Public comments for: Summertime Hyperhalogenation of Cooling Tower Systems (Amendment to Chapter 8 in Title 24 of the RCNY)

Comments

Comment:
Comments from the Baltimore Aircoil Company regarding summertime hyper-halogenation of cooling tower systems.
Agency: DOHMH
Comment:
Dear Ms. Burdynik: Thank You for the opportunity to provide comments on the proposed Amendment to Chapter 8 in Title 24 of the RCNY for Summertime Hyperhalogenation of Cooling Tower Systems. We have two comments on the proposed amendment as follows: - The amended cooling tower rule requires measurement of free halogen residual to confirm that the a 5 ppm residual is maintained for a minimum of 6 hours during hyperhalogenation of the cooling tower system. However, the interval between measurements or number of measurements that must be taken within the 6 hour period is not indicated. Is there a requirement for the interval or number of measurements for free residual halogen that must be taken during the 6 hour period, OR is taking a measurement at the beginning of the hyperhalogenation and one at the end to confirm a minimum 5 ppm residual adequate? - The rule amendment requires submission of an affidavit to NYC DOHMH within 2 days of hyperhalogenation which must include system identification number, the hyperhalogenation procedure performed, name and quantity of chemicals used, dose and contact time, effective pH ranges of biocides, pH and halogen residual monitoring results, service date, and name and qualification of the person who applied the biocide. The 2 day submission requirement does not provide adequate time for water treatment contractors to prepare and forward this information to cooling tower owners for submission to NYC DOHMH. We recommend a modification of this requirement to provide, at a minimum, 5 business days for submission of the hyperhalogenation affidavit to the NYC DOHMH to allow for submission of an accurate and complete affidavit. Jimmy Ng, P.E. Environmental Engineer New York State Office of Mental Health
Agency: DOHMH
Comment:
Please find attached Barclay Water Management's public comments on the proposed amendment on Summertime Hyperhalogenation of Cooling Tower Systems to Chapter 8 in Title 24 of the RCNY. Thank you.
Agency: DOHMH
Comment:
Dear Ms. Burdeynik: Thank you for the opportunity to comment on the new NYCDOH proposed amendment for additional halogenation requirements for cooling towers in New York City. In our view the proposed amendment is following a path that has already proven ineffective in reducing the incidence of Legionellosis in New York. The amendment focuses only on one potential source of Legionella bacteria, namely cooling towers. It also seeks to place most of the burden on reducing Legionella on building owners, who are ill equipped to meet this burden. These measures have been tried here in New York, in other states, and in Europe. The results show these efforts have done nothing to curb Legionellosis. A new approach is warranted, one where the focus is on the municipal water supply before it enters buildings, and one that also focuses on all of the potential outlets that could spread the bacteria, including shower heads, faucets, spas, fountains and others. Ensuring more residual chlorine is present throughout the water system is needed to bring down the incidence of this disease. We note that the requirement of additional hyperhalogenation seems misplaced for the simple reason that this is already in the regulations. The Rules of New York City, Chapter 8 Cooling Towers incorporate disinfecting regimes including hyperhalogenation and testing when legionella levels are higher than prescribed in Table 8-1 Corrective Actions. If the DOH is concerned about elevated Legionella bacteria during the July to August timeframe, a less expensive and more effective alternative to the proposed amendment would be to require one of the already mandated Legionella bacteria tests be performed during that period of the year. As stated above we feel that a different approach entirely is warranted. EVAPCO and other major global cooling tower manufacturers recommended that New York City broaden the scope of the local law to include all building water system end points and New York’s potable water supply. We explained that a singular focus on cooling towers would not reduce the incidence of Legionellosis in New York City. The position that Legionella bacteria enters buildings with the municipal supply water and therefore has the potential to reach several outlets is shared by the Association of Water Technologies, which states: “While cooling towers and evaporative condensers are also a potential source related to Legionnaires’ disease, and long thought to be the major source of Legionella-causing disease, current data suggest that domestic (potable) water plumbing systems are responsible for an even larger number of cases of legionellosis.” NYCDOH did not accept this point of view and instead continued with a singular focus on cooling towers as a source of legionellosis. This approach has not been effective in reducing the incidence of disease in New York City. Evapco's response is attached. Daryn Cline EVAPCO
Agency: DOHMH
Comment:
To: Svetlana Burdeynik NYC Dept. of Health and Mental Hygiene (NYC DHMH) Dear Ms. Burdeynik, Ecolab respectfully has attached our comments on the Proposed Amendment to Chapter 8 changes. A shorter version of our comments can be found below: GENERAL COMMENT Nalco Water, a division of Ecolab, supports the proposed regulation that requires hyperhalogenation of cooling towers during the peak summer months. As a company, we already recommend this action to our clients, and many are already employing the protocols as stipulated in the proposal. While we generally support the aims of the hyperhalogenation proposal, we recommend two changes: 1.) As hyperhalogenation is a prophylactic measure, we believe that additional Legionella sampling required in the regulation is unnecessary and provides no additional benefit. Consequently, the unusual 15 to 45-day period prescribed in the proposal poses an unnecessary scheduling complication and adds administrative burden on building owners. As there is already a required 90-day routine legionella sampling requirement in the regulation, we recommend removing this section from the proposal. 2.) We also believe that the proposed requirement for the “affidavit of correction” to be completed within 2 days is overly restrictive. Disinfection will typically be performed by an entity other than the building owner who would, in turn, provide the documentation to the owner to submit it to the city’s online portal. This process may span a weekend and go beyond the 2 day requirement. We recommend changing the proposed requirement from 2 days to 5 days, which would be consistent with the legionella sample reporting window required by Local Law 76. Thank you again for the opportunity to provide comments on this important issue. If we can help clarify any of the forgoing comments, please do not hesitate to call me at the number in the attachment. We very much appreciate the opportunity to comment and we look forward to participating in the June 29th public hearing. Regards, Sean Keefer Director, State Government Relations Ecolab
Agency: DOHMH
Comment:
The second sentence of (f) Summertime hyperhalogenation reads, "The hyperhalogenation must be performed by a person qualified to apply biocide pursuant to §8-05(c)(1)." Does this mean the qualified biocide applicator must remain on site for the entire six hours. It would seem an unnecessary expense for the tower owner. The qualified person does the weekly inspections and checks pH and checks the halogen levels. Why can't the qualified person take the readings required in (f)(3)?
Agency: DOHMH
Comment:
8-04, 2(f) (3) ..."Additionally, the pH and halogen residuals must be measured at two independent sampling locations withing the cooling tower system during hyperhalogenation to verify the minimum biocide residual was achieved and maintained." Comment #1 - In small tower systems (less than 100 tons, with less than 300 gallons of circulated water volume), a single sample from the remote sump (basin) adequately represents the water quality distributed throughout the cooling tower system because of the high volume turnover. Comment #2 - The minimum number of samplings should be specified. 8-04, 2(f) (4) - "A legionella culture sample must be collected in accordance with 8-05(f)(3) within 15 to 45 days after the hyperhalogenation..." Comment #1 - Clarification should be made regarding the 15 to 45 days after hyperhalogenation. Can the sampling occur after August 31st?
Agency: DOHMH