One of the most burdensome requirements of New York City’s cooling tower compliance law is the 3-times-per-week cooling tower water quality testing obligation. This requirement calls for testing of pH, conductivity, temperature, and biocide chemical level three times each week, with no more than two days in between testing. For most building owners, fulfilling this requirement translates to testing your cooling tower water every Monday, Wednesday, and Friday.
Sounds simple enough, but this requirement in practice is ripe for errors and requires further planning. Building owners must ask themselves:
- Who will complete this testing?
- What if that person takes a vacation, calls out sick, or no longer works in the building?
- Who trains this person on how to do the testing properly?
- Who trains this person’s backup?
- Do they have enough testing materials?
- Are they thinking about ordering testing material before they run out?
The list goes on, and not having a reliable team can put your building at risk of being fined.
Why is Testing Required so Often for Compliance?
If the testing is done correctly and on time, in theory, the building owners are utilizing that data to fine tune their treatment program to best control bacteria growth that could lead to Legionnaires disease outbreaks. On the surface, this sounds like a quality approach to best control bacteria. However, to make this requirement actually useful, the NYC Department of Health & Mental Hygiene (NYC DOHMH) needs to take it a step further.
Water Quality Testing Example
Assume your biocide chemical level goal range is 1–4 ppm of chlorine. If your on-site staff completes that water quality testing on Monday, Wednesday and Friday as required and the results are 1.4, 1.2 and 1.6 ppm respectively, as shown below, should you be satisfied with those results? They are all within range, right?
To truly understand if the treatment program is being applied properly, we need more datapoints than just 3 moments in time during a week. We need to understand the chemical levels after the biocide chemical has been fed, and where it falls to its lowest point.
Minimal Data can lead to Inadequate Interpretation
With just three data points we can’t truly see if the treatment is effective or not. With the exact same Monday, Wednesday and Friday data points shown above, if the biocide curve looked like the chart below, it’s obvious to even the untrained eye that the treatment program is NOT meeting expectations.
Although Monday, Wednesday and Friday are still at 1.4, 1.2 and 1.6 respectively and above the goal, the majority of the week is well below the goal:
With multiple data points during the day, and dozens of data points during the week, we can clearly see that the program is falling short of the goal, but with JUST Monday, Wednesday and Friday samples, we would be blissfully unaware of the poor treatment, and operating with a false sense of security that our tower was safe.
What can the Department of Health do?
NYC DOHMH should alter the existing cooling tower law to require chemical feed equipment with real-time monitoring capabilities if they truly want building owners and operators to have the best chance of preventing the next Legionnaires outbreak.
Real-time monitoring with remote reporting capabilities, as well as alarms for chemical parameters out of range show real chlorine curves, not just three weekly data points. By seeing the full picture, property managers can work with their treatment providers to not only control bacteria, but also control corrosion inhibitor feed to maximize the lifespan of these expensive and integral pieces of equipment. Chemical applications can be fine-tuned to result in chlorine curves that look like this:
Contact Our Cooling Tower Experts
Metro Group has been the trusted source for building solutions since 1925. Our compliance programs use the most advanced chemical treatment programs and equipment, reassuring you’ll never have to pay a cooling tower fine! For more information about the most advanced treatment equipment on the market and how Metro Group will install it free of charge, visit our NYC Cooling Tower Compliance Overview or email mdorvilliers@metrogroupinc.com.
