UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WSG 120
Date Signed: October 29, 1996
MEMORANDUM
SUBJECT: Section 301 of the Safe Drinking Water Act Amendments of 1996
FROM: Cynthia C. Dougherty, Director
Office of Ground Water and Drinking Water
TO: Water Division Directors
Regions I - X
The purpose of this memorandum is to give you the language and context of Section 301
of the Safe Drinking Water Act Amendments of 1996. There has been some concern among the
Regions, States and the water utility industry over the use of potable water source heat pumps.
Demonstration projects have been installed in several states with the cooperation and
encouragement of the US Department of Energy. The Office of Ground Water and Drinking
Water, the Office of Research and Development and several Regions have raised a number of
concerns about the use of these types of heat pumps firm pub lie health and water quality
perspectives. Congress in the 1996 Amendments to the Safe Drinking Water Act repealed the
section of the Energy Act that required the Secretary of the Department of Energy to encourage
the use of these heat pumps.
Section 301 of the Safe Drinking Water Act amends the Energy Conservation and
Production Act by repealing section 3013, "Geothermal Heat Pumps." This section of the
Energy Act is quoted in its entirely below:
The Secretary shall- -
(1) encourage states, municipalities, counties and townships to consider allowing
the installation of geothermal heat pumps, and, where applicable, and consistent
with public health and safety, to permit public and private water recipients to
utilize the flow of water from, and back into, public and private water mains for
the purpose of providing sufficient water supply for the operation of residential
and commercial geothermal heat pumps; and
(2) not discourage any local authority which allows the use of geothermal heat
pumps from - -
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WSG 120
(A) inspecting, at any reasonable time, geothermal heat pump connections
to the water system to ensure the exclusive use of public or private water
supply to the geothermal heat pump system; and
(B) requiring that geothermal heat pumps systems be designed and
installed in a manner that eliminates any risks of contamination to th
public water supply.
A number of memoranda on municipal water source heat pumps have been issued over
the last few years. Both the Office of Research and Development and the Office of Water have
discouraged the use of this technology until satisfactory test results using the protocol developed
by the Office of Research and Development are provided. Among our numerous concerns are
the potential deterioration of water quality and the advisability of cross-connections between
heat exchangers and potable water mains. Our position remains unaltered, as no new data have
been submitted to deal with our concerns. The repeal of this section of the Energy Act does not
prohibit the use of this type of heat pump. As a consequence, we need to remain vigilant to any
potential drinking water concerns arising from the sue of this heat pump technology.
In this regard, I would request that the Regions consider the following suggestions. First,
each Region should attempt to identify any existing or proposed installations in their States. In
addition, we should remain vigilant to any public health or water quality problems that develop
and provide support to the States as the need arises.
If there are any questions you have concerning this matter or you have any information to
share, Steve Clark on 202-260-7159, is our oint of contact.
cc: Vanessa Leiby, ASDWA
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