Cooling Towers: What You Need to Know
Just in time for the heat of summer, maintenance requirements for cooling towers are finally here. The Department of Health and Mental Hygiene recently released Chapter 8 of Title 24 of the Rules of the City of New York, specifically outlining ongoing maintenance requirements for city cooling towers. This is in addition to Annual Certification with the DOB, as outlined in Local Law 77 of 2015. Additionally, owners of cooling towers must also abide by SSC Part 4, which includes registration and reporting with the State of New York (in addition to any city requirements).
The Department of Health and Mental Hygiene recently released Chapter 8 of Title 24 of the Rules of the City of New York, specifically outlining ongoing maintenance requirements for city cooling towers
While we recommend reading Chapter 8 with your management team, we’ve outlined some of the most critical components of the law below.
While Chapter 8 includes a number of definitions, two are particularly important: “qualified person” and “responsible person”. These roles are responsible for different and specific maintenance-related tasks. A qualified person is a NYS licensed and registered professional engineer; a certified industrial hygienist; a certified water technologist with specific industry experience and training; or an environmental consultant with at least two years of operational experience in water management planning and operation.
The standards for being a responsible person are less specific, but just as important. In general, a responsible person is an employee or person whose services are retained by the owner. They must be capable of performing daily and weekly tasks in accordance with the maintenance plan, and be able to check and record cooling tower specifics, as outlined by the law.
In general, a responsible person is an employee or person whose services are retained by the owner.
Now that we’ve determined who is involved, here’s a brief overview of some of the things they have to do:
Mandatory tasks by both qualified persons and responsible persons must be performed in order to comply with the cooling tower’s maintenance plan, required by law and developed by the property’s qualified person in line with Chapter 8 requirements. The plan must be kept on-site and must be accessible if requested by an inspector. §8-03(a)-(d) lists specifics that must be included in the plan, and cites that owners must follow the most stringent requirements if there are conflicts between Chapter 8, SSC 4, the Administrative Code, or the manufacturer’s instructions. There are also standards to follow when a cooling tower ceases operation or goes back into operation after a certain length of time.
Select Tasks and Timing:
- Where a responsible person must monitor the cooling tower at least weekly, a qualified person is required to perform compliance inspections (process outlined in the law) at least once every 90 days.
- The tower must be cleaned whenever routine monitoring indicates a need, but no less than twice annually.
- Per the law, water in a cooling tower system must be treated at least once a day when the system is in operation, and such treatment may be automated (unless the maintenance plan specifically outlines how manual or less frequent biocide additions will effectively control legionella growth).
- A bacteriological indicator to estimate microbial content of recirculating water must be collected and interpreted according to law at least once per week while the tower is in operation.
If taking manual water quality measurements:
Water quality parameters must be measured at least 3 times each week, provided that no more than two days pass without such measurement when the cooling tower system is operating.
If there are continuous, automated, and/or remote water quality measurements:
The management program and plan must show how effective measurements of system process control are being monitored. Results must be properly recorded and made available to the department upon request.
Owners must keep and store records onsite for at least 3 years. In addition to completing Annual Certification with the DOB, owners must post the DOB-assigned Cooling Tower Registration number on the device.
Rounding out Chapter 8 is a list of 30 different possible infractions that may be issued for failure to follow any component of this law. Fines range from $250 for certain first offenses to $2,000 for select repeat violations.
To avoid those penalties, make sure the following docs are on your mandatory reading list, and review requirements with your qualified and responsible persons:
- ANSI/ASHRAE 188-2015, Sections 5, 6, and 7.2
- Local Law 77 of 2015 – DOB
- SSC Part 4 – New York State DOH
- Chapter 8 of Title 24 – DOHMH
A summary of this information (and other Cooling Tower-related basics) can be found in the SiteCompli NYC Violations Compliance Guide 2016 – click here to download a digital copy.