New York City Cooling Tower Start-Up Requirements

By Frank Fortino

This month, we’re providing additional guidance to expand on our February article on Legionella compliance. Understanding the New York City Department of Health (DOH) requirements is extremely important, not only for public safety, but also for limiting potential liability for penalties, fines, and claims. As previously discussed, city law requires owners to provide proper daily records and reports on cooling towers, and regulation compliance supports everyone’s best interests. Your chief engineer or third-party consultant should be very well-versed on these requirements. Should you or anyone at your firm need information or have questions, I am available to discuss or guide you in this matter.

After a cooling tower has been shut down or left untreated for five or more days, turning it back on involves more than flipping a switch. Chapter 8 of the New York City Health Code requires building owners to follow a specific start-up procedure, as outlined below.

1. Cleaning and disinfection. First, clean the cooling tower thoroughly—either through scrubbing or power-washing—to remove scale, biofilm, or any other debris that may have accumulated. Then, disinfect the tower, using an approved biocide to kill pathogens such as Legionella. Each building should have a maintenance program and plan (MPP) developed by a qualified person, which provides detailed guidance for cleaning and disinfection.
2. Fill and circulation. Next, follow the MPP specifications for filling the cooling tower with water and for circulating biocides and chemicals. Once filled and turned on, the operational system must meet all city requirements for system monitoring, maintenance, and water quality testing.
3. Compliance inspections. Following start-up, a qualified individual must perform and document a compliance inspection. The start-up inspection includes a physical assessment of the complete cooling tower system, testing all components for potential contaminants and other adverse conditions, and ensuring that the water treatment equipment works correctly. In addition, the inspection includes reviewing operational records for completeness.
4. Legionella Within 14 days of activating the cooling tower, a water sample must be collected and analyzed for the presence of Legionella. The laboratory analyzing the sample must be certified by the DOH’s Environmental Laboratory Approval Program. Based on the culture results, action must be taken according to Table 8-1 of the New York City Health Code, Chapter 8.
5. Documentation. Building owners are required to maintain detailed records of all procedures and actions performed on cooling tower systems. Such records should all operations and actions, including inspections, sampling, treatment, etc., as well as the dates of each.

If you have any questions or require additional information regarding cooling tower requirements, please contact Metropolis Group at 212.233.6344.