-bound, sack-like structures
within a cell) of respirable size containing live L. pneumophila. The vesicles are resistant to
freeze-thawing and sonication (a procedure that uses sound waves to break cells), and the
bacteria within the vesicles are highly resistant to biocides. Several studies have also shown that
amoebae can serve as reservoirs for many bacteria, including Legionella, and these amoebae are
resistant to disinfection. This suggests that decreasing the health risk associated with amoebae-
resisting bacteria may require physical removal of the amoeba by filtration (Loret and Greub,
2010; Loret et al., 2008). An understanding of the microbial diversity of biofilms and the
variables that affect the growth of biofilms is important to managing water-based pathogenic
diseases. Proper engineering controls, water treatment and more effective monitoring approaches
are needed to help manage risk of exposure to Legionella (Ashbolt, 2015).
Another survival mechanism of Legionella spp. is their ability to enter a viable but non-
culturable (VBNC) state. The VBNC state is part of the normal life-cycle of legionellae as they
grow within host cells (Robertson, et al., 2014). Bacteria in a VBNC state fail to grow on culture
media, where they would normally grow, yet are still alive and could cause disease (Buse et al.,
2013; Oliver, 2010). Numerous chemical and environmental factors have been reported to induce
a VBNC state, including nutrient starvation, temperature, high salt concentrations, low oxygen
concentration, heavy metals, pipe material and chemical treatment (including water disinfection)
(Ducret et al., 2014; Aileron et al., 2013; Buse et al., 2013; Oliver, 2010; Kana et al., 2008;
Colbourne and Dennis, 1989). Studies suggest that bacteria in the VBNC state can maintain their
infectivity, multiply in their hosts and recover their ability to grow on solid media (Ducret et al.,
2014; Aileron et al., 2013; Oliver, 2010; Steinert et al., 1997).
1.3 Legionella Occurrence and Risk from the Distribution Systems and Premise
Plumbing Systems
Premise plumbing systems have been identified as a source of Legionella infection (Stout et al.,
1992; Muder et al., 1986). Within healthcare facilities such as hospitals and nursing homes the
potable water supply is the most common source of exposure (Lin et al., 201 la). Exposure to
legionellae has also been associated with other types of premise plumbing systems (e.g., hotels
and other buildings with complex water distribution systems) (Silk et al., 2012; Hung et al.,
1993; Tobin et al., 1981a and 1981b). The European Centre for Disease Prevention and Control
(ECDC) reports that 58 percent of sampling sites that tested positive for Legionella in 2014 were
from cooling towers and 26 percent were from water systems, including 66 hot water systems, 31
cold water systems and 184 non-specified water systems (ECDC, 2016).
Legionella spp. are known to be present in finished water from water treatment plants (Lu et al.,
2016; Buse et al., 2012) and can persist and grow in the biofilms of municipal water distribution
systems (Lu et al., 2016; Wingender and Flemming, 2011; States et al., 1987). Lu et al. (2015)
identified diverse Legionella spp. including L. pneumophila, L. pneumophila sgl and L. anisa, in
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sediment samples from municipal drinking water storage tanks in 18 locations across 10 states.
In the Lu et al. (2015) study, quantitative polymerase chain reaction (qPCR)3 was used instead
of a culture-based approach, and Legionella spp. were detected with a frequency of
approximately 67 percent. A co-occurrence of Acanthamoebae and Legionella was observed.
Quantitative PCR-based monitoring complements culture-based methods in the presence of
disinfectants that affect cell culturability (Bedard et al., 2016).
Schwake et al. (2016) conducted two surveys of tap water, one in small buildings (e.g., single-
story homes and businesses) and the other in two hospitals in Flint, Michigan. They found L.
pneumophila in the two hospitals but not in the small buildings. Schwake et al. (2016) looked at
linkages between a Legionella outbreak and changes in municipal water quality and operational
changes in the distribution system. The study mentions that water utilities may have a role to
play in controlling proliferation of pathogens in premise plumbing.
Further, L. pneumophila can form biofilm from secreted substances (i.e., extracellular polymeric
substances) and can multiply within such biofilms (Mampel et al., 2006). Therefore, biofilms in
municipal drinking water systems can be a potential source of water contamination (Wingender
and Flemming, 2011) and drinking water from municipal systems can possibly contaminate the
premise plumbing systems in hospitals and other buildings with L. pneumophila (Donohue et al.,
2014; States et al., 1987). Section 1.2.3 discusses optimal conditions that may lead to Legionella
growth in premise plumbing systems.
Several surveys have found Legionella in premise plumbing systems, including in buildings that
had not been linked to recognized outbreaks:
•	Bartley et al. (2016) traced the epidemiology of two nosocomial (hospital-acquired) cases
of Legionnaires' disease at a hospital in Australia. Whole genome sequence analysis was
performed on L. pneumophila isolates from the patients infected in 2013. The genome
sequences were found to be closely related to those of isolates from the hospital water
distribution system and to retrospective isolates from a patient infected in 2011.
•	Bedard et al. (2016) found L. pneumophila in the hot water system of a hospital from 85
percent of sampled taps despite copper treatment. A significant decrease in L.
pneumophila count by culture was observed following heat shock disinfection. Ongoing
corrective measures were implemented, which included increasing the hot water
temperature from 55 to 60 degrees C, flushing taps weekly with hot water, removing
excess lengths of pipe and maintaining a temperature of 55 degrees C throughout the
system. A low level of contamination remained in areas with hydraulic deficiencies.
•	Rhoads et al. (2016a) studied L. pneumophila trends in controlled, replicated pilot-scale
hot water systems with continuous recirculating lines. They demonstrated the potential
3 A quantitative polymerase chain reaction assay detects a specific gene target known to be associated with a
specific genus/species/serogroup. qPCR cannot distinguish between viable and nonviable cells (Donohue et al.,
2014).
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for thermal control strategies to be undermined by distal taps and corrective mixing.
Rhoads et al. (2016b) surveyed a cross-section of green buildings and compared them to
conventional buildings. They found increased water age and decreased chlorine and
chloramine residuals in the green buildings, as well as increased levels of total bacteria
16S rRNA genes and increased levels of gene markers for Legionella. The authors
concluded that the elevated water age inherent to achieving the sustainability goals of
plumbing systems in green buildings raised concerns with respect to the chemicals and
microbiological stability of the water quality.
•	Donohue et al. (2014) used two qPCR assays to evaluate incidence of L. pneumophila
serogroup 1 in 272 water samples collected in 2009 and 2010 from 68 public and private
cold drinking water taps across the United States. L. pneumophila serogroup 1 was
detected in 47 percent of the taps.
•	Stout et al. (2007) isolated L. pneumophila and L. anisa from 14 hospital water systems.
They observed high-level colonization of the premise plumbing system (defined as 30
percent or more of the distal outlets being positive for L. pneumophila) for 6 of the 14
hospitals with positive findings.
•	Borella et al. (2005b) studied Legionella in hot water samples of 40 hotels in five Italian
cities. They detected Legionella in 30 hotels and 60.5 percent of samples. L. pneumophila
was found in 87 percent of positive samples, and L. pneumophila serogroup 1 was in 45.8
percent of positive samples. Of the samples positive for L. pneumophila serogroup 1,
75.8 percent had concentrations of 1,000 CFU/L (colony-forming units per liter) or more.
The authors found that L. pneumophila serogroup 1 presence correlated with soft water
and higher chlorine levels (>0.1 milligrams per liter (mg/L)). They also noted that P.
aeruginosa was less likely to occur at these chlorine levels and more likely to occur in
hard water.
•	Patterson et al. (1997) sampled hot and cold water outlets in 69 organ transplant units in
the United Kingdom for Legionella and protozoa. They found Legionella in 55 percent of
units and L. pneumophila in 45 percent. Other Legionella (the blue-white fluorescent
group, which includes L. gormanii, L. bozemanii and others) were detected in 26 percent
of organ transplant units. Protozoa of genera known to support growth of Legionella were
found in 58 percent of units. The authors found a significant association between
detection of Legionella and the presence of these protozoan genera in the cold water
outlets sampled.
•	Wadowsky et al. (1985), using tap water from their laboratory, found that naturally
occurring L. pneumophila multiplied at a temperature between 25 and 37 degrees C (77
and 99 degrees F), at pH levels of 5.5 to 9.2, and at concentrations of dissolved oxygen of
6.0 to 6.7 mg/L. They also noted that Legionella growth did not occur in tap water when
the dissolved oxygen level was less than 2.2 mg/L. They also observed an association
between the multiplication of L. pneumophila and non-legionellaceae bacteria, which
were also present in the water culture.
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•	Wadowsky et al. (1982) sampled showerheads, shower pipes and water and sediment
collected from the bottom of hot water tanks in 11 buildings, including five homes and
three hospitals. L. pneumophila serogroups 1, 5 and 6 were isolated from the drinking
water fixtures in seven buildings including one of the five homes. Legionella spp. were
also present in water and sediment in hot water tanks maintained at temperatures from 39
to 54 degrees C (102.2 to 129.2 degrees F), but not found in tanks maintained between 71
and 77 degrees C (between 159.8 and 170.6 degrees F). The authors hypothesized that hot
water tanks are the major source and seed of L. pneumophila in premise plumbing
systems.
•	Tobin et al. (1981b) conducted a premise plumbing system survey of 31 buildings
including hospitals and hotels, 6 of which were associated with sporadic cases or
outbreaks of Legionnaires' disease. For the 6 buildings (hospitals and hotels) associated
with cases of Legionnaires' disease, the study found L. pneumophila in all of the premise
plumbing systems and in the cooling water for each of the 3 buildings with cooling
towers. For buildings that had not previously experienced an outbreak, the study found L.
pneumophila in 4 out of 24 taps or showers, 3 out of 9 cooling towers, and 1 out of 15
storage tanks.
The growth of Legionella within a premise plumbing system may be a function of the system's
pipe or other plumbing materials, water temperature, water quality and other system-specific
factors. Tai et al. (2012) found that copper inhibited biofilm growth at temperatures typically
found in hot water systems (20, 37 and 44 degrees C or 68, 99 and 111 degrees F), whereas
stainless steel and polyethylene promoted development of biofilm and growth of L. pneumophila.
Biofilm formation by L. pneumophila was found to be inhibited in iron-rich conditions (Hindre
et al., 2008). Moritz et al. (2010) found that L. pneumophila and P. aeruginosa penetrated
biofilms grown in cold water on different plumbing materials in the laboratory—ethylene-
propylene diene-monomer (EPDM) rubber, silane cross-linked polyethylene, electron ray cross-
linked polyethylene and copper. The pathogens, added to biofilms after 14 days, became part of
the biofilms in EPDM and the polyethylenes; however, only L. pneumophila grew in the copper
biofilm, and only in low numbers. In a study of eight different plumbing materials, latex and
synthetic rubbers (ethylene-propylene) grew the most extensive biofilm, probably because these
materials leach the most nutrients (Rogers et al., 1994).
1.4 Regulatory Context
EPA regulates Legionella under the Surface Water Treatment Rule (SWTR). The SWTR has
treatment technique requirements to control for Giardia and viruses. The SWTR's treatment
technique requirements presume that if sufficient treatment is provided to control for Giardia
and viruses (i.e., 3-log (99.9-percent) inactivation of Giardia and 4-log (99.99-percent)
inactivation of viruses), then Legionella risks will also be controlled. In addition, the Revised
Total Coliform Rule (USEPA, 2013a) and the Ground Water Rule (USEPA, 2006a) have
treatment technique requirements that address bacteria. Corrective actions related to treatment
technique violations may provide some control of Legionella. All of these rules apply to public
water systems (PWSs).
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Premise plumbing systems that do not meet all the exemption criteria in the Safe Drinking Water
Act (SDWA) Section 1411 and 40 CFR 141.3 are subject to federal drinking water regulations
under 40 CFR Part 141. Adding certain water treatment technologies in a premise plumbing
system could impact the chemical and microbial quality of the water and change the regulatory
status of the premise plumbing system. The criteria for being a regulated PWS are provided at 40
CFR 141.3. Where there are questions about the application of these criteria, the primacy agency
(e.g., the state) typically makes the determination based on these criteria and any relevant site-
specific considerations. EPA has issued guidance that primacy agencies may use as they make
regulatory application decisions (USEPA, 1976 (Revised in 1998); USEPA, 1990 (Revised in
1998)). States and/or local governments may have drinking water standards for such systems
even if federal regulations do not apply.
A determination of which technology is best suited for a particular premise plumbing system is
case-specific in part due to the complex and diverse nature of premise plumbing systems and
local water chemistry. This document does not specifically recommend the addition of treatment
nor the installation of any of the technologies discussed herein; however, it does provide
information regarding the operational requirements with which regulated PWSs must comply.
This information is included only to provide the reader with a comprehensive understanding of
the technologies.
Facility owners or operators who are considering adding treatment to their building's premise
plumbing system may wish to consult with their water supplier (i.e., PWS) to better understand
any potential water quality issues before making treatment-related decisions. The installation of
treatment may also trigger cross connection control measures to protect the water supplier. If a
decision to add treatment in the premise plumbing system seems likely, EPA advises facility
owners or operators to consult with their primacy agency for any specific requirements that may
apply before they add any treatment.
In addition to the drinking water regulations under SDWA, manufacturers of pesticidal treatment
technologies used to control Legionella and other microbial contaminants need to comply with
the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) requirements, which are
independent of the SDWA requirements. Under FIFRA, pesticide devices are regulated, and
unless exempt, pesticide products that contain a substance or mixture of substances and that
make a pesticidal claim must be registered by EPA prior to sale or distribution. Registration of a
pesticide product under FIFRA does not mean that it meets the requirements of SDWA or vice
versa. See Questions 7 and 8 in Section 4 for more information.
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2 Risk Management Approaches and Technologies to Control Legionella
2.1 Overview of Current State of Knowledge
The following sections of this document describe risk management approaches and technologies
for controlling Legionella growth in premise plumbing systems. The information presented is
based on the references reviewed during the preparation of this document; Appendix A.l lists the
references cited in Section 2.3 and the type of study (e.g., lab study, field study, etc.). Section 2.2
introduces risk management approaches as a framework for identifying and prioritizing hazards
within a particular premise plumbing system and determining the specific control measures for
each priority hazard. Section 2.3 introduces several commercially available technologies that
show some effectiveness in mitigating Legionella growth in premise plumbing systems,
including chlorine, monochloramine, chlorine dioxide, copper/silver ionization (CSI), ultraviolet
(UV) light disinfection and ozone. For each technology, the document provides background
information, general characterization of its effectiveness against Legionella, potential water
quality issues and operational conditions (including monitoring frequency and location). This
document does not rank or recommend any one technology over another. The information in
Section 2.3 is presented in the context of national primary drinking water regulation
requirements. The EPA advises facility owners or operators to consult with the primacy agency
and/or water supplier about applicability of such requirements to a premise plumbing system.
In Section 3, other strategies (i.e., remediation methods) are discussed, including emergency
superheat-and-flush disinfection, shock hyperchlorination and point-of-use (POU) filtration. This
section summarizes what is currently known about the performance of these individual
technologies for controlling the occurrence of Legionella bacteria and other waterborne
pathogens in buildings.
In general, all of the technologies discussed in this document have been shown to offer some
degree of effectiveness against Legionella. However, the long-term eradication of Legionella
from a premise plumbing system has not been demonstrated consistently with any of these
technologies. Complex plumbing systems, such as those found in a multi-story building, may
have areas where there is less exposure to disinfectants and heat, which could provide
opportunities for bacteria to grow. Legionella bacteria may be found in biofilms or in sections of
the plumbing system with long water residence times, depending on the pipe materials, water
temperature and other system-specific factors. The effectiveness of a technology against
Legionella growth in biofilm or Legionella ingested by amoebae is often cited as a concern.
Other studies suggest that disinfectants, disinfection byproducts and other environmental
pollutants may induce an increase in antimicrobial resistance of bacteria, including pathogens
such as L. pneumophila (Ashbolt et al., 2013).
The retention of viable Legionella in amoebae cysts is an important factor for risk management
of water distribution and premise plumbing systems. Springthorpe et al. (2014) discusses the
importance of the association between opportunistic pathogens, such as Legionella, and free
living protozoa (which include amoebae), and how the protozoa might lead to long term
persistence of the pathogens by allowing them to relocate and/or avoid interventions, such as
disinfection. Wang et al. (2013) suggest that natural systems may provide conditions, such as an
abundance of beneficial microbial diversity, that may help prevent and potentially control the
growth of opportunistic pathogens that can be found in engineered environments.
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Establishing and maintaining a disinfectant residual throughout the system is critical for the
effectiveness of chlorine, monochloramine, chlorine dioxide and CSI treatments. Maintaining a
disinfectant residual provides increased protection in the event Legionella is released into the
premise plumbing system (e.g., sloughing off of biofilm material containing Legionella) or
enters a premise plumbing system through the PWS distribution system. Ozone and UV
disinfection do not produce a disinfectant residual (USEPA, 2007). Therefore, water treated with
only these methods, in some cases, may be susceptible to subsequent contamination unless
treatment is at the point of use or supplemental treatment is provided. For these reasons, more
than one type of treatment or control measure may be necessary to inhibit Legionella growth in a
premise plumbing system (VHA, 2014). The use of risk management approaches is further
discussed in Section 2.2.
The effectiveness of a particular technology is dependent upon building-specific characteristics
such as pipe material, age and condition; water usage rates and water age; and water quality
parameters (e.g., pH, hardness, organic contaminants, inorganic contaminants, types of
waterborne pathogens). Therefore, decision makers may want to consider the specific conditions
of each premise plumbing system before making a decision and ensure that the conditions are
adequate for the selected approach.
The physical and chemical characteristics of the finished water from water treatment plants may
have an impact on the effectiveness of the treatment technologies discussed in this document,
albeit not to the same degree. For example, chlorine and chlorine dioxide disinfectant residuals
may be difficult to maintain as the water temperature increases due in part to faster reactions
with organic materials or pipe surfaces. In contrast, temperature has little impact on the
effectiveness of copper or silver ions. The pH of the finished water will impact the effectiveness
of chlorine, monochloramine and copper ions, but it will have less of an impact on the
effectiveness of chlorine dioxide and silver ions. Other physical parameters (such as turbidity)
and chemical constituents (such as chlorides and dissolved organic carbon) can also affect the
performance of specific technologies. These issues are covered in more detail in Section 2.3.
Ensuring proper maintenance is a priority for all of the technologies discussed. Failures of
technologies put in place to protect the occupants of buildings from exposure to Legionella have
resulted in outbreaks (CDC, 2013). Safety concerns also exist for most of the technologies
(USEPA, 1999b, 1999c). The use of strong oxidants such as chlorine requires proper handling to
avoid adverse health risks. The Stage 1 and Stage 2 Disinfectants and Disinfection Byproduct
Rules (D/DBPRs) require regulated PWSs using chlorine, monochloramine and chlorine dioxide
to maintain disinfectant and disinfection byproduct (DBP) concentrations below the Maximum
Residual Disinfectant Level (MRDL) and Maximum Contaminant Level (MCL) to reduce risks
from such exposure concerns (USEPA 2006b; USEPA, 1998). Water quality issues are discussed
for each technology in Section 2.3.
Unless & Legionella outbreak occurs, the decision to employ additional treatment is often
difficult for facility owners or operators. Some facility owners or operators choose to install
supplemental disinfection treatment systems as a preventative measure based on economic or
insurance reasons. The detection of Legionella bacteria in tap water samples from a building is
likely the most common reason some facilities may choose to add treatment.
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The CDC does not recognize a safe level of Legionella and recommends certain preventative and
corrective actions in health facilities that care for patients who are at higher risk for Legionella
infection (CDC, 2003). The CDC encourages facility owners or operators to develop and
implement comprehensive water safety management plans (CDC, 2016; Garrison et al., 2015).
Routine environmental sampling including monitoring for Legionella can be performed as part of
a building-specific water safety plan (CDC, 2016; ASHRAE, 2015; NYDOH, 2015); however,
the CDC notes that there are knowledge gaps in how to use Legionella test results as a measure
of risk for disease transmission (Demiijian et al., 2015; Garrison et al., 2015). An environmental
assessment of the various components of a facility's premise plumbing system can help
determine vulnerabilities. These elements commonly include consideration of hot and cold water
temperatures, proper service of heating components, water softeners, water fixtures (e.g.,
showers), spas, water features, humidifiers and cooling towers. In combination with patient
surveillance, the environmental assessment and a facility plan will assist in the overall evaluation
and control of Legionella risks (CDC, 2016; NYDOH, 2015; NYDOH, 2016).
Some limitations and uncertainties associated with the information presented in this document
include:
•	Some studies were conducted in PWS distribution systems; thus, some results may not be
directly applicable to premise plumbing system environments. Likewise, some studies
were performed under laboratory conditions that may not necessarily reflect "real-life"
plumbing system conditions.
•	The information on the infectious dose of Legionella is limited due to difficulties in
culturing the organism. Many factors can impact the infectious dose, such as the amount
of Legionella that has been inhaled, the vulnerability of the person and the infectivity of
the organism.
•	Robust data on qPCR or culture counts in water that lead to disease outbreaks are not
available.
•	Further clarity is needed regarding the ecology of Legionella to help inform the infectious
dose question. Legionellae's capacity to colonize biofilms, grow inside protozoa and
enter a "viable but non culturable" state increases the uncertainty associated with
interpreting monitoring results.
2.2 Risk Management Approaches
2.2.1 Background
Risk management approaches refer to programs that systematically apply risk management
principles to reduce biological (including Legionella), chemical and physical risks associated
with premise plumbing systems. Different names are used throughout the literature to describe
risk management approaches. Some examples of risk management approaches include water
management programs (WMPs), hazard analysis and critical control point programs (HACCP)
and water safety plans (WSPs).
The HACCP concept was established in the early 1960s to ensure the safety of food from
microbiological hazards for astronauts working in space (Mortimore and Wallace, 2015).
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Beginning in the mid-1970s, HACCP principles were applied to the food industry as a
preventative approach for addressing biological, chemical and physical hazards.4 The process for
using this approach in a water system was originally described within a food journal, Food
Control, in 1994 (Havelaar, 1994).
WSPs were developed by the WHO as a comprehensive risk management approach that uses
multiple barriers based on HACCP to ensure public health protection from the source to the tap
(WHO, 2011a, 2009, 2007 and 2005).
The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE)
Standard 188 describes a risk management approach that establishes minimum legionellosis risk
management requirements for premise plumbing systems. ASHRAE uses the term water
management program (WMP) to describe the risk management approach (ASHRAE, 2015).
In 2016, the CDC published guidance to help facility operators and owners develop and
implement a water risk management program to reduce risks of Legionella growth and spread in
premise plumbing systems. The guide can also help the target audience assess and strengthen any
water risk management program already in place by providing practical resources to help facility
operators ensure that the program is comprehensive, effective and in line with industry standards.
The guide also highlights special considerations for healthcare facilities (CDC, 2016).
The American Industrial Hygiene Association (AIHA) recommends using a risk management
approach based on industrial hygiene principles and emphasizes proactive routine assessments
(AIHA, 2015). The American Society for Testing and Materials (ASTM) International D5952
guidance (ASTM International, 2015) describes a process for identification of cases of
Legionnaires' disease or Pontiac fever and appropriate responses to water system contamination.
The Health and Safety Executive of the United Kingdom (HSE) has issued guidance (HSE,
2013) to help employers and landlords comply with the Health and Safety at Work Act as it
applies to Legionella. The approved code of practice recommends identification and assessment
of sources of risk, preparation of a plan, implementation of the plan (including control measures
as needed), monitoring, record keeping and designation of a qualified person to assist with
compliance.
2.2.2 Applications of Risk Management Approaches
The application of any risk management approach, such as WMP, HACCP or WSPs can be
beneficial for the proper management of premise plumbing systems, to protect water quality and
public health in general. For more information on WMPs, please refer to the ASHRAE Standard
188 (ASHRAE, 2015). For more information on WSPs, the reader is referred to WHO
documents (WHO, 2011; WHO, 2005). For information about the HACCP, WMP and WSP
4 This approach to food safety was recognized by WHO as being essential for controlling foodborne disease. In
1993, the Codex Alimentarius Commission food code, established by the Food and Agriculture Organization of the
United Nations and the World Health Organization (WHO), adopted the HACCP approach (FAO, 1998).
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elements, see Appendices A.2 through A. 5 of this document. Slight variations can be observed in
the elements or steps described by each approach.
EPA does not make any specific recommendation regarding the use of any particular approach.
EPA advises facility operators and owners to determine which approaches may be more suitable
to their specific needs or whether a combination of approaches is appropriate.
Water system managers have found success in implementing risk management approaches such
as WMPs, HACCP and WSPs, similar to the successes seen in the food industry for many years.
•	In Iceland, an estimated 68 percent of the population consumes drinking water from
systems with WSPs. In a 2008 evaluation of water systems, the authors noted that
compliance with drinking water standards improved considerably upon implementation
of WSPs (Gunnarsdottir and Gissurarson, 2008).
•	Five full-scale HACCP applications in Australian water distribution systems resulted in
reductions in customer complaints and water quality incidents (Martel et al., 2006).
•	Researchers in Japan have concluded that HACCP ensures safe and high quality drinking
water; they also have proven success with safe water through the previous uses of
HACCP for bottled water and ice production (Yokoi at al., 2006).
Risk management approaches have proven to be effective for controlling the growth of
significant pathogens in premise plumbing systems, as documented in the following case studies:
•	In Minnesota, the Mayo Clinic used HACCP principles to build a water management
program for its multi-campus healthcare facilities (Krageschmidt et al., 2014). During
implementation of the program, the water management team identified and addressed
corrosion and distribution piping design issues and differences in how hazards were
controlled between buildings. The clinic found the application of these principles to be a
practical and effective approach for improving management of water systems. Forming a
multidisciplinary team to develop and implement the plan was productive and increased
awareness of water quality issues.
•	Evaluations of outbreaks of Legionnaires' disease have shown system deficiencies to be
contributing factors to outbreaks (CDC, 2013). The implementation of risk management
approaches may identify and help to correct these deficiencies.
•	Cristino et al. (2012) reported the successful implementation of risk assessment-based
water management plans to control Legionella in long-term care facilities. Under baseline
conditions, three hot water systems were colonized with L. pneumophila and one was
colonized with L. londiniensis. Specific control measures (e.g., disinfection,
environmental monitoring) were implemented in each system, and no cases of hospital-
acquired legionellosis occurred during the study period.
•	In 2004, a university clinic in Germany adopted the WSP concept. One immediate
success this clinic noted was the correction of an infrastructural failure that was identified
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during the process. Three years after implementation, two additional improvements were
noted: a lowered rate of sepsis in very low birth weight neonates and no cases of
nosocomial Legionnaires' disease since implementation (Dyck et al., 2007).
In addition to applying risk management concepts to existing premise plumbing systems,
engineers can also use these concepts in the design phase for new premise plumbing systems to
help reduce and control hazards (NYDOH, 2016; Krageschmidt et al., 2014; Facility Guidelines
Institute, 2014). For example, designing a system to minimize water age and dead-end pipelines
may limit the occurrence of waterborne pathogens. Another example is to exclude the use of
decorative fountains or other water features that generate aerosols which can be a source of
Legionella (HSE, 2009). After reviewing published medical literature and external standards
pertaining to healthcare facilities, the Veterans Health Administration (VHA) decided to prohibit
the use of decorative fountains in its facilities (VHA, 2014). The Facility Guidelines Institute
guidance document includes information on the planning, design and construction of hospitals
and outpatient facilities and safety risk assessments (Facility Guidelines Institute, 2014). The
Occupational Safety and Health Administration (OSHA) recognizes the importance of having
controls for premise plumbing systems in place, as under certain conditions any water source can
be a source of disease and illness (OSHA, 1999).
2.2.2.1 Temperature Approach for Legionella Control
A risk management approach to control Legionella in premise plumbing systems may include
thermal control of hot and cold water loops in addition to secondary disinfection or other control
measures. Thermal control involves maintaining the temperature in hot and cold water systems
outside of the range in which Legionella can ideally grow (between 35 and 46 degrees C or 95 to
115 degrees F; see Section 1.2.3). Although cold water systems are usually maintained at a
temperature less than 20 degrees C (68 degrees F), the temperature can increase during periods
of low flow or non-usage (VHA, 2014) as well as during seasonal temperature fluctuations.
A number of entities suggest raising the hot water temperature to a certain level for effective
control of Legionella growth. To inhibit Legionella growth in health care facilities, nursing
homes and other high-risk premise plumbing systems, several reports suggest that the hot water
temperature be at least greater than 50 degrees C (122 degrees F) at outlets (HSE, 2014; Hruba,
2009; WHO, 2007; Blanc et al., 2005; ASHRAE, 2000; Ezzeddine et al., 1989). Specific
suggestions for hot water temperature control include the following:
•	Bedard et al. (2016) reported that corrective measures were implemented to control L.
pneumophila in the hot water system of a hospital. The corrective measures included
increasing the hot water temperature from 55 degrees C (131 degrees F) to 60 degrees C
(140 degrees F).
•	Bedard et al. (2015) found that systems in which water temperature was maintained
higher than 60 degrees C (140 degrees F) coming out of water heaters and greater than 55
degrees C (131 degrees F) throughout the hot water system were negative for L.
pneumophila.
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•	The United Kingdom's Health and Safety Executive recommends the water heater
temperature be maintained at greater than 60 degrees C (140 degrees F), with the
temperatures at the outlets reaching 55 degrees C (131 degrees F) in healthcare premises
and 50 degrees C (122 degrees F) in other building types within one minute (HSE, 2014).
•	The Veterans Health Administration (VHA) requires that all VHA-owned facilities where
patients, residents or visitors stay overnight maintain water temperatures at 51.1 degrees
C (124 degrees F) or higher in hot water systems to inhibit Legionella growth (VHA,
2014).
•	In France, regulations for Legionella control were recently extended to all public
buildings. Target values for water temperature include greater than 55 degrees C (131
degrees F) at the water heater outlet and greater than 50 degrees C (122 degrees F) for
any points in the hot water system including points of use and return loops (Republique
Fran9aise, 2010).
•	Blanc et al. (2005) reported that after increasing the water heater temperature from 50
degrees C to 65 degrees C (149 degrees F), a Swiss hospital experienced a significant
reduction in the occurrence of Legionella. The temperature at most outlets was greater
than 50 degrees C (122 degrees F).
•	Darelid et al. (2002) reported that maintenance of a circulating hot water temperature
greater than 55 degrees C (131 degrees F), together with a 10-year surveillance program,
had successfully controlled Legionnaires' disease in a Swedish hospital. This case study
is described in more detail in Section 3.1.1.2.
Circulation of water throughout the hot water distribution system may be necessary for effective
thermal control. Accelerating the flow of water in a system has resulted in a noticeable reduction
in the concentration of Legionella (Ezzedine et al., 1989). Positive Legionella detections have
occurred at outlets where water circulation was known to be poor (Blanc et al., 2005). Bedard et
al. (2015) suggested that nightly shutdown of water recirculation loops be avoided since
temperature losses in dead end loops in the system can result in conditions favorable to
Legionella growth.
To monitor efficacy of thermal control in a WSP, temperature monitoring at the main
components in the system and temperature profiling at outlets can be considered to help identify
and correct risks (Bedard et al., 2015). Temperature profiling at intermediate locations, such as
subordinate flow and return loops feeding different floors of a facility, allows discovery of dead
legs and flow rate deficiencies (Bedard et al., 2016). It may be difficult for older buildings to
raise their water heater temperature sufficiently to maintain elevated temperatures at outlets
(HSE, 2014; WHO, 2007). The efficacy of temperature control in distal low flow areas is
important to consider as Legionella growth has been shown to be more abundant, with few
exceptions, in the hot water system where temperatures are less than 45 degrees C (113 degrees
F) (Serrano-Suarez et al., 2013).
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Heating water to temperatures necessary to control for Legionella can result in greater energy
use. While increasing temperature is an effective form of controlling Legionella growth,
increasing energy use can result in other negative environmental impacts. For more information
on how to mitigate other environmental impacts, please visit the ENERGY STARฎ website at:
https://www.energystar.gov/buildings. and the WaterSenseฎ website at:
http ://www3. epa. gov/watersense/com m erci al/i ndex. html.
In addition to increasing energy use, increasing water temperature can increase scalding risks.
For most adults, it takes 9 minutes for a second degree burn to occur at 49 degrees C (120
degrees F) while at 51 degrees C (124 degrees F) it takes 3 minutes (Moritz and Henriques,
1947). However, the assessment of scalding risk and selection of hot water temperatures should
consider the susceptibility of people at higher risk of scalding including young children, the
elderly, the disabled and those with sensory loss (HSE, 2014; VHA, 2014).
Installing automatic compensating mixing valves on outlets can be used to minimize the risk of
scalding injury (HSE, 2014; WHO, 2007; ASHRAE, 2000). No scalding injuries were reported
with the use of automatic compensating mixing valves over a period of 10 years in a hospital
maintaining the temperature at 55 degrees C (131 degrees F) throughout the premise plumbing
system (Darelid et al., 2002). However, the blended water downstream of these mixing valves
may allow Legionella growth; facility managers may want to consider conducting a comparative
risk assessment to determine where these valves can be used safely (HSE, 2014). The EPA
WaterSenseฎ program recommends using a showerhead and automatic compensating mixing
valve that are marked with the same flow rate at a pressure of 45 psi (additional information is
available on EPA's website:
http://vvvvvv3.epa.gov/vvatersense/docs/shovverheads finalsuppstat508.pdf).
Changes in water temperature can affect the efficacy of disinfection treatment, as discussed in
Section 2.3. Addition of treatment as part of a risk management approach program of a building
could have regulatory implications (see Section 1.4). EPA advises facility owners or operators
who are considering adjustments to their premise plumbing system to consult with their water
supplier and primacy agency for any specific considerations or requirements that may apply,
including plumbing code requirements.
2.2.3 Environmental Testing
Environmental testing involves collecting water samples from the premise plumbing system and
analyzing for L. pneumophila or other hazards of concern, as well as for water quality parameters
(pH, temperature, disinfectant residual) that may indicate efficacy of treatment performance and
overall water quality. Environmental testing may be performed as part of an outbreak
investigation in order to determine the source and stop transmission of the contaminant or during
implementation of a risk management Legionella prevention plan such as a WMP, HACCP or
WSP (ASHRAE, 2015; AIHA, 2015; Kozak et al., 2013). Legionella testing data inform risk
assessments and inspection and maintenance programs (Ditommaso et al., 2010).
Stout et al. (2007) found that environmental monitoring followed by clinical surveillance proved
to be effective in identifying previously unrecognized cases of hospital-acquired Legionnaires'
disease. The study was conducted at 20 hospitals in 13 states. None of the hospitals had
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previously experienced endemic hospital-acquired Legionnaires' disease. L. pneumophila and L.
anisa were isolated from 14 hospital water systems. High-level colonization of the premise
plumbing system (defined as 30 percent or more of the distal outlets being positive for L.
pneumophila) was demonstrated for 6 of the 14 hospitals with positive findings. More than 600
patients were evaluated for Legionnaires' disease from 12 hospitals. Hospital-acquired
Legionnaires' disease was identified in 4 hospitals, all of which had serogroup 1 in 30 percent or
more of the distal outlets.
Demirjian et al. (2015) evaluated medical records and conducted an environmental assessment in
a large Pennsylvania hospital to characterize a Legionnaires' disease outbreak that had occurred
between 2011 and 2012. The authors also evaluated the contributing factors. As part of the
hospital's Legionella prevention protocol, they implemented monthly system-wide superheat and
flush protocols if at least 30 percent of the distal sites showed Legionella growth, "until culture
results returned to an acceptable level" (less than 30 percent positive). Based on the 2011-2012
records, the authors found that all definite healthcare-associated cases occurred when sampling
results were far below the 30 percent threshold. The authors concluded that definite healthcare-
associated cases occurred when only 4 percent of distal sites were positive. In this outbreak, the
level of Legionella detected was <10 CFU/mL in almost all of the water samples. The authors
also noted that quantitative culture results in general have poor precision and can vary within a
range of 3-log CFU/mL of viable legionellae. As mentioned in Section 2.1, CDC does not
recognize a safe level of Legionella.
A review by Allen et al. (2012) also concluded that the 30 percent threshold provides both low
specificity (74 percent) and sensitivity (59 percent).
Using Legionella test results as a measure of risk for disease transmission may be problematic
due to knowledge gaps, including but not limited to, infectious dose, susceptibility of potential
hosts and virulence of the strain, as described in the following references:
•	CDC and WHO recognize that environmental Legionella counts alone cannot predict the
probability of human infection from a water system because other factors, such as the
exposure dose and level of host susceptibility, contribute to the likelihood of infection
(Demiijian et al., 2015; WHO, 2007; Sehulster and Chinn, 2003).
•	The lack of reliable and definitive human infectious dose information for Legionella
makes environmental monitoring results difficult to translate into action levels that can
directly reduce human health risks (Demirjian et al., 2015; Buse et al., 2012; Schoen and
Ashbolt, 2011; Storey et al., 2004a; Storey et al., 2004b; O'Brien and Bhopal, 1993;
Fitzgeorge et al., 1983).
•	While detection of Legionella in a premise plumbing system may indicate conditions
conducive to Legionella persistence, some studies suggest that the strains of Legionella
detected during non-outbreak routine environmental testing may not be the strains usually
known to cause disease (Kozak-Muiznieks et al., 2014; Euser et al., 2013; Harrison et al.,
2009, Kozak et al., 2009; Doleans et al., 2004).
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Current challenges to environmental testing tor Legionella include the following:
•	Despite a number of published procedures for the detection of Legionella in water
samples, standard culture methods remain limited by their sensitivity and unreliability in
detecting a wide range of Legionella spp. on a consistent basis (Buse et al., 2012) and
detecting VBNC Legionella (Oliver, 2010). The time it takes to receive results limits the
utility of testing. CDC has established the Environmental Legionella Isolation
Techniques Evaluation (ELITE) Program for the certification of laboratories that are
proficient in Legionella isolation by culture (http://www.cdc.gov/legionella/elite.html).
This is a voluntary program to identify laboratories that use procedures that are consistent
with federal recommendations and meet or exceed industry standards for the recovery of
Legionella. Culture protocols include water sample treatment and isolate identification
and characterization. Other methods, such as molecular (PCR), serological or rapid
analysis tests, are not evaluated under this program, and neither are sampling methods.
•	Lucas et al. (2011) reported on the results of a pilot study for the ELITE program, which
was conducted from September 2008 through March 2009. One of the issues reported
with routine sampling is the variability in recovery of legionellae from repeated sampling
of sites, as documented by several researchers. In one study of variability, Flanders et al.
(2014) evaluated the effects of sample holding and shipping times on Legionella test
results while taking into account measurement errors. Based on 159 original samples and
2,544 split samples, the authors determined that holding time increased the root mean
squared error by 3 to 8 percent.
•	There is a lack of standardized protocols for the selection of sampling sites and the
frequency of sampling (Lucas et al., 2011; WHO, 2007).
Guidelines on routine environmental testing for Legionella vary among different agencies,
including the CDC, WHO, AMA and ASHRAE.
•	AIHA (2015) recommended using validated laboratory methods to measure viable
Legionella bacteria rather than surrogate indicators (e.g., chlorine residual) as part of
routine assessments on a semi-annual frequency. AIHA also suggests that Legionella
testing should be conducted for validation of the plan (i.e., confirming that the plan is
effective at controlling the identified hazards), and as part of the outbreak investigation to
determine the environmental source of the disease (AIHA, 2015).
•	ASHRAE (2015) suggested that the team responsible for developing and implementing
the building's risk management plan for Legionella control decide whether or not
Legionella testing should be conducted. Criteria that can support such a decision include:
prior history of legionellosis, buildings that serve at-risk or immunocompromised
populations, and the incorporation of control limits (i.e., defined values for chemical or
physical parameters) into the risk management program (ASHRAE, 2015; HSE, 2014).
•	HSE (2014) suggests that monthly Legionella testing be conducted in premise plumbing
systems that provide treatment with biocides and where water is stored or distribution
temperatures are reduced. Monitoring is expected to continue until treatment
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effectiveness and control can be confirmed. HSE provides additional guidance on
sampling locations in hot and cold water systems.
•	VHA (2014) recommends routine environmental testing for Legionella in VHA facilities
as a way to validate the effectiveness of measures for Legionella control.
•	The Maryland Department of Health and Mental Hygiene (2000) recommends that water
distribution systems within acute care hospitals be routinely cultured for Legionella at a
facility-specific schedule determined by risk assessment.
Despite the limitations of environmental monitoring, both WHO and CDC acknowledge using
Legionella testing as one way to verify and validate a WSP (Garrison et al., 2015; WHO, 2007).
If a decision is made to conduct routine environmental testing for Legionella as part of a risk
management approach, studies recommend that a building-specific sampling plan be developed
that specifies the location of sampling sites, the type of samples, the frequency of sampling, the
sample collection method and the sample analysis method (AIHA, 2015; Krageschmidt et al.,
2014). Ditommaso et al. (2010) concluded that hospitals could adopt a simple and efficient
environmental sampling strategy for Legionella testing in hot water systems by conducting water
sampling including water from the recirculation loop, and excluding biofilm sampling. However,
there is no consensus on how many and which types of samples to take (e.g., bulk water or
biofilm), nor how often to perform the sampling in order to accurately assess the risk from
Legionella.
2.3 Technologies
2.3.1 Chlorine
2.3.1.1 Background
Chlorine and chlorine-based compounds are disinfectants that can serve the dual role of
efficiently inactivating microorganisms during water treatment, as well as maintaining the
quality of the water as it flows from the treatment plant to the consumer's tap. Numerous studies
have demonstrated that chlorine effectively kills many disease-causing bacteria and other
pathogens (McGuire, 2006).
Chlorine is added to drinking water as elemental chlorine (chlorine gas), sodium hypochlorite
solution or dry calcium hypochlorite. Due to safety issues with chlorine gas, many U.S. water
systems have switched to sodium hypochlorite for disinfection (McGuire, 2006). Chlorine can be
applied by facilities for routine treatment of both hot and cold domestic water; it can be applied
to the cold and hot water tanks or to the entire distribution system. However, free chlorine
degrades rapidly in hot water systems (Health Protection Surveillance Centre, 2009). Chlorine
can also be used at high doses for emergency disinfection of potable water systems through
shock chlorination (also called shock hyperchlorination). Shock chlorination is covered in more
detail in Section 3.1.2.
For chlorine to be effective against microorganisms, it must be present in sufficient
concentration, and must have adequate time to react. For primary disinfection in the municipal
water system, this combination of concentration and reaction time is expressed as C (mg/L) x T
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(min) or CT. For continued protection against potentially harmful organisms in distribution
systems or premise plumbing systems, some level of chlorine needs to be maintained after the
initial application. The remaining chlorine is known as residual chlorine.
The addition of chlorine to water creates two chemical species that together make up "free
chlorine." These species, hypochlorous acid (HOC1, electrically neutral) and hypochlorite ion
(OC1", electrically negative), behave very differently. Hypochlorous acid is more reactive than
the hypochlorite ion and is also the stronger disinfectant and oxidant. The ratio of hypochlorous
acid to hypochlorite ion in water is determined by pH. At low pH (6-7), hypochlorous acid
dominates, while at high pH (>8.5) the hypochlorite ion dominates. Thus, the pH of the incoming
water may be a factor when deciding upon the use of chlorine as a disinfectant or in the
engineering design when addressing issues such as CT for the target organism(s).
Chlorine was first used in the U.S. as a primary disinfectant of drinking water in Jersey City,
New Jersey, in 1908 (USEPA, 1999b). Chlorine is widely credited with virtually eliminating
outbreaks of waterborne disease in the United States and other developed countries. Among
PWSs that disinfect, chlorine is the most commonly used disinfectant (AWWA Disinfection
Systems Committee, 2008).
2.3.1.2 Characterization of Effectiveness against Legionella
Both laboratory and full-scale studies have been conducted to assess the effectiveness of chlorine
against Legionella. These studies included a range of physical and chemical water conditions
such as chlorine dose and residual levels, temperature and pH. Kim et al. (2002) reviewed
available literature on the efficacy of various disinfectants against Legionella, findings related to
chlorine disinfection include the following:
•	Relatively high doses of chlorine (2-6 mg/L) were needed for continuous control of
Legionella in water systems (Lin et al., 1998a).
•	Muraca et al. (1987) reported that chlorine was more effective at a higher temperature (43
degrees C (109.4 degrees F) compared to 25 degrees C (77 degrees F)), but it decayed
faster at the higher temperature.
•	The association of L. pneumophila with protozoa including amoebae required much
higher doses of chlorine for inactivation (Kilvington and Price, 1990). Kim et al. (2002)
noted that this association with protozoa may explain why chlorine can suppress
Legionella in water systems but cannot usually prevent its regrowth.
The laboratory studies described below examined the effectiveness of chlorine in inactivating
Legionella under a range of pH, temperature and chlorine residual levels, although the
temperatures tested in some studies were lower than temperatures likely to occur in a building's
hot water system. Results showed a wide range of CT values needed for all inactivation levels.
While experiments performed to compare efficacy of disinfectants can be useful to demonstrate
relative efficacy under the conditions of the experiment, it should not be implied that these
values could be used in the field for premise plumbing water systems.
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•	Giao et al. (2009) found that L. pneumophila (strain NCTC 12821) could not be detected
using cell culture after exposure to 0.7 mg/L of chlorine in the laboratory for 30 minutes
at room temperature (20 degrees C, or 68 degrees F). With a chlorine concentration of 1.2
mg/L, cultivability was lost after 10 minutes. Viability of these cells was only slightly
affected when measured using the rapid SYTO 9/propidium iodide fluorochrome uptake
assay. When cells that had been exposed to 1.2 mg/L of chlorine for 30 minutes were co-
cultured with Acanthamoebapolyphaga, they recovered their cultivability after 72 hours.
•	Jacangelo et al. (2002) conducted laboratory studies to examine the efficacy of current
disinfection practices (e.g., chlorine dioxide, free chlorine and monochloramine) for
inactivation of waterborne emerging pathogens including Legionella. Chlorine doses of
1.0 to 4.0 mg/L were used. Three different temperatures (5, 15 and 25 degrees C, or 41,
59 and 77 degrees F, respectively) and three different pH (6.0, 7.0 and 8.0) values were
examined. The observed CT values for 2-log (99-percent) reduction of L. pneumophila at
pH 6 ranged from 40 to 500 min-mg/L, depending on the temperature. Observed CT
values at pH 7 and pH 8 ranged from 50 to >320 min-mg/L and 25 to >1,000 min-mg/L,
respectively. These CT values were at least an order of magnitude higher than those
reported by Kuchta et al. (1983) below. The wide range of CT values reported in the
literature could be due to different water quality conditions and test protocols used for
inactivating Legionella.
•	Kuchta et al. (1983) studied the effects of various chlorine concentrations, temperatures
and pH levels on Legionella in tap water. The chlorine residuals used (0.1 and 0.5 mg/L)
were consistent with residual levels that would be expected in PWSs. The observed CT
value for 2-log (99-percent) reduction of L. pneumophila at pH 6 was 0.5 min-mg/L at a
temperature of 21 degrees C (69.8 degrees F). Observed CT values at pH 7 and pH 7.6
ranged from 1 to 6 min-mg/L and <3 to 9 min-mg/L, respectively. The authors noted that
contact times for the clinical and other environmental sources of Legionella were as long
as, or longer, than those required for river samples, although long contact times were
needed regardless of serogroup or origin. The authors concluded that low chlorine
concentrations (0.1 mg/L) allowed Legionella to survive for relatively long periods of
time. Increasing the total chlorine concentration predictably enhanced the bactericidal
effect, resulting in a 99-percent (2-log) kill within the first 5 minutes at a concentration of
0.5 mg/L.
The following pilot studies evaluated the efficacy of chlorine disinfection for inactivating
Legionella without co-occurring microbial organisms. Both studies were completed using warm
water conditions.
•	Saby et al. (2005) tested the efficiency of several disinfectants in a hot water system pilot
unit. The pilot unit was supplied by tap water pre-heated to 30 degrees C (86 degrees F).
Legionella-conl&minated water was mixed with the tap water before heating.
Colonization of the biofilm by Legionella was found after seven weeks. After
colonization of pipes in the pilot unit, various treatments were tested. Shock
hyperchlorination at 50 mg/L of free chlorine residual for 12 hours was found to be very
effective in reducing Legionella in the water; however, the pipe networks were
recolonized in three to four weeks. The authors stated this could be explained by the
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inefficiency of shock hyperchlorination treatment on bacteria in biofilms. Continuous
chlorine at a dose of 3 mg/L for two periods of four weeks was also examined. The
results showed that treatment with chlorine was effective at maintaining low levels of
viable bacteria, including Legionella. However, a malfunction of the chlorination system
resulted in a positive result for Legionella within 28 hours. The authors concluded that
continuous chlorination allows only for containment of Legionella and that technical
problems with treatment could result in rapid recolonization. Temperature control at 40
degrees C (104 degrees F) and 55 degrees C (131 degrees F) was also evaluated as part of
this study. While temperature control at 55 degrees C was the best technical and
economic solution to Legionella control, continuous chlorination was also a good
solution.
•	Muraca et al. (1987) compared chlorine, heat, ozone and UV for inactivating L.
pneumophila in a model premise plumbing system. A suspension of L. pneumophila was
added to the system and allowed to circulate. Chlorine disinfection consisted of
maintaining a residual concentration between 4 and 6 mg/L through multiple additions of
chlorine. Chlorine experiments were conducted at 25 and 43 degrees C (77 and 109.4
degrees F, respectively). Continuous chlorination at a dose of 4 to 6 mg/L resulted in a 5-
to 6-log (99.999- to 99.9999-percent) decrease of L. pneumophila in six hours. Chlorine
disinfection at 43 degrees C (109.4 degrees F) inactivated L. pneumophila more reliably
and completely than disinfection at 25 degrees C (77 degrees F). Due to thermal
decomposition of chlorine residual, more chlorine was needed to maintain a residual of
4-6 mg/L at 43 degrees C (109.4 degrees F) than at 25 degrees C (77 degrees F) (a total
of 40 mL of Clorox bleach (5.25 percent chlorine) as opposed to 18 mL). The authors
noted that in addition to the higher doses required to overcome residual decomposition, a
drop in chlorine levels or failure of chlorination equipment could allow Legionella to
survive. As a result, the authors concluded that chlorination of hot water systems is more
difficult to regulate than that of cold water systems.
The interaction of Legionella with co-occurring organisms can affect the efficacy of chlorine for
the inactivation of Legionella. The following laboratory studies evaluated the effects of co-
occurring amoebae on Legionella inactivation by chlorine disinfection:
•	Dupuy et al. (2011) also investigated the interaction of amoebae and L. pneumophila. The
authors compared the efficiency of three oxidizing disinfectants (chlorine,
monochloramine and chlorine dioxide). These disinfectants were used on three
Acanthamoeba strains, L. pneumophila alone, and Acanthamoeba and L. pneumophila in
co-culture. Chlorine efficiency was evaluated at 30 degrees C (86 degrees F) and at 50
degrees C (122 degrees F). An initial dose between 2 mg/L and 3 mg/L was applied, with
a free chlorine residual of 1 mg/L at the end of the treatment. Results were presented as
CT (min-mg/L) values. Chlorine was found to inactivate all three strains of
Acanthamoeba studied, both infected with L. pneumophila and not infected. At least a 3-
log (99.9-percent) inactivation was obtained for all strains at a CT of approximately 60
min-mg/L. There was a significant difference in inactivation between the strains of
Acanthamoeba studied, with more than 3-log inactivation found at a CT of less than 10
min-mg/L for one strain. Inactivation efficiency was slightly higher at 50 degrees C (122
degrees F).
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•	In a study of the interaction of thermotolerant amoebae and Legionella, Storey et al.
(2004a) evaluated the efficacy of heat and chlorine as disinfectants. The study found that
a 2-log (99-percent) reduction in free-living (planktonic) L. pneumophila was achieved at
30 minutes with free chlorine concentrations of 1 mg/L and 2 mg/L (at 37 degrees C, or
98.6 degrees F). A 3-log (99.9-percent) reduction of L. pneumophila was achieved after
10 minutes with a free chlorine concentration of 10 mg/L (at 37 degrees C, or 98.6
degrees F). The efficacy of free chlorine in the reduction of Acanthamoeba castellanii (an
amoeba)-bound L. erythra was also evaluated. A free chlorine dose of 1 mg/L achieved
less than 0.5-log reduction at contact times of 60 minutes or less, whereas a 2 mg/L dose
resulted in a 3-log (99.9-percent) reduction at contact times of >30 minutes (at 37 degrees
C or 98.6 degrees F). A free chlorine dose of 10 mg/L and contact time of 10 minutes
achieved a 3.2-log reduction. The study found that the interaction of legionellae and
Acanthamoebae increased the resistance of legionellae to thermal treatment and increased
their sensitivity to chlorine. The authors also noted the tolerance of Acanthamoebae to
high chlorine doses and thermal treatment. Cysts retained their viability at free chlorine
levels of 100 mg/L after 10 minutes and at free chlorine levels of less thanlO mg/L after
30 minutes. The authors cited a prior study by Kilvington and Price (1990) that found that
cysts were able to maintain their viability at free chlorine concentrations of 50 mg/L or
less.
•	Based on a survey of drinking water supplies in England, Colbourne and Dennis (1989)
observed that L. pneumophila survived conventional water treatment, including
disinfection with chlorine, and retained its ability to colonize pipe surfaces and grow in
warm water premise plumbing systems, despite being non-culturable.
The following laboratory studies evaluated the effectiveness of chlorine when biofilm is present:
•	Using copper and stainless steel coupons, Cooper and Hanlon (2009) found that mature
L. pneumophila biofilms (one and two months old) survived a one-hour treatment with 50
mg/L chlorine and continued to grow after treatment, reaching a population of 106 CFU
per coupon (20-mm diameter disc). The authors also found that planktonic L.
pneumophila was able to survive and persist at free chlorine concentrations of 0.5 mg/L.
•	Loret et al. (2005) expanded on the de Beer et al. (1994) study described later in this
section by using a simulated premise plumbing system consisting of pipe loops to
compare disinfectants for Legionella control in biofilms in premise plumbing systems.
The pilot unit also included piping off of the main pipe loop to simulate areas at the ends
of a water system (dead ends) with low flow conditions. Tap water and injection of
cultured natural Legionella strains were used to establish biofilms. Low temperature (35
degrees C, or 95 degrees F) relative to hot water systems and low water velocity, as well
as high retention times, were maintained to favor the growth of Legionella and biofilms.
Each pipe loop was treated with one of the studied disinfectants for three months. The
loop receiving chlorine was maintained with a residual dose of 2 mg/L. Each type of
disinfectant used in the study displayed rapid initial results in the treated loops, with
Legionella populations decreasing to undetected levels (less than 500 CFU/L) within
three days of treatment, in all cases. However, Legionella remained undetected over the
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whole study period only with sodium hypochlorite, electro-chlorination, chlorine dioxide
and monochloramine. (Ozone and copper/silver allowed occasional re-emergence of
detectable Legionella.) Ozone, electro-chlorination and chlorine treatments resulted in a
reduction of biofilm thickness to below detection limits (<5 jam) after one week. A
chlorine dosage rate of 2.5 mg/L removed biofilm better than a chlorine dioxide dosage
rate of 0.5 mg/L. Flushing of the dead ends at a rate of 20 percent of the volume per day
did not result in a significant reduction in Legionella. After a single complete flushing, all
simulated dead end sections of piping returned to their initial contamination level within
24 hours. The study concluded that chlorine and chlorine dioxide were the most effective
treatment methods in this study (as compared to ozone, monochloramine and
copper/silver). The authors suggest that the experimental protocol did not allow for
maintenance of a stable product and resulted in insufficient dosing in the pipe loops.
•	de Beer et al. (1994) studied the degree to which chlorine penetrates a biofilm based on
bulk concentration. For this study, biofilms consisting of P. aeruginosa and K.
pneumoniae were grown for one week, with a maximal thickness of 150-200
micrometers (|im). Transient chlorine concentration profiles were measured in biofilms
with a microelectrode that was developed for the investigation and was sensitive to
concentrations of chlorine in the micromolar range. The transient chlorine micro-profiles
showed slow chlorine penetration into the biofilm, with the rate dependent on the bulk
concentration of chlorine. The penetration time exceeded 60 minutes even at the highest
concentration tested (0.36 millimolar (mM)). The biofilm matrix, consisting of cells and
extracellular polymeric substances, was determined to be a substrate for the chemical
reduction of chlorine. Chlorine concentrations measured in biofilms were typically only
20 percent or less of the concentration of the bulk liquid. The micro-profiles showed that
following exposure to 2.5 mg/L chlorine for one hour, only the upper 100 |im of the cell
clusters was penetrated by chlorine. Findings showed that the limited penetration of
chlorine into the biofilm (as determined by penetration depth and rate of penetration) is
likely a key factor influencing the reduced efficacy of chlorine against biofilms compared
to its effectiveness against planktonic cells. Rapid regrowth after chlorine treatment may
have originated from areas within biofilms that are highly resistant to chlorine.
Several studies describe the application of continuous chlorination in hospitals or long-term care
facilities in combination with heat treatment and in some cases with shock chlorination.
•	Cristino et al. (2012) reported the successful application of various shock disinfection
methods (e.g., heat shock, chemical shock with peracetic acid and chlorine dioxide)
followed by continuous chlorination for long-term care facilities, including three hot
water systems that were colonized by L. pneumophila and one hot water system
colonized by L. londiniensis. No cases of hospital-acquired legionellosis occurred during
the study period. Although three of four systems reported that 100 percent of samples
were positive for Legionella before and after shock treatment, the mean Legionella count
was reduced by up to 69 percent as a result of shock disinfection. Two years of
environmental monitoring after shock disinfection showed that Legionella counts either
continued to decrease or remained at post-treatment levels.
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•	Snyder et al. (1990) reported a successful application of heat flushing followed by
continuous supplemental chlorination to reduce L. pneumophila in a hospital hot water
system. Twelve of 74 sampling sites in the hot water system were culture-positive for L.
pneumophila. Heat flushing (>60 degrees C, or >140 degrees F) at hot water system
outlets for 30 minutes alone reduced the number of Legionella-positive samples by 66
percent, but within four months, the number of positive samples had increased.
Continuous supplemental chlorination was added to the hot water system at a dosage rate
of 2 mg/L. After six weeks, the number of Legionella-\)Os\ti ve samples decreased from
37 percent (43 of 115 samples) to 7 percent (8 of 115 samples). After 17 months of
continuous supplemental chlorination, no new cases of legionellosis had occurred.
Several studies explored the potential tor Legionella to develop resistance to oxidative
disinfectants such as chlorine. As described in Section 1.2.3, biofilms and amoeba hosts may act
as physical barriers to protect Legionella from chlorine or other disinfectants. However,
legionellae themselves may easily acquire (and lose) resistance to disinfectants.
•	Flynn and Swanson (2014) determined a possible mechanism by which resistance can be
conveyed. They found that bacterial DNA segments, which can be transferred from one
bacterium to another, can confer resistance to oxidative stress. This resistance could
allow L. pneumophila to withstand exposure to chlorine, as well as to hydrogen peroxide
produced by macrophages or by exposure to antibiotics.
•	Kuchta et al. (1985) showed that L. pneumophila isolated from hospital hot water systems
was less resistant to chlorine after being grown for multiple generations on an agar
medium. The contact time required to achieve a 99-percent (2-log) reduction with a
chlorine concentration of 0.25 mg/L was 10 minutes on a passaged culture, as opposed to
60 to 90 minutes for Legionella cultured directly from tap water samples.
Additional studies that compare the effectiveness of other disinfectants to chlorine to control for
Legionella are cited in subsequent sections for various technologies.
•	In a study of Legionella control in full-scale water systems of older hospital buildings in
Rome, Italy, Orsi et al. (2014) evaluated the effectiveness of shock hyperchlorination and
continuous chlorination over a five-year period. Thirty-eight buildings were studied and
1,308 samples were analyzed for the presence of Legionella. Samples were collected
before and/or after several chlorination treatment scenarios (before and after shock
hyperchlorination, shock hyperchlorination followed by continuous hyperchlorination)
from cold water piping, mixed cold and hot piping, and hot water piping. Shock
hyperchlorination was described as an applied concentration of 20-50 mg/L, and
continuous hyperchlorination was described as a continuously applied concentration of
0.5-1.0 mg/L. The study found a significant association between the presence of
Legionella in the buildings' premise plumbing systems and the lack of continuous
chlorination following shock hyperchlorination. Isolation of Legionella was more
frequent in mixed water samples (20-40 degrees C (68-113 degrees F)) than in cold or
hot water samples. The authors concluded that continuous free chorine levels of 0.5 to 1.0
mg/L resulted in significant reductions in Legionella counts in the old hospital water
systems. However, this treatment did not completely control Legionella.
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•	Lin et al. (1998a) reported that some hospitals that initially adopted chlorination
converted to other methods of disinfection because of failure to control Legionella and
corrosion of the premise plumbing system. Also, Casini et al. (2014) isolated Legionella
strains more tolerant of free chlorine from a water system after years of chlorine
treatment.
2.3.1.3 Potential Water Quality Issues
Chlorine can react with organics, inorganics and non-halogens in the water to form DBPs
(USEPA, 2006b).
Some DBPs have been shown to cause cancer and reproductive effects in lab animals and may
cause bladder cancer and reproductive effects in humans (USEPA, 2010). In a simulated premise
plumbing system of pipe loops, Loret et al. (2005) found trihalomethane (THM) levels >100
micrograms per liter (|ig/L), with an applied chlorine dose of 2 mg/L. For comparison, the EPA
drinking water standard for total THM (TTHM) is 80 |ig/L. Orsi et al. (2014) noted that special
equipment was needed in certain health care settings (e.g., dialysis, neonatal care) to reduce free
chlorine and THM levels.
Some DBPs are likely to be carcinogenic to humans by all routes of exposure, while others have
suggestive evidence of carcinogenicity (NTP, 2006; USEPA, 2005a). For more information
about THMs and potential health effects, see EPA's health criteria document for brominated
THMs (USEPA, 2005a).
Continuous chlorination at high levels in premise plumbing systems can result in objectionable
tastes and odors along with irritation of skin, eyes and mucous membranes.
Continuous chlorination can contribute to corrosion, with associated leaks, in plumbing systems
and may require the simultaneous use of corrosion-inhibiting chemicals. Various corrosion
effects have been reported for systems using chlorination:
•	Sarver et al. (2011) reported that continuous hyperchlorination increased leaks by up to
30-fold, consistent with extensive laboratory work in soft higher-pH waters.
•	Castagnetti et al. (2011) found that no high density polyethylene (HDPE) pipe failure
occurred after 2,000 hours of exposure to 2.5 mg/L chlorine.
•	Hassinen et al. (2004) studied corrosion in HDPE pipe exposed to chlorinated water (3
mg/L) at elevated temperatures (105 degrees C, or 221 degrees F) and found evidence of
polymer degradation on the unprotected inner walls of the pipe.
•	Loret et al. (2005) observed similar corrosion marks on mild and galvanized steel
coupons installed in pipe loops for various treatment chemicals (chlorine,
monochloramine, chlorine dioxide, CSI and ozone).
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•	Kirmeyer et al. (2004) reported that higher copper corrosion rates are associated with free
chlorine compared to equivalent levels of chloramine; however, this is a site-specific
issue.
•	In a study by Grosserode et al. (1993), leaks first appeared in the copper pipes of a
premise plumbing system about two years after installation of the chlorine injectors.
Significant deterioration was noted only in the hot water system. The addition of silicate
corrosion inhibitors reduced the total number of leaks per year by >80 percent.
2.3.1.4 Operational Conditions
Parameter Conditions Indicating Operational Effectiveness
The efficacy of chlorination is affected by many factors, including chlorine concentration,
contact time, pH, temperature, turbidity, buffering capacity of the water, concentration of organic
matter, iron and the number and types of microorganisms in the water system (in biofilms and
free-living). Lin et al. (2002) reported that 2-6 mg/L of chlorine was needed for continuous
control of Legionella in water systems. The bactericidal action of the chlorine is enhanced at
higher temperatures and at lower pH levels. The anti-microbial efficacy of chlorine declines as
pH increases >7, with significant loss of efficacy at pH >8. However, free chlorine is degraded
rapidly at elevated water temperatures, which is a concern for hot water chlorination (Health
Protection Surveillance Centre, 2009). Turbidity interferes with the disinfection process by
providing protection for organisms; turbidity may need to be reduced prior to disinfection
(WHO, 2011b).
Installation Considerations
Chlorine should be stored in the original shipping containers or compatible containers and sited
away from direct sunlight in a cool area. Feed rates should be regularly adjusted to account for
any losses in chlorine content during storage or handling.
NSF/ANSI Standard 60 certification can help ensure that the quality and effectiveness of water
treatment chemicals have been reviewed and found to be acceptable for potable water
applications. Some primacy agencies require NSF/ANSI 60 certification. A facility considering
application of chlorine gas as the form of chlorine to be used for disinfection would also need to
consider potential safety and security concerns. Additional safety procedures will likely be
required for personnel training and equipment. Existing OSHA, state or local fire authority
regulations may apply and may need to be consulted. Special water system engineering
construction standards may also apply for some primacy agencies.
Monitoring Frequency and Location
If a premise plumbing system is a regulated PWS, then the SWTR (USEPA, 1989a) requires
that PWSs adding chlorine and using a surface water supply or a ground water supply under the
direct influence of surface water monitor for the presence of the residual disinfectant in the
distribution system or at the entry point to the distribution system (EP). The disinfectant level
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must be at least 0.2 mg/L at the EP and detectable in at least 95 percent of samples collected
within the distribution system.
The Stage 1 D/DBPR requires that PWSs that use chlorine maintain a residual disinfectant level
of less than 4.0 mg/L as a running annual average (USEPA, 1998).
As stated in the SWTR, PWSs that use chlorine are required to monitor for combined or total
chlorine residual or heterotrophic plate count (HPC) bacteria in the distribution system at
locations that have been approved by the primacy agency (USEPA, 1989a). These parameters
could provide operational information to indicate the need for chlorine dose adjustments, system
flushing and managing water age within finished water storage facilities.
Maintenance Needs
Operations and maintenance practices for chlorine disinfection systems include maintenance of
an appropriate disinfectant residual, regular system cleaning and flushing, inspections, and water
quality monitoring. Newly constructed or rehabilitated piping systems are cleaned and flushed
prior to initial disinfection. Routine flushing and water quality monitoring are recommended to
assure that adequate disinfectant levels are maintained throughout the premise plumbing system
(HSE, 2014).
Since chlorine is recognized as being less effective than other disinfectants at penetrating and
controlling established biofilms, chlorination may not be effective if large amounts of scale and
sediment are present in the system. These solids are prone to biofilm formation and may need to
be removed by cleaning before effective disinfection can be achieved (HSE, 2014). Loret et al.
(2005) recommended flushing dead ends daily with disinfected water and removing premise
plumbing fixtures and pipes that are rarely used.
2.3.2 Monochloramine
2.3.2.1 Background
The primary use of monochloramine (NH2CI) in water systems is to maintain a disinfectant
residual in the distribution system. Monochloramine has a more persistent and stable disinfectant
residual than chlorine (USEPA, 1994). It causes fewer unpleasant tastes and odors in drinking
water than other disinfectants (USEPA, 1994). Monochloramine has a much lower disinfection
efficacy than free chlorine (Symons, 1978) and if used as a primary disinfectant it requires a
much longer contact time.
Monochloramine is effective for controlling bacterial regrowth and controlling biofilms due to its
ability to penetrate the biofilm, although excess ammonia can cause biofilm growth (USEPA,
1999c; LeChevallier et al., 1988a). Monochloramine and chlorine have different mechanisms of
action; monochloramine is more specific, and chlorine reacts with a wider array of compounds.
When inactivating bacteria in the biofilm, monochloramine is able to penetrate, whereas chlorine
may get consumed through reactions that do not occur with monochloramine (Lee et al., 2011;
LeChevallier, 1988b). For equivalent chlorine concentrations, monochloramine was shown to
initially penetrate biofilm 170 times faster than free chlorine, and even after subsequent
application to a monochloramine-penetrated biofilm, free chlorine penetration was limited (Lee
et al., 2011). The mechanism of inactivation for chloramine is thought to involve inhibition of
proteins or protein-mediated processes such as respiration (USEPA, 1999c).
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Monochloramine can be formed by first adding chlorine then ammonia or vice versa. Often
ammonia is added after chlorine has acted as a primary disinfectant for a period of time, and the
resulting monochloramine is used as a residual disinfectant (USEPA, 1999b; USEPA, 1999c).
Although monochloramine is the dominant form produced under conditions typically found in a
drinking water system, two other forms of chloramines (dichloramine and trichloramine
(nitrogen trichloride)) can also be produced when excessive levels of hypochlorite are present or
at low pH levels (USEPA, 1994). Monochloramine is the preferred form of chloramine for use in
drinking water treatment due to fewer taste and odor issues and its disinfection efficacy.
Monochloramine is a colorless water-soluble liquid (WHO, 2004) with a freezing point at -66
degrees C (-86.8 degrees F).
Monochloramine has been used in the treatment of drinking water for nearly 100 years (USEPA,
2009). It was first used in water treatment in the mid-1910s; the City of Ottawa first used
chloramines in 1915 due to the rising costs of bleach. Denver, Colorado, started using
monochloramine around the same time as a way to control organisms in the distribution system
(Symons, 1978). Its use gained popularity in the 1930s and 1940s but soon declined due to the
shortage of ammonia during World War II. The use of monochloramine has been increasing in
the past couple of decades due to concerns over DBPs associated with chlorine use (USEPA,
1999c). As of 2009, 1 in 5 Americans were using drinking water treated with chloramines
(USEPA, 2009) and this usage rate is projected to increase due to implementation of the Stage 2
D/DBPR (Seidel et al., 2005; USEPA, 2005b).
2.3.2.2 Characterization of Effectiveness against Legionella
Laboratory studies have used a wide range of CT values under different water quality test
conditions for inactivating Legionella by monochloramine disinfection.
•	Jakubek et al. (2013) evaluated inactivation of L. pneumophila in nuclear power plant
cooling circuits with monochloramine formed by combining sodium hypochlorite and
ammonia solution with a chlorine-to-ammonia mass ratio of 4.8 (at pH 7.5-8.5 and 25-35
degrees C (or 77-95 degrees F)). The results showed 99.9-percent (3-log) inactivation of
environmental strains of L. pneumophila with a CT range between 16.14ฑ3.07 min-mg/L
and 64.88ฑ19.07 min-mg/L for various strains. The study also found that temperature, pH
and initial bacterial concentration affected the ability of monochloramine to inactivate
Legionella.
•	Dupuy et al. (2011) conducted a laboratory study to evaluate the inactivation of both free
and intracellular L. pneumophila (co-occurring with Acanthamoeba) using
monochloramine (initial concentration of 0.8 mg/L), chlorine (2-3 mg/L) and chlorine
dioxide (0.4 mg/L). Chlorine disinfection studies were conducted at 30 degrees C (86
degrees F) and 50 degrees C (122 degrees F) to simulate cooling tower and building hot
water system environments, respectively. Monochloramine and chlorine dioxide
disinfection studies were conducted at 30 degrees C (86 degrees F). All samples were
treated with disinfectant for one hour and disinfectant residual concentration was
measured to calculate CT. Each disinfection treatment was determined to be "efficient"
when a 3-log (99.9-percent) reduction was reached. Results showed no difference
between the inactivation of both forms of Legionella by monochloramine, while the other
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disinfectants (chlorine and chlorine dioxide) were not as efficient in inactivating the
intracellular Legionella.
•	Jacangelo et al. (2002) examined inactivation of waterborne emerging pathogens such as
Legionella by selected disinfectants, including monochloramine. Pre-formed
monochloramine was used at a target pH of 7.0. Two different temperatures (5 degrees C
(41 degrees F) and 25 degrees C (77 degrees F)) and two different mass ratios of chlorine
to ammonia (3:1 and 7:1) were examined. The observed CT values for 99-percent
inactivation (2-log reduction) of L. pneumophila ranged from >320 to >1,000 min-mg/L.
At a water temperature of 5 degrees C (41 degrees F), the CT value at a 3:1 ratio was
>1,000 min-mg/L and was >320 to >1,000 min-mg/L at a 7:1 ratio. At a temperature of
25 degrees C (77 degrees F), the CT was >630 to >1,000 min-mg/L at a 3:1 ratio and was
>320 to >1,000 min-mg/L at a 7:1 ratio. These CT values were similar to CT values for
Giardia inactivation under the same conditions.
•	Donlan et al. (2002) conducted a study with three different monochloramine
concentrations (0.2 mg/L, 0.5 mg/L and 1.5 mg/L) and three different contact periods (15,
60 and 180 minutes). All scenarios involved a temperature of 30 degrees C (86 degrees F)
and a pH of 7. A monochloramine concentration of 0.2 mg/L was ineffective for all
contact periods. At the 0.5-mg/L concentration and 180-minute contact time, 99 percent
of L. pneumophila was inactivated (i.e., 2-log removal). Using the 1.5-mg/L
concentration of monochloramine, 99.9 percent of L. pneumophila was inactivated (i.e.,
3-log removal) at 60 and 180 minutes contact time.
•	A study conducted by Cunliffe (1990) evaluated L. pneumophila contact time in a lab-
simulated model experiment. This study used a 2.5:1 chlorine-to-ammonia mass ratio
prepared by mixing ammonium chloride with sodium hypochlorite at 30 degrees C (86
degrees F) and pH 8.4-8.6. The average CT level for 99-percent inactivation was 15 min-
mg/L. The results showed that L. pneumophila was more sensitive to monochloramine
than Jl coli.
The wide range of CT values reported in the literature could be due to different water quality
conditions and different methodologies used for inactivating Legionella.
In another laboratory study, Tiiretgen (2008) did not calculate CT but determined the resistance
of L. pneumophila to monochloramine, taking into account both culturability and viability. He
found that at 2 mg/L, after 24 hours, an environmental isolate of L. pneumophila serogroup 1
could not be cultured. However, viable L. pneumophila were detected using epifluorescence
microscopy.
One study compared the occurrence of Legionella in water distribution systems with chlorine
and monochloramine disinfected water. Whiley et al. (2014) measured Legionella spp., L.
pneumophila and mycobacterium avium complex in two drinking water distribution systems:
distribution system (DS) 1, using chlorine disinfection, and DS2, using chloramine disinfection.
Samples were collected and disinfectant residual was measured four times throughout the year
and at different distances from the treatment plant. In DS1, the five sampling sites were located
between 5 and 22 kilometers (km) from the treatment plant and had free chlorine residuals in the
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range of 0.2 to 1.3 mg/L. In DS2, the five sampling sites were located between 1 and 137 km
from the treatment plant and had monochloramine residuals in the range of <0.05 (at a dead-end
location) to 3.9 mg/L. All three microbes were detected throughout both distribution systems and
at different points throughout the year. The only recurring trend was an increase in
microorganisms when the disinfectant residual decreased (for both chlorine and chloramine),
especially at dead ends in the system (<0.05 mg/L of monochloramine).
Several laboratory and pilot-scale studies reported on the efficacy of monochloramine in
controlling Legionella when biofilm is present on pipe surfaces.
•	Wang et al. (2012) evaluated the effects of disinfectant (chlorine and chloramine), water
age (1 to 5.7 days) and pipe material (polyvinyl chloride, iron and cement) on multiple
pathogens, including Legionella, using simulated distribution systems. Two sampling
events occurred after six and 14 months. The results showed systems treated with
chloramines had higher levels of bacteria and protozoa at shorter water ages than systems
treated with chlorine. Chloramine concentrations were depleted faster than chlorine due
to nitrification of the chloramine. The effects of pipe type on pathogen growth mainly
became evident after water age reached 5.7 days, after the majority of the disinfectant
residual was depleted. Legionellae were only detected during the 14-month sampling
event in bulk water and at lower water ages for chloraminated systems.
•	Loret et al. (2005) evaluated disinfectants and their effects on biofilm. They studied
Legionella control in a pipe loop receiving continuously treated water. Monochloramine
treatment was evaluated for one month. The ratio of chlorine to ammonia for
monochloramine was 2:1, and an average dose of 0.5 mg/L was used. Planktonic
Legionella decreased to undetectable levels after three days and stayed undetectable for
the remainder of the month. There were no viable Legionella in the biofilm after six days
of treatment. Biofilm thickness increased with monochloramine treatment after one
month of treatment, unlike with the other disinfectants (e.g., chlorine, chlorine dioxide).
The study results showed that monochloramine was effective against Legionella, but it
was not effective in removing the biofilm completely (Loret et al., 2005). Their study
concluded that monochloramine was ineffective at inactivating amoeba or biofilm. For a
more detailed description of the Loret (2005) study see Section 2.3.1.2.
•	Lee et al. (2011) and Pressman et al. (2012) used microelectrodes to investigate the
penetration of chlorine, monochloramine, oxygen and free ammonia in nitrifying biofilm.
While this research clearly demonstrated that monochloramine had a greater penetration,
the authors found this penetration did not necessarily translate to immediate viability loss.
Even though free chlorine's penetration was limited compared to that of
monochloramine, it more effectively (on a cell membrane integrity basis) inactivated
microorganisms near the biofilm surface. The authors also found that the presence of
higher free ammonia concentrations allowed a larger biomass to remain active during
monochloramine application, particularly the organisms deeper within the biofilm,
leading to faster recovery in oxygen utilization when monochloramine was removed. The
authors suggested that limiting the free ammonia concentration during monochloramine
application would slow the onset of nitrification episodes by maintaining the biofilm
biomass at a state of lower activity.
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•	Donlan et al. (2002) evaluated L. pneumophila levels within a biofilm reactor. They
found monochloramine to be more effective than chlorine in identical conditions for L.
pneumophila inactivation, leading the authors to conclude that monochloramine may be
more effective for the inactivation of Legionella in drinking water distribution systems.
Several studies evaluated the addition of monochloramine for the treatment of premise plumbing
systems.
•	Coniglio et al. (2015) studied the addition of monochloramine following colonization of
two hospital hot water systems with L. pneumophila serogroups 3 and 6 (100 percent of
samples were positive). Prior to installing monochloramine treatment, the hospital had
implemented a combined control strategy which proved to be ineffective:
o Raised the hot water temperature from 55-60 degrees C (131-140 degrees F) to
65-70 degrees C (149-158 degrees F);
o Periodic shock hyperchlorination (50 ppm as free chlorine for 1 hour at distal
sites),
o Point-of-use filters (0.2 micron) in high risk areas, changed every 30 days;
o Addition of hydrogen peroxide (17 mg/L).
Upon installation of monochloramine treatment, temperature was lowered to 60 degrees
C (140 degrees F); pH was between 7.8 and 8.5. Monochloramine treatment began at 3.0
mg/L and after one month was decreased to 2.0-2.5 mg/L. For the next year, legionellae
were undetected in all samples, except during one month when the monochloramine
generator failed for 15 days. Ammonium, nitrite and nitrate levels did not exceed their
limits during the study.
•	Baron et al. (2015) noted that treatment of a building's hot water system with
supplemental monochloramine resulted in reduced total bacteria count, as well as reduced
species diversity, compared to a control (untreated) hot water system that supplied water
provided by the PWS. They observed that the reduced bacterial diversity resulted in a
lack of competition which could provide an opportunity for Legionella to colonize a
premise plumbing system, particularly if treatment is interrupted or compromised.
•	Baron et al. (2014a) studied the microbial ecology of a hot water system within a hospital
following the introduction of monochloramine. Samples were taken three months before
and immediately prior to the addition of an on-site monochloramine generation system
and then every month for six months after the addition. Monochloramine levels were
targeted at 1.5-3.0 mg/L as chlorine. Samples were taken at multiple sites within the
hospital's hot water system and analyzed by three methods. The authors observed a shift
in microbial ecology immediately after the addition of the disinfectant; the number of
operational taxonomic units significantly increased. Microbial ecology variation based on
sampling location within the hospital's hot water system (including automatic and
standard faucets) increased after the addition of monochloramine. There was a
statistically significant increase in the relative abundance of genera associated with
denitrification after the addition of monochloramine. Waterborne pathogen-containing
genera were also examined. After the addition of monochloramine, an increase in counts
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of Acinetobacter, Mycobacterium, Pseudomonas and Sphingomonas was observed, using
16S rRNA sequencing. Trends for Legionella counts varied but did not show an increase.
The sequencing method used was not specific enough to determine changes in individual
species; however, a longer-term study of the same facility using cell culture (Duda et al.
(2014), described later in the document) noted that P. aeruginosa did not increase and L.
pneumophila serogroup 1 decreased. The addition of monochloramine to the hospital's
water system had an impact on the types and amounts of microorganisms found in the hot
water system.
•	Duda et al. (2014) observed a significant reduction in Legionella at distal sites (i.e., sink
taps and showers located at distant points in the premise plumbing system) after a
monochloramine generation system was installed in a hospital hot water system,
replacing a copper-silver ionization system. Monochloramine levels ranged from 1.0 to
4.0 mg/L, measured as Cb. The average number of positive sites declined from 53
percent during baseline to 9 percent post-disinfection, based on 29 months of monitoring
data including a five-month baseline period and 24 months' data following installation.
For most of the post-disinfection study, the percentage of positive distal sites was less
than 10 percent. However, during months 10, 12 and 24, the percentage of positive
samples was 26, 33 and 22 percent, respectively. During months 10 and 12, the authors
noted that nitrate and total ammonia were elevated, suggesting incomplete reaction of
chlorine and ammonia and thus decreased formation of monochloramine. The authors
noted that no samples tested positive for nitrifying bacteria. The authors also noted
increased pH during these months and month 24, greater than the optimal pH for
monochloramine disinfection (7.5). Legionella speciation changed as a result of
monochloramine disinfection. L. pneumophila serogroup 1 presence in samples, for
instance, decreased from 90 percent of samples during baseline to 49 percent post-
disinfection, while L. bozemanii presence increased. The authors found that presence of
other opportunistic bacteria, such as P. aeruginosa and Mycobacteria, did not increase
post-disinfection.
•	Casini et al. (2014) studied monochloramine disinfection at dosage rates of 2-3 mg/L in
the hot water system of a university hospital. Compared to disinfection with chlorine
dioxide at 0.4-0.6 mg/L, monochloramine performed better because it removed
planktonic Legionella and it didn't require endpoint filtration. At a monochloramine
dosage rate of 2 mg/L, nontuberculous Mycobacteria were isolated; increasing the dosage
rate to 3 mg/L reduced the culturability of Mycobacteria.
•	A hospital in Italy added monochloramine treatment to a hot water network within the
building using a device to continuously distribute monochloramine (Marchesi et al.,
2013; Marchesi et al., 2012). The disinfectant levels were maintained between 1.5 and 3.0
mg/L. Hot water samples were analyzed for Legionella spp. and Pseudomonas spp. over
a one-year period. Both organisms decreased in terms of the number of positive samples.
Before the addition of continuous treatment, 97 percent of samples were positive for
Legionella. After treatment, approximately 13 percent of samples were positive for
Legionella. The authors concluded that, based on this study, continuous injection of
monochloramine in a building hot water system has potential for controlling Legionella
(Marchesi et al., 2012). Marchesi et al. (2013) continued the study for a total of 36
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experimental months with the same parameters for monochloramine and confirmed that
Legionella control with monochloramine was rapid, as 7 out of the 8 positive samples
occurred within the first eight months of the total 36-month experimental period. The
eighth positive sample occurred at 15 months, when the monochloramine dosage rate
decreased below 1 mg/L. Use of monochloramine did not increase chlorite levels and
nitrification did not occur. The authors suggested that a monochloramine concentration
between 2 and 3 mg/L should be maintained to assure a Legionella concentration less
than 102 CFU/L.
Several studies evaluated Legionella occurrence in premise plumbing systems receiving
water from a PWS, and no additional treatment was provided at the buildings.
•	Weintraub et al. (2008) evaluated water and biofilm samples from hot water systems in
53 buildings in San Francisco before and after the PWS switched to monochloramine for
residual disinfection in February 2004. Chlorine was used for primary disinfection
throughout the study period. The total chlorine level in finished water was 0.6 mg/L on
average prior to conversion and 1.97 mg/L on average in 2004 following conversion.
Samples were collected from each building six times during the two-year study period—
three samples before and after the conversion to monochloramine. Sampling results
showed that 60 percent of hot water systems and 72 percent of buildings contained
Legionella before conversion to monochloramine compared to 4 percent of hot water
systems and 9 percent of buildings after the conversion. After the conversion to
monochloramine, there was an approximate 10-fold increase in the concentration of total
chlorine in the buildings' hot water systems. Also, prevalence of Legionella decreased by
96 percent in POU outlets (Weintraub et al., 2008).
•	Flannery et al. (2006) compared Legionella colonization of hot water systems for two
years to determine if a conversion from chlorine to monochloramine in the municipal
water supply would reduce Legionella levels in the building hot water system. The results
showed 60 percent colonization of the hot water system before conversion and 4 percent
colonization after the conversion. After switching to a disinfectant with a more stable
residual, higher concentrations of total chlorine were measured within building hot water
systems. The authors concluded that increasing the amount of water supplies disinfecting
with monochloramine might reduce the incidence of Legionnaires' disease.
•	Moore et al. (2006) evaluated Legionella colonization within building hot water systems
in Pinellas County, Florida, before and after the wholesale PWS had converted from
chlorine to monochloramine for residual disinfection treatment. Legionella colonization
of premise plumbing systems decreased from 19.8 percent (19 of 96 buildings) to 6.2
percent (6 of 96 buildings). The samples in this study were taken a few months before
and a few months after the conversion to monochloramine.
•	Heffelfinger et al. (2003) concluded that hospital water systems using a monochloramine
disinfectant residual were at a lower risk of Legionnaires' disease cases than systems
using a chlorine residual, based on survey data. Out of 459 surveys sent, 166 hospitals in
the U.S. responded (a 36-percent response rate). Of the 166 survey respondents, 38 (25
percent of survey respondents) were selected as case studies because they had reported
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definite cases of Legionnaires' disease in the period 1994 to 1998 or outbreaks of
hospital-acquired Legionnaires' disease in the period 1989 to 1998, and they had not
changed their water disinfection practices during the study period. Six of the 38 case
study hospitals (16 percent) received municipal water treated with monochloramine for
disinfection. Hospitals reporting occurrence of Legionnaires' disease were more likely to
have used supplemental disinfection beyond that supplied by the municipal water. Of the
128 survey respondents that reported no cases of Legionnaires' disease during the study
period, 59 (46 percent) used monochloramine disinfection. The hospitals supplied by
drinking water with a monochloramine disinfectant residual were less likely to have
definite cases or outbreaks than hospitals with chlorine disinfectant residuals (adjusted
odds ratio: 0.20; 95-percent confidence interval: 0.07-0.56).
• Kool et al. (2000) conducted a case control study comparing disinfection methods in
water supplied to hospitals with reported Legionnaires' disease (32 hospitals) with the
disinfection methods used in water supplied to control hospitals (48 hospitals) with no
reported disease. They found that hospital water systems supplied with water treated by
chlorine were more likely to have reported an outbreak of Legionnaires' disease than
hospitals supplied with water treated by monochloramine (odds ratio 10:2 and 95-percent
confidence interval: 1.4-460). The authors infer that 90 percent of the outbreaks might
have been prevented had the residual used in the case hospitals contained
monochloramine (Kool et al., 2000; Kool et al., 1999). The cases in this study were based
on previous records of infections and not on Legionella measurements in the water
supply (Kim et al., 2002).
2.3.2.3 Potential Water Quality Issues
Potential water quality issues associated with monochloramine include corrosion, formation of
DBPs and nitrification. The use of monochloramine can cause corrosion of the pipes and
materials used in water systems. Corrosion can occur in two forms, including pitting and a more
uniform thinning of pipe surfaces (Kirmeyer et al., 2004). Zhang et al. (2002) studied the effects
of monochloramine on uniform corrosion of copper coupons at pH values of 7.6 to 8.4 and
observed that the corrosion mechanism may be significantly affected by the presence of
monochloramine.
Kirmeyer et al. (2004) also reported that chloramine can attack rubber and plastic components in
a water system and that 43 percent of utilities surveyed experienced an increase in degradation of
rubber materials after chloramine disinfection was implemented. Loret et al. (2005) observed
corrosion marks on mild and galvanized steel coupons installed in pipe loops for
monochloramine treatment that were similar to corrosion marks on coupons exposed to other
disinfectants (chlorine, chlorine dioxide, CSI and ozone), except the coupons exposed to CSI
also had copper deposits.
Monochloramine can react with pipe scale differently than other disinfectants, resulting in lead
leaching in system materials containing lead (Edwards and Dudi, 2004). However, corrosion
may not occur in all cases. Duda et al. (2014) found a temporary increase in copper and silver
concentrations during the first few months of their 18-month study, which they felt was due to
the release of copper and silver ions that had accumulated during prior treatment with copper-
silver ionization. Corrosion control and maintenance of premise plumbing systems will be
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important to consider before adding disinfectants. Further research is needed to evaluate the
interactions of disinfectants with water chemistry and piping materials in a premise plumbing
system and to better understand the effects of these interactions on the efficacy of pathogen
inactivation (Rhoads et al., 2014). Water temperature, pH and disinfectant concentration affect
corrosion rates.
Additional information about chloramines and chloramine-related research, and answers to
questions raised by the public related to exposure to chloramines can be found at EPA's website:
http://www.epa.gov/dwreginfo/basic-information-about-chloramines-and-drinking-water-
disinfection. Monochloramine has the ability to react with organics, inorganics and non-halogens
in the water to form DBPs (USEPA, 2006b).
Although chloramination significantly reduces formation of some DBPs associated with chlorine
disinfection, such as THM and HAAs, its usage can contribute to the formation of other DBPs
such as nitrosamines. For more information regarding nitrosamines please see the N-
nitrosodimethylamine (NDMA) fact sheet (USEPA, 2014a) at EPA's website:
http://www2.epa.gov/sites/production/files/2014-
03/documents/ffrrofactsheet contaminant ndma january2014 final.pdf. NDMA does not
currently have a health-based standard under the Safe Drinking Water Act. EPA's Integrated
Risk Information System (IRIS) has classified NDMA as a probable human carcinogen based on
the induction of tumors in rodents and non-rodent mammals.
Nitrification is a potential problem for utilities that utilize chloramines as a disinfectant and may
occur when finished water contains excess ammonia and low chloramine residual (Kirmeyer et
al., 2004). Areas of the distribution system with higher water age and warmer temperatures are
more susceptible to nitrification. Nitrification is a microbiological process that oxidizes ammonia
to form nitrite and nitrate. Increased nitrate levels provide nutrients for the growth of nitrifying
bacteria. Nitrification can also degrade the aesthetic quality of the water resulting in taste and
odor issues as well as particles in the water (AWW A, 2013). Breakpoint chlorination can occur
due to imbalances in chlorine and ammonia concentrations, resulting in the formation of nitrate,
nitrogen chloride and nitrogen gas. Once nitrification occurs, maintaining monochloramine
disinfectant residual becomes very difficult within the nitrified areas of the distribution system,
allowing pathogenic organisms that may be present in biofilm or pipe scale to proliferate. The
American Water Works Association's (AWW A) Manual M56 recommends that any utility using
chloramines develop and implement a nitrification control plan (AWW A, 2013).
Monochloramine can inhibit biological growth on filters, which could be positive in that it helps
keep the filters clean, but this inhibition can also reduce biodegradable dissolved organic carbon
removal, a problem if the filters were put in place for that purpose. Although nitrification may be
an issue for public water distribution systems, several studies in hot water premise plumbing
systems found no evidence of nitrification (Coniglio et al., 2015; Duda et al., 2014; Marchesi et
al., 2013, 2012).
Converting disinfection to monochloramine can have an impact on organisms other than
Legionella. A study by Moore et al. (2006) found that, in addition to Legionella, premise
plumbing systems were colonized with Mycobacteria before and after a conversion from
chlorine to monochloramine in the PWS. The proportion of buildings colonized with
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Mycobacteria increased from 19.1 percent during the chlorine phase to 42.2 percent after the
conversion to monochloramine. The number of samples within the distribution system containing
detectable levels of coliform increased from two samples during the chlorine phase to twenty
samples after the conversion (Moore et al., 2006).
Pry or et al. (2004) saw similar results in a study conducted in Florida. After conversion to
monochloramine, Mycobacteria increased, total coliforms and heterotrophic bacteria levels
increased, and nitrification occurred in the storage tanks. Facility owners or operators who
consider treating water with monochloramine to control for Legionella should be cognizant of
potential unintended consequences, such as increases in Mycobacteria and other waterborne
pathogens, and take the necessary protective measures to protect public health. Gomez-Alvarez
et al. (2012) also observed that Legionella-like genes were more abundant under chlorine
treatment, while mycobacterial genes were more abundant under monochloramine treatment
conditions in laboratory simulated distribution systems.
2.3.2.4 Operational Conditions
Parameter Conditions Indicating Operational Effectiveness
The normal dosage rate for monochloramine is between 1.0 and 4.0 mg/L.
The case studies cited earlier generally support maintaining a chloramine residual in the premise
plumbing system in the range of 1 to 2 mg/L as an effective means for containing biofilm
growth, minimizing Legionella colonization and preventing outbreaks. As such, premise
plumbing system practices such as maintenance of appropriate pH, maintenance of chlorine-to-
ammonia ratios, flushing and frequent monitoring to demonstrate residual maintenance on an
ongoing basis are essential. The current practice is to use a chlorine-to-ammonia ratio of 3:1 to
5:1 to produce monochloramine. The amount of organic nitrogen in the water prior to addition of
ammonia will also affect how much ammonia is needed to reach the desired ratio (USEPA,
1999c).
The rate of reaction for the conversion of chlorine to monochloramine is sensitive to pH and can
also be affected by contact time and temperature. The optimum pH range for formation of
monochloramine is 7.5 to 9 (WHO, 2004). Monochloramine is relatively stable under varying
temperatures once formed. Cunliffe (1990) evaluated monochloramine decay at two different
temperatures. Water incubated at 55 degrees C (131 degrees F) showed a loss of residual after 50
hours, from 1.3 to 0.35 mg/L. After five days at 30 degrees C (86 degrees F), the concentration
dropped from 1.3 to 0.8 mg/L.
Installation Considerations
Guidelines for design and implementation of chloramination systems include the following:
•	AWWA M56 Manual, Nitrification Prevention and Control in Drinking Water. Second
Edition (AWWA, 2013).
•	Simultaneous Compliance Guidance Manual for the Long Term 2 and Stage 2 DBP Rules
(USEPA, 2007).
•	The Water Research Foundation manual Optimizing Chloramine Treatment (Kirmeyer et
al., 2004).
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• Alternative Disinfectants and Oxidants Guidance Manual (EPA 815-R-99-014) (USEPA,
1999c).
Monitoring Frequency and Location
The SWTR (USEPA, 1989a) requires all PWSs that use surface water or ground water under the
direct influence of surface water and that choose monochloramine as a disinfectant to monitor for
the presence of a disinfectant residual in the distribution system and at the EP. The disinfectant
level must be at least 0.2 mg/L at the EP and detectable in at least 95 percent of samples
collected within the distribution system.
The Stage 1 D/DBPR also requires PWSs that use monochloramine to maintain a residual
disinfectant level running annual average of less than 4.0 mg/L (USEPA, 1998).
PWSs that use chloramines are required to monitor for combined or total chlorine residual or
HPC in the distribution system at locations that have been approved by the primacy agency.
These parameters could provide operational information to indicate the need for chloramine dose
adjustments, system flushing and water age management within finished water storage facilities.
Monochloramine can be measured by amperometric titration (Symons, 1978), N,N-di ethyl-p-
phenylenediamine (DPD) ferrous titrimetric, DPD colorimetric methods (USEPA, 1999c) and
commercially available adapted indophenol methods (Hach MonochlorF) (Lee et al., 2007). EPA
has approved multiple methods for measuring combined chlorine as well as total chlorine. A list
of approved methods is available through EPA's website (USEPA, 2014b).
Other monitoring should be conducted to identify the onset of nitrification, which is common in
systems that use chloramination. Kirmeyer et al. (2004) recommended monitoring HPC,
chloramine residual, ammonia, nitrate and nitrite to detect nitrification in the distribution system.
A system-specific monitoring plan should be developed to identify sampling locations,
parameters and sampling frequency.
Maintenance Needs
Operating and maintenance practices for chloramine disinfection systems include maintenance of
an appropriate disinfectant residual, regular system cleaning and flushing, inspections and water
quality monitoring. Newly constructed or rehabilitated piping systems are cleaned and flushed
prior to initial disinfection. Routine flushing and water quality monitoring are recommended to
assure that adequate disinfectant levels are maintained throughout the premise plumbing system
(HSE, 2014).
Many systems using monochloramine as a residual disinfectant periodically use free chlorine to
control biological growth that may have occurred in the distribution system or on equipment
(AWWA, 2013).
Approaches for preventing nitrite and nitrate formation within the distribution system include
decreasing water age through flushing or operational changes, increasing the pH, decreasing
temperature, decreasing total organic carbon concentration, increasing monochloramine
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residuals, increasing the chlorine-to-ammonia ratio and decreasing the excess ammonia
concentration (USEPA, 1999c).
2.3.3 Chlorine Dioxide
2.3.3.1	Background
Chlorine dioxide is a water-soluble gas that can easily diffuse through cell membranes of
microorganisms. It has been found to be superior in penetrating biofilms as compared to chlorine
(Lin et al., 201 lb). Studies have shown that chlorine dioxide is an effective disinfectant (when
used correctly) for inactivating certain bacterial pathogens (e.g., E. coli, Salmonella), viruses
(e.g., poliovirus, coxsackie virus) and protozoan pathogens (e.g., Giardia) (USEPA, 1999c). It
has a high oxidation potential). Its use as a biocide can be maintained over a wider pH range than
can the use of chlorine or CSI (Lin et al., 201 lb).
Chlorine dioxide was first used as a disinfectant in the early 1900s at a spa in Belgium; its use in
drinking water disinfection became more common in the 1950s (USEPA, 1999b). In the 1970s,
more than 100 U.S. water treatment facilities used chlorine dioxide for taste and odor control,
iron and manganese oxidation, or final disinfection; in Europe, chlorine dioxide was being used
at several thousand water treatment facilities, primarily for final disinfection (Symons et al.,
1977). In the 1980s, use of chlorine dioxide as an alternative primary disinfectant to chlorine
increased in the United States after EPA promulgated a regulation for TTHM (Aieta and Berg,
1986). Since the late 1980s, chlorine dioxide has been evaluated (Dupuy et al., 2011; Loret et al.,
2005; Jacangelo et al., 2002; Berg et al., 1988) and later implemented as an effective disinfectant
to control Legionella and biofilm in hot and cold premise plumbing systems (Casini et al., 2014;
Marchesi et al., 2013; Cristino et al., 2012; Marchesi et al., 2011; Zhang et al., 2009; Sidari et al.,
2004).
Use of chlorine dioxide in PWSs is regulated by the Stage 1 and Stage 2 D/DBPRs. Chlorine
dioxide itself can cause acute health effects and has an MRDL of 0.8 mg/L. Chlorite, a DBP of
chlorine dioxide disinfection, is also regulated by EPA due to potential health concerns. The
Stage 1 D/DBPR sets an MCL of 1.0 mg/L for chlorite.
Chlorine dioxide is usually generated on site from sodium chlorite solutions and one or more
other chemical precursors (e.g., sodium hypochlorite, hydrochloric acid, sulfuric acid) or by an
electrochemical oxidation process. Stock solutions produced on site typically have a
concentration of 500 mg/L. Chlorine dioxide gas cannot be compressed or stored commercially
because it is explosive under pressure. Therefore, chlorine dioxide gas is never shipped (USEPA,
1999b). Water treatment chemicals must meet the appropriate ANSI/AWWA standards or
NSF/ANSI Standard 60 (GLUMRBSPPHEM, 2012).
2.3.3.2	Characterization of Effectiveness against Legionella
Laboratory and pilot-scale testing have generally shown that chlorine dioxide disinfection can be
effective in controlling Legionella:
• Dupuy et al. (2011) compared chlorine dioxide, chlorine and monochloramine in treating
L. pneumophila and Acanthamoeba strains alone or in co-cultures (i.e., L. pneumophila
grown within amoebae). Dosage rates were 0.4 mg/L for chlorine dioxide, 2-3 mg/L for
chlorine (for a residual free chlorine concentration of ~1 mg/L) and 0.8 mg/L for
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monochloramine. All samples were treated with disinfectant for one hour and then the
disinfectant residual was measured. Chlorine and chlorine dioxide were more efficient at
reducing free L. pneumophila than co-cultured L. pneumophila (i.e., providing at least a
3-log (99.9-percent) reduction of the bacterial population at study conditions). Chlorine
dioxide was found to be highly efficient in inactivation of Acanthamoeba M3 amoebae
only, less so in inactivating the other two Acanthamoeba strains discussed in the paper.
•	Loret et al. (2005) compared the performance of several alternative disinfectants under a
controlled pilot-scale simulation of a typical premise plumbing system. Tap water and
injection of cultured natural Legionella strains were used to establish biofilms in each
pipe loop. Low temperature (35 degrees C, or 95 degrees F) and low water velocity were
maintained to favor the growth of Legionella and biofilms. Each pipe loop was treated
with one of the studied disinfectants for three months. The target dosage rate for chlorine
dioxide was 0.5 mg/L. The authors determined that chlorine dioxide and chlorine were
the most effective in controlling Legionella, biofilm and protozoa. Chlorine dioxide had
longer residual activity in the system than did chlorine. Chlorite levels were measured in
the chlorine dioxide pipe loop at levels >0.2 mg/L. Legionella populations decreased to
undetected levels (<500 CFU/L) within the first three days of treatment for all
disinfectants. Biofilm reduction started one week after treatment was initiated. Biofilm
thickness was reduced to <5 |im with chlorine dioxide and several other disinfectants, as
compared to a measured biofilm thickness of 13-35 |im in the untreated pipe loop.
•	Jacangelo et al. (2002) conducted laboratory studies to evaluate chlorine dioxide, free
chlorine and monochloramine for inactivation of waterborne emerging pathogens,
including Legionella. The chlorine dioxide dose rate was 1.0 mg/L. Two different
temperatures (5 and 25 degrees C, or 41 and 77 degrees F) and two different pH values
(6.0 and 8.0) were examined. The observed CT values for 2-log (99-percent) reduction
of Legionella were reported. At 5 degrees C, the observed CT values ranged from >320
to >1,000 min-mg/L at pH 6.0 and from >250 to 630 min-mg/L at pH 8.0. At 25 degrees
C, the observed CT values ranged from 50 to 200 at pH 6.0 min-mg/L and from 50 to 130
min-mg/L at pH 8.0.
However, one laboratory study found that L. pneumophila was not inactivated by disinfection
with chlorine dioxide at levels that might be used for shock disinfection (emergency
remediation). Mustapha et al. (2015) compared culturability and viability of three L.
pneumophila strains in response to chlorine dioxide exposure. At 4 mg/L, L. pneumophila could
be detected using cell culture, but at 6 mg/L, no bacteria were detected. However, the authors
found that VBNC cells could be detected at chlorine dioxide concentrations of 4-7 mg/L using
flow cytometry. Two strains of the VBNC cells became culturable after co-culture with
Acanthamoebapolyphaga, but neither strain was able to cause infection in macrophage-like
cells.
Chlorine dioxide disinfection systems have been installed in hospitals to control Legionella and
biofilm in hot and cold water systems (Casini et al., 2014; Marchesi et al., 2013; Cristino et al.,
2012; Marchesi et al., 2011; Zhang et al., 2009; Sidari et al., 2004).
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•	Casini et al. (2014) reported the application of a WSP approach using multiple
disinfectants and filtration to control Legionella in a hospital's hot water system. The risk
management strategy was developed and refined over a 9-year period. Continuous
disinfection with chlorine dioxide (0.4-0.6 mg/L in recirculation loops) was provided.
Additional treatment included endpoint filtration and a shift to monochloramine
disinfection (2-3 mg/L) after chlorine-tolerant Legionella spp. were identified. After nine
years, the number of sampling sites that were positive for Legionella decreased by 51
percent, from 66.7 percent to 32.9 percent, and the mean Legionella count decreased by
78 percent.
•	Marchesi et al. (2013) reported a strong reduction in L. pneumophila contamination in
three hospital hot water systems over a three-year period compared to the untreated
systems. A concentration of 0.50-0.70 mg/L chlorine dioxide was applied to the hot
water systems, which contained water at temperatures up to 60 degrees C (140 degrees F)
in the recirculation loop, with the goal of maintaining a minimum concentration of 0.30
mg/L at distal sites. On average, the three systems reduced Legionella occurrence from
96 percent of sampling sites to 46 percent.
•	Cristino et al. (2012) described use of chlorine dioxide for chemical shock treatment and
continuous treatment after the hot water system in a long-term care facility was found to
be colonized with L. pneumophila. In addition to thermal shock and chemical shock with
peracetic acid, chlorine dioxide was applied at a dose sufficient to obtain a 5-mg/L
residual throughout the premise plumbing system for a one-hour contact time. The water
was then drained and fresh water introduced to the systems until the chlorine dioxide
residual was <0.3 mg/L. A continuous chlorine dioxide system was installed in the hot
water supply at a dose sufficient to maintain a minimum 0.3-mg/L residual at distal taps.
The shock treatment reduced Legionella counts from 104—105 CFU/L to zero to 102
CFU/L. Environmental monitoring conducted during the continuous chlorine dioxide
treatment period showed that Legionella counts remained at stable levels (zero to 103
CFU/L). No cases of hospital-acquired legionellosis occurred during the study period.
•	Marchesi et al. (2011) compared the performance of treatment alternatives for controlling
Legionella contamination in hospital hot water systems, including two hot water plants
that installed chlorine dioxide treatment systems in 2005. Chlorine dioxide successfully
maintained Legionella levels at <100 CFU/L when the dosage rate was maintained at a
minimum of 0.3 mg/L at outlets; however, when the boiler water temperature was less
than 58 degrees C (136 degrees F), treatment was ineffective. Electric boilers and POU
filters had better performance than chlorine dioxide.5 The authors suggested
implementing chlorine dioxide and electric boilers in parallel to control Legionella.
5 The electric boilers were installed on cold water lines in high-risk areas; each boiler served one to two patient
rooms.
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•	Zhang et al. (2009) evaluated using chlorine dioxide to treat for L. pneumophila in two
hospitals reporting cases of hospital-acquired legionellosis. Water quality parameters
were very similar between the two systems, except pH was 7.70 for Hospital A and 8.57
for Hospital B. Water temperatures in cold and hot water taps were 4-31 degrees C (39-
88 degrees F) and 27-52 degrees C (81-186 degrees F), respectively. Hospital B had
previously tried a superheat-and-flush of the hot water system and replacing a storage
tank that was colonized with Legionella, but those measures were unsuccessful.
Disinfection systems installed at Hospital A (January 2003) and Hospital B (April 2004)
injected chlorine dioxide at the cold water service line to each building using a dosage
rate of 0.5-0.7 mg/L. Although both hospitals achieved significant reductions in
Legionella occurrence in the hot water system, Hospital B achieved control after six to 10
months of treatment, whereas Hospital A required 18 months. The longer treatment
period for Hospital A was attributed to the longer time needed to achieve a chlorine
dioxide residual >0.10 mg/L. The residual concentration for chlorine dioxide at the distal
sites varied from zero to 0.11 mg/L depending on the building, date and type of tap (hot
or cold). The occurrence of Legionella at hot water taps decreased from 60 percent of
sampling sites before chlorine dioxide addition to <10 percent of sampling sites after
treatment; however, a significant decrease in the concentration of Legionella in positive
samples was not observed. No cases of hospital-acquired Legionnaires' disease were
detected after installation of the chlorine dioxide system.
•	Sidari et al. (2004) reported on the first controlled field evaluation in the United States of
a chlorine dioxide treatment system installed in June 2000, at a hospital linked to three
cases of hospital-acquired Legionnaires' disease. Legionellae were eliminated (i.e., the
authors had no positive results) from the hot water system, but only after 20 months of
treatment. Rates of positive Legionella detections decreased significantly, from 23
percent to 12 percent for hot water taps, and to almost zero percent for the cold water
reservoir. Reductions in chlorine dioxide concentrations were observed at hot water distal
sites and were attributed to a longer retention time and elevated water temperatures. Hot
water temperatures at distal sites ranged from 26 to 61 degrees C (79 to 142 degrees F)
during the second sampling phase. Average chlorine dioxide residuals were 88 percent
lower for the hot water tap than the cold, or 0.08 mg/L and 0.68 mg/L, respectively. No
cases of Legionnaires' disease occurred after the chlorine dioxide treatment system was
installed.
2.3.3.3 Potential Water Quality Issues
Chlorite and chlorate are the most prominent byproducts of chlorine dioxide disinfection (WHO,
201 lb; Gates et al., 2009; USEPA, 2006b). Chlorite could cause anemia in some people and
affect the nervous systems of some infants, young children and fetuses of pregnant women.
Ongoing exposure to chlorate ion can lead to an enlarged thyroid (USEPA, 2012). Findings on
DBP formation in building water systems using chlorine dioxide disinfection include:
•	In an Italian hospital where chlorine dioxide was used to control L. pneumophila in the
hot water supply, chlorite levels higher than 0.7 mg/L were measured when the chlorine
dioxide residual was > 0.3 mg/L (Marchesi et al., 2013).
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•	In another study (Zhang et al., 2009), chlorine dioxide concentrations among different
sampling locations over two years ranged from zero to 0.70 mg/L, whereas chlorite
concentrations ranged from zero to 0.82 mg/L. The average chlorate concentrations in hot
and cold water were below the detection limit of 0.10 mg/L.
•	Chlorine dioxide does not form the high levels of chlorinated DBPs that chlorination does
(Gates et al., 2009).
•	Compared to chlorine and monochloramine, chlorine dioxide has more objectionable
tastes and odors at concentrations necessary for secondary disinfection (more than 0.2
mg/L in North America) (Gates et al., 2009). Although the odor threshold of chlorine
dioxide in tap water is not well-documented in the literature, general practice indicates
that concentrations from 0.2 to 0.4 mg/L are easily detected (Gates et al., 2009).
Kerosene-like and cat-urine-like odors were reported in some homes with new carpets
when volatizing chlorine dioxide reacted with airborne volatiles (Dietrich et al., 1991).
Chlorine dioxide is considered less corrosive than chlorine (Lin et al., 201 lb). Some reports
suggest that chlorine dioxide can cause damage to polyethylene pipes (Yu et al., 2013; Chord et
al., 2011; Yu et al., 2011) while another study showed that no pipe failure occurred after 2,000
hours of exposure to 5 mg/L chlorine dioxide (Castagnetti et al., 2011). Chlorine dioxide
concentrations tested by Yu et al. and Castagnetti et al. are greater than those likely to be used
for continuous disinfection. High concentrations are a possibility for shock disinfection purposes.
Information on other types of pipes is sparse (Gates et al., 2009). Loret et al. (2005) observed
corrosion marks on mild and galvanized steel coupons installed in pipe loops for chlorine dioxide
treatment that were similar to corrosion effects for other disinfectants (chlorine, chloramine, CSI
and ozone), except that the coupons exposed to CSI also had copper deposits.
2.3.3.4 Operational Conditions
Parameter Conditions Indicating Operational Effectiveness
Dosage rate is an important design criterion for chlorine dioxide disinfection systems. Chlorine
dioxide dosage rates of 0.4 to 0.7 mg/L were reported by systems experiencing successful
treatment performance (HSE, 2014; Casini et al., 2014; Marchesi et al., 2013; Zhang et al.,
2009). Zhang et al. (2009) reported that the dosage rate was between 0.5 and 0.7 mg/L,
depending on the flow rate of cold water entering the buildings.
The required disinfectant dosage rate is dependent on system-specific conditions including pipe
material and condition, the water's disinfectant demand, water temperature, the extent of biofilm
on pipe surfaces, pipe diameter and length, complexity of the premise plumbing system,
treatment goals (e.g., Legionella control) and the water turnover rate. Zhang et al. (2008)
determined that scale from corroded iron pipe in the distribution system would cause more
chlorine dioxide loss than typical levels of total organic carbon found in finished water. One
study (Zhang et al., 2009) reported the chlorine dioxide demand of the premise plumbing was
determined to be 0.20 mg/L after six hours of contact time at 23 degrees C (73.4 degrees F) and
pH 7.8.
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Maintaining a total chlorine dioxide residual of 0.1-0.5 mg/L at the tap is usually sufficient to
control Legionella, although higher residuals may be necessary in a heavily colonized system
(HSE, 2014). Some systems have established a treatment goal of maintaining a minimum
chlorine dioxide residual of 0.3 mg/L at distal taps (Marchesi et al., 2013; Cristino et al., 2012;
Sidari et al., 2004). If treatment with a residual higher than 0.8 mg/L is determined to be
necessary, the facility should ensure that emergency disinfection procedures are developed and
followed so that human consumption of a concentration of chlorine dioxide greater than the
MRDL does not occur.
Several studies identified factors that limited the effective performance of chlorine dioxide
disinfection for Legionella control:
•	Casini et al. (2014) reported that performance of a hospital water system appeared to be
affected by an accidental event in a water tank of the municipal water system that caused
sediment buildup and increased water contamination in the hospital water system. After
the event, no further reduction in Legionella colonization was observed with only
disinfection treatment. As a result, the hospital modified its WSP to include POU
filtration with 0.2-|im sterile filters in critical areas of the system (e.g., intensive care
units (ICUs), transplant wards).
•	The lack of proper monitoring for a chlorine dioxide treatment system for drinking water
was noted at a New York health care facility after it experienced a Legionella outbreak in
2010 (CDC, 2013). Two hospitalizations for acute respiratory illness were reported and
no deaths occurred.
•	Zhang et al. (2009) noted the importance of achieving an adequate disinfectant residual
and its effect on the amount of time needed to control Legionella.
•	Sidari et al. (2004) reported differences in the time required to control Legionella in a
hospital's hot and cold water systems after a chlorine dioxide treatment system was
installed in June 2000. The water treatment goal was to achieve a minimum chlorine
dioxide residual of 0.3 mg/L at distal sites. Chlorine dioxide residuals in the hot water
loop averaged 0.08 mg/L (88 percent lower) compared to an average of 0.33 mg/L at cold
water taps. This may explain why 20 months of treatment was required to control (i.e.,
achieve zero occurrence) Legionella from the hot water system, whereas only 15 months
of treatment was needed for the cold water system.
Installation Considerations
The location of disinfectant application point(s) is a critical design decision. The location may
affect the required dosage rate and the time needed to inactivate Legionella. For example, if
chlorine dioxide is added at the cold water service entry point to the building, the dosage rate
should be sufficient to achieve an adequate disinfectant residual at hot water taps at distant points
in the building. However, the need to comply with drinking water standards may drive a design
decision to install multiple treatment units in the building's premise plumbing system.
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Monitoring Frequency and Location
The SWTR (USEPA, 1989a) requires that all PWSs using chlorine dioxide monitor for the
presence of a disinfectant residual in the distribution system and at the EP. The disinfectant level
must be at least 0.2 mg/L at the EP and detectable in at least 95 percent of samples collected
within the distribution system. The Stage 1 D/DBPR requires that all PWSs using chlorine
dioxide monitor daily at each entry point to the distribution system to ensure it is not exceeding
the MRDL (USEPA, 1998). Chlorine dioxide is a contaminant with acute health effects. Chlorine
dioxide has a short sample hold time and should be measured immediately after sample
collection; therefore, under the Stage 1 D/DBPR, on-site analysis at the water system is required.
If the daily chlorine dioxide measurement exceeds 0.8 mg/L, three follow-up distribution system
chlorine dioxide samples must be measured the following day, as required by the Stage 1
D/DBPR.
The Stage 1 D/DBPR and Stage 2 D/DBPR require that all PWSs using chlorine dioxide monitor
chlorite for compliance with the MCL (USEPA, 2006b). Chlorite must be monitored daily at the
EP, in addition to being measured in a three-sample set each month in the distribution system as
detailed in the Code of Federal Regulations (CFR) at 40 CFR 141.132(b)(2). Daily monitoring
can be conducted on-site; monthly monitoring should be conducted at a certified laboratory (see
40 CFR 141.131(b). Footnote 8 in Table).
Maintenance Needs
Operation and maintenance practices for chlorine dioxide disinfection systems include
maintenance of a disinfectant residual, regular system cleaning and flushing, inspections and
water quality monitoring. Routine flushing and water quality monitoring are recommended to
assure that adequate disinfectant levels are maintained throughout the premise plumbing system
(HSE, 2014).
2.3.4 Copper-Silver Ionization
2.3.4.1 Background
Commercially available CSI systems typically consist of flow cells that contain metal bars or
anodes (containing copper and silver metals) surrounding a central chamber through which piped
water flows. A direct electric current is passed between these anodes, releasing the copper and
silver ions into the water stream. The amount of ions released depends on the composition of the
anode and is controlled by the electrical current applied to the bars and the water flow rate.
The use of silver ionization for water disinfection was developed by the National Aeronautics
and Space Administration (NASA) for Apollo spacecraft drinking water and wastewater systems
(Albright et al., 1967). The combined use of copper and silver ions for water treatment initially
focused on the disinfection of swimming pools (Yahya et al., 1989) as an alternative to using
high levels of chlorine. Liu et al. (1994) first reported on the effective use of CSI treatment for
controlling Legionella in hospital water systems, specifically for L. pneumophila. CSI systems
are currently used in buildings with complex water systems to control the growth and occurrence
of Legionella bacteria. Lin et al. (201 lb) documented CSI applications controlling Legionella in
hospitals worldwide.
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2.3.4.2 Characterization of Effectiveness against Legionella
Case studies constitute the majority of the published reports on the efficacy of CSI in controlling
Legionella in premise plumbing systems (Demirjian et al., 2015; Dziewulski et al., 2015; Chen et
al., 2008; Modol et al., 2007; Blanc et al., 2005; Stout and Yu, 2003; Kusnetsov et al., 2001;
Rohr et al., 1999; Liu et al., 1998; States et al., 1998; Liu et al., 1994). The studies generally
describe situations where Legionella bacteria were found in a premise plumbing system and CSI
was initiated in an attempt at Legionella control. Many of the reviewed laboratory studies
indicate that copper and silver ions can inactivate Legionella and reduce the incidence of
legionellosis. However, as with other technologies, other studies showed that Legionella can be
protected from copper and silver ions when it is associated with biofilms or amoebae. The
potential for Legionella to develop resistance to copper and silver ions has also been suggested
by several studies.
•	Dziewulski et al. (2015) demonstrated the efficacy of CSI for inactivating both L.
pneumophila and L. anisa under alkaline water conditions (pH 8.7-9.9) in two health care
facilities. No cases of legionellosis occurred during the study period. CSI treatment
reduced the number of CFU and the percentage of samples found to be culture-positive.
After CSI treatment was established, culture positivity was reduced from 70 percent to
<30 percent. The study suggests that silver ions played a major role in controlling
legionellae, generally in the range of 0.01-0.08 mg/L.
•	Demirjian et al. (2015) characterized an outbreak at a Pennsylvania hospital between
2011 and 2012 and evaluated contributing factors in a large hospital using CSI to prevent
Legionella growth. Of 25 locations where samples were collected for Legionella culture,
23 were positive for Legionella, while the mean copper and silver ion concentrations
were measured at or above the manufacturer's recommended levels for Legionella
control (0.30 and 0.02 ppm, respectively). They observed that Legionella remained viable
in vitro in the presence of copper and silver ion concentrations within the manufacturer's
recommended levels, while chlorine residual levels were low or not present during the
investigation. They hypothesized that organic material could have increased during
construction work in the hospital. The authors concluded that this could have led to
consumption of the chlorine residual, leaving CSI as the only method for Legionella
control.
•	Chen et al. (2008) studied the implementation of copper-silver ionization in both hot and
cold water at the point of entry to a hospital in Taiwan. CSI was applied to cold water
because the subtropical climate in Taiwan resulted in cold water with temperatures up to
30 degrees C (86 degrees F). During the first three months of implementation,
copper/silver concentrations in the hospital wards were 0.094/0.020, 0.114/0.014 and
0.110/0.007 mg/L at months 1, 2 and 3, respectively. The percentage of positive L.
pneumophila samples declined from 30 to 20 percent. During months 4-7, the hospital
increased the copper/silver levels to 0.143/0.008, 0.157/0.011, 0.180/0.017 and
0.212/0.014 mg/L, respectively. The percentage of positive samples declined to 5 percent
and, in months 7-11, to zero. In the ICUs, however, the hospital was able to reduce but
not completely control Legionella during the study. Copper and silver levels in the ICUs
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were thought to be diluted by connection with a reverse osmosis system installed in the
unit.
•	Modol et al. (2007) described how a large hospital experienced success in decreasing the
number of positive Legionella samples after initiating CSI. The hospital had discontinued
the use of chlorine in the hot water system due to difficulties in maintaining minimum
concentrations at distal points in the building's premise plumbing system. It also
discontinued frequent superheating due to pipe damage and poor compliance with heating
and flushing procedures. Initially, the copper and silver levels were maintained at 0.1-0.3
mg/L and 0.01-0.03 mg/L, respectively. While the treatment system was under repair for
two months, the percentage of positive samples for Legionella increased from 20 percent
to 65 percent. Following the interruption in treatment, hospital staff increased copper and
silver concentrations to 0.4 and 0.04 mg/L. Legionella samples taken after the increase
were 16 percent positive.
•	Blanc et al. (2005) reported that no significant difference was observed in the percentage
of water and biofilm samples positive for Legionella spp. after CSI treatment was
installed in 1999. The CSI system electrodes were composed of 8 percent silver and 92
percent copper, and the copper concentration in the water was 0.3 mg/L. A significant
reduction in Legionella isolates was observed after the hot water system temperature was
increased from 50 to 65 degrees C (122 to 149 degrees F) in the year 2000.
•	Survey results by Stout and Yu (2003) showed that of 13 hospitals reporting at least 30
percent Legionella-positive samples before CSI treatment began, nine hospitals reported
a sustainable (over a period of 6-9 years) decrease in the number of Legione/Ia-positi ve
samples; five hospitals reported no positive samples after treatment. This survey also
showed that all of the hospitals reported cases of hospital-associated Legionnaires'
disease before CSI treatment, and all but one reported no cases after treatment.
•	Lin et al. (2002) studied the effects of pH and other water quality parameters on CSI
treatment for Legionella control using water from a hospital hot water system. At pHs of
7.0 and 9.0, copper ions achieved a 6-log and 1-log (99.9999 and 90 percent) reduction,
respectively, in the number of L. pneumophila in 24 hours. Silver ions achieved a 6-log
reduction in 24 hours at all ranges of water quality parameters tested.
•	Based on four years of monitoring data, Kusnetsov et al. (2001) reported that legionellae
were no longer detected in the circulating warm water of a hospital water system after
CSI treatment was employed and silver concentrations were increased to levels greater
than 3 |ig/L. However, water samples collected from taps and showers that were not used
on a regular basis showed that even a high silver concentration (55 |ig/L) did not prevent
growth of Legionella.
•	Rohr et al. (1999) indicated that CSI had an initial impact on Legionella occurrence in the
hot water system of a German university hospital, where 100 percent of sampling sites
were positive for Legionella before treatment and 55 percent of sampling sites had
positive results one year after treatment was initiated. Over the next three years, 75-78
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percent of samples were positive for Legionella. However, Lin (2000) disagreed with
Rohr et al.'s (1999) results that the CSI system did not effectively control Legionella in
this system. Lin (2000) pointed out that the CSI system was not effective because it did
not maintain an adequate concentration of copper and silver ions in the treated premise
plumbing system (200-400 |ig /L of copper and 20-40 |ig /L of silver was crucial). Lin
(2000) also noted that Rohr et al. did not provide evidence for the development of
Legionella resistance to copper or silver. Rohr (2000) responded to Lin's (2000)
comments, and explained that the purpose of the study was to evaluate control of
Legionella using a CSI system that met German regulations limiting silver ion
concentrations to a maximum of 10 |ig/L.
•	States et al. (1998) reported that CSI treatment was successful in reducing the percentage
of samples testing positive for Legionella from 100 percent to less than 17 percent on
average over a two-year period.
•	Lin et al. (1996) found that L. pneumophila serogroup 1 was completely inactivated (6-
log (99.9999-percent) reduction) within 2.5 hours using copper ions at concentrations of
0.1 mg/L without silver ions, and more than 24 hours was needed to achieve a similar
reduction using silver ions at concentrations up to 0.08 mg/L without copper ions. When
both copper and silver ions were used, inactivation was achieved at copper and silver
concentrations of 0.04 mg/L.
•	Based on laboratory studies with filtered well water (pH 7.3), Landeen et al. (1989)
determined that copper ions (at 0.4 mg/L) and silver ions (at 0.04 mg/L) can achieve a 3-
log (99.9-percent) reduction in L. pneumophila at room temperature when the contact
time is at least 24 hours.
Other studies have reported the potential occurrence of Legionella strains that appear to be less
sensitive to the toxic effects of certain chemicals such as copper and silver. Microorganisms are
highly adaptive. It is well documented that within the bacterial world there are cellular
mechanisms which allow bacteria to survive hostile environments.
There is an understanding of how bacterial gene systems can confer resistance to copper and
silver (Nies, 1999). Some of these gene systems are found in Legionella (Bondarczuk and
Piotrowska-Seget, 2013). One common resistance mechanism in gram-negative bacteria (such as
Legionella) requires an energy-dependent protein that protects the cell by acting as a pump to
export copper ions out of the cell (Bondarczuk and Piotrowska-Seget, 2013). The occurrence of
Legionella strains potentially tolerant of silver in CSI treatment was noted by Rohr et al. (1999);
however, Lin (2000) commented that Rohr et al.'s (1999) conclusion is not supported by any
data in their report and noted the silver ion levels used were below the recommended levels for
control of Legionella. Rohr (2000) responded to Lin (2000) that the multiple regression analysis
reported in the 1999 paper shows a decreasing influence of silver ions on Legionella counts
during the 4-year study period.
Hypochlorous acid, the active disinfecting chlorine species, is in part toxic to bacterial cells by
virtue of interfering with the production of energy (in the form of adenosine triphosphate (ATP))
needed for many cellular processes including heavy metal resistance enzymes (Barrette et al.,
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1989). The synergy between free chlorine and heavy metal ions on Legionella copper resistance
mechanisms and Legionella susceptibility is generally unstudied. However, Landeen et al. (1989)
showed increased (although not statistically significant) inactivation rates of L. pneumophila
with copper and silver ions in the presence of 0.4 mg/L free chlorine.
2.3.4.3 Potential Water Quality Issues
Use of CSI may result in corrosion. Materials compatibility and water quality will dictate the
severity of corrosion. Awareness of the types of materials and water chemistry in a premise
plumbing system is critical to maintaining system integrity. Loret et al. (2005) observed
corrosion marks on mild and galvanized steel coupons installed in pipe loops for CSI treatment
that were similar to corrosion effects for other disinfectants (chlorine, chloramine, chlorine
dioxide and ozone), except that the coupons exposed to CSI also had copper deposits. Although
pitting corrosion was not observed during the study, intense corrosion occurred within the pipe
loop after the study was completed, suggesting that CSI treatment may lead to pipe corrosion
under some conditions. Type III pitting usually occurs in soft water with alkaline pH >8.0
(Edwards et al., 1994), at distal or stagnant locations and at moderately warm temperatures
Edwards et al., 1994). Lytle and Schock (2008) found that waters with high pH (pH 9 and
possibly as low as 8), low dissolved inorganic carbon (<10 mg/L and possibly as high as 25
mg/L) and chloride levels of 14-38 mg/L promoted pitting corrosion.
High concentrations of both copper and silver have been reported in systems employing CSI, to
levels approaching the maximum contaminant level goal and action level for copper (1.3 mg/L)
and the secondary maximum contaminant level (SMCL) for silver (0.1 mg/L) (States at al., 1998;
Rohr et al., 1999). As copper levels in copper piping can rise during periods of stagnation, high
levels of copper can occur in early morning first-draw water samples (Araya et al., 2004; Araya
et al., 2003a; Araya et al., 2003b; Araya et al., 2003c; Araya et al., 2001; Knobeloch et al.,
1994). Copper, but not silver, was found to concentrate on biofilm material in premise plumbing
systems employing CSI treatment (Liu et al., 1998; Zevenhuizen et al., 1979).
Copper toxicity from ingestion of drinking water has been reported even without the contribution
of copper from CSI systems (Araya et al., 2004; Araya et al., 2003a; Araya et al., 2003b; Araya
et al., 2001; Knobeloch et al., 1998; Knobeloch et al., 1994). Symptoms of copper toxicity
include nausea, abdominal cramps, vomiting and diarrhea.
Both copper and silver can have negative aesthetic effects on water: color, taste and odor and
staining issues (Hong et al., 2010; Dietrich, 2009; Stout and Yu, 2003; Edwards et al., 2000;
Knobeloch et al., 1998; Knobeloch et al., 1994). Edwards et al. (2000) attributed the rare
occurrence of blue water to corrosion of copper plumbing. Ingesting high levels of silver can also
lead to a skin discoloration condition called "argyria" (Drake and Hazelwood, 2005; WHO,
2003; USEPA, 1989b). According to WHO (2003), the lowest dose of silver that may lead to
occurrence of argyria has not been determined, but, in general, silver levels up to 0.1 mg/L can
be tolerated without risk to health. Silver levels approaching the SMCL of 0.1 mg/L have been
reported in premise plumbing systems using CSI treatment (Rohr et al., 1999; States et al., 1998).
Laboratory studies have been conducted on the effectiveness of CSI in reducing levels of other
bacterial species commonly found in built environments, including Pseudomonas,
Stenotrophomonas, Acinetobacter (all gram-negative bacteria like Legionella) and
Mycobacterium. Copper and silver ions appear to act synergistically (the total effect is greater
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than the sum of the individual effects) toward L. pneumophila (Lin et al., 1996), Pseudomonas
and Acinetobacter (Huang et al., 2008), while the ions act antagonistically (the interaction of the
two metals lessens the effect of each metal acting individually) toward Stenotrophomonas
(Huang et al., 2008). Mycobacterium was shown to be 100-fold less sensitive to copper and
silver ions than Legionella (Lin et al., 1998b), and copper and silver levels that controlled
Legionella were unable to control the occurrence of Mycobacterium in a hospital premise
plumbing system (Kusnetsov et al., 2001). Shih and Lin (2010) tested CSI in a model water
system against Pseudomonas, Stenotrophomonas and Acinetobacter with 72 hours exposure to
copper and silver concentrations of 0.2 and 0.02, 0.4 and 0.04, and 0.8 and 0.08 mg/L. In
biofilm, CSI achieved 2- to 3-log reduction (99-to 99.9-percent) of these pathogens. In free-
floating bacteria, CSI achieved a 4- to 7-log reduction, except for Acinetobacter, where even
with 0.8 and 0.08 mg/L copper and silver concentrations, the reduction was only 2 log (99
percent). The authors noted that concentrations of copper and silver decreased during the 72
hours, probably because ions were attached to individual cells, and that this could have
contributed to regrowth during that period.
Field studies of CSI have reported some effectiveness in reducing fungi in hospital water
systems, especially Fusarium spp. (Chen et al., 2013). A report on healthcare facilities in Spain
with (n=9) and without (n=7) ionization treatment systems cited a fungal isolation rate of 28
percent versus 77 percent, respectively (Pedro-Botet et al., 2007). CSI has not been reported to
reduce levels of heterotrophic bacteria or amoebae in either a controlled laboratory study (Rohr
et al., 2000) or a case study (States et al., 1998).
2.3.4.4 Operational Conditions
Parameter Conditions Indicating Operational Effectiveness
Maintaining copper and silver at the levels recommended by the manufacturer is a best practice
in achieving operation effectiveness. Note that monitoring typically includes measurement of the
total metal concentration, which includes copper and silver that are bound up as complexes, as
well as copper and silver ions. The presence of copper and silver ions is thought to be critical for
treatment effectiveness, so maintaining proper pH and avoiding interfering materials (e.g.,
phosphates, chlorides) is also important (Zevenhuizen et al., 1979). Examples of interferences
include:
•	In the presence of 20-40 mg/L of chloride ions, silver ion levels are significantly (60
percent) decreased by complexing with chloride (and are presumably less microbiocidal)
(Lin et al., 2002).
•	Phosphates, such as those added for corrosion control, can bind to copper ions as well as
silver ions, reducing their treatment effectiveness (Zevenhuizen et al., 1979).
The presence of dissolved organic carbon at 2 mg/L, calcium at 100 mg/L, magnesium at 80
mg/L and bicarbonate at 150 mg/L did not appear to decrease the treatment efficacy of copper
and silver ions against L. pneumophila in a laboratory study (Lin et al., 2002).
The impact of pH on the ionic nature (and thus the microbiocidal action) of copper in solution is
also important. At pH levels >6.0, copper forms insoluble complexes with a number of
compounds. While in the pH range typical of potable waters (pH 6-9), silver ions are not
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diminished. In a controlled laboratory study (Lin et al., 2002) found that at a pH of 7, exposure to
0.4 mg/L of copper resulted in a 4-log (99.99-percent) reduction of L. pneumophila in one hour
however, at a pH of 9, there was no appreciable decrease in L. pneumophila over the same period
of time with the same copper exposure. Dziewulski et al. (2015) demonstrated efficacy of CSI
under alkaline water conditions (pH 8.0-9.8) and found that silver ions controlled the L.
pneumophila serotypes 1 and 6, and L. anisa.
With regard to the effects of temperature, one study (Landeen et al., 1989) found no significant
difference in L. pneumophila inactivation rates in experiments conducted at room temperature
(21-23 degrees C, or 69.8-73.4 degrees F) and elevated temperature (39-40 degrees C, or
102.2-104 degrees F) using water with 0.2 mg/L free chlorine, with or without 400 |ig/L of
copper and 40 |ig/L of silver.
Installation Considerations
CSI systems can be plumbed into either the cold water entry pipe or plumbed into the hot water
line. Care should be taken to install devices downstream of any process that will remove or
exchange copper and silver ions. Note that construction that includes new copper pipe can add
copper to water for a time via leaching.
Newly installed CSI systems generally require a period of time to adjust system output in order
to achieve the desired level of metal ions. Representatives from the manufacturer are typically
involved in on-site start-up and balancing of the system.
Monitorins Frequency and Location
Initial monitoring during start-up is critical to ensure the copper action level in the Lead and
Copper Rule is not exceeded. A facility that is considering installation of CSI should consult
with its primacy agency to determine a protocol for initial monitoring. During the initiation of
CSI, weekly monitoring with inductively coupled plasma/mass spectrometry (ICP/MS) (e.g.,
EPA Method 200.8) or atomic absorption spectroscopy (e.g., Standard Methods 311 IB) can be
conducted to determine accurate levels of copper and silver.6 As treatment proceeds, the
frequency of analysis may be reduced, but these methods remain the only reliable and accurate
means to determine copper and silver concentrations.
Lin et al. (201 lb) recommend monitoring copper on a weekly basis using a field colorimeter kit,
and monitoring silver once every two months by atomic absorption spectroscopy or the
inductively coupled plasma method. Operational monitoring of copper is generally conducted at
various locations throughout the premise plumbing system to monitor for process changes in
copper concentration (e.g., high copper concentrations that may be indicative of improper
application, and no detectable copper). Based on a 1995 survey of 16 hospitals, Stout and Yu
6 The National Environmental Methods Index (https://www.nemi.gov/home/') "is a searchable database that allows
scientists and managers to find and compare analytical and field methods for all phases of environmental
monitoring."
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(2003) reported that 94 percent (15 of 16) of hospitals conducted routine monitoring for copper
and silver ions.
According to the United Kingdom Health and Safety Executive (2014), both copper and silver
levels should be monitored monthly, or no less than quarterly, at the same locations within the
building, using appropriate sampling procedures, and submitted for analysis by ICP/MS or
atomic absorption (HSE, 2014). Sampling locations will vary in specific buildings and should
include both taps that are frequently and infrequently used. When appropriate, the facility owner
or operator should work with the primacy agency to determine a site sampling plan for the water
system. First-draw and flushed samples will often yield different results (Liu et al., 1994). First-
draw sample testing can indicate how periods of low water flow may affect metal levels given
the water quality conditions found in a specific building, while flush samples will measure the
metal levels in the main cold or hot water lines feeding individual taps. Knowledge of how water
flows in any particular building is essential in determining the best monitoring frequency and
locations.
Maintenance Needs
The copper- and silver-containing anodes are sacrificial and should be rehabilitated periodically
as they become smaller, according to the recommendations of the manufacturer. Anodes can also
wear down due to high shear velocities (Chen et al., 2008). The anodes typically will develop
scale from calcium in all but the softest waters and should be cleaned by scraping/acid treatment
on a regular basis. Scale build-up reduces the surface area from which ions can be released,
lowering the ion output. Any time a component of a water system is opened to the environment
for maintenance, such as scraping, procedures should ensure that the system components are re-
installed in a sanitary condition (i.e., disinfected).
Regular flushing of water lines (either through the frequent use of taps or routine weekly
flushing) was cited as a critical factor in maintaining the effectiveness of CSI systems
(Kusnetsov et al., 2001; Liu et al., 1994).
2.3.5 Ultraviolet Light Disinfection
2.3.5.1 Background
UV disinfection is a well-established treatment technology for inactivating pathogens present in
the environment. In the drinking water context, UV disinfection was initially most widely used in
Europe, with hundreds of installations in place by 1985 (USEPA, 2006c). In North America, UV
disinfection has been more widely employed in drinking water applications since 2000 to address
health concerns associated with Cryptosporidium. As of the spring of 2008, there were at least
300 PWSs in the United States and Canada with UV installations treating flows >350 gallons per
minute (Wright et al., 2012).
UV reactor validation is used to define the operational conditions under which the pathogens of
concern are inactivated for a specific UV reactor manufacturer and model. Validation is a
method of determining the operating conditions under which a UV reactor delivers a specified
dose. This generally involves initial tests using a surrogate organism (e.g., bacteriophage MS2)
rather than the target pathogen (e.g., Cryptosporidium) to establish the dose relationship between
the two organisms. The conditions that are examined for full-scale testing to establish dose are
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flow rate, UV transmittance (UVT) (a measure of the fraction of incident light transmitted
through a material) and lamp output. EPA has developed guidance for validation of UV reactors
(USEPA, 2006c). There are also validation standards for UV reactors from organizations based
in Austria (Osterreichisches Normungsinstitut - ONORM) and Germany (Deutsche Vereinigung
des Gas- und Wasserfaches - DVGW) that use a benchmark UV dose of 40 millijoules per
square centimeter (mJ/cm2) (GLUMRBSPPHEM, 2012; USEPA, 2006c).
There are two methods for validating UV units. In short, the setpoint approach establishes a
measured UV intensity that corresponds to a specific dose and flow rate. The dose control
method (also referred to as the calculated dose approach) provides a means of determining the
required intensity that corresponds to a specific flow rate, UVT and dose. Reactors using the
setpoint approach do not need a separate UVT monitor and in some cases may be easier to
operate; however there are operational disadvantages (USEPA, 2006c).
2.3.5.2 Characterization of Effectiveness against Legionella
There are several important lessons from installations of UV disinfection in hospital settings and
UV installations in general:
•	UV disinfection can be effective at controlling Legionella in facility piping (Hall et al.,
2003; Franzin et al., 2002; Liu et al., 1995). In the case of one new facility, a UV
disinfection unit was installed on the incoming water supply, and none of the 930 cultures
of hospital water were positive. In addition, there were no confirmed hospital-acquired
Legionella infections over a 13-year study period (Hall et al., 2003).
•	UV is only effective at inactivating Legionella in the water that flows through the UV
reactor. For existing facilities with Legionella present in the piping systems downstream
of a UV reactor, supplemental controls such as thermal treatment or chemical disinfection
will be necessary.
•	UV reactors need to be maintained to remain effective. The quartz sleeves that house the
reactors can be fouled by iron, manganese, calcium carbonate or other deposits that
decrease UV output. Lamps and other reactor components also need to be replaced
periodically in order to maintain treatment effectiveness. Fouling of the UV lamps was
found to decrease effectiveness of the UV treatment. Liu et al. (1995) added filters to
prevent scaling on UV lamps installed near the point of use in a hospital's cold and hot
water systems. After treatment with superheat/flush and shock chlorination, and
installation of filters to remove particles that foul the UV lamps, the UV intensity of the
lamps remained at 100 percent throughout the experiment and the showers remained
Legionella-free for a period of three months.
Relatively low UV doses appear to inactivate L. pneumophila (Exhibit 2-1). A dose of 1 mJ/cm2
was found adequate, in a recirculating model system, to achieve 99-percent (2-log) reduction in
six different Legionella species. (Gilpin et al., 1985).
A dose of 30 mJ/cm2 achieved 99.999-percent (5-log) reduction in 20 minutes in a recirculating
model premise plumbing system under three different test conditions (non-turbid water at 25
degrees C (77 degrees F); turbid water at 25 degrees C; and non-turbid water at 43 degrees C
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(109.4 degrees F)). However, viable numbers of L. pneumophila remained in the treated water
despite six hours of continuous UV light exposure. UV irradiation was not affected by turbid
conditions or increased temperature. (Muraca et al., 1987).
Usually, there are limited opportunities for exposure to light for water treated and held in
premise plumbing systems. However, if there is a significant opportunity for light repair (repair
of UV-induced DNA damage using photo-reactivating light), such as in water used in tubs, pools
and baths, a higher UV dose should be considered. At a UV dose adequate to achieve 99.9-
percent (3-log) reduction of L. pneumophila, subsequent exposure to fluorescent light for one
hour resulted in only a 68 percent (0.5-log) reduction following initial inactivation by low
pressure (LP) UV lamps and only 60 percent (0.4-log) reduction following inactivation by
medium pressure (MP) UV lamps (Oguma et al., 2004). Similar significant light repair of
Legionella has been observed by others (Knudson, 1985).
Exhibit 2-1: UV doses (mJ/cm2) for inactivation of L. pneumophila
L. pneumophila
strain
Lamp
Type
1-log
2-log
3-log
4-log
Reference
Philadelphia Type 2
LP
0.92
1.84
2.76
No data
Antopol and Ellner,
1979
Philadelphia 1
(no light repair)
LP
0.5
1.0
1.6
No data
Knudson, 1985
Philadelphia 1
(with light repair)
LP
2.3
3.5
4.6
No data
Knudson, 1985
Philadelphia 1
ATCC33152
LP
1.6
3.2
4.8
6.5
Oguma et al., 2004
Philadelphia 1
ATCC33152
MP
1.9
3.8
5.8
7.7
Oguma et al., 2004
Notes:
LP = Low pressure lamps, which have a single output of UV peaking around a wavelength of 254 nanometers.
MP = Medium pressure lamps, which have polychromatic (or broad spectrum) output of UV at multiple wavelengths.
2.3.5.3 Potential Water Quality Issues
UV disinfection does not produce a disinfectant residual (USEPA, 2007). Also, when UV
disinfection is applied to waters containing a disinfectant residual, the residual may be
diminished following treatment with UV (USEPA, 2006c). Therefore, water treated using only
UV disinfection may, in some cases, be susceptible to contamination at downstream points. More
than one type of disinfection or other control measure may be needed to protect the treated water
downstream of UV disinfection, between the UV lamp and the taps and other water outlets (e.g.,
showerheads).
At UV doses typically used in drinking water, UV disinfection does not support the formation of
regulated DBPs (USEPA, 2006c). In addition, UV disinfection does not change the pH or treated
water quality in such a way as to make it more corrosive to premise plumbing (USEPA, 2006c).
Mercury can be released into the treated water when a UV lamp breaks (Wright et al., 2012). The
amount of mercury that could potentially enter the water depends on the type of lamp and
operation. Vapor phase mercury can dissolve into solution and be discharged downstream
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whereas liquid phase or amalgam mercury would tend to settle in the UV reactor. The author
recommends developing a mercury mitigation plan (Wright et al., 2012).
2.3.5.4 Operational Conditions
Parameter Conditions Indicating Operational Effectiveness
Water quality data are needed to adequately characterize the water to be treated by a UV reactor
and identify any pre-treatment or UV equipment design features that may be necessary.
Manufacturers may have their own data requests, though the following list will cover most water
quality information needed (AWW A, 2012; USEPA, 2006c):
•	Temperature - Some reactor components may not be tolerant of water >35 degrees C (95
degrees F). For this reason, the UV manufacturer should be consulted about the thermal
tolerances of the equipment for installations on hot water plumbing.
•	Turbidity - Excessive turbidity and certain dissolved species inhibit the effectiveness of
UV disinfection (WHO, 2011). Light transmission through water is impaired by
particulates.
•	Disinfectant type and residual - Some reactor components may not be tolerant of certain
disinfectants or high doses, so UV equipment manufacturers should be consulted about
exposure of UV reactors to chemical disinfectants.
•	UVT - Components in the water can absorb UV light and reduce the dose delivered to
the microorganisms from the UV reactor. UVT (which can be calculated from UV
absorbance) is a key parameter in making sure that the UV reactor is properly sized for
the facility.
•	Iron and manganese - These constituents can foul quartz sleeves, leading to decreased
UV output. Iron concentrations >0.1 mg/L may cause operational issues.
The operation of a small UV reactor is typically governed by two key parameters: the flow
through the reactor and UV sensor reading(s). Over time, UV sensors will drift out of calibration.
For this reason, the readings from a UV duty sensor installed in the reactor should be compared
against a reference sensor temporarily inserted in the reactor. PWSs typically make these sensor
checks on a monthly basis. If the calibration ratio between the duty and reference sensor readings
is >1.2, then follow-up actions such as recalibration or replacement of the UV sensor should be
taken (USEPA, 2006c). For installations that use an online UVT monitor to control UV output,
weekly comparisons between online and benchtop UVT measurements are recommended
(USEPA, 2006c).
Installation Considerations
There are several sources of design guidance for the application of UV disinfection to potable
water supplies (AWW A, 2012; USEPA, 2006c). These references cover a range of applications
from those producing only a few gallons per day to millions of gallons per day. The following
checklist is tailored to institutional settings for Legionella control:
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•	Hydraulics should allow for even flow through the reactor. Control valves and reducers
should be avoided within five pipe diameters upstream of the UV reactor. Pipe
expansions should also be avoided for at least ten pipe diameters upstream of the reactor
to avoid jetting and swirling flow through the UV reactor.
•	Redundancy or other measures should be built in to allow a UV reactor to be taken out of
service for cleaning, lamp replacement and other maintenance.
•	Valves to isolate UV reactors may be necessary. In some cases, such as when UV
reactors are flooded with cleaning chemicals, special valve arrangements may be
beneficial on the outlet and inlet piping.
•	Power quality analysis includes review of sub-second power interruptions and voltage
sags at the location of a proposed UV installation. Power protection, power conditioning
equipment or an uninterruptible power supply may be necessary in some cases.
•	Alarm and reactor shutdown conditions should be clearly identified.
•	A lamp breakage response plan should be developed that defines emergency response
actions that will be taken if a lamp breaks. Low velocity traps or other piping
configurations to collect broken lamp components should be considered. The potential for
hydraulic transients should be evaluated because they may cause the quartz sleeves that
house UV lamps to fail.
Maintenance Needs
UV reactors, like other Legionella treatment options, require routine maintenance to ensure that
the UV dose remains adequate for inactivation of pathogens. Some of the basic maintenance
items include cleaning the quartz sleeves housing the lamps and periodically replacing the lamps,
as their output decreases with time. Most UV lamps installed in smaller reactors will typically be
rated for 8,000-12,000 hours of operation (one year of continuous operation equals 8,736 hours).
To better understand the lamp output over time, premise plumbing operators may want to consult
with the UV equipment manufacturer (USEPA, 2006c). In addition, some reactor components
can be affected by disinfectants, including chlorine, added prior to the reactor, requiring
additional maintenance. For a detailed list of recommended maintenance activities for a UV
reactor, please see EPA's Ultraviolet Disinfection Guidance Manual for the Final Long Term 2
Enhanced Surface Water Treatment Rule (USEPA, 2006c).
2.3.6 Ozone
2.3.6.1 Background
Ozone is used in drinking water treatment for disinfection and oxidation (USEPA, 1999d, 2007).
It is generated on-site as a gas using either air or liquid oxygen and is then transferred (dissolved)
into the water phase. When dissolved in water, molecular ozone (O3) is unstable and decomposes
to hydroxyl radical, which is a stronger and typically more reactive oxidizing agent than
molecular ozone. Ozone decomposes quickly during water treatment (USEPA, 1999d, 2007).
Therefore, during a typical ozonation process, both molecular ozone and the hydroxyl radical
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may contribute to the oxidation of contaminants of concern. The relative importance of these two
oxidants depends on the concentrations of the oxidants and the reactivity of the contaminant with
each oxidant.
The use of ozone in drinking water treatment is widespread throughout the world (Steiner et al.,
2010). As an oxidant, ozone can be used to oxidize iron, manganese, taste and odor compounds,
and DBP precursors. It can oxidize organic matter into smaller molecules that are more easily
biodegradable. As a primary disinfectant, ozone is more effective than chlorine, chloramines and
chlorine dioxide for inactivation of Cryptosporidium, Giardia and viruses (USEPA, 1999d,
2007). However, ozone cannot be used as a secondary disinfectant because it decays very rapidly
and cannot maintain a residual in the distribution system (USEPA, 1999d, 2007).
2.3.6.2 Characterization of Effectiveness against Legionella
Information on ozone systems installed in hospitals and other types of buildings for L.
pneumophila control is lacking. Only one paper, by Edelstein et al. (1982), evaluated the efficacy
of ozone for eradicating L. pneumophila in hospital plumbing fixtures, but the result of the study
was inconclusive.
Edelstein et al. (1982) applied continuous ozonation to the water supply in an unoccupied
hospital building to evaluate whether it would control L. pneumophila in plumbing fixtures with
positive cultures. The water supply was split into two wings: one treated with ozone, the other
untreated. In their laboratory study, using distilled water, more than 3-log (99.9-percent)
reduction in L. pneumophila was achieved by exposure to 0.32 mg/L of ozone for 20 minutes.
However, results from ozonation of the water supply system (average ozone levels of 0.79 and
0.58 mg/L in two study phases, respectively) were difficult to interpret because the non-ozonated
water in the control wing also showed inactivation of L. pneumophila due to a higher water
usage rate and an unexpected rise in the chlorine residual in the control wing (average chlorine
residual levels of 0.24 and 0.12 mg/L in two study phases, respectively). Although the treatment
wing had a smaller number of positive cultures (3 of 12) than the control wing (8 of 12), the
researchers could not reach a conclusion on the role of ozone in the inactivation of L.
pneumophila. The study indicated that when ozonation was stopped, L. pneumophila regrew and
reached levels close to the pre-test conditions at the end of the stagnation phase. Moreover, the
authors pointed out one important factor for continual dosing of ozone, namely that residual
ozone at the faucet or shower head led to the release of gaseous ozone into the air (an issue
discussed in Section 2.3.6.4).
Several laboratory studies have reported rapid and effective inactivation of Legionella with
ozone (Jacangelo et al., 2002; Domingue et al., 1988; Muraca et al., 1987).
• Loret et al. (2005) used a simulated distribution system consisting of pipe loops to
compare the effectiveness of several disinfectants to control Legionella in biofilms in
premise plumbing. The study concluded that ozone was effective to control planktonic
and biofilm-associated populations within the pipe loops but was ineffective within dead
end sections. For a more detailed description of the Loret (2005) study see Section
2.3.1.2.
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•	Jacangelo et al. (2002) conducted laboratory studies to evaluate multiple disinfectants,
including ozone, for inactivation of waterborne emerging pathogens including
Legionella. The ozone dosage rate was 1.0 mg/L. The model-predicted CT values for 2-
log (99-percent) inactivation of Legionella at pH 7 were 2.5, 0.16 and 1.1 min-mg/L at 5,
15 and 25 degrees C (41, 59 and 77 degrees F), respectively.
•	Domingue et al. (1988) conducted laboratory experiments to compare the bactericidal
effects of ozone, hydrogen peroxide and free chlorine on "free" L. pneumophila cells.
Ozone was the most potent of the three disinfectants, with a greater than 2-log (99-
percent) inactivation in L. pneumophila occurring during a 5-minute exposure to 0.10-0.3
mg/L ozone. The researchers reported little to no effect of pH and temperature on ozone
inactivation of L. pneumophila. The pH ranged from 7.2 to 8.9. Experiments were
conducted at 25, 35 and 45 degrees C (77, 95 and 113 degrees F).
•	Muraca et al. (1987) compared the efficacy of chlorine, heat, ozone and UV light for
inactivating L. pneumophila in a bench-scale model plumbing system. L. pneumophila
was added to the system and allowed to circulate. Continuous ozonation for five hours at
a concentration of 1 to 2 mg/L achieved a 5-log inactivation of L. pneumophila at 25 and
43 degrees C (77 and 109.4 degree F, respectively). Neither turbidity nor the higher
temperature (43 degrees C, or 109.4 degrees F) was reported to affect the efficacy of
ozone.
2.3.6.3 Potential Water Quality Issues
Ozone decomposes in water relatively rapidly. The half-life of ozone in finished drinking water
depends on temperature, pH and alkalinity, and can vary from minutes to hours. This time-scale
is short relative to chlorine-based disinfectants, and as such, ozone is not generally considered to
produce a disinfectant residual. Therefore, water treated with ozone may, in some cases, be
susceptible to contamination at downstream points. For this reason, more than one type of
treatment or control measure may be necessary to protect the treated water.
Disinfection byproducts formed from ozone disinfection include bromoform, monobromoacetic
acid, dibromoacetic acid, dibromoacetone, cyanogen bromide, chlorate, iodate, bromate,
hydrogen peroxide, hypobromous acid, epoxides, ozonates, aldehydes, ketoacids, ketones and
carboxylic acids (WHO, 201 lb).
Ozonation of water containing inorganic bromide can produce bromate, a regulated DBP with an
MCL of 10 |ig/L. The disinfection process of a PWS will likely have transformed any bromide in
water to organically bound bromine or inorganic bromamines. In either case, these forms of
bromine are less likely to contribute to bromate formation via an ozonation process in a premise
plumbing system. As such, bromate formation may not be as relevant as in the water treatment
plant.
Other ozonation byproducts such as aldehydes and organic acids are more readily biodegradable
and may contribute to assimilable organic carbon (AOC) and hence biological growth in the
distribution system. In addition, these ozonation byproducts are more likely to form some types
of DBPs upon chlorination or chloramination (Carlson and Amy, 2001; Shah and Mitch, 2012).
However, these general concepts regarding ozonation pertain to treatment of water at the plant.
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Ozonation of water that has already undergone treatment, including exposure to a chlorine or
chloramine residual in the distribution system en route to the building (e.g., hospital) has not
been studied to a great extent. Therefore, impacts of ozonation on AOC or DBP formation in a
premise plumbing system are still unclear.
Loret et al. (2005) observed corrosion marks on mild and galvanized steel coupons installed in
pipe loops for ozone treatment that were similar to corrosion effects caused by other disinfectants
(chlorine, chloramine, chlorine dioxide and CSI), except that the coupons exposed to CSI also
had copper deposits.
2.3.6.4 Operational Conditions
As water temperature increases, ozone disinfection efficiency increases (USEPA, 1999d).
However, because ozone decomposes quickly in hot water, it is difficult to maintain an effective
concentration throughout the system to control Legionella. Therefore, there is a need to balance
the tradeoffs between potentially higher inactivation rates and lower available CT (i.e.,
disinfectant residual concentration "C" multiplied by contact time "T") with increased water
temperature. Due to the faster decomposition of ozone in warm water, water leaving the ozone
contactor with a concentration of 1 to 2 mg/L may not have a concentration high enough to
inactivate Legionella when it reaches distal parts of the system. In the range of 6 to 9, pH will
not impact the efficacy of ozone disinfection. However, ozone decomposes faster at higher pH,
and as such, there is a lower available CT for a given ozone dose. Carbonate alkalinity also has a
considerable impact on ozone decomposition, with increasing alkalinity slowing down ozone
decay, and thus increasing the available CT for a given ozone dose.
One important aspect of ozone-based treatment in a building is the potential for ozone residual
that reaches the tap to degas from the water and expose building occupants to ozone gas.
Edelstein et al. (1982) noted ozone-related odors from the treated water and within the building
where ozone treatment was being conducted, but the researchers did not measure airborne ozone
concentrations. Ozone is a toxic gas (i.e., it is a principal component of smog). It can corrode
steel pipes and fittings, concrete, rubber gaskets and other materials (USEPA, 2007). Due to
safety concerns and the corrosiveness of ozone, on-site generation of ozone gas requires
containment or a separate structure. Ambient air monitoring may also be required for compliance
with local regulations.
Ozone disinfection is a relatively complex process. Operational and maintenance demands are
significantly greater than those for chlorine and chloramines (USEPA, 2007).
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3 Other Strategies Used to Control for Legionella
3.1 Emergency Remediation
Emergency remediation of a premise plumbing system is triggered by & Legionella outbreak
associated with a potable water system, identification of suspected cases of the disease associated
with a potable water system, identification of Legionella-positive water results during routine
environmental testing or failure of control measures (ASHRAE, 2015; VHA, 2014). Several
agencies and organizations have published standards or guidance documents on when and how to
conduct emergency remediation (ASHRAE, 2015; HSE, 2014; VHA, 2014; HSE, 2009; CDC,
2003; ASHRAE, 2000). Some of these documents apply to not only premise plumbing systems
but also cooling towers and evaporative condensers; whirlpool spas; decorative fountains; and
other aerosol-generating air coolers, humidifiers and air washers. This section provides an
overview of commonly used emergency remediation methods, including superheat-and-flush
disinfection, shock hyperchlorination, POU filtration and any combination of these methods.
Appendix A.l lists the references cited in Section 3 and the type of study (e.g., lab study,
literature review).
3.1.1 Superheat-and-Flush Disinfection
3.1.1.1	Background
The superheat-and-flush disinfection method involves raising the water temperature in the hot
water heater sufficiently high to ensure hot water is delivered to outlets; circulating the hot water
through all water outlets, faucets and showerheads; and then flushing with the hot water for a
suitable period. In building water systems that are not heavily contaminated, a constant hot water
heater temperature of 60 degrees C (and 55 degrees at the outlets) is often enough to control (but
not necessarily eliminate) Legionella, as described in Section 2.2.2.1. For example, Dennis et al.
(1984) showed that in a laboratory at 54 degrees C, a 90-percent (1 log) reduction in L.
pneumophila 74/81 serogroup 1 occurred after 27 minutes. At 58 degrees C the same reduction
took only six minutes. Where emergency remediation is required, raising the temperature of hot
water tanks to 71-77 degrees C (160-170 degrees F) and keeping the water temperature at
outlets >65 degrees C (149 degrees F) during flushing are recommended (Sehulster and Chinn,
2003; ASHRAE, 2000). The optimal flush time reported varies from 10 to 30 minutes depending
on the characteristics of the premise plumbing system. A 30-minute flush, first adopted by Best
et al. (1983), is recommended as a good practice.
3.1.1.2	Characterization of Effectiveness against Legionella
The superheat-and-flush method can be effective as an emergency disinfection procedure for
building hot water systems, particularly in hospital outbreak scenarios.
• Best et al. (1983) first reported the use of superheat-and-flush to control Legionella from
a hospital water supply by raising the temperature of hot water tanks as high as 77
degrees C (170.6 degrees F) for 72 hours and flushing the water outlets for 30 minutes
with hot water. After flushing, the number of samples testing positive for Legionella was
reduced, followed by a decline in the incidence of legionellosis. The temperature of the
hot water storage tanks was intermittently increased on eight occasions to 60-77 degrees
C (140-170.6 degrees F), resulting in a decrease in the number of months in which cases
of Legionnaires' disease occurred and the proportion of nosocomial pneumonias caused
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by L. pneumophila and Pittsburgh pneumonia agent (now designated L. micdadei).
•	Darelid et al. (2002) reported the successful application of thermal shock disinfection
after a 1991 nosocomial outbreak of Legionnaires' disease in a Swedish hospital. The hot
water temperature was raised from 45 degrees C to 65 degrees C (113 degrees F to 149
degrees F) to maintain the circulating hot water temperature greater than 55 degrees C
(131 degrees F) to control the bacteria. Environmental monitoring was conducted over a
10-year period to confirm whether this thermal shock treatment was sufficient or if
chemical disinfection was required. The monitoring results showed that complete
eradication of Legionella was not possible, but the occurrence of nosocomial
Legionnaires' disease was controlled by maintaining the circulating hot water
temperature greater than 55 degrees C (131 degrees F).
However, an inadequate temperature for the superheat (less than 65 degrees C, or 149 degrees F)
or a short flush time (such as five minutes) is ineffective for the control of Legionella, as
experienced at some hospitals (Chen et al., 2005). Even 70 degrees C may allow some bacteria to
survive and acquire resistance (Allegra et al., 2011). The shock treatment may not provide long-
term control of Legionella if the premise plumbing system does not maintain a proper
temperature or a residual chlorine level.
•	Allegra et al. (2011) tested the heat susceptibility of Legionella strains isolated from hot
water in four hospital distribution systems over several years. The authors compared
susceptibility of each group of strains using samples collected prior to and following heat
treatment in the distribution system. They exposed Legionella from each sample to 70
degrees C (158 degrees F) for 30 minutes in the laboratory and determined the percentage
of viable and VBNC cells remaining using flow cytometry. Strains of L. pneumophila
serogroup 1 demonstrated highly variable heat resistance (mean percentage of viable and
VBNC cells ranged from 11.7 percent to 71.7 percent). One group of strains in one
distribution system developed resistance over time, apparently in response to repeated
heat shock, with the mean percentage of viable and VBNC cells increasing from 12.7 to
70.5 percent.
•	Chen et al. (2005) conducted superheat-and-flush treatment on the water supply for a
1,070-bed medical center in southern Taiwan. The treatment procedure involved
removing faucet aerators and showerheads at distal sites, flushing distal sites with cold
water for two minutes, and flushing distal sites with hot water at 60 degrees C (140
degrees F) for five minutes. The procedure was conducted once a day for five
consecutive days on each portion of the water system. Water samples were collected
before treatment and 10 days after treatment. The first heat and flush treatment,
performed over an eight-week period, controlled Legionella in patient wards and reduced
the colonization rate in ICUs from 80 percent to 25 percent. But two months later, the
colonization rate had increased from zero to 15 percent in patient wards, and from 25
percent to 93 percent in the ICUs. The second superheat-and-flush treatment, performed
over a 2-day period, resulted in much smaller reductions in the colonization rate.
•	Stout et al. (1998) compared effectiveness of superheat-and-flush to CSI for controlling
Legionella in the Pittsburgh Veterans' Affairs Health Care Center. There were an average
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of six cases of Legionnaires' disease per year for the 13 years when superheat-and-flush
was employed, as compared to two cases per year for the 3 years when CSI was used.
The percentage of distal sites positive for L. pneumophila was 15 percent for superheat-
and-flush compared to 4 percent for CSI. Because the conditions during the two study
periods may not have been comparable, the authors used findings from another hospital
study for verification (Mietzner et al., 1997). Stout et al. (1998) concluded that a properly
maintained and monitored CSI system was more effective than the superheat-and-flush
method.
•	Mietzner et al. (1997) conducted thermal treatment of a hot water circuit in a hospital by
flushing hot water (>60 degrees C, or >140 degrees F) through distal fixtures for 10
minutes. Sampling of the faucets showed that positive samples decreased from
approximately 80 percent to 1 or 2 percent of samples immediately following the initial
treatment, then increased to 36 percent within 61 days of the treatment. Three additional
heat-flush treatments resulted in zero detection of L. pneumophila. But recolonization
occurred within 29 days of the last treatment. The heat-flush treatment failed to provide
long-term control of L. pneumophila.
Combining the superheat-and-flush method with supplemental continuous chlorination (Cristino
et al., 2012; Heimberger et al., 1991; Snyder et al., 1990) or UV light irradiation (Liu et al.,
1995) has achieved some success in decontaminating hospital water systems.
•	Cristino et al. (2012) reported the successful application of various shock disinfection
methods (e.g., heat shock, chemical shock with peracetic acid and chlorine dioxide)
followed by continuous chlorination for long-term care facilities, including three hot
water systems that were colonized by L. pneumophila and one hot water system
colonized by L. londiniensis. No cases of hospital-acquired legionellosis occurred during
the study period. Although three of four systems reported that 100 percent of samples
were positive for Legionella before and after shock treatment, the mean Legionella count
was reduced by up to 69 percent as a result of shock disinfection. Two years of
environmental monitoring after shock disinfection showed that Legionella counts either
continued to decrease or remained at post-treatment levels.
•	Liu et al. (1995) conducted superheat-and-flush and shock chlorination treatment prior to
UV treatment of a hospital's hot and cold water systems. Five years of surveillance data
at untreated control sites (three showers and 20 other water outlets) showed that 30-80
percent of sites were persistently colonized with L. pneumophila (i.e., 1-300 CFU per
swab). The UV treatment units were located near points of use such as showers. Filters
were added to prevent scale accumulation on the UV lamps. The study showed that UV
plus pre-filtration could prevent Legionella recolonization for three months after shock
treatment.
•	Heimberger et al. (1991) reported the successful application of hot water flushing and
supplemental chlorination to control Legionella at a tertiary care hospital in Syracuse,
New York. L. pneumophila was found in 6 of 32 water samples, including samples from
one of two hot water tanks. Initial treatment of the hot water system included tank
cleaning, hot water flushing and shock chlorination but did not include continuous
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supplemental chlorination. One month after initial treatment, L. pneumophila was again
detected from a hot water tank and several taps, and another case of legionellosis
occurred. In response, hot water flushing, shock chlorination and continuous
supplemental chlorination were conducted. On a monthly basis, each hot water tank is
taken offline, cleaned and treated with hot water. In the 7.5 months after these practices
were employed, all samples were negative for Legionella and no new cases of
legionellosis had occurred.
•	Snyder et al. (1990) reported a successful application of heat flushing followed by
continuous supplemental chlorination to reduce L. pneumophila in a hospital hot water
system. Twelve of 74 sampling sites in the hot water system were culture-positive for L.
pneumophila. Heat flushing (>60 degrees C, or >140 degrees F) at hot water system
outlets for 30 minutes alone reduced the number of Legionella-positive samples by 66
percent, but within four months, the number of positive samples had increased.
Continuous supplemental chlorination was added to the hot water system at a dosage rate
of 2 mg/L. After six weeks, the number of Legionella-\)Os\ti ve samples decreased from
37 percent (43 of 115 samples) to 7 percent (8 of 115 samples). After 17 months of
continuous supplemental chlorination, no new cases of legionellosis had occurred.
3.1.1.3	Potential Water Quality Issues
Regrowth of Legionella following superheat-and-flush has been identified as an issue (Chen et
al., 2005; Stout and Yu, 2003). Recolonization could be caused by the survival properties of
Legionella (i.e., the ability to colonize biofilms, ability to parasitize and multiply within
protozoa, and ability to enter a VBNC state, as discussed in Section 1.2.3), or failure to properly
address the conditions that caused the problem (such as dead ends and long water residence
times). Researchers have revealed that L. pneumophila can rapidly proliferate after temperatures
are lowered, presumably via microbial response to the nutrients released by the newly killed
biofilm (necrotrophy) (Temmerman et al., 2006). This finding indicates that disturbing the
microbial ecology on a short-term basis may exacerbate pathogen regrowth in the long-term
(Pruden et al., 2013). EPA advises facility owners or operators who are considering adjustments
to their premise plumbing system to consult with their primacy agency for any specific
considerations or requirements that may apply including plumbing code requirements. See
Section 2.2.2.1 for additional information on a temperature approach for Legionella control.
3.1.1.4	Operational Conditions
The superheat-and-flush method generally does not require special equipment; however, it is
labor-intensive and time-consuming (Chen et al., 2005) due to the need to monitor hot water
temperature and flushing time. Several limitations of the superheat-and-flush method need to be
recognized:
•	Superheat-and-flush is only effective when the water temperature at distal outlets reaches
the required temperature and the flushing is conducted for the required duration (Chen et
al., 2005). Superheat-and-flush requires sufficient hot water heating capacity (HSE,
2014).
•	Superheat-and-flush requires considerable energy and manpower resources.
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• Thermal disinfection will not disinfect downstream of thermostatic mixer valves and so is
of limited value where such valves are installed (HSE, 2009).
•	Scalding is a significant hazard (HSE, 2014; Health Canada, 2013; WHO, 2011). Caution
and close supervision must be taken during emergency disinfection to protect patients,
staff and visitors from scalding.
Recommendations for conducting an effective superheat-and-flush, based on the published
standards and guidelines (HSE, 2014; VHA, 2014; HSE, 2009; CDC, 2003; ASHRAE, 2000),
are summarized as follows:
•	When possible, perform flushing when the fewest building occupants are present (e.g.,
nights and weekends).
•	Post signage and warning notices at all areas of the building to alert occupants of the
potential scalding hazard.
•	Maintain water heater temperatures at 71-77 degrees C (160-170 degrees F) while
progressively flushing each outlet in the system for up to 30 minutes at 65 degrees C (149
degrees F).
•	Flushing multiple outlets simultaneously can save time, but should not exceed the
capacity of the water heater and the flow capacity of the system.
•	Perform flushing in a manner that reduces the risk of scalding and aerosolization of
potable water in patient-care areas.
•	Following superheat-and-flush treatment, maintain hot water system temperature >60
degrees C (140 degrees F) in all hot water lines.
•	At the end of the procedure, collect samples of water at distal outlets of the water system.
After the water temperature has returned to normal, Legionella culture should be
performed within two to seven days to determine efficacy of the treatment; the delay in
testing is intended to reduce false negative results caused by VBNC cells (HSE, 2014).
Culture should be repeated within two weeks of treatment to determine if there is any
short-term control. Repeat the procedure until decontamination is achieved. Following
decontamination, microbiological checks must be repeated periodically.
3.1.2 Shock Hyperchlorination
3.1.2.1 Background
Hyperchlorination involves injecting chlorine at an elevated concentration into the premise
plumbing system in one of two modes: shock or continuous hyperchlorination. Shock
hyperchlorination, often used for emergency disinfection, is the injection of chlorine to achieve a
level of 20-50 mg/L of free chlorine (as chlorine) (HSE, 2014; VHA, 2014). After a sufficient
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contact time, the water is flushed and the residual chlorine is returned to its normal level.
Continuous chlorination (sometimes called continuous hyperchlorination) is accomplished by
continuous injection of chlorine to achieve at least 0.5-1.0 mg/L (as chlorine) free chlorine
(HSE, 2014). It is often performed as a post-emergency disinfection procedure to aid the control
of Legionella and biofilms. Continuous hyperchlorination in premise plumbing systems is
discussed in Section 2.3.1.
3.1.2.2 Characterization of Effectiveness against Legionella
Hyperchlorination can be applied to the cold- and hot-water tanks and to the entire premise
plumbing system. It may be the only option in some healthcare facilities where superheat-and-
flush cannot be used because hot water lines are not available at every distal site or they cannot
reach the required high temperature.
The success of hyperchlorination in the control of Legionella has been mixed, as shown in the
case studies described later in the document and other studies in Section 2.3.1:
•	Garcia et al. (2008) conducted long-term surveillance and studied the persistence of L.
pneumophila in finished water systems at a hospital and a hotel before and after multiple
hyperchlorination treatments. Each facility had been associated with cases of
Legionnaires' disease. Prior to May 1998, the hotel's finished water system was
interconnected with the industrial water system. Over the period August 1992 to April
2001, at least seven hyperchlorination treatments were applied using a dosage rate of 10
mg/L and contact time of five hours, or a dosage rate of 20 mg/L and contact time of
eight hours. Between 1984 and 1995, the hospital's water system was treated with
hyperchlorination four times (dosage rate and contact time not stated by authors).
Environmental monitoring after each treatment showed that legionellae were absent for a
period of a few months. New cases of Legionnaires' disease also occurred after
hyperchlorination. The results of Legionella testing also demonstrated that successive
hyperchlorination treatments did not modify the susceptibility of bacteria to new
treatments with chlorine or other disinfectants. The authors noted that interaction with
other microorganisms, such as amoebae, could favor the persistence of L. pneumophila,
as noted in a previous investigation by Kilvington and Price (1990).
•	Despite shock hyperchlorination (with 50 mg/L) being applied to the cold- and hot-water
tanks and to the whole premise plumbing system, L. pneumophila colonization persisted
in a 250-bed hospital (Biurrun et al., 1999). A continuous chlorine system was installed
in the cold-water tanks to achieve approximately 0.8 mg/L of free residual chlorine at the
cold-water outlets (higher levels of chlorine and thermal treatment were not desired due
to the poor condition of the piping). This, along with elimination of dead ends,
replacement of contaminated fixtures, and other corrective measures, reduced the number
of positive sample sites from 88 percent to 17 percent. But one month later, colonization
was detected at a positive rate of 58 percent.
•	Grosserode et al. (1993) reported a 10-year follow-up study of the efficacy and
environmental effects of hyperchlorination for control of nosocomial legionellosis at a
university hospital. In the 10 years following an outbreak in 1981, the incidence fell
dramatically from 35 to less than 1 per 1,000 admissions; the frequency of cases of
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legionellosis also declined significantly from 16 cases among 21 tested to 5 cases among
294 tested. No legionellae were isolated from the more than 500 water samples collected
during the 10-year period.
In general, the efficacy of shock hyperchlorination is affected by the same factors as continuous
hyperchlorination, as described in Section 2.3.1. Shock hyperchlorination, if conducted alone,
would not achieve long-term control of Legionella. Researchers reported that Legionella could
be protected within free-living protozoan cysts of Acanthamoebae, which can survive free
chlorine concentrations up to 50 mg/L (Storey et al., 2004a; Kilvington and Price, 1990).
3.1.2.3	Potential Water Quality Issues
Regrowth of L. pneumophila may occur within days or weeks after shock hyperchlorination is
discontinued (Cooper and Hanlon, 2009), just as with the superheat-and-flush method. Multiple
shock hyperchlorination treatments may be needed in response to positive potable water cultures,
followed by continuous hyperchlorination or other treatment measures to achieve long-term
results.
Caution must be taken during shock hyperchlorination to avoid exposures to high disinfectant
levels. Signs and warning labels should be posted at sinks and other outlets to warn the building
occupants not to use the water (HSE, 2014). When possible, shock hyperchlorination should be
performed when the fewest building occupants are present (e.g., nights and weekends).
3.1.2.4	Operational Conditions
Recommendations for conducting effective shock hyperchlorination, based on published
guidelines (HSE, 2014; HSE, 2009; ASHRAE, 2000; Grosserode et al., 1993), are summarized
in this section:
Shock hyperchlorination of hot and cold water systems can significantly impact the physical
integrity of the piping system and water fixtures if applied incorrectly or too often. Corrosion of
metal pipes and appurtenances may occur from exposure to high levels of free chlorine (CDC,
2003). Therefore, routinely performing these procedures is not recommended (HSE, 2014).
Other recommendations include the following:
•	Post signage and warning notices at all areas of the building to alert occupants of the
potential chemical hazard.
•	When possible, shut off and bypass any existing water treatment equipment (e.g., water
softeners, carbon filters).
•	Clean the tanks and associated fittings. Remove sediment, sludge and stagnant water.
Correct other problems that may allow harboring of Legionella. For instance, fixtures and
fittings that contain rubber may facilitate growth of Legionella. Rubbers containing
thiuram disulfide do not enhance the growth of Legionella, and some have suggested the
use of such rubber in water systems (Niedeveld et al., 1986).
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•	To prevent colonization from recurring after emergency disinfection is discontinued, the
initial conditions that caused the problem (such as long water residence times) need to be
identified and corrected; the water temperature needs to be maintained at a proper level
(>60 degrees C, or 140 degrees F); or a residual disinfection treatment needs to be
installed for long-term routine operation.
•	Consider the use of continuous hyperchlorination, or another form of long-term treatment
if cases continue to be identified or if a Legionella strain isolated from patients persists in
the premise plumbing system. If Legionella isolates are limited to the hot water system,
continuous hyperchlorination should be initiated for the hot water system alone. Chlorine
levels need to be adjusted as required to keep DBPs at acceptable levels.
•	Monitor the hyperchlorinated premise plumbing system for pipe damage. Assays for
levels of copper, lead and iron, along with use of corrosion and water stability indexes,
may permit early detection and control of corrosion problems.
3.2 Point-of-Use Filtration
3.2.1 Background
POU filtration is defined as the use of a device applied to a single tap for the purpose of reducing
contaminants in drinking water at that one tap. POU filtration can be used at specific taps,
faucets and showerheads as a temporary measure to provide a physical barrier against
Legionella. Hospitals have used this technology to try to reduce disease transmission (Ortolano
et al., 2005). POU water filtration may be an effective measure for remediation situations if a
limited patient area can be targeted. Filters can be installed immediately and are a better
alternative than restricting showering and providing bottled water.
Advances in membrane filter technology have resulted in POU filtration systems capable of
removing microorganisms (USEPA, 2005c; USEPA, 2001). These treatment systems include
microfiltration (MF), ultrafiltration (UF), nanofiltration (NF) and reverse osmosis (RO)
processes. MF and UF use hollow-fiber membrane material contained in cartridges that separate
particles using a sieving mechanism based on the pore size and particle size. NF and RO use
spiral-wound (consisting of a flat sheet of membrane material wrapped around a central
collection tube) filter elements or cartridges. They are semi-permeable membranes without
definable pores. NF and RO are both pressure-driven systems that function similarly in their
removal mechanisms for microbial contaminants. Exhibit 3-1 describes the average pore size and
molecular weight cut-off requirements for different membrane filtration devices. For
comparison, Legionella cells are typically 0.3-0.9 micrometers (|im) wide and 2-20 |im long
when grown in laboratory culture (WHO, 2007).
Though ozone and UV may also be applied at the POU, this literature review does not include
information regarding POU application for these technologies.
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Exhibit 3-1: Membrane filtration guide for removal of microbial contaminants
Nominal Pore Size (microns)
0.0001 0.001
0.01
0.1
1.0
10
100
Molecular Weight
(daltons)
200
20,000 200,000
Microbial
Contaminants
Cryptosporidium
Viruses
Bacteria
Giardia
Membrane
Filtration Process
UF
NF
RO
Source: USEPA, 2005c.
EPA defines two criteria for membrane filtration technology for pathogen removal under the
Safe Drinking Water Act's (SDWA) Long Term 2 Enhanced Surface Water Treatment Rule (40
CFR 141.2):
•	The filtration system must be a pressure- or vacuum-driven process and remove
particulate matter larger than 1 |im (for Cryptosporidium, specifically) using an
engineered barrier, primarily via a size exclusion mechanism.
•	The process must have a measurable removal efficiency for a target organism that can be
verified through the application of a direct integrity test.
Many home owners; facility owners; and operators of hospitals, nursing homes and hotels utilize
POU membrane filtration devices, often in a proactive manner but also in response to
emergencies (USEPA, 2006d). Some hospitals use POU membrane filtration treatment in areas
populated with high-risk patients (e.g., in oncology wards, bone marrow and solid organ
transplant units, and ICUs).
Two ANSI standards exist for certification of POU devices used for removal of microbial
contaminants: Standard 53 (Drinking Water Treatment Units - Health Effects) and Standard 58
(Reverse Osmosis Drinking Water Treatment Systems). POU filtration devices have been
certified by NSF International for removal of protozoa, bacteria and viruses in general, using
surrogate microorganisms as challenge organisms during testing and evaluation. Lists of POU
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devices certified by independent, accredited laboratories to meet these standards are available
from Underwriters Laboratories (www.ul.com). NSF International (www.nsf.org/certified/dwtu)
and the Water Quality Association (www.wqa.org). Note that although some POU filtration
devices have been certified to meet bacterial removal standards, they have not been certified
specifically for removal of Legionella.
3.2.2 Characterization of Effectiveness against Legionella
Several case studies describe the effectiveness of POU membrane filtration devices for removal
of Legionella.
•	Casini et al. (2014) reported the efficacy of POU filtration installed in selected wards of
an Italian hospital to further reduce Legionella growth within the building hot water
system after chloride dioxide disinfection. POU filters used in this study had a 0.2-|im
nominal pore size and 30-day replacement rate. This integrated disinfection-filtration
strategy, although expensive, significantly reduced Legionella counts to less than 103
CFU/L and achieved a positive sample rate of less than 30 percent.
•	Baron et al. (2014b) evaluated a new faucet filter at five sinks in a cancer center and
found that legionellae were removed from all filtered samples for 12 weeks, exceeding
the manufacturer's recommended maximum duration of use of 62 days. The filters
contain a 30-|im pre-filtration layer, a l-|im membrane and a 0.2-|im membrane.
•	Marchesi et al. (2011) performed a 10-year review of multiple treatment methods to
control for Legionella at a hospital in Italy, including POU filtration, though information
on the characteristics of the filters was not supplied. Filters were placed in high-risk units
of the hospital only, where high levels of Legionella contamination were identified, and
were replaced every 30 days. No legionellae were detected at taps containing POU filters.
•	Daeschlein et al. (2007) evaluated a reusable POU filter for removing waterborne
pathogens, including L. pneumophila, in a hospital's transplant unit for eight weeks.
Filters had three configurations: (1) hollow fiber of polyethersulfone with pore size 0.2
|im and surface area of 800 cm2; (2) hollow fiber of polyethersulfone with pore size 0.2
|im, surface area of 1100 cm2, and inner encasement coated with nanosilver; and (3) same
as (2) with metallic silver outlet.
Filters were placed on 18 taps (12 taps, six showers) in the hospital's transplant unit and
each filter was monitored for pathogens at one, four and eight weeks, reprocessed and re-
used in three additional trials. Over the test period, no Legionella or other pathogens were
detected in any filter effluent. Because bacterial counts in filtered water exceeded the
limit of >100 CFU/mL eight times, the following criteria were developed to prevent
carry-over contamination from re-use of the filters: filters were cleaned with a strong
chemical followed by flushing and thermal disinfection in a quality control-compliant
washer-disinfector once a week, in addition to alcohol disinfection of the filter
encasement. With this reprocessing, the authors determined that filters should be changed
after four weeks in high-risk areas and after eight weeks in moderate-risk areas.
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•	A newer version of the filters described in the example by Daeschlein et al. (2007) was
evaluated by Vonberg et al. (2008) at a hospital in Germany. The new version had a
membrane surface coated with nanosilver. Fifteen taps in a thoracic surgery department
were selected and sampled before adding filters. Filters were placed on those taps and
sampled after one, two, three and four weeks of usage. Samples were analyzed for the
pathogens Legionella and Pseudomonas, in addition to the indicators enterococci and
heterotrophic bacteria. Legionellae were detected in nearly half (48.3 percent) of taps
before filters were added and only one sample (week 1) after filters were added (L.
pneumophila serogroup 1, 4 CFU/mL); no Pseudomonas were detected. The authors did
not attempt to reprocess the filters as in the Daeschlein study and did see heterotrophs
increase to >100 CFU/mL in some filters after one week of use. The authors concluded
that incorporation of nanosilver in the filter's membrane surface coating may prevent
biofilm growth in this POU device and that use of these POU filters with weekly
replacement in high-risk patient wards may be effective at preventing nosocomial
legionellosis.
•	Sheffer et al. (2005) evaluated POU filtration devices containing positively charged nylon
membranes with a 0.2-|im nominal pore size. Filters were placed on four taps in the
administration building at a hospital and monitored for Legionella, heterotrophic bacteria,
and Mycobacteria, along with three taps without filters, every 2-3 days for 13 days,
before and after a one-minute flush. Samples from taps with filters before flush were
negative for Legionella during the 13-day period, while mean concentration in taps
without filters was 104.5 CFU/mL. Mycobacterium gordonae was isolated from 10.3
percent of taps without filters before flushing, but no Mycobacteria were isolated from
taps with filters before flushing. Heterotrophs were significantly reduced at taps with
filters. One post-flush sample from a tap with a filter was positive tor Legionella on day
10, with a concentration of 5 CFU/mL. No post-flush samples from taps with or without
filters were positive for Mycobacteria. The authors concluded that the POU filters used in
this study effectively controlled Legionella and Mycobacteria through seven days of use.
•	Molloy et al. (2008) evaluated three types of POU solid block activated carbon filters for
removal of L. pneumophila in a laboratory-simulated domestic water system: (1) carbon
containing copper, (2) carbon containing copper and silver and (3) carbon without metals.
Filters were challenged with tap water seeded with L. pneumophila multiple times and
water was monitored under simulated domestic use for six weeks. Levels of Legionella
were reduced by all three filters by nearly 8 log (99.999999 percent), but they were
detected in all filter effluents for the length of the study. The authors concluded that the
organisms attached to the carbon blocks and sloughed off over time.
3.2.3 Potential Water Quality Issues
POU filters have the potential to concentrate bacteria (Molloy et al., 2008) and foster growth of
pathogens (Daeschlein et al., 2007; Sacchetti et al., 2015), especially if devices are not properly
maintained. Failure of filters could lead to the release of high levels of pathogens. Membranes
may foul (Warris et al., 2010) or be degraded by microorganisms.
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3.2.4 Operational Conditions
In general, most POU devices include pre-filtration (usually granular activated carbon) to treat
inlet water and prevent clogging of the central membrane, the central filtration membrane and
post-filtration, in a module configuration. Design guidance for POU filtration devices can be
found in EPA's Membrane Filtration Guidance Manual (USEPA, 2005c). Facility owners and
operators are advised to follow the manufacturer's operational guidance for the POU system
being employed. There is a variety of commercially available systems with unique design
features and operational conditions. Additional guidance on operation and maintenance for POU
treatment devices, including examples of maintenance logs, can be found in EPA's POU or POE
Treatment Options for Small Drinking Water Systems (USEPA, 2006d). A detailed maintenance
log should be kept for each system, based on the state's requirements, if any. Maintenance
typically includes the following:
•	Tracking flows - Flow meters are used to measure the total flow treated, as flow values
may be used to determine filter membrane or other component replacement parameters.
•	Replacement parts - Components should be replaced as required by the manufacturer or
monitoring data, to ensure water free of microbial contaminants. Minimal components
needing regular replacement include exhausted membranes and pre- and post-filters. A
30-day replacement rate was reported in the studies using POU filters for Legionella
control in hospitals (Casini et al., 2014; Marchesi et al., 2011).
•	Visual check of mechanical conditions - All components, including the mechanical
warning device, should be inspected visually on a regular basis and parts
replaced/repaired if necessary, in addition to being replaced as specified by the routine
replacement schedule.
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4 Questions and Answers on Legionella Control in Premise Plumbing
Systems
4.1	Public Health Concerns
Ql. What are the threats from Legionella in a premise plumbing system?
Legionella spp. are naturally occurring bacterial pathogens that can be present in municipal and
other water supplies. Premise plumbing systems may provide conditions (e.g., long water
residence times, water temperatures favorable (e.g., warm) for Legionella growth and low
disinfectant residual levels) that favor growth of Legionella to levels that may result in increased
risk to public health. For additional information please see Section 1.2 of this document.
Q2: Do all species of Legionella cause disease?
Although most of the diagnosed cases of legionellosis (Legionnaires' disease and Pontiac fever)
are associated with Legionella pneumophila (serogroup 1), approximately half of all the species
of Legionella have been associated with clinical cases of legionellosis. However, it is probable
that most legionellae can cause human disease under the appropriate conditions (e.g., in
individuals in higher risk groups) (Borella et al., 2005a; Fields, 1996; Fang et al., 1989). For
additional information, please see Section 1.2 of this document.
Q3. Do you need to eliminate all legionellae in order to have a safe building environment?
Not necessarily. Due to the highly variable and inconclusive information that is available, it is
not feasible to establish a definitive action level below which the risk from disease is eliminated.
Facility owners or operators may choose to assess the population they serve for individual factors
that may increase the risk of disease (e.g., age, immunosuppression) to reduce the risks from
legionellae. See Section 1.2.2 for additional information on risk factors. The facility owner/
operator may want to evaluate the premise plumbing system processes that could contribute to
Legionella growth (e.g., long water residence times and low disinfectant residual levels). This
assessment should allow the facility manager to determine the necessary stringency of the risk
management plan and measures (see Section 2.2 for additional information).
4.2	Potential Regulatory Requirements
Q4. What constitutes being a regulated public water system?
The criteria for being a regulated public water system (PWS) are provided in SDWA Section
1411 and 40 CFR 141.3. Where there are questions about the application of these criteria, the
primacy agency (typically the state) will make the determination based on these criteria and any
relevant site-specific considerations.
Q5. Will a building that installs a treatment specifically designed for Legionella and serves
a population above the threshold of a PWS definition be subject to SDWA requirements?
See response to Question 4.
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Q6. Do I need to comply with drinking water standards if I'm only treating the hot water
(not for drinking purposes)?
If you have been determined to be a regulated PWS you have to comply with applicable drinking
water standards (see response to Question 4). EPA considers water for human consumption to
include water for bathing, showering and dishwashing as well as water for drinking, food
preparation, brushing teeth and hand washing (see 40 CFR 141.801 and 63 FR 41940. Aug. 5.
1998). independent of its temperature.
Q7. If I comply with the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
pesticide requirements, am I in compliance with the Safe Drinking Water Act (SDWA)
requirements?
No. The pesticide requirements under FIFRA are independent of the SDWA requirements. Each
mandate targets complementary, yet different, environmental and public health protection
objectives. Registration of a pesticide product or regulatory compliance of a pesticide device
under FIFRA does not mean that it meets the requirements of other environmental and public
health protection statutes, including the SDWA or vice versa.
The objective of FIFRA is to protect human health and the environment through regulation of
pesticide distribution, sale and use. All pesticides distributed or sold in the United States must be
registered (licensed) by EPA, unless exempt. Registration assures that pesticides are properly
labeled and that, if used in accordance with their approved labeling (USEPA, 2013b), they will
not cause unreasonable adverse effects on the environment or human health.
Stakeholders should note that antimicrobial pesticide registrations are specific to pests, use sites
and use patterns. For instance, a product registered as a disinfectant for control of Legionella in
cooling towers cannot be sold or distributed for use in other sites for which it is not registered
(i.e., for control of Legionella in PWSs).
The SDWA is the main federal law that ensures the quality of Americans' drinking water. Under
the SDWA, Congress directs EPA to set national standards to protect public health, but allows
states, tribes and territories to seek EPA approval for primary responsibility to implement and
enforce these regulations. EPA maintains oversight of the states', tribes' and territories' drinking
water programs, including independent federal enforcement authority in primacy states.
While there are no requirements under SDWA that prohibit the installation of a given
technology, the primacy agency is typically responsible for accepting the installation or usage of
new technologies in PWSs. Both SDWA and FIFRA allow states to have stricter standards than
those prescribed in federal regulations. This includes the authority to request additional data or
information before approving a drinking water treatment technology or pesticides (see response
to Question 8 for additional information) to be used within the state. In the case of a pesticide, a
state can require compliance with a state-specific pesticide registration process in addition to the
EPA registration. With regard to technologies for drinking water treatment, primacy agencies
and technology manufacturers can refer to EPA's Water Supply Guidance (WSG) 90 (USEPA,
1996) for guidance on some of the types of data or information that may be requested as part of
the primacy agency's evaluation and approval of alternative drinking water treatment
technologies.
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Q8. What are the pesticide registration requirements related to pesticide products and
devices for the control of Legionella (and other microbial contaminants)?
Pesticide products and devices that make antimicrobial claims of efficacy against L.
pneumophila are subject to certain EPA regulatory requirements. FIFRA defines a pesticide as
any substance or mixture of substances intended for preventing, destroying, repelling or
mitigating any pest. The term pesticide includes antimicrobials (e.g., sanitizers and disinfectants)
in addition to various other substances used to control pests. Products that contain a substance or
mixture of substances and that make a pesticidal claim must be registered by EPA prior to sale
or distribution, unless exempt. For products that claim efficacy against a public health pest, an
applicant must submit data demonstrating that efficacy to obtain a registration.
While devices are subject to certain EPA regulatory requirements, they do not require
registration as pesticide products. A pesticide device is defined in FIFRA as an instrument or
contrivance (without a chemical substance) that is used to destroy, repel, trap or mitigate any
pest such as insects, weeds, rodents, animals, birds, mold/mildew, bacteria and viruses. Devices
include instruments or contrivances such as ultraviolet light systems, ozone generators, water
filters, etc. A device is subject to the FIFRA prohibition against misbranding and must be
produced in an EPA-registered establishment. Additional information on pesticide devices and
the associated FIFRA requirements is available on EPA's website and in the Pesticide
Registration Manual.
4.3 Control Measures
Q9. What measures can a facility owner or operator take to control the colonization and
amplification of Legionella in a premise plumbing system?
Buildings can vary in their characteristics (e.g., dimensions, location with respect to the servicing
PWS) as well as their purposes. The appropriate measures depend on those characteristics and
purposes. A risk management approach, including good design and engineering, can ensure a
comprehensive preventative method is followed to address potential health risks related to the
premise plumbing system. See Section 2.2 of this document for information on risk management
approaches. For additional information on how to develop and implement a risk management
program to reduce risks from Legionella in premise plumbing systems see the CDC's guidance.
Developing a Water Management Program to Reduce Legionella Growth & Spread in Buildings:
A Practical Guide to Implementing Industry Standards (CDC, 2016).
Q10. Does EPA regulate Legionella?
EPA regulates Legionella under the Surface Water Treatment Rule (SWTR). The SWTR has
treatment technique requirements to control for Giardia and viruses. The SWTR's treatment
technique requirements presume that if sufficient treatment is provided to control for Giardia
and viruses (i.e., 3-log (99.9-percent) inactivation of Giardia and 4-log (99.99-percent)
inactivation of viruses), then Legionella risks will also be controlled. In addition, the Revised
Total Coliform Rule (USEPA, 2013a) and the Ground Water Rule (USEPA, 2006a) have
treatment technique requirements that address bacteria. Corrective actions related to treatment
technique violations may provide some control of Legionella. All of these rules apply to PWSs.
They would not apply to premise plumbing systems unless the facility is a regulated PWS. See
response to Question 4.
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Qll. What treatment technologies does EPA approve for control of Legionella in drinking
water?
EPA does not approve any treatment technologies specifically for control of Legionella in
drinking water. See response to Question 17.
Q12. What is supplemental disinfection?
For the purposes of this document, supplemental disinfection refers to any additional treatment,
such as that added to reduce Legionella, used to supplement or boost the treatment provided by
the distributor of the water being received. To address water quality and pathogen control needs,
facility operators and owners, after a careful review of the premise plumbing system conditions,
may wish to implement a supplemental application of a disinfectant specific to and within the
premise plumbing system.
Q13. What happens if I add supplemental disinfection in my building?
If a decision to add treatment to the premise plumbing system seems likely, EPA advises facility
owners and operators to consult with their primacy agency to determine if any SDWA
requirements apply; in addition, there may be state or local requirements that apply. You may
also wish to consult with your water supplier (i.e., PWS) to better understand any potential water
quality issues before making treatment-related decisions. See Section 1.4 for additional
information.
Q14. What should I do before I consider supplemental treatment as a risk management
measure?
Assuming facility owners and operators have already identified and begun to address underlying
premise plumbing system deficiencies that may lead to Legionella risks (see Section 2.2 for more
information on Risk Management Approaches), those considering the addition of a supplemental
system are encouraged to contact their primacy agency, the PWS and other state and local
authorities and familiarize themselves with applicable federal, state and local regulations (e.g.,
building codes, local health codes). Facility owners and operators should also become familiar
with the characteristics and needs of their system to help determine the most appropriate action
(e.g., implementing a risk management approach and/or control technologies). Please see Section
2.2 on for more information on risk management approaches and Section 2.3 of this document
for more information on control technologies that could be used as supplemental treatment.
Q15. Are there any advantages to supplemental disinfection?
Facilities that design, operate, control and monitor supplemental treatment systems are trying to
help ensure that a high level of water quality is maintained, thereby improving public health
protection. Providing supplemental disinfection may help maintain the high level of water
quality throughout the premise plumbing system.
Q16. Are there any disadvantages to supplemental disinfection?
Operating supplemental water treatment requires the commitment of financial, physical and staff
resources to monitor the treatment process (e.g., disinfection byproducts formation, corrosion), to
ensure proper function and Legionella control. Other disadvantages may include formation of
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disinfection byproducts, corrosion of piping or possible degradation of piping materials. An
additional disadvantage is that installation of supplemental treatment could lead to a false sense
of security. For example, installation of supplemental treatment does not negate the need for
facility owners or operators and customers to respond to water supply emergencies (i.e., boil
water advisories, "do not consume" notices, "do not use" notices) issued by the selling system.
4.4	New Technology Approval
Q17. What is EPA's process for approval of treatment technologies to control Legionella in
drinking water?
Technologies that have antimicrobial claims (e.g., control of Legionella) need to comply with
registration or other requirements for pesticide products and devices under FIFRA (see response
to Question 8).
The EPA does not have an approval process for drinking water treatment technologies under
SDWA. Rather, the Agency recognizes technologies used for drinking water treatment for their
capacity to achieve treatment technique requirements for control of pathogens (under rules such
as the SWTR, GWR and LT2ESWTR). The EPA defers to the primacy agency for the approval
of technologies that PWSs can use to comply with treatment technique regulations. EPA, in
cooperation with the Association of State Drinking Water Administrators, state drinking water
program personnel, industry representatives and other stakeholders, developed a Water Supply
Guidance document (WSG 90) (USEPA, 1996) that provides a streamlined protocol to facilitate
consistent state approvals of new drinking water treatment technologies. WSG 90 is not meant to
replace current state plan review and approval processes.
Q18. How do states approve new treatment technologies for Legionella control?
Many states utilize a plan approval or permitting process to approve the installation of treatment
at PWSs. For new treatment technologies, many states (47) require conformance to ANSI/NSF
Standard 60 and/or 61. In addition, states may require third-party validation of efficacy. States
may also use the protocol described in WSG 90 to facilitate consistent state approvals of new
drinking water treatment technologies. WSG 90 is not meant to replace current state plan review
and approval processes.
If you are planning to install additional treatment in your facility, consult with your primacy
agency regarding any additional specific requirements. If you require further assistance, contact
the appropriate EPA regional office for additional information. For additional information,
please refer to Question 28 (Additional Sources of Information).
4.5	Permitting
Q19. What is the procedure for plan review and permitting to operate a Legionella
treatment system?
The procedure for plan review and approval or permitting varies from state to state. Some states
require a permit to construct/install a treatment system and a separate permit to operate the
system. Water system owners and operators should consult with their water provider and
primacy agency to find out specific procedures and requirements. Alternatively, contact the
appropriate EPA regional office for additional information.
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4.6 Sampling and Monitoring
Q20. If I am only treating the hot water, where should I take compliance samples?
SDWA requirements for PWSs apply to any water for human consumption independent of the
temperature of the water. Consult with your primacy agency regarding site-specific
requirements. Alternatively, contact the appropriate EPA regional office for additional
information.
Q21. What type of sampling (based on the selected treatment) will I be required to do?
Consult with your primacy agency regarding applicable sampling requirements. Alternatively,
contact the appropriate EPA regional office for additional information.
Q22. What residual disinfectants and disinfection byproducts (DBPs) do I need to monitor?
The Stage 1 D/DBPR and Stage 2 D/DBPR established maximum contaminant levels for DBPs
and maximum residual disinfectant levels for disinfectant residuals. They also specify the
monitoring requirements that regulated PWSs must perform for residual disinfectants and DBPs
(type, frequency and location), which will vary depending on the type of system, population
served and type of disinfectants being used. See the Stage 1 and 2 D/DBPR Quick Reference
Guide (USEPA, 2010) for more information on these regulations.
Q23. If I choose to use chlorine dioxide as a control technology are there any unique DBP
monitoring requirements that are different from chlorine and monochloramine?
Yes. If you are subject to the Stage 1 or Stage 2 D/DBPR requirements you may be required to
analyze daily chlorite samples on-site and send monthly chlorite samples to a certified laboratory
(see 40 CFR 141.13 1 (b). Footnote 8 in Table). In contrast, if you are using chlorine or
monochloramine you may be required to send quarterly samples for total trihalomethanes and
certain haloacetic acids.
Q24. Does EPA require Legionella testing if treatment for its control is installed? If so,
what are the targets for meeting control?
No. EPA does not have requirements for Legionella testing. However, state or local agencies
may specify such requirements in the permit conditions issued to the facility. In addition, there
may be requirements for monitoring of water quality parameters or treatment process parameters
on a routine basis.
Q25. If a facility has treatment and has either an outbreak or has Legionella test results
showing detections, are they required to report to the primacy agency?
If the facility is a regulated PWS, it must comply with 40 CFR 141.75 (a)(5)(i), which states the
PWS must report waterborne disease outbreaks potentially attributable to that system to the state
as soon as possible but no later than the end of the next business day. Also, there will be
reporting requirements defined by the state in response to a waterborne disease outbreak,
Legionella detection or even water quality conditions that may contribute to an outbreak.
Facilities that are not regulated PWSs may be required by the state to share information about an
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outbreak or Legionella detection with local health authorities. These agencies will be able to
assist with response actions.
4.7	Operator Certification
Q26. What qualifications do I need to operate treatment installed at my facility to treat
Legionella?
It depends on a number of factors, including whether your facility is a regulated PWS, the type
of water source and the type of treatment. EPA regulations require certain systems to be operated
by qualified personnel who meet the requirements specified by the state (40 CFR 141.70(c)).
EPA, in cooperation with states, developed and published guidelines specifying minimum
standards for certification and recertification of operators of community and non-transient non-
community water systems. These guidelines are currently being implemented through state
operator certification programs.
Certain systems that use chemical disinfectants must be operated by qualified personnel who are
included in a state register of qualified operators (40 CFR 141.130(c)). In addition, there are state
operator certification programs that may apply if your facility is a regulated PWS (see questions
in Section 4.2). While the specific requirements may vary, the goal is the same: to ensure that
skilled professionals are overseeing the treatment and distribution of safe drinking water.
Therefore, before adding treatment, EPA advises that you consult with your primacy agency to
determine if your facility is a regulated PWS and what qualifications or certifications you may
need to operate the treatment. More information on operator certification is available on EPA's
website.
4.8	Unintended Consequences
Q27. What are some of the unintended consequences of installing additional treatment for
Legionella?
For unintended consequences related to specific treatment technique requirements, please see the
subsections in this document entitled "Potential Water Quality Issues" for specific control
technologies (see Section 2.3).
4.9	Additional Sources of Information
Q28. How can I obtain additional information on each treatment method?
For additional information on any remaining general questions you can contact:
Safe Drinking Water Hotline by phone or email at:
-	(800)426-4791
-	hotline-sdwa@epa.gov
EPA's Drinking Water Website: www.epa.gov/safewater
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Appendices
A.l Types of Studies by Technology
This table identifies the type of studies conducted for each of the technologies presented in
Sections 2.3 and 3 of this document. Laboratory studies involve model distribution and
premise plumbing systems. The table also includes field studies which were conducted in
the actual distribution system or premise plumbing system.

... ... , . Distribution Premise Literature
Laboratory Field System P|Umbing Review or
Study Study ^ System stuUdy Survey
Chlorine

Lin et al., 1998a
X X
Muraca et al., 1987
X X
Kilvington and Price, 1990
X
Kim et al., 2002
X
Giao et al., 2009
X
Jacangelo et al., 2002
X
Kuchta et al., 1983
X
Saby et al., 2005
X X
Dupuy et al., 2011
X
Storey et al., 2004a
X
Colbourne and Dennis,
1989
X
Cooper and Hanlon, 2009
X
Loret et al., 2005
X X
de Beer et al., 1994
X
Cristino et al., 2012
X X
Snyder et al., 1990
X X
Flynn and Swanson, 2014
X
Kuchta et al., 1985
X
Orsi et al., 2014
X X
Casini et al., 2014
X X
Sarver et al., 2011
X X
Castagnetti et al., 2011
X X
Hassinen et al., 2004
X
Kirmeyer et al., 2004
x X
Grosserode et al., 1993
X X
Monochloramine

Jakubek et al., 2013
X
Dupuy et al., 2011
X
Jacangelo et al., 2002
X
Donlan et al., 2002
X
Cunliffe, 1990
X
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Laboratory
Study
Field
Study
Distribution
System
Study
Premise
Plumbing
System Study
Literature
Review or
Survey
Turetgen 2008
X
Whiley et al., 2014

X
X


Wang et al., 2012
X

X


Loret et al., 2005
X


X

Lee et al., 2011
X
Pressman et al., 2012
X
Coniglio et al., 2015

X

X

Baron et al., 2015

X

X

Baron et al., 2014a

X

X

Duda et al., 2014

X

X

Casini et al., 2014

X

X

Marchesi et al., 2013

X

X

Marchesi et al., 2012

X

X

Weintraub et al., 2008

X
X
X

Flannery et al., 2006

X
X
X

Moore et al., 2006

X
X
X

Heffelfinger et al., 2003


X
X
X
Kool et al., 2000


X
X
X
Kirmeyer et al., 2004


X

X
Zhang et al., 2002
X
Loret et al., 2005
X


X

Edwards and Dudi, 2004
X
Moore et al., 2006

X

X

Pryoret al., 2004

X
X


Gomez-Alvarez et al., 2012
X

X


Chlorine Dioxide

Dupuy et al., 2011
X
Loret et al., 2005
X


X

Jacangelo et al., 2002
X
Mustapha et al., 2015
X
Casini et al., 2014

X

X

Marchesi et al., 2013

X

X

Cristino et al., 2012

X

X

Marchesi et al., 2011

X

X

Zhang et al., 2009

X

X

Sidari et al., 2004

X

X

Gates et al., 2009
X
Dietrich et al., 1991
X
Lin et al., 2011b
X
Yu et al., 2013
X
Chord et al., 2011

X

X

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Laboratory
Study
Field
Study
Distribution
System
Study
Premise
Plumbing
System Study
Literature
Review or
Survey
Yu et al., 2011
X
Castagnetti et al., 2011

X

X

Copper-Silver Ionization

Yahya et al., 1989
X
Liu et al., 1994

X

X

Lin et al., 2011b
X
Demirjian et al., 2015

X

X

Dziewulski et al., 2015

X

X

Chen et al., 2008

X

X

Modol et al., 2007

X

X

Blanc et al., 2005

X

X

Stout and Yu, 2003



X
X
Rohret al., 1999

X

X

Liu et al., 1998

X

X

States et al., 1998

X

X

Lin et al., 2002

X

X

Kusnetsov et al., 2001

X

X

Lin et al., 1996
X
Landeen et al., 1989
X
Loret et al., 2005
X


X

Edwards et al., 1994
X



X
Lytle and Schock, 2008
X


X

Araya et al., 2004
X



X
Araya et al., 2003a
X



X
Araya et al., 2003b
X
Araya et al., 2003c
X
Araya et al., 2001
X
Knobeloch et al., 1994

X

X
X
Zevenhuizen et al., 1979
X
Knobeloch et al., 1998

X
X
X

Hong et al., 2010
X
Dietrich, 2009
X
Huang et al., 2008
X


X

Lin et al., 1998b
X
Shih and Lin, 2010
X


X

Chen et al., 2013

X

X

Pedro-Botet et al., 2007

X

X

Rohret al., 2000
X
Ultraviolet Light

Wright et al., 2012

X


X
Hall et al., 2003

X

X

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Laboratory
Study
Field
Study
Distribution
System
Study
Premise
Plumbing
System Study
Literature
Review or
Survey
Franzin et al., 2002

X

X

Liu et al., 1995

X

X

Gilpin et al., 1985
X
Muraca et al., 1987
X


X

Oguma et al., 2004
X
Knudson,1985
X
Antopol and Ellner, 1979
X
Ozone

Steineret al., 2010
X
Edelstein et al., 1982

X

X

Jacangelo et al., 2002
X
Domingue et al., 1988
X
Muraca et al., 1987
X


X

Loret et al., 2005
X


X

Carlson and Amy, 2001
X

X


Shah and Mitch, 2012
X
Superheat-and-Flush

Dennis et al., 1984
X
Best et al., 1983

X

X

Darelid et al., 2002

X

X

Chen et al., 2005

X

X

Allegra et al., 2011
X
X

X

Stout et al., 1998

X

X

Mietzneret al., 1997

X

X

Cristino et al., 2012

X

X

Heimbergeret al., 1991

X

X

Snyder et al., 1990

X

X

Liu et al., 1995

X

X

Stout and Yu, 2003



X
X
Temmerman et al., 2006
X
Pruden et al., 2013



X
X
Shock Hyperchlorination

Garcia et al., 2008

X

X

Kilvington and Price, 1990
X
Biurrun et al., 1999

X

X

Grosserode et al., 1993

X

X

Storey et al., 2004a
X
Cooper and Hanlon, 2009
X
Niedeveld et al., 1986
X
POU Filtration

Ortolano et al., 2005
X
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Laboratory
Study
Field
Study
Distribution
System
Study
Premise
Plumbing
System Study
Literature
Review or
Survey
Casini et al., 2014

X

X

Baron et al., 2014b

X

X

Marchesi et al., 2011

X

X

Daeschlein et al., 2007

X

X

Vonberg et al., 2008

X

X

Sheffer et al., 2005

X

X

Molloy et al., 2008
X


X

Sacchetti et al., 2015

X

X

Warris et al., 2010
X
X

X

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A.2 Elements of Hazard Analysis and Critical Control Points
Step 1 - Assemble HACCP Team - Pull together a multidisciplinary team to prepare, develop,
verify and implement the plan.
Step 2 - Describe Drinking Water - Describe the utility's drinking water, including its source,
treatment, storage, distribution and any existing standards for quality and safety.
Step 3 - Identify Intended Use - Describe how the drinking water is used and the major users.
Step 4 - Construct Flow Diagram - For a comprehensive HACCP plan, this would be a
schematic showing sources of water, details of treatment, storage, pumping and distribution to
end users. For a HACCP plan directed towards a distribution system, the schematic would be
restricted to showing the water flow path from the treatment plant to end users.
Step 5 -Confirm Flow Diagram - Since the flow diagram is a critical element used as a basis
for the HACCP plan, its accuracy should be confirmed by the HACCP team.
Step 6 - Conduct a Hazard Analysis - Using the process flow diagram, identify hazards, their
likelihood of occurrence, potential consequences and control measures.
Step 7 - Determine the Critical Control Points (CCPs) - For each significant hazard, identify
points in the process where the consequences of failure are irreversible.
Step 8 - Establish Critical Limit(s) - Determine critical limits for the CCPs that will trigger a
corrective action. A critical limit is a criterion which separates acceptability from
unacceptability.
Step 9 - Establish a System to Monitor Control of the CCPs - Establish monitoring points,
frequency and responsibility.
Step 10 - Establish Corrective Actions - Develop plans for follow-up activity when critical
limits are exceeded.
Step 11 - Validate/Verify HACCP Plan - Have the HACCP team and other affected parties
check the HACCP plan for accuracy, ability to implement and potential effectiveness.
Step 12 - Establish Documentation and Recordkeeping - Develop a record keeping system to
track system performance at CCPs.
Source: WHO (1997).
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A.3 Elements of a Water Management Program
PROGRAM TEAM—Identify persons responsible for Program
development and implementation.
DESCRIBE WATER SYSTEMS/FLOW DIAGRAMS—Describe
the potable and nonpotable water systems within the building and
on the building site and develop water-system schematics.
ANALYSIS OF BUILDING WATER SYSTEMS—Evaluate where
hazardous conditions may occur in the water systems and
determine where control measures can be applied.
CONTROL MEASURES—Determine locations where control
measures must be applied and maintained in order to stay within
established control limits.
MONITORING/CORRECTIVE ACTIONS—Establish procedures
for monitoring whether control measures are operating within
established limits and, if not, take corrective actions.
CONFIRMATION—Establish procedures to confirm that
ฆ	the Program is being implemented as designed (verification),
and
ฆ	the Program effectively controls the hazardous conditions
throughout the building water systems (validation).
DOCUMENTATION—Establish documentation and communication
procedures for all activities of the Program.
Source: ASHRAE (2015).
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A.4 Water Safety Plan Modules
Module 1 Assemble team
Set up a team and decide on a methodology by which a WSP will be developed.
Module 2 Describe the water supply system
Visit and thoroughly describe the complete water supply system, from catchment to
consumer.
Module 3 Identify the hazards and assess the risks
Identify all the hazards and hazardous events that could affect the safety of a water
supply from the catchment, through abstraction, treatment, storage, distribution and
point-of-use practices to the point of consumption, and assess the risks associated with
each hazardous event.
Module 4 Determine and validate control measures, re-assess and prioritize risks
Consider if controls or barriers are in place for each hazardous event, check if these
controls are effective and re-assess the risks in light of these controls and their
effectiveness.
Module 5 Develop, implement and maintain an improvement plan
Implement an incremental improvement and upgrade plan where necessary.
Module 6 Define monitoring of control measures
Implement plans for ongoing monitoring of controls or barriers to ensure that they
continue to work effectively.
Module 7 Verify the effectiveness of the WSP
Verify that the WSP as a whole is working effectively to support the consistent delivery
of safe and acceptable drinking water.
Module 8 Prepare management procedures
Establish and document management procedures, including standard operating
procedures (SOPs) and emergency response plans.
Module 9 Develop supporting programmes
Establish and document supporting programmes such as operator training, consumer
education, optimization of processes and research and development.
Module 10 Plan and carry out periodic WSP review
Regularly review and update the complete WSP.
Module 11 Revise WSP following an incident
Following any incident or event, consider if it could have been prevented or the impact
reduced, determine whether the response was sufficient and effective, and update the
WSP to incorporate any identified areas for improvement.
Source: WHO (2009).
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A.5 Elements of the American Industrial Hygiene Association Assessment Approach
The American Industrial Hygiene Association suggests that amplification of Legionella is one of
the links to Legionnaires' disease (AIHA, 2015). "A Routine Assessment... is inherently a
proactive effort intended to determine if Legionella amplification is occurring in building water
systems or other identified sources, or if current control measures are effectively keeping
Legionella populations in check. An Investigative Assessment... is performed as part of an
Outbreak Investigation intended to identify possible sources of Legionella amplification and
exposure that have caused illness in workers, visitors, residents or members of the public."
Routine Assessment Steps
1.	Inventory water systems.
2.	Observe and characterize water systems for Legionella amplification hazard.
3.	Conduct environmental sampling.
4.	Identify control measures.
Investigative Assessment Steps
1.	Inventory water systems.
2.	Observe and characterize water systems for Legionella amplification hazard.
3.	Conduct environmental sampling.
4.	Identify control measures.
5.	Perform disease surveillance.
Source: AIHA (2015).
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