Can our team still attempt WEc4.1 with a system that does not require blow-down and does not require chemical treatment as an alternative compliance method? Here is an excerpt from the plan:

1. Chemical Treatment: The water is pre-treated with a water softener and UV filter; there is no chemical treatment required.
2. Bleed-off/Blowdown: The cooling tower has no automatic blowdown feature, which wastes water and requires 1,500 gallons of water per day. The blowdown process is used when cleaning with acid or eliminating hard metal or other buildup. Because the water is pretreated, blowdown will not be necessary. Because using the blowdown feature is not necessary, the system saves 1,250 gallons per day.

With no blow-down requirements (except for annual maintenance), there is no need for conductivity meter/automatic controls. Similarly, the cooling tower water is pre-treated with a water-softener (non-toxic) and a UV light. Overall this method minimizes the amount potable water consumption for cooling tower equipment through effective water management, (as stated by the intent of WEc4.1) but does not meet the requirements for conductivity meters or "chemical" treatment.

Would this system be ineligible for this credit?