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If you are a building owner in New York operating a cooling tower, you have probably heard all kinds of theories about the "new rules" for maintaining them. As per the new cooling tower laws that were recently passed in both New York City and New York State, cooling towers that exist in the Five Boroughs of NYC must be electronically registered with both the city and state; and with just the state for the rest of counties throughout New York. All cooling towers throughout the entire State of New York were required to be registered through their appropriate websites by no later than September 17th, 2015. There is a New York City Cooling Tower Registration Website and a New York State Cooling Tower Registration Website that have been set up for this purpose. This post will explain who is responsible for registering NY cooling towers and what information will be required now and in the future.
The New York City Department of Health and Mental Hygiene had made it clear that it is taking the registration process very seriously. The DOH has gone so far as to subpoena various organizations, including water treatment companies and cooling tower maintenance companies, that may have information as to the specific locations of cooling tower throughout the city. These organizations have been asked to provide detailed information about every cooling tower that they are aware of throughout the five boroughs of NYC.
The bottom line is: If you are a property owner in New York and you have a cooling tower on your property, there are new laws that you need to comply with. If you haven't registered your cooling tower yet, you should probably do so immediately. The NY City and NY State DOH has made it pretty clear that they are not going to be too lenient on outliers.
Who is responsible for registering NY cooling towers?
According to the laws, the ultimate responsibility for registering a NY State or New York City Cooling Tower lies with the building owner. Both the NY City and NY State Cooling Tower Laws hold the building owner accountable for cooling tower registration, ongoing maintenance and record keeping. Building tenants that own and/or operate cooling towers at their location may be responsible to act in accordance with the law via contract or agreement with their landlords, but it is the building owner that is ultimately responsible for compliance with the laws; and it will be the building owner that faces fines and penalties for not complying with law.
Does my cooling tower need to be registered even if it doesn?t work or we no longer use it?
Yes. The new laws pertain to all cooling towers, evaporating condensers and/or fluid coolers, and regardless of whether they are operational, they must be registered. In the event of a decommissioned system, the owner is required to notify the appropriate departments (NY City DOH, NY State DOH, or both) within 30 days after removing or permanently discontinuing its use. The cooling tower must be drained and sanitized in compliance with the requirements of the NY City and State Departments of Health for discontinuance of a cooling tower.
What kind of information do I need to have ready to register my cooling tower in NY?
When you first log into the New York City and New York State registration websites, you will need to choose a User Name and Password. Make sure that you write these down and keep them with your cooling tower maintenance records. The website for the city and state are not identical, but they do ask for a lot of the same information, which includes:
Address of the building at which the cooling tower is located;
County of Building, if in New York City, Borough of Building;
Block & Lot assigned by NYC Department of Finance (This can be obtained at http://a810-bisweb.nyc.gov/bisweb/bispi00.jsp);
Building Identification Number (Your BIN # can be obtained at http://a810-bisweb.nyc.gov/bisweb/bispi00.jsp);
Intended use of cooling tower;
Name, address, telephone number and email address of owner;
Equipment Type (Cooling Tower, Fluid Cooler, Evaporative Condenser);
Manufacturer and model number of the cooling tower;
Specific unit serial number of the cooling tower;
Cooling capacity (tonnage) of the cooling tower;
Basin capacity of the cooling tower;
Commissioning date of the cooling tower;
Date of when Last Shutdown was started;
Date of when Last Shutdown was ended;
Date of Last Emergency Disinfection and Cleaning;
Date of Last Routine Bacteriological Sample Collection;
Test Results of Last Routine Bacteriological Sample;
Date of Last Inspection; and
Who performs the maintenance on the equipment (the name of your cooling tower water treatment company)
What do I need to do after I register my cooling tower?
Both the NY City and NY State Cooling Tower laws require that cooling towers have an ongoing maintenance program, quarterly inspections, and an annual certification. All of these must be documented and be made a part of your required record keeping.
Here is a breakdown of what you need to do to be compliant with both the City and State Cooling Tower Laws:
Ongoing Maintenance Plan for NY Cooling Towers ? Building owners must implement a maintenance program and plan for their cooling tower that is in accordance with sections 5, 6, and 7.2 of the American Society of Heating, Refrigeration and Air-conditioning Engineers Standard 188 ? Legionellosis: Risk Management for Building Water Systems (ANSI/ASHRAE Standard 188-2015) and with the cooling tower manufacturer?s instructions. This will include a full water treatment program that controls microbiological activity, scale, and corrosion. The maintenance plan must be developed by a qualified person (ie. a licensed water treatment professional) and must be implemented and/or supervised by a person holding a 7G New York State Pesticide Applicators License, so that they may legally administer a biocide or legionella treatment. Click here to get your copy of ANSI/ASHRAE Standard 188-2015.
Quarterly Inspection and Testing of NY Cooling Towers ? At a minimum, cooling towers, other than cooling towers whose use has been permanently discontinued and for which a notice of such discontinuation has been sent to the Department of Buildings, shall be inspected and tested at least as frequently as every three months during periods of the year such cooling towers are in use.
Your licensed water treatment professional may perform your inspection; however, all inspections must be performed in accordance with current standard industry protocols including, but not limited to, ANSI/ASHRAE Standard 188-2015.
Each inspection shall include an evaluation of:
the cooling tower and associated equipment for the presence of organic material, biofilm, algae and other visible contaminants.
the general condition of the cooling tower, basin, packing material, and drift eliminator;
the water make-up connections and control;
the proper functioning of the conductivity control; and
the proper functioning of all dosing equipment (pumps, strain gauges)
Any deficiencies found during inspection will be reported to the owner for immediate corrective action. Your cooling tower inspector must document all deficiencies found during the inspection as well as any corrective actions that were completed. These findings, deficiencies, and corrective actions must be reported to the owner, recorded, and retained on site. All findings must also be reported to the New York STATE Department of Health.
Each inspection shall include a test for the presence of microbes in the water of the cooling tower. NY State and NY City shall by rule establish (i) the targets and acceptable methods of microbial testing and laboratory analysis, (ii) the levels of microbes in cooling towers that are indicative of a maintenance deficiency requiring mitigation, including but not limited to maintenance to prevent potential health risks, and (iii) the levels of microbes in cooling towers that present a serious health threat and require immediate action and reporting.
Where the results of any such test indicate levels of microbes that are indicative of a maintenance deficiency requiring mitigation, including but not limited to maintenance to prevent potential health risks, the owner of the building that has such cooling tower shall, polymer within 48 hours after such owner knows or reasonably should know of such results, clean and disinfect the cooling tower in accordance with the rules of NY City and/or State.
Where the results of any such test indicate levels of microbes that present a serious health threat, the owner of the building that has such cooling tower shall, within 24 hours after such owner knows or reasonably should know of such results, (i) notify the department and (ii) clean and disinfect the cooling tower, including an additional application of biocide, in accordance with the rules of NY City and/or State.
Annual Certification of NY Cooling Towers ? The owner or operator of a cooling tower shall file a certification each year that such cooling tower was inspected, tested, cleaned and disinfected, that the condition of the cooling tower is appropriate for its intended use, and that a maintenance program and plan has been developed and implemented as required to be in compliance with New York City and New York State Cooling Tower Laws. Such certification shall be submitted by November 1, 2016 and by November 1 of each year thereafter. This applies to both the City and State laws.
Recordkeeping Requirement for NY Cooling Towers ? A cooling tower owner shall keep and maintain records of all inspections findings, deficiencies, corrective actions, cleanings, disinfections, and tests performed pursuant to this section for at least three years. The owner shall maintain a copy of the maintenance program and plan required by the NY City and/or State cooling tower laws on the premises where the cooling tower is located. Such records and plan shall be made available to the NY City and/or State Department of Health immediately upon request.
Isn?t that a lot of stuff to do? I never had to do this before.
Yes, it?s a lot; and at first glance, it may even seem overwhelming. But there is some good news: if you are contracting one of top water treatment companies in New York to do your cooling tower water treatment, then you are probably already fulfilling most of the NY City and State requirements! A good water treatment company is already treating your cooling tower system to an industry accepted standard, they are most likely inspecting your tower on monthly basis, they are furnishing full reports of their findings and tests, and they are recommending, if not performing, seasonal cooling tower cleanings. So while the laws may seem overwhelming, most reputable water treatment companies will have no problems helping you stay in compliance.
What are the websites where I need to register my NY cooling tower?
For New York CITY Cooling Towers (including ALL FIVE BOROUGHS), please visit:
New York City Cooling Tower Registration Website
For New York STATE Cooling Towers, please visit:
New York State Cooling Tower Registration Website
IMPORTANT NOTE: If you are in New York City, you MUST register on BOTH the New York City and New York State Registration websites.
Is there anyone to help me?
Yes, the Department of Health and Mental Hygiene is available to answer your questions regarding the cooling tower laws in NYC. If you already know what to do, but now need to comply, you can reach out to any one of the reputable water treatment companies. We are here to help and we can be reached at 888-616-3545.
Where can I get a copy of the New York City and New York State Cooling Tower Regulations and Laws?
You can download a copy of both the NY State and NY City laws through these links below:
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Clarity Water Technologies is known throughout the east coast as an innovative industrial/commercial water treatment company and the innovators of 360 Degree Legionella Management Service. To put it simply: As New York City's Top Environmental Consultants, we make commercial HVAC and industrial process machinery last longer and run more efficiently, with less fuel and less downtime, by chemically treating the water that runs through it. Typical systems that we treat include steam boilers, chillers and cooling towers; however, we also offer advanced wastewater, glycol services, odor control and fuel treatment services. We are one of Northeast?s most trusted Legionella remediation companies and are widely accepted as one of the best consulting firms to establish best practices for the implementation of ASHRAE Standard 188 - Legionellosis: Risk Management for Building Water Systems.
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New York City Water Treatment Expert and Environmental Consultant, Greg Frazier has a vast knowledge of Industrial Water Treatment and is currently the Managing Partner of Clarity Water Technologies, one of the best Environmental Consulting firms in New York. Mr. Frazier has over 19 years of Industrial Water Treatment experience and holds a degree in Chemical Engineering from the University of Tennessee. Clarity Water Technologies specializes in comprehensive water treatment services. Clarity's service goes far beyond administering Cooling Tower Water Treatment chemicals - it also includes Cooling Tower Maintenance and HVAC Cleaning Services.
