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New York City Department of Education

Division of School Facilities

Cooling Tower Water Management Plan

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

Water Treatment Manager, Director of Facilities, Deputy Director of Facilities, Custodian

Engineer/Building Manager, Borough Contract Manager, Contract Manager, and Borough
Maintenance Planner.

Responsibilities of the Team

Water Treatment Manager

The Water Treatment Manager oversees the Division of School Facilities’ Water
Management Program designed to prevent Legionella contamination.
Responsibilities include:
- Managing the direction of the overall Program citywide and making sure that all
NYC schools participating in the Program are in compliance with New York City
Local Law 77 and New York State law Title 10 Part 4:
- Central point of contact for all agency regulatory compliance associated with cooling
- Supervises contracted services and manages contractor performance regarding the
water treatment and disinfection of Legionella bacteria from cooling towers in NYC
school buildings.
- Manages NYC and NYS regulatory compliance governing cooling towers.
- Responsible for the inspection, disinfecting, testing and cleaning of cooling towers
and water treatment.
- Performs inspections, makes and records observations on the progress of the water
treatment program at NYC schools. Evaluates data collected.
- Reviews water treatment reports provided by licensed service providers. Assesses
productivity and effectiveness of contracted services.
- Prepares management reports associated with cooling towers.
- Reports and shares findings with the New York City Department of Buildings and
the New York City Department of Health and Mental Hygiene.

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
- Approving and expediting requests for repairs.
- Ensuring all records are kept and maintained at the school by the Custodian
- Review daily water quality reports provided by their respective Custodian

Custodian Engineer & Building Manager

Under the supervision of the Deputy Director of Facilities, the Custodian Engineer and the
Building Manager is responsible for:

- 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.

Borough Maintenance Planner

Under the supervision of the Director of Facilities, the Borough Maintenance Planner is
responsible for:

- 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.

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
- 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
- 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

Effective Water Treatment

Water treatment will be performed on a daily basis by an automatic chemical feeder. The
operation, maintenance, and verification of the feeder operation will be done by a certified
and licensed water treatment contractor bi-weekly. The treatment will eliminate harmful
bacteria, bio-film and control scale, solids, and corrosion. It also includes blowdown, the
continuous flow of a small portion of the recirculating water to a drain to eliminate
dissolved solids, and to control scale, corrosion and biological contamination.

Ensure Adequate Airflow

Poor airflow through the tower reduces the transfer of heat from the water to the air. Poor
airflow can be caused by debris at the inlets or outlets of the tower, in the fill, loose fan and
motor mountings, poor motor and fan alignment, poor gearbox maintenance, improper fan
pitch, damage to fan blades, or excessive vibration. Reduced airflow due to poor fan
performance can ultimately lead to motor or fan failure.

Ensure Adequate Pump Performance

Proper water flow is important to achieve optimum heat transfer. Loose connections,
failing bearings, cavitation, clogged strainers, excessive vibration, and operating outside of

design conditions result in reduced water flow, reduced efficiency, and premature
equipment failure.

Table 1 provides a schedule for maintenance tasks.

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
( 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.

Deputy Director of Facilities:

Using the CT application found on the DSF Single Sign-On page (https://www.opt- the DDFs will perform, at
minimum, weekly checks of the work submitted by the Custodian Engineers and Building
Managers listed in Table 1 of this Plan. The DDFs will be responsible for reviewing the
information submitted by Custodian Engineers and Building Managers for completeness
and for any data that is categorized as outside acceptable parameters that would raise
question(s) for possible presence of biological activity. A checkbox will be found at the end
of the CT application page indicating a review was performed and approved by the DDF.

Water Treatment Manager:

All submittals will be reviewed for completeness and compliance with NYC Local Law 11
and NYS Title 10, Part 4 laws.

Table 1: Maintenance Schedule for Cooling Towers

Description Comments Frequency

Cooling Tower Turn on/check of sequence operation Daily
Use/Sequencing (Custodian Engineer/ Building Manager)
Overall Visual Complete overall visual inspection to be sure all equipment Daily
Inspection is operating and safety systems are in place
(Custodian Engineer/ Building Manager)
Clogging Inspect for clogging, make sure water is flowing in tower. Daily
(Custodian Engineer/ Building Manager)
Operate Makeup Operate switch manually to ensure proper operation Weekly
Water Float (Custodian Engineer/ Building Manager/ Independent
Switch Certified and Licensed Water Treatment Contractor)
Vibration Check for excessive vibration in motors, fans, and pumps Weekly
(Custodian Engineer/ Building Manager/ Independent
Certified and Licensed Water Treatment Contractor)
Check Tower Check for loose fill, connections, leaks, etc. Weekly
Structure (Custodian Engineer/ Building Manager/ Independent
Certified and Licensed Water Treatment Contractor)
Check Belts and Adjust all belts and pulleys Weekly
Pulleys (Custodian Engineer/ Building Manager/Independent
Certified and Licensed Water Treatment Contractor)
Test Water Test for proper concentrations of dissolved solids, and Bi-Weekly
Samples* chemistry (Open)
Adjust blowdown and chemicals as necessary
Perform bi-weekly for open towers and monthly for closed
(Independent Certified and Licensed Water Treatment
*Manufacturer’s Recommendations:
 pH: 6.5-9.0
 Hardness as CaCO3: 30 to 750 ppm
 Alkalinity as CaCO3: 500 ppm max
 Total Dissolved Solid (TDS): 1500 ppm max
 Conductivity: 2400 micromhos
 Chlorides: 250 ppm max as Cl, 410 ppm max as NaCl
 Sulfates: 250 ppm max
 Silica: 150 ppm max

 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
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
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)
Motor Alignment Align the motor coupling to allow for efficient torque Monthly
(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)

Legionella Test for the presence of Legionella or Legionella causing At least 1X
Testing bacteria (Independent Certified Laboratory) every 90
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)

Cooling Tower System Shutdown and Start-Up Procedure

Start-Up for Drained Systems

To be performed by a Certified and Licensed Water Treatment Contractor:

- 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).

Start-Up for Undrained (Stagnant) Systems (If Applicable)

To be performed by a Certified and Licensed Water Treatment Contractor:

- 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.

Response to Legionella Test Results

To be performed by a Certified and Licensed Water Treatment Contractor:

Action 1 - Cleaning followed by biocide treatment of the system, if appropriate.

Action 2 - Cleaning and or biocide treatment. Take immediate steps to prevent employee

Table 2: Cooling Tower Legionella Count

Colony Forming Units (CFU) per milliliter
0-10 10-100 100-1000 >1000
A. Increase biocide addition/s
B. Increase biocides, review program, retest till <10
C. Disinfect and clean within 30 days, review program
D. Disinfect and clean within 7 days, review program

1. Shut off the cooling tower fans.

2. Keep makeup water valves open and the circulation pumps operating.
3. Close outdoor air intake vents located within 30 meters of the cooling tower.
4. Achieve an initial free residual chlorine (FRC) of at least 50 mg/L.
5. Add a dispersant to tower water within 15 minutes of chlorine addition, then
maintain 10 mg/L FRC for 24 hours.
6. Drain and refill the system, then repeat steps 4 and 5 at least once to remove all
visible algae-like film.
7. Using a brush and water hose, thoroughly clean all water-contact areas, including
the basin, sump, fill, spray nozzles, and fittings.
8. Circulate 10 mg/L FRC for one hour, then flush the system until free of all sediment.
9. Refill the system with clean water and return to service.

Note: It is generally recommended today that dispersant-chlorination (only)

disinfection procedures for Legionella also include a final step of maximum dosing (per
EPA label) of a non-oxidizing antimicrobial combination – either a synergistic
combination in one product or two separately applied products.

Clean-up Procedure

To be performed by a Certified and Licensed Water Treatment Contractor:

1. Clean and disinfect the entire cooling system including attached chillers and/or
storage tanks (sumps) following the "Wisconsin Protocol" 1 Emergency Protocol, as
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
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.

Wisconsin Division of Health. Control of Legionella in Cooling Towers: Summary Guidelines, June 1987,
Wisconsin Department of Health and Social Sciences.

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.


To be performed by a Certified and Licensed Water Treatment Contractor:

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.

Water Sampling Protocol

To be performed by an Independent Certified and Licensed Laboratory certified for

microbial water analysis and experienced in Legionnaires' disease bacteria (LDB)
detection using culture methods that measure colony forming units (CFU) of LDB per
milliliter of water.:

- Before starting decontamination, collect swab samples using pre-packaged sterile

swabs in their own containers or small sterile glass or polypropylene bottles
provided by the laboratory.
- These samples should be cultured to determine the degree of contamination and the
subtype of L. Pneumophila before treatment. Contact the biocide manufacturer for
instructions on appropriate neutralization to prevent continuation of bactericidal
action during sample transit.
- Collect at least three water samples (200 milliliters to 1 liter Volume). Include water
from the incoming makeup water supply, water from the basin of the unit most
distant from the makeup water source, and recirculated water from the HVAC
system at its point of return to the unit.

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).

- 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.

- Ship samples to the testing laboratory using overnight mail.
- Make arrangements for weekend receipt when shipping on a Friday.

John T. Shea, CEO

William Estelle, Executive Director
Ken Mahadeo, Director of Maintenance and Optimization
Kimberley Coke, Water Treatment Manager