Understanding a Cooling Tower MPP Series – Part 7

Notification and Communication Strategies

For the last part of our MPP series we will talk about the communications requirement of RCNY 8-03. This component requires a management program & plan to identify how results from cooling tower related activities will be received by different team members, and ultimately notification given to the department of health if necessary. This area will also spell out the flow of results that require corrective action will be communicated and acted upon. Items that need to be covered by communication strategies are:

  • Process control activities (3x weekly testing, 1x week visual inspection etc…)
  • Weekly bacteriological indicators (i.e. dip slides)
  • Legionella Samples
  • Tower Inspection Reports
  • Any other cooling tower related monitoring or activities to maintain the system

By having this component in place, the department of health will have an understanding of how corrective action is to occur, and which team members responsibility certain aspects will fall under in relation to responding to the condition. As with other requirements during an annual inspection the Department of Health will verify if adequate documentation exists when referenced against the notification protocol.

For any help pertaining to Notification and Communication Strategies or any other MPP needs, please reach out to The Metro Group at 718-729-7200

MPP Series Part 1: https://metrogroupinc.com/understanding-mpp-series/

MPP Series Part 2: https://metrogroupinc.com/understanding-mpp-series-part-2/

MPP Series Part 3: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-risk-assessment/#respond

MPP Series Part 4: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-part-4/

MPP Series Part 5: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-part-5/

MPP Series Part 6: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-part-6/

Understanding a Cooling Tower MPP Series: Part 5

Corrective Action

As part of an MPP it is required to denote how corrective action will be carried out as per DOH requirements shown in tables 8-1 and 8-2 of RCNY Chapter 8. The following items are categories that need to be monitored and have corrective action taken if necessary.

  • Bacteria dip slides that come back with a result greater than 10,000 cfu will require a corrective action which varies based on the level of the result, and if there are consecutive weeks of high results.
  • Positive Legionella concentrations greater than 10 cfu will also require differing forms of corrective action depending on the level.
  • Finally pH, Conductivity, Total Chlorine, and Inhibitor levels can also require corrective action if there is a pattern of being either below or above the recommended level limits.

Documenting these actions is crucial to ensure that proper necessary action is taken when a cooling tower returns what could be a dangerous result. Having this information contained within an MPP will allow the Department of Health to ensure that proper results exist as laid out within the plan. Below is a copy of the NYC tables outlining necessary corrective action.

 

MPP Series Part 1: https://metrogroupinc.com/understanding-mpp-series/

MPP Series Part 2: https://metrogroupinc.com/understanding-mpp-series-part-2/

MPP Series Part 3: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-risk-assessment/#respond

MPP Series Part 4: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-part-4/

Understanding A Cooling Tower MPP Series: Part 4

Part 4. Control Measures

For the next segment of our understanding an MPP series we highlight the control measures section. This requirement has multiple components that include but are not limited to the following:

  1. Checklists for routine monitoring (3x weekly water quality testing and 1x weekly visual inspection)
  2. Checklists for the mechanical maintenance requirements
  3. A table that denotes the different water treatment program items and their frequency, what team members responsibility it falls on, and how this work is verified as being performed.

The reason this section exists is to spell out how this work is to be completed in more detail, and to help allow inspectors to verify documentation as it is spelled out in the plan (i.e. if a building is supposed to have legionella samples taken in May, July, and September are those sample results in the applicable section of their logbook?). This will also help management assure that if they are using an outside mechanical contractor, or trying to cover that requirement in-house that they can be sure to cover the proper items necessary. If management has any question as to whose responsibility a particular requirement for cooling tower compliance, the control measures section would be a great place to get an understanding of the itemized requirements.

To read more on this series click below:

MPP Series Part 1: https://metrogroupinc.com/understanding-mpp-series/

MPP Series Part 2: https://metrogroupinc.com/understanding-mpp-series-part-2/

MPP Series Part 3: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-risk-assessment/#respond

Understanding a Cooling Tower MPP Series: Part 3

Part 3. Risk Assessment

The next section required to be included in preparation of a management program and plan is the risk assessment. Naturally, this is one of the most important components of the plan as it will segregate and identify a number of factors specific to the site that will dictate risk management, and minimize risk of legionella. As required by RCNY chapter 8 the risk assessment must evaluate the following data:

  1. Any dead legs or stagnant water in the recirculation system
  2. Operating configurations and conditions that may occur after periods of extended inactivity lasting more than three (3) days, including idling or low circulation while not being fully drained.
  3. System parts that require continual operation throughout the year making regular, periodic offline cleaning and disinfection difficult.
  4. Any components that may add additional risk factors for organic material buildup and microbial growth such as strainers and out-of-use filters.
  5. Sources of elevated organic contamination, including, but not limited to windblown debris, bird waste and plant material
  6. Design configurations that present risk of direct sun exposure on basin, deck or fill.
  7. Ventilation intakes or other routes for human exposure to cooling tower aerosols.
  8. System components adversely affecting water quality management procedures.
  9. Other risk or limiting factors or constraints in the cooling tower system’s design and functioning.

By virtue of collecting the following data it allows the qualified person for the cooling tower to create a proper treatment protocol that will factor in any extraneous information that will require treatment to diverge from a standard program. The risk assessment will also factor in external elements that could adversely affect the cooling tower itself. Finally, this will also identify areas that need to be continually monitored for change, this ties in with the weekly visual inspection requirement (8-04a).

For any help pertaining to Risk Assessment or any other MPP needs, please reach out to The Metro Group at 718-729-7200

 

To read more on this series click below:

MPP Series Part 1: https://metrogroupinc.com/understanding-mpp-series/

MPP Series Part 2: https://metrogroupinc.com/understanding-mpp-series-part-2/

MPP Series Part 4: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-part-4/

Understanding A Cooling Tower MPP Series: Part 2

Part 2. System Identification

As part of the requirements when compiling a management program and plan, the Department of Health asks that a qualified person includes a system identification section. This portion of an MPP is supposed to include the following:

1.The number of cooling towers in the cooling tower system
2.The location of each cooling tower in relation to the building and the building address, block and lot number.
3.The Dimensions and characteristics of the cooling tower system including total recirculating water volume, cooling tower tonnage, biocide delivery method, flow rate and other key characteristics
4.The purpose of the cooling tower system and seasonal or year-round operation including start and end date, if applicable. For systems with multiple cooling towers, conditional operation, such as cycling or scaling related to cooling demand, must also be noted.
5.The New York City Department of Buildings registration number for each cooling tower.
6.The cooling tower manufacturer model number and serial number, if applicable.
7.A flow diagram or schematic of the cooling tower system, identifying all the principal components and appurtenances of the cooling tower system including makeup water and waste stream plumbing locations.

Example System Identification containing all required sections of RCNY 8-03 Subsection (b)

This data will provide some crucial information to the inspectors on site in allowing them to have a deeper understanding of how the system is used, what it is used for, and understand how chemical treatment is being applied to the system. Failure of this section being complete will not only lead to a violation of section RCNY 8-03 for the MPP’s sufficiency, but can also lead to a violation of section RCNY 8-05f4 which requires the sampling locations to be clearly defined within the flow diagram.

Example Flow Diagram containing all required elements from RCNY 8-03 Subsection (b)(7)

With any help pertaining to system identification or any other MPP needs, please reach out to The Metro Group at 718-729-7200

 

To read more on this series click below:

MPP Series Part 1: https://metrogroupinc.com/understanding-mpp-series/

MPP Series Part 3: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-risk-assessment/

MPP Series Part 4: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-part-4/

 

 

Understanding a Cooling Tower MPP Series: Part 1

Part 1. Team Members and Their Responsibilities

As part of creation of a management program and plan it is crucial to lay out the different members that will be involved with the servicing and management of the cooling tower, and assign responsibilities as necessary. Typical categories of team members fall under these roles:

1. Owner – The owner of the cooling tower equipment.
2. Owners Representative – Typically responsible for NYC & NYS Compliance Registration/Uploads. Also typically the primary record keeper
3. Responsible Person – Typically responsible for the weekly visual inspection, 3x weekly water quality testing, and also a primary record keeper
4. Mechanical Contractor – Typically responsible for preventative maintenance and/or repairs to the tower
5. Account Manager – Typically a liaison to all involved parties as well as an additional record keeper
6. Service Technician – Performs monthly treatment, disinfections, and quarterly inspections
7. Qualified Person – Creates & Maintains the MPP, quarterly legionella sampling, inspection review and sign off, secondary record keeping

The delegation of these different roles helps assure all necessary parts of compliance are covered, and it is clear who is responsible. This will also identify for the Department of Health during time of inspection how the person they are speaking with is related to the cooling tower management. It is imperative that all functions are identified and each team members full contact information is provided according to section RCNY 8-03 to be compliant. Lastly, it is important this data is consistent with the information as registered with the NYS/NYC. It is expected that team members will change over time and that both the MPP and registration portals are updated as needed to be kept up to date.

For assistance in creation or management of an MPP please contact The Metro Group at 718-729-7200

 

To read more on this series click below:

MPP Series Part 2: https://metrogroupinc.com/understanding-mpp-series-part-2/

MPP Series Part 3: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-risk-assessment/

MPP Series Part 4: https://metrogroupinc.com/understanding-cooling-tower-mpp-series-part-4/

Guaranteed Fine For Your Building

If you own, or manage a building that owns and operates a cooling tower you already know; NYC is looking fine you for even the smallest deviation from Local Law 77.

One aspect of the law that you may not be aware of is that your annual cooling tower certification document must be uploaded to the Department of Buildings (DOB) website. Most operators think that having their certification on site, or uploading it to the Department of Health’s website is sufficient; but it’s not. If you don’t upload it to the DOB website you WILL receive a fine, and the ECB/OATH Hearing Officers WILL NOT dismiss that fine (if you are lucky they may reduce the amount).

The certifications are due by November 1st and can be uploaded here: http://coolingtowers.cityofnewyork.us.

For assistance with your annual certification and expert cooling tower compliance work from the NYC’s best and longest standing water treatment company please call the Metro Group at 718-729-7200

Is Your Cooling Tower Compliant for 2017?

In NYC, Local Law 77 requires two cooling tower cleanings to be completed each year by November 1st.  The 2nd tower cleaning can be completed at any time during the year, so there is no need to delay scheduling the cleaning until you are ready to shut down. Delaying scheduling of the 2nd tower cleaning can only lead to potential fines.  If it gets too cold workers will not be able to clean the tower, leaving your tower out of compliance, and the building open to fines.  As the season gets later, the tower cleaning schedule fills up very quickly. If you don’t get your cleaning scheduled now you could miss the November 1st deadline, again leaving the building open to potential fines.  Also, the longer you wait to schedule the cleaning, the more difficult it will be to obtain your end-of-year certification on time.  The bottom line – it’s best to get your 2nd tower cleaning scheduled sooner, rather than later.

Finally, if you plan on shutting down your tower early, and it has not been cleaned yet, you should keep it running until the cleaning has been completed. Proper shut-down/start-up procedures must be followed, and it is much more efficient to shut-down once at the end of the season.

For expert cooling tower compliance work from the NYC’s best and longest standing water treatment company please call the Metro Group at 718-729-7200