Public comments for: Cooling Towers - New Chapter 8 in Title 24 of the Rules of the City of New York to establish rules for maintenance of cooling towers

Comments

Comment:
Dear nycdoh, my family and I run a small FSE in Manhattan.Years ago the city started a water conservation program and we were told that all water-cooled refrigeration equipment would be required to use a water recirculation system in order to save water.We use water cooled equipment because it is more energy efficient, which it seems to be encouraged now by the city.Our cooling tower is the smallest(7 tons capacity) that was commercially available at the time, a little bigger than a standard refrigerator.we have always cleaned and maintained the system ourselves because it operates more efficiently when it is clean.The recent problems with very large Air Conditioning system cooling towers that were not being maintained in NYC has caused concern and we feel we are being unfairly included in this group.The nycdoh should realize that all cooling tower systems are not the same and should draft their new regulations accordingly, possibly by size and configuration, proximity to hospitals,ect.We understand the concerns of the nycdoh to protect the public from health hazards caused by improperly maintained equipment,but just as all restaurants are inspected and graded on their performance maintaining their cleanliness and food protection practices,so should cooling tower systems on their size,use and the realistic risk they could possibly pose to their immediate areas.Thank you for allowing me to comment on this ongoing issue,Paul LaMarca, plant manager,Lamarca Pasta Inc. 161 e 22nd st. NY NY 10010, 212 673 7920
Agency: DOHMH
Comment:
Comments are attached
Agency: DOHMH
Comment:
see attached document
Agency: DOHMH
Comment:
LiquiTech Environmental has been successfully remediating and preventing Legionella bacteria in water for approximately 30 years. LiquiTech is proud to call most of NYC's top hospitals our client for the last couple decades, providing highly effective long term solutions that prevent the occurrence of Legionnaires Disease (LD) when the program is properly maintained. These facilities have proven that LD is a completely preventable public health problem when an effective disinfection program is effectively maintained by achieving the goal of no LD cases. We applaud the DOH for taking decisive action to address this significant public health concern. It is a good first step to improving public safety. We believe some important adjustments could make the regulation more pragmatic for building operators while simultaneously improving the outcomes by reducing the incidence of Legionnaire's Disease. Regarding the scope of exposure to Legionella, the causative agent. Historical records show that cooling towers account for less than 25% of Legionnaire's Disease cases. While this is an area of significant concern, greater consideration should be given to preventing Legionella in potable water systems. Potable drinking water systems have been identified as the source of many more cases of Legionnaire's Disease accounting for approximately 60% to 70% of overall cases and must be considered in order to reduce the overall impact of LD. Additionally, many experts believe that because cooling towers tend to result in larger clusters of cases they are historically more easily implicated in outbreaks. As testing for LD intensifies, it is predicted that we will catch more cases associated with potable water and cooling towers will account for even less of the overall cases of LD as a percentage. We are confident that the 323% increase from 2005-2014 is a result of greater awareness and better detection of a pre-existing problem, not that LD is actually occurring more, its just being detected more. Biocides should also be appropriately registered with US EPA Office of Pesticides Program for the effective control specifically against Legionella. Biocides without this registration have not met US EPA requirements under FIFRA and have not demonstrated an effective capability to control Legionella. Additionally, unregistered treatment methods are prohibited from making any claims against Legionella and cannot be installed for this purpose. Without an automated system, a daily testing regimen should be reconsidered as it is overkill from a monitoring control standpoint, may not be feasible for many facilities and will likely be too burdensome for others. Thank you for your time and consideration.
Agency: DOHMH
Comment:
I am in favor of cooling towers regulation. I believe treatment should be required, along with monitoring. However, after reading the extensive rules that have been proposed, I believe some modifications should be made. Unfortunately, the timing of the law and the limited window for public comment, would not allow for complete technical debate on the merits of each rule. I believe that some rules regarding the constant circulation of systems and/or extremely low bacteria levels (Legionella counts 10x lower than past OSHA recommendations haven no proven benefit). It will lead to increased doses of microbiocides and/or excessive electrical consumption. This will lead to both water and carbon pollution. It is approximately 20 pounds of carbon/ pump-horsepower to operate a circulation pump with some pumps requiring more than 50hp. This will add over 1000 pounds of carbon into the atmosphere for every extra day that this pump is required to run. For some system this is more than 100,000 lbs of carbon per year! I believe daily testing has many merits. However, some facilities are not staffed seven days a week. This will be quite burdensome on owners and operators.
Agency: DOHMH
Comment:
The following comments are submitted on behalf of Consolidated Edison Company of NY, Inc. (“Con Edison”): (6) Proposed Section 8-06(b) requires a Legionella sample be tested and analyzed prior to the startup of a cooling tower that has been shutdown for 5 days or more. It can take up to 2 weeks to obtain the results of a Legionella test. Con Edison operates utility system critical cooling towers. The delay of an additional 2 weeks before bringing a unit back into service will negatively impact utility system reliability. We request the ability to test and clean the cooling tower and bring the unit into service prior to receiving the test results. If a positive legionella test result is received, additional disinfection would be carried out as indicated by the result. (6) Proposed Section 8-06(b) requires a Legionella sample be tested and analyzed prior to the startup of a cooling tower that has been shutdown for 5 days or more. It can take up to 2 weeks to obtain the results of a Legionella test. Con Edison operates utility system critical cooling towers. The delay of an additional 2 weeks before bringing a unit back into service will negatively impact utility system reliability. We request the ability to test and clean the cooling tower and bring the unit into service prior to receiving the test results. If a positive legionella test result is received, additional disinfection would be carried out as indicated by the result.
Agency: DOHMH
Comment:
The following comments are submitted on behalf of Consolidated Edison Company of NY, Inc. (“Con Edison”): (5) While the summary on page 3 of the proposed rule recognizes a difference between specifying new cooling towers with a drift eliminator and the difficulty of retrofitting a drift eliminator onto an existing cooling tower, proposed Section 8-04(e) “Aerosol and Mist Control” does not include this distinction. The addition of a drift eliminator onto an existing cooling tower requires an engineering evaluation to determine the feasibility of this modification without reducing the effectiveness of the unit to the point of eliminating its usefulness. If an engineering analysis determines that no manufacturer provided drift eliminator can be fitted to an existing unit without causing a significant negative impact on unit efficiency and effectiveness, then that unit would be exempt from the requirement.
Agency: DOHMH
Comment:
The following comments are submitted on behalf of Consolidated Edison Company of NY, Inc. (“Con Edison”): (4) The definition for “Responsible Person” in proposed section 8-02 discusses required daily water quality treatment measurements. Proposed Section 8-04(a) discusses “at least weekly” monitoring. Proposed Section 8-05(f) “Water Quality Monitoring” requires a daily test of pH, temperature and residual biocide. We request that the requirement for water quality testing be set to “at least weekly” as a daily water quality test is unnecessarily burdensome. The incubation period for legionella is 2 to 10 days. In a routinely maintained system, a weekly test would be sufficient to detect any irregularities and take corrective action.
Agency: DOHMH
Comment:
The following comments are submitted on behalf of Consolidated Edison Company of NY, Inc. (“Con Edison”): (3) Con Edison operates a cooling tower at its LNG plant that is covered by a State Pollution Discharge Elimination System (SPDES) permit. The cooling tower discharges water directly into the ground. For this reason, the unit uses the Residual Oxygen Species (ROS) system described above to eliminate the presence of chemicals in the discharge water. We request consideration in the regulation for all sites that are governed by a SPDES permit such that compliance with the proposed rule cannot violate the requirements of the SPDES permit. The SPDES permit holder can work with city and state agencies to determine an acceptable treatment method while maintaining compliance with all other regulations and permit requirements.
Agency: DOHMH
Comment:
The following comments are submitted on behalf of Consolidated Edison Company of NY, Inc. (“Con Edison”): (2) Proposed Section 8-05 requires the daily treatment of cooling tower water with a biocide registered with New York State DEC. This section also specifically forbids the use of non-chemical water treatment devices. Con Edison currently operates a cooling tower at its LNG plant that uses Residual Oxygen Species (Ozone) as the daily water treatment method. This is an accepted and well established water treatment method in the potable water treatment industry. ROS can persist in water for up to 20 minutes while the cooling tower in question has a turnover rate of less than 3 minutes, thus ensuring that there is residual ROS in the system at all times that it is in operation. We request consideration in the regulation for the use of this technology as an acceptable equivalent to the use of a DEC approved chemical biocide for daily water treatment. As described below, chemical biocide can be harmful to the LNG infrastructure and may reduce reliability of the system. In the event of a positive legionella test, a chemical disinfection of the unit would be performed. (2A) The unit serves multiple shell and tube heat exchangers of varying metallurgy. The introduction of harsh oxydizers into the system risks degradation of the metal and system failure. Many components of this system are custom made and have a replacement lead time in excess of 2 years due to engineering and fabrication requirements. A failure of one of these components would endanger system reliability by removing the liquid natural gas (LNG) storage from the system. The LNG storage is used to provide additional supply to the system during peak demand and is an emergency backup supply should one of the main gas supply lines into the city be disrupted.
Agency: DOHMH

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