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:
Part II Copper-Silver Ionization, Ultra-Violet Light, and Ozonation are non-chemical biocides recognized by regulating bodies and have been used by thousands building operators and industries. With the right sizing, application and dosing, these integrated water treatments could prove to be an effective tool in eradicating these problems in Cooling Tower operations and maintenance. At the same time the system would drastically reduce the chances of human error leading to fatalities originating from the cooling towers. Return on Investment (ROI) considering Water and Power Savings can be less than 5 years. These closed loop filtration with electronic descaling and basin sweeping systems could be retro-fitted with existing chemical treatment as a Hybrid System, making the non-chemical approach the fail-safe option to prevent fatalities. This option can also reduce water consumption by more than 30% of the total water being used in a building. 1. Benefits of these integrated system are the following: • Eradication of Bacteria, targeting Legionnaire’s disease in particular • pH balance with acceptable Langlier Saturation Index(LSI) and Ryznar Index(RI) for better corrosion and scaling control • Increased Equipment Life • Improved and Reliable System with Higher Efficiency • Reduced Maintenance and Labor Costs • Improved Chemical Control • Safe Environment • Water Savings of more than 30% in the building • Energy Savings of more than 5% in a building • 24/7 monitoring system with remote access that send indicators/markers of possible high bacteria These redundancies are justified by the resulting higher Cycles of Concentration that leads to balanced water chemistry with less make-up water, less bleed off and less sewer charges.
Agency: DOHMH
Comment:
Part I Based on the proposed rules we believe the following should be added to prevent human error and fatalities: • An integrated water treatment system should have a Fail-Safe redundancy of multiple levels. • This is important for many reasons. Bacteria can build up a tolerance and immunity to chemicals biocides over time. Utilizing multiple forms of biocide treatment increase the effectiveness of controlling and eliminating bacteria in cooling towers. • A Closed Loop side-stream filtration, either with Centrifugal Separators with micronic discharge filters or High Efficiency Multi-Media Filters, dedicated to clean the sump or basin of the tower and part of the Process Water. o This design returns filtered and treated water back to the system for water conservation as well. Particulates are collected in the Filter Bag Housing. • Combine the above side-stream filtration with an Electronic Descaling Frequency Resonator that restructures water molecules. This is so the calcium and magnesium carbonates, the most common form of scales and bio-film in process water, may precipitate and be filtered. This device would remove existing scales in pipes, tubes and in plates. Scaling and bio-film become the habitat for bacteria even after cooling towers are drained. When cooling towers are drained the bacteria lies dormant and multiplies again over time. This is similar to cases we have heard about last summer after a full cleaning. • Manifolded Basin Sweeper-Nozzles prevents stagnation of water in the basin and cleans majority of the basin area of particulates, sediments from the air and process water. In almost all cases bacteria is found lying in the stagnant areas of the cooling tower. • Integrating these side-stream filtration, electronic descaling and basin sweeping with any two of the following disinfection systems would ensure redundancy and fail-safe operation of the cooling tower by preventing and controlling growth of bacteria, molds and algae. The system would work in conjunction with current chemicals being used, namely: 1. Copper-Silver Ionization 2. Ultra-Violet Light 3. Ozonation
Agency: DOHMH
Comment:
Please see attached comment letter from Memorial Sloan Kettering Cancer Center.
Agency: DOHMH
Comment:
1) Using HPC dipsides may underestimate or overestimate HPC concentrations buy an order of magnitude or more. Also every different HPC dipslide manufaturer uses different formulations of agar; some use different formulations of "nutrient agar" while others use BCYE agar for HPC counts. These dipslides are not supported by consistent manufacturing processes nor are they supported by scientifically sound method verification or validation. I suggest that the use of dipslides be eliminated and replaced by HPC culture tests following Standard Methods for HPC Testing using Standard Plate Count Agar and following Standard Method specified shipping/holding time requirements. 2) Please define what you mean by Legionella species. Do you want all Legionella species identified and enumerated? Do you want all Legionella species serotypes identified and enumerated? 3) CDC and other international health agencies have conducted research that documents that potable water is responsible for more cases of Legionnaires' Disease than cooling towers. Do you have any plans to expand testing of roof top potable water storage tanks beyond coliform testing to also include HPC and Legionella testing. Do you have plans to include remedial action levels for those potable water storage tanks as well?
Agency: DOHMH
Comment:
2) Breed – cold water basins commonly have stagnant zones, making it easy for bacteria to breed. Increased water velocity and turbulence in the basin can be accomplished making it more difficult for Legionella to breed. Require either the use of a “flow through” basin, sloped basin, or basin sweeper system to significantly help the effectiveness of routine maintenance and water treatment. Corrosion can be a source for breeding. Many cooling towers are constructed from galvanized metal and susceptible to corrosion. Although this can be a more expensive upgrade, consider requiring a minimum of 304 stainless steel or FRP (with fire sprinkler system if FRP and over 250 ft2 in base area) construction and compatible piping materials to reduce the possibility of corrosion to significantly help the effectiveness of routine maintenance and water treatment. 3) Spread – once Legionella feeds and breeds inside the cooling tower, it is spread from the cooling tower to the susceptible host through mist or drift. Section 8-04.c.e. calls for drift losses between 0.005% and 0.002%. This is already the same drift loss percentage in most base specifications and likely the cooling towers that caused the 2015 outbreaks. It doesn’t help. The major cooling tower manufacturers and OEM/aftermarket providers of drift eliminators promote drift eliminators with maximum drift loss of 0.0005%. Some variance may be needed for some designs based on specific applications. Require a maximum drift rate of 0.001% when operating at design conditions across the board for all cooling tower designs. This represents an average 71% reduction in the amount of mist or drift that’s able to travel from a cooling tower to a susceptible host. With 5,000 cooling towers registered, there is a cooling tower being installed, replaced or rebuilt almost every day in NYC. There are many additional minimum design feature requirements that can incrementally reduce the potential for Legionnaires’ disease from cooling towers. However, these are very simple and significantly meaningful requirements that can be added to building code now for new and replacement or rebuilt cooling towers to ensure a substantial reduction in the root cause feeding and breeding Legionella in cooling towers. When combined with 71% fewer emissions working in conjunction with Chapter 8 inspection, operating, maintenance, and water treatment guidelines, we hold the keys to substantially reducing Legionnaires’ disease from cooling towers.
Agency: DOHMH
Comment:
These amendments are helpful as they provide greater specificity on proper requirements for routine inspection, operation, maintenance, and water treatment. However, they lack a critical component of cooling tower Legionnaires’ disease risk mitigation, which is the specificity on minimum cooling tower design requirements. There is no meaningful deviation in acceptable design features contained within this document compared to the cooling towers associated with the 2015 outbreaks, the same basic design still being installed throughout NYC on a daily basis. As reported by the New York Times on October 1, 2015, a new cluster of Legionnaires’ disease took place in the Bronx less than two (2) months after the cooling towers were disinfected. Routine inspection, maintenance, and water treatment is not enough, and the root cause has to be addressed through minimum cooling tower design requirements. Cooling towers can feed, breed, and spread Legionella in an accelerated or limited manner, depending on their design. Readily available technology already commonly exists and is offered by the major manufacturers that substantially reduces the ability for the cooling tower to feed, breed, and spread Legionella. These design features that can help dramatically reduce the potential for a person to become infected with Legionnaires’ disease from a cooling tower are rarely installed. This is because they cost slightly more, are not in “base” specifications, and are not required by building code. Not all cooling towers have the exact same design, and design features for significantly reducing the feeding, breeding, and spreading of Legionella vary by design. Design features that allow almost any manufacturer to immediately participate in substantially reducing the ability for Legionella to feed, breed, or spread include: 1) Feed – scale and algae are commonly present in cooling towers and are primary food sources for Legionella. Many forced draft cooling towers block 100% of the sunlight contact from the circulating water, and therefore eliminate algae. Induced draft cooling towers can be outfitted with antimicrobial fill media and drift eliminators that substantially reduce scale build up. Require either a design that allows no sunlight to contact the water so algae is no longer present or the use of antimicrobial fill media and drift eliminators for reduced scale build up to significantly help the effectiveness of routine maintenance and water treatment.
Agency: DOHMH
Comment:
The following commentary is specific for cooling towers that operate on a seasonal basis: The regulations state that a seasonally operated cooling tower should be inspected every 90 days (during normal operation). However, there is currently no requirement for an inspection to be conducted during the off season (prior to the tower’s start up date). Not conducting a cooling tower inspection prior to start up, may prove to be counterproductive in achieving the ultimate goal: Providing consistent water treatment applications, which safeguard a cooling tower from the development and proliferation of Legionella Pneumophila.  There are a multitude of reasons why an off season inspection would benefit the building owner of a cooling tower. For this commentary, I will provide 3 reasons why it would be beneficial to conduct off season cooling tower inspections. 1st reason: A water treatment company may have no other alternative but to run their chemical tubing outside and then this same tubing drops into the cooling tower basin. Unfortunately, there is a high inclination for this tubing to freeze and then crack during the winter. All chemical tubing lines should be inspected prior to start up. 2nd example: There are hundreds of water treatment stations that are located outside (next to the cooling tower) in the winter. These water treatment stations, water treatment devices, cooling tower manifolds, and valves may freeze and then crack. All of these necessary water treatment devices must be fully operational prior to a cooling tower’s start up. 3rd example: Ice may damage the plastic fill over the winter. If the fill is damaged, then this section of fill will need to be repaired/replaced prior to start up or this damage will leave the tower susceptible to more drift misting out of the eliminators. *** Taking into consideration the above noted commentary, it is highly recommended that the NY State and NYC law makers consider adding the following statement into the future rules: • One (1) off season cooling tower inspection should be conducted for seasonally operated cooling towers. This inspection should be conducted 4 – 6 weeks prior to the start up the seasonally operated cooling tower; this will allow enough time to correct problems found during the inspection. Steven Serrano, CWT President of Empire Cooling Tower Inspections and Services
Agency: DOHMH
Comment:
Is it necessary to create the double work: to register and to certified the same kind of work with DOB.... and with the Dept. of Health? In my opinion it's a bureaucratic and overlapping work. The new standard requirements for the cooling towers maintenance are rightfully set very high, and the public will be much safer from now on, without creating the same paperwork for 2 different agencies. Thank you. WP "Local Law 77 added a new Article 317 to Title 28 of the Administrative Code that required owners of cooling towers to register them with the Department of Buildings (“DOB”) by September 17, 2015. Towers must be inspected, tested, cleaned and disinfected in accordance with new Administrative Code §17-194.1 and rules adopted by the Department. Owners and operators of cooling towers must annually certify to DOB that their cooling towers have been inspected, tested, cleaned and disinfected and that a management and maintenance program has been developed and implemented in accordance with Administrative Code §17-194.1. Statewide, including in New York City, owners of all cooling towers must also comply with SSC Part 4, which includes registration with and reporting requirements to the State Department of Health."
Agency: DOHMH

Pages