G.B. Collins Engineering, P.A. Comments to Proposed Code Modification SW7074-A1

Similar documents
2017 Florida Building Code 6 th Edition, Public Swimming Pool Changes, FBC Section 454.1, Effective January 1, 2018

Gas Injection Systems

Pool Standards 2014 (Amended 2017)

CHAPTER 64E-9 PUBLIC SWIMMING POOLS AND BATHING PLACES

Commandant United States Coast Guard

Existing Rule Language Compared to Proposed Rule Language

Disinfection in Communal Bathtubs Ronald George

Florida Department of Health Guideline for Routine Inspection Checklist

2009 NEW MEXICO SWIMMING POOL, SPA AND HOT TUB CODE

ANTI-ENTRAPMENT PLAN

Health risks posed by unregulated Water Park Installations in NSW

In this presentation we will talk about Florida Administrative Code, 64E-9 and how it regulates swimming pools and pool operator s responsibilities.

NZQA registered unit standard version 2 Page 1 of 5

Commandant United States Coast Guard

Drinking Water Safety Plans, Disinfection of Drinking Water & Revised EPA Disinfection Manual

Florida Senate SB 1694 By Senator Haridopolos

Safety Standards for Canadian Swimming Pools and Waterfronts Swimming Pool Standard

ENVIRONMENTAL HEALTH DIVISION POOL SAFETY 2017 UPDATES

SERVICE BULLETIN This service bulletin is for Accu-Tab Blue Calcium Hypochlorite Tablets (EPA Reg. No )

Ozone PLUS Germicidal UV Advanced Oxidation Process (AOP) A Synergistic Sanitation Approach for Residential Pools

B o a r d o f H e a l t h

Complete FAQ. Contents. General 1 Health 2 Technology 3 Equipment 4 Chemistry 7 Commercial 8

1 Exam Prep NSF/ANSI Tabs and Highlights

FINAL EXPRESS TERMS FOR PROPOSED BUILDING STANDARDS OF THE CALIFORNIA DEPARTMENT OF PUBLIC HELATH

5. Clearances- Fingerprinting and Training Requirements. 7. Record Keeping and Reporting Responsibilities

Commercial Pool Purification

Component Certification Specification for Floatation or Sensory Deprivation Systems and Related Equipment (CCS-12804)

Accu-Tab Systems 2000 P Series by Axiall Corporation

BUILDING STANDARDS INFORMATION BULLETIN 17-08

ORDINANCE NO AN ORDINANCE OF THE CITY OF FOLSOM AMENDING CHAPTER OF THE FOLSOM MUNICIPAL CODE CONCERNING SWIMMING POOLS, SPAS AND HOT TUBS

Disinfection Overview

A Guide to Safe Operation of Spray Pad/Splash Pad

Swimming Pool Requirements

REQUIREMENTS FOR ONBOARD LIFTING APPLIANCES AND ANCHOR HANDLING WINCHES

Aquatic Facilities Water Spray/Play Ground Application, Design & Operating Requirements Environmental Health Guide

Australian Standard. Swimming pool safety. Part 3: Water recirculation systems AS AS

Saskatchewan Health S A WHIRLPOOL DESIGN/OPERATIONAL T C H E W STANDARDS. Updated 02/00

INTERNATIONAL MARITIME ORGANIZATION

NZQA registered unit standard version 2 Page 1 of 5

Industry update on Ontario s Public Pools and Recreational Camps Regulations under the Health Protection and Promotion Act

AS AS Australian Standard. Spa pools. Part 2: Private spas. This is a free 6 page sample. Access the full version online.

Control of Legionella

MANAGEMENT PROCEDURE FOR LABORATORY VENTILATION

Public Swimming and Bathing Facilities Operators Guide 2018

WAKE COUNTY POOL PERMIT PRE-SEASON AUDIT 2014

Understanding and Compliance of the Virginia Graeme Baker Pool & Spa Safety Act

ANNEX AMENDMENTS TO THE INTERNATIONAL CODE FOR FIRE SAFETY SYSTEMS (FSS CODE) CHAPTER 15 INERT GAS SYSTEMS

Information sheet swimming pools Page 1 of 8. Introduction INFORMATION SHEET LVD ADCO PUMPS AND OTHER ELECTRICAL APPLIANCES FOR MOBILE SWIMMING POOLS

Industry Training for 2018 Aquatic Health Regulations. Chapter 2 Facility Design and Construction

Commandant United States Coast Guard

A GUIDE TO THE SIX ESSENTIAL ELEMENTS OF POOL MAINTENANCE.

Calibration Requirements for Direct Reading Confined Space Gas Detectors

Performance Validation of UV Reactors for Recreational Water O. Karl Scheible, Ernest (Chip) Blatchley III, PhD, PE, BCEE & Chengyue Shen, PhD

CHAPTER XXII SWIMMING POOLS 22 1 CONFORMITY REQUIRED.

TITLE XIV POOL AND SPA SAFETY

Piped Air SCBA Refilling System Standard

UsER manual for Watersens ph -REDOX

SMALL BUSINESS IMPACT STATEMENT

Summary of Substantive Changes between the 2003 and the 2014 editions of ANSI/APSP/ICC 1 American National Standard for Public Swimming Pools

TABLE OF CONTENTS CERTIFICATION OF COMPANIES, TECHNICIANS, AND TECHNICIAN APPRENTICES 2 REQUIREMENTS FOR SWIMMING POOL SERVICE COMPANY CERTIFICATION 3

Alberta Health. Pool Standards July 2014 (Amended January 2018)

New Jersey State Sanitary Code Chapter IX Public Recreational Bathing N.J.A.C. 8:26 Changes 1/16/18

Building Code Guidelines for Residential Pools

Biological Safety Cabinet Guidelines

SNOHOMISH HEALTH DISTRICT SANITARY CODE WATER RECREATION FACILITIES

Pool Information 2015

PUBLIC SPA CHECKLIST. Planning and Building Department City of Mississauga 300 City Centre Drive, 3th Floor Mississauga ON L5B 3C1

List of Forms. Form Description Page No. Form Commercial Swimming Pool Discharge Application Form 31-4

POOL CARE GUIDE. The E-Z Clor System To Perfect Pool Water.

Jennifer Hatfield FSPA Government Relations Consultant J. Hatfield & Associates, PL

TITLE 11. DEPARTMENT OF JUSTICE NOTICE OF PROPOSED RULEMAKING

While UV technology has been used in other

IMO HARMFUL AQUATIC ORGANISMS IN BALLAST WATER. Draft International Convention for the Control and Management of Ships Ballast Water and Sediments

MEMORANDUM. SUBJECT: Proposed revision to NSF/ANSI 50 Equipment for Swimming Pools, Spas, Hot Tubs and other Recreational Water Facilities (50i107)

NOW THEREFORE, BE IT ORDERED by the Galveston County United Board of Health of the Galveston County Health District as follows:

AWS C2.21M/C2.21:2003 An American National Standard. Specification for Thermal Spray Equipment Acceptance Inspection

Acid- Rite ph Adjustment System 2500 by Axiall, a Westlake Company

Swimming Pools, Hot Tubs and Spas

Installation and Maintenance Manual. ECO Filtration Unit with 6-way-Top-Mount-Valve. Art. Nr

I. Site Information. Pump Information

Dan Johnson, CBP Swim, Incorporated Lead Dog Aquatic Consulting

Permitt pursuant to. statements. for Construction. Application. permit, a signed

DELTA UV RESIDENTIAL ULTRAVIOLET DISINFECTION SYSTEMS

Cable Pressurization Buffering

SR: FA: PR: CT: All plans must be at least 18 x 24 and drawn to scale (min. ¼ per foot for pools or 1 per foot for spas and wading pools)

Accu-Tab Systems 1000 Series by Axiall Corporation

Pool and Spa. Water Testing

PHYSICAL FACILITIES Consultant s Handbook Division 33 Utilities 1300 Disinfecting Underground Potable Water Piping.

CUSTOMER ASSISTANCE GUIDE BUILDING PERMIT APPLICATION SUBMITTAL REQUIREMENTS

SWIMMING POOL OPERATION AND MAINTENACE GUIDE

CITY COUNCIL AGENDA MEMORANDUM

Accu-Tab PowerBase 3012AT by Axiall Corporation

Appendix A ORDINANCE NO. An ordinance amending Chapter 43A, Swimming Pools, of the Dallas City Code by amending

Jackson County Department of Public Health Application to Construct, Install, Remodel or Modify a Public Swimming Pool

CHAPTER 5 WATER QUALITY, TEST KITS, RECORD KEEPING

Office Use Only Fee Paid

PUBLIC SWIMMING POOLS REGULATION

SANITIZERS SANITIZERS

hth EASIFLO SYSTEM New Generation for 2015 Feeder specifications hth EASIFLO The perfect solution for treatment of commercial swimming pools

B o a r d o f H e a l t h

Transcription:

G.B. Collins Engineering, P.A. Comments to Proposed Code Modification SW7074-A1 I. REFERENCES: CURRENT CODE PROVISIONS Florida Building Code, 5th Edition (2014) Chapter 4 Special Detailed Requirements based on Use and Occupancy Section 454 Swimming Pools and Bathing places (Public and Private) 454.1 Public swimming pools and bathing places. 454.1.9.8 Interactive Water Features (IWFs) 454.1.9.8.6.1 The filter system shall filter and chemically treat all water that is returned to the spray features. The filter system shall draft from the collector tank and return filtered water directly to the spray features. Excess water not required by the spray features shall be returned to the collector tank. 454.1.9.8.6.2 The water feature pump shall draft from the collector tank. 454.1.9.8.6.3 Alternatively, the contained volume of the system may be filtered and chemically treated based upon a 30-minute turnover of the contained volume with 100 percent returned to the collector tank by manifold piping. If this alternative is chosen, all water returned to the spray feature(s) must also be treated with an Ultraviolet (UV) light disinfection equipment to accomplish protozoan destruction in accordance with sound engineering and the requirements of Section 454.1.6.5.16.6. This alternative must have the ability to feed 6 mg/l free chlorine to the feature water as it is returned to the spray feature. The UV disinfection equipment shall be electrically interconnected such that whenever it fails to produce the required UV dosage, the water spray features pump(s) and flow will be immediately stopped. II. BACKGROUND: CURRENT MODIFICATION PROPOSAL: SW7074-A1 On June 21, 2016, Bob Vincent from the Department of Health ( DOH ), in response to proposed code modification SW7074, proposed alternate language, known as SW7074-A1. SW7074-A1 provides: 454.1.9.8.6.1 Strike all, and Add: All (100%) of the water from the collector tank must be first filtered, treated with disinfectant and ph adjustment chemicals, and then final treatment provided by an NSF Standard 50 certified UV disinfection unit with a minimum 40 mj/cm2 dose before any of this treated water is piped to the water features. 454.1.9.8.6.2 Strike all, and Add: In the design above and the alternative below: excess water not required by the water features shall be returned to the collector tank; the recirculation system Page 1 of 6

Statutes. shall be sized to treat the contained volume of water based upon a 30 minute turnover with a chlorine feeder/generator capable of producing a dosage of at least 12ppm; and the UV disinfection equipment shall be electrically interconnected such that whenever it fails to produce the required UV dosage, the water spray features pump(s) and flow will be immediately stopped. 454.1.9.8.6.3 Strike all, and Add: In lieu of 454.1.9.8.6.1, the recirculation system must be designed to continuously return 100% of the water to the collector tank after all (100%) of the water is first filtered, treated with disinfectant and ph adjustment chemicals, and the final treatment provided by a validated UV disinfectant unit described in 454.1.6.5.16.6 before any of this treated water is piped to the water features. 454.1.9.8.6.8 Delete this code section as unnecessary SW7074-A1 is now moving into the rulemaking stage under chapter 120 of the Florida III. SW7074-A1 LACKS SUPPORT FOR ITS REQUIREMENT OF A VALIDATED UV DISINFECTANT UNIT SW7074-A1 provides two alternative requirements for UV disinfectant units for Interactive Water Features ( IWFs ) but lacks support for the requirement of one UV disinfectant unit over the other. As written, the modification will lead to inconsistent enforcement, a restraint on trade, and the need for additional code modifications. The proposed modification to section 454.1.9.8.6.1 ( Mod 1 ) provides, in part: final treatment provided by an NSF Standard 50 certified UV disinfection unit with a minimum 40 mj/cm2 dose before any of this treated water is piped to the water features (emphasis added) as opposed to the proposed modification to section 454.1.9.8.6.3 ( Mod 3 ) which states and the final treatment provided by a validated UV disinfectant unit described in 454.1.6.5.16.6 before any of this treated water is piped to the water features (emphasis added). Section 454.1.6.5.16.6 provides: Ultraviolet (UV) light disinfectant equipment may be used as supplemental water treatment on public pools (and additional treatment on interactive water features (IWF's)) subject to the conditions of this paragraph and manufacturer's specifications. Page 2 of 6

UV is encouraged to be used to eliminate or reduce chlorine-resistant pathogens, especially the protozoan cryptosporidium. 1. UV equipment and electrical components and wiring shall comply with the requirements of the National Electrical Code and the manufacturer shall provide a certification of conformance to the department. 2. UV equipment shall meet UL standards and shall be electrically interlocked with recirculation pump(s) on all pools and with feature pumps(s) on an IWF such that when the UV equipment fails to produce the required dosage as measured by an automated sensor, the feature pump(s) are disabled so the water features do not operate. 3. UV equipment shall be validated by a capable party that it delivers the required and predicted UV dose at the validated flow, lamp power and water UV transmittance conditions, and has complied with all professional practices summarized in the USEPA Ultraviolet Disinfectant Guidance Manual dated November 2006, which is publication number EPA 815-R-06-007 available from the department at http://www.floridashealth.org/environment/water/swim/index.htmlor at http://www.epa.gov/safewater/disinfection/lt2/pdfs/guide_lt2_uvguidance.pdf. 4. UV equipment shall constantly produce a validated dosage of at least 40 mj/cm2 (millijoules per square centimeter) at the end of lamp life. 5. The UV equipment shall not be located in a side stream flow and shall be located to treat all water returning to the pool or water features. 1 The proposed modification lacks support as to why an NSF Standard 50 certified UV disinfection unit with a minimum 40 mj/cm2 dose is permitted in Mod 1 but a validated UV disinfectant unit is required by Mod 3. In fact, a NSF certified UV disinfectant unit can have the same specifications as a validated system. A validated system undergoes validation testing to determine the operating conditions under which a UV reactor delivers the validated dose. 2 NSF, however, performs very similar testing including but not limited to product evaluations, product testing in a laboratory, and manufacturing facility testing. Accredited by the American National Standards Institute (ANSI), NSF has developed American National Standards under the scope of public health, safety, environment and sustainability assessment. NSF standards are developed through a public process that ensures balanced input from industry representatives, public health/regulatory officials and consumer 1 A proposed code modification (SW7014) is currently pending for paragraph 3 of this provision. SW7014 proposes to add the words used in higher risk facilities such as interactive water features, wading pools, and activity pools after the first two words ( UV equipment ) of paragraph 3. 2 The validated does is defined as the UV dose in units of millijoule per centimeter squared (mj/cm2) delivered by the UV reactor as determined through validation testing. Page 3 of 6

representatives. NSF s impartial accredited certification provides all stakeholders, industry, regulators, users and the general public, assurance that a certified product, material, component or service complies with the technical requirements of the referenced standard. This impartiality in carrying out its certifications controls all conflicts of interest and ensures its objectivity and transparency. As such, the certification provided by NSF has been relied upon within the commercial pool industry and should be relied upon within this modification. The NSF Standard 50 is the standard used by many other states for UV disinfectant units on IWFs. For example, California requires UV disinfectant units to comply with the requirements established by the NSF/ANSI 50-2010: 3106 B.16 Ultraviolet light disinfection shall be used to supplement disinfection methods required in this Chapter unless another treatment process is provided that has been determined by a NRTL to be capable of providing at least the equivalent level of reduction of cryptosporidium as the ultraviolet light disinfection system specified in this section. The ultraviolet light disinfection unit shall comply with the applicable requirements established by the NSF/ANSI 50-2010 performance standard effective August 2010. Cal. Code Regs. tit. 24 3106. Another example is Indiana which requires that ultraviolet light dosage be forty (40) mj/cm2 or greater (which is the standard under Mod 1): 675 IAC 20-5-23 Disinfectant equipment and chemical feeders (2) Secondary disinfection such as ultraviolet light or ozone in addition to chemical disinfection. (A) Disinfection equipment shall be tested and listed for use in spray pad disinfection. (B) Ultraviolet light dosage shall be forty (40) mj/cm2 or greater. (C) Ultraviolet light systems shall have a properly calibrated light intensity meter, automatic water flow shutoff in the event the light intensity decreases below recommended level and an alarm to advise of a malfunction. (d) Skimmer baskets shall not be used as chemical feeders. 675 Ind. Admin. Code 20-5-23. These are just two examples of many. Thirty-one U.S. states, including Florida, utilize and/or require NSF certified pool products, including but not limited to UV disinfectant units. Page 4 of 6

Furthermore, Mod 3 is not sufficiently clear and will result in uneven and inconsistent enforcement, which restrains trade. Under Mod 3, a UV disinfectant unit must be validated by a capable party that the unit complies with the practices of the USEPA Manual. However the Florida Building Code fails to define a capable party. This ultimately sets the DOH and Florida contractors and engineers up for conflict and will most certainly lead to inconsistent enforcement and the need for additional code modifications. This must be addressed before the code modification is set into law. In sum, a validated UV disinfectant unit does not provide superior filtration or other benefit over a NSF Standard 50 certified UV disinfectant unit. Requiring a validated UV disinfectant unit will restrain trade by significantly increasing the cost of construction and maintenance of IWFs and pool systems while failing to provide any benefit sufficient to justify the increased costs. Furthermore, ambiguities and lack of clarity within SW7074-A1 will cause uneven, inconsistent, and potentially selective enforcement which will further restrain trade by discouraging engineers and contractors from designing and building IWFs. IV. PROPOSED MODIFICATION TO SW7074-A1 Mod 1: 454.1.9.8.6.1 All (100%) of the water from the collector tank must be first filtered, treated with disinfectant and ph adjustment chemicals, and then final treatment provided by an NSF Standard 50 certified UV disinfection unit with a minimum 40 mj/cm2 dose before any of this treated water is piped to the water features. Mod 2: 454.1.9.8.6.2 In the design above and the alternative below: excess water not required by the water features shall be returned to the collector tank; the recirculation system shall be sized to treat the contained volume of water based upon a 30 minute turnover with a chlorine feeder/generator capable of producing a dosage of at least 12ppm; and the UV disinfection equipment shall be electrically interconnected such that whenever it fails Page 5 of 6

to produce the required UV dosage, the water spray features pump(s) and flow will be immediately stopped. Mod 3: 454.1.9.8.6.3 Strike all OR in alternative stricken language marked through and alternative language in bold In lieu of 454.1.9.8.6.1, the recirculation system must be designed to continuously return 100% of the water to the collector tank after all (100%) of the water is first filtered, treated with disinfectant and ph adjustment chemicals, and the final treatment provided by a validated UV disinfectant unit described in 454.1.6.5.16.6 NSF Standard 50 certified UV disinfection unit with a minimum 40 mj/cm2 dose before any of this treated water is piped to the water features. Respectfully submitted, Samuel A. Liberatore G.B. COLLINS ENGINEERING, P.A. Page 6 of 6