This plan provides specific guidelines and requirements that will ensure the clean and safe
operation and maintenance of the cooling towers associated with the school’s cooling
system to prevent and minimize the risk of Legionella contamination.
Program Team
Director of Facilities
The Director of Facilities is responsible for the overall Program in the seven jurisdictional
areas of New York City.
Deputy Director of Facilities
Under the supervision of the Director of Facilities, the Deputy Director of Facilities is
responsible for:
- Coordinating and assisting with the operation and maintenance of the cooling
tower.
- Approving and expediting requests for repairs.
- Ensuring all records are kept and maintained at the school by the Custodian
Engineer.
- Review daily water quality reports provided by their respective Custodian
Engineers.
- Conducting daily visual inspections for water discoloration, biofilms, algae, and
other foreign items, and reporting back to the Deputy Director of Facilities.
- Maintaining inspection logs, the water program plan, all chemical treatments, and
maintenance records on-site.
- Verifying the proper operation of automatic chemical feeders for the cooling towers.
- Using the Pool Water Test Kit provided to check and log the values of the Free
Available Chlorine, Total Chlorine, pH, Temperature, and Total Dissolved Solid of the
cooling tower water daily.
- Producing all maintenance, operating, repair logs, and water test reports to all
regulatory agencies upon inspection.
- Planning and scheduling all testing, treatment, maintenance, and repair of the
cooling tower.
- Reviewing all water treatment and test reports.
- Investigating and following up on abnormalities in reports provided.
- Scheduling random tests for Legionella using an Environmental Service Provider
other than the one performing the water treatment.
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Borough Contract Manager & Contract Manager
Under the supervision of the Borough Maintenance Planner, the Borough Contract
Manager and the Contract Manager are responsible for:
- Developing the scope of work for contracted vendors performing testing, treatment,
and disinfection of cooling towers.
- Supervising contractor performing water treatment, testing, disinfection, and
routine maintenance of cooling tower.
- Reviewing water chemistry reports and reporting back to the Borough Maintenance
Planner.
- Engaging and supervising independent consultants performing testing and
inspection when needed.
- Reviewing test reports for deficiencies and abnormalities in water chemistry.
- Reviewing Legionella test reports.
- Supervising start up and shut down of cooling towers.
- Maintaining all water treatment, maintenance, and operation records of the cooling
towers.
- Reviewing specific reports on corrosion, water consumption, aerobic microbial
level, anaerobic microbial level, Legionella level, system turbidity, conductivity,
mineral and metal concentration (including Calcium, Magnesium, Silicon, Cadmium,
Iron, Copper), alkalinity and treatment chemical levels (Phosphate, Nitrites etc.),
total chlorine levels, inhibitor levels, and total dissolved solids (conductivity tests).
Program Details
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design conditions result in reduced water flow, reduced efficiency, and premature
equipment failure.
Submittals
All inspection/work performed related paperwork will need to be submitted to the Water
Treatment Manager no later than 2 business days after completion of work by the
subcontractor or DOE employees where applicable. Other submittals will be conducted in
the following manner:
Custodian Engineers:
Using the Cooling Towers (CT) application found on the DSF Applications web page
(http://www.opt-osfns.org/nycdsf/staff.aspx#page=applications) custodian engineers
will perform the daily and weekly cooling tower maintenance tasks listed in Table 1 of this
Plan. Once all data is entered and all tasks are completed, the records will be saved in the
CT application and marked as complete for the day, to be further reviewed by the Deputy
Director of Facilities (DDF) that is responsible for the assigned school. Annual tasks are
also listed. Use the note section of the CT application in order to denote when maintenance
inspections were conducted or concerns arise.
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Table 1: Maintenance Schedule for Cooling Towers
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Treat the system with sodium hypochlorite to a level of
4 to 5 mg/L (ppm), free chlorine residual at a pH of 7.0
to 7.6 when conducting shock treatments.
The chlorine residual must be held at 4 to 5 mg/L
(ppm) for six hours, measurable with standard
commercial water test kits.
Check and document the free available chlorine, total
chlorine, temperature and total dissolved solid daily.
Maintain an average daily free available chlorine level
of 0.5-1.0 ppm. Adjust feed rate of oxidizing biocide as
needed to maintain the 0.5-1.0 free available chlorine
level
Note: These recommendations are an industry standard that
were developed to cover a wide range of towers. The
maintenance for the NYC DOE towers maintain stricter
guidelines.
Check Drift Look for proper positioning and scale buildup Monthly
Eliminators, (Certified and Licensed Water Treatment Contractor)
Louvers, and Fill
Check Motor Check for excessive wear and secure fastening Monthly
Supports and Fan (Certified and Licensed Water Treatment Contractor)
Blades
Motor Alignment Align the motor coupling to allow for efficient torque Monthly
transfer
(HVAC Contractor)
Inspect Nozzles Make sure water is flowing through nozzles in the hot well Annually
for Clogging (Certified and Licensed Water Treatment Contractor) (March 1 –
April 30)
Clean Tower Remove all dust, scale, and algae from tower basin, fill, and Annually
spray nozzles (March 1 –
(Certified and Licensed Water Treatment Contractor) April 30)
Check Bearings Inspect bearings and drive belts for wear Annually
Adjust, repair, or replace as necessary (March 1 –
(Custodian Engineer/Building Manager/Certified and April 30)
Licensed Water Treatment Contractor)
Motor Condition Check the condition of the motor through temperature and Annually
vibration for noisy operation. (March 1 –
(Custodian Engineer/ Building Manager/Certified and April 30)
Licensed Water Treatment Contractor)
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Legionella Test for the presence of Legionella or Legionella causing At least 1X
Testing bacteria (Independent Certified Laboratory) every 90
days.
Annual Per Local Law 77, the owner or operator of a cooling tower Annually
Certification shall file a certification each year that such cooling tower (by
was inspected, tested, cleaned and disinfected in compliance November
with section 17-194.1 of the administrative code and the 1st)
rules of the department of health and mental hygiene, and
that the maintenance plan has been implemented
(Water Treatment Manager)
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Cooling Tower System Shutdown and Start-Up Procedure
- Clean all debris, such as leaves and dirt, from the cooling tower.
- Fill the system with water. While operating the condensing water pump(s) and prior
to operating the cooling tower fans, execute one of the two alternative biocidal
treatment programs* described below:
1) Treat with the biocide that had been used prior to shut down. Utilize the
services of the water treatment supplier. Maintain the maximum
recommended biocide residual (for the specific biocide) for a sufficient
period of time (residual and time will vary with the biocide) to bring the
system under good biological control.
2) Treat the system with sodium hypochlorite to a level of 4 to 5 mg/L (ppm)
free chlorine residual at a pH of 7.0 to 7.6. The chlorine residual must be held
at 4 to 5 mg/L (ppm) for six hours, measurable with standard commercial
water test kits.
*Once one of these two biocidal treatments has been successfully completed,
the fan can be turned on and the system can be returned to service. Resume
the standard water treatment program (including biocidal treatment).
- Remove accessible solid debris from the cooling tower sump and from any remote
storage tank(s) that may be used.
- Perform one of the two biocide pretreatment procedures (described above in
“Start-Up for Drained Systems”) directly to the cooling tower sump or remote
storage tank. Do not circulate stagnant bulk cooling water over cooling tower fill or
operate cooling tower fans during pretreatment.
- Stagnant cooling water may be circulated with the main cooling system pump(s) if
tower fill is bypassed. Otherwise add approved biocide directly to the bulk water
source and mix with either manual or by side stream flow methods. Take care to
prevent the creation of aerosol spray from the stagnant cooling water from any
point in the cooling water system.
- After biocidal pretreatment has been successfully completed, the cooling water
should be circulated over the tower fill with fans off. When biocide residual is
maintained at a 4 to 5 mg/L (ppm) level for at least six hours, the cooling tower fans
may be operated.
Note: All systems are required to be drained at the end of the Cooling Season as per
DOE Requirements.
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Response to Legionella Test Results
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Clean-up Procedure
1. Clean and disinfect the entire cooling system including attached chillers and/or
storage tanks (sumps) following the "Wisconsin Protocol" 1 Emergency Protocol, as
follows:
a) "Shock" treat cooling tower water at 50 ppm free residual chlorine.
b) Add dispersant.
c) Maintain 10 ppm chlorine for 24 hours.
d) Drain system.
e) Refill and repeat steps (a) through (d).
f) Inspect system for visual evidence of biofilm. If found, repeat steps (a)
through (d).
g) Perform mechanical cleaning (cooling tower design may require modified
procedures).
h) Refill system, bring chlorine to 10 ppm, and circulate for one hour.
i) Flush system.
j) Refill with clean water in accordance with an effective water treatment
program. The unit is now ready to be returned to service.
2. Identify and eliminate all water leaks into the cooling water system.
3. After completing step 1, sample the cooling water for analysis of CFU of L.
Pneumophila. The unit may be put into service provided the medical monitoring
program has been implemented. If sample culture results indicate detectable levels
of L. Pneumophila, repeat chlorination and resample the water.
4. Once the non-detectable level for L. Pneumophila has been achieved, institute
maintenance as outlined in the Wisconsin Protocol to ensure continued safe and
proper operation, as follows:
Inspect equipment weekly.
Drain and clean quarterly.
Treat circulating water for control of microorganisms, scale, and corrosion.
This should include systematic use of biocides and rust inhibitors, preferably
supplied by continuous feed, and monthly microbiologic analysis to ensure
control of bacteria.
Document operation and maintenance in a log or maintenance records book.
5. Test cooling-system water at the following intervals to verify that there is no
significant growth of Legionella, as follows:
Test weekly for the first month after return to operation.
Test every two weeks for the next two months.
Test monthly for the next three months.
1
Wisconsin Division of Health. Control of Legionella in Cooling Towers: Summary Guidelines, June 1987,
Wisconsin Department of Health and Social Sciences.
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6. The standard for Legionella concentration throughout the six months of monitoring
is fewer than 10 CFU per milliliter (based on PathCon guidelines)*. The maintenance
program will continue indefinitely as long as the cooling tower is in operation.
*If any sample contains 10 or more CFU Legionella per milliliter, take immediate steps
to reduce levels to acceptable limits. These steps may include increased frequency of
application or concentration of biocides, pH adjustment, additional "shock" treatments,
or any other action that reduces Legionella levels. Take new water samples, and begin
the testing schedule again. Make the results of all water monitoring tests available to
building occupants.
Shutdown
When the system is to be shut down for a period of more than three days, the entire system
(cooling tower, system piping, heat exchangers, etc.) should be drained of waste.
Sample Preparation
- Wrap vinyl tape clockwise around the neck of each bottle to hold its screw cap
firmly in place and seal the interface between the cap and the bottle.
- Wrap absorbent paper around bottles, and place the bottles in a sealable (zip-
lock) plastic bag.
- Place the sealed plastic bag in an insulated container (Styrofoam chest or box).
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Storage:
- Samples should be protected from temperature extremes such as sunlight or other
external heat or cold sources during transport and storage, for example,
temperatures below 3°C (37°F) and above 30°C (86°F).
- Samples should be stored at room temperature (20° ± 5°C, 68°F) and processed
within two days.
Shipping:
- Ship samples to the testing laboratory using overnight mail.
- Make arrangements for weekend receipt when shipping on a Friday.
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