A recent outbreak of Legionnaires’ disease last fall in Orange County left 22 people sick including one who died. Local health officials said the outbreak seemed connected to Disneyland as 19 of the 22 people who were infected visited the park.
The California Occupational Safety and Health Administration in March cited the park and fined it more than $33,000 for failing to properly clean cooling equipment linked to the outbreak and for other related violations.
Disneyland officials said the source of the outbreak could have been elsewhere in Anaheim and have appealed the citation however the California Occupational Safety and Health Administration said “The employer did not follow the manufacturer’s cooling tower start-up maintenance and water treatment procedure to control outbreaks of Legionnaires’ disease.
On or about June 15, 2018, the New York DEP, in conjunction with the New York City Bureau of Water has turned on emergency wells as well as opened a water main from the Croton Reservoir to add to the New York City Water supply. This last time this occurred was in June 2016 and lasted for approximately six months.
Prior to this date, New York City was being fed by the northern reservoirs such as the Catskill which is mostly made up of softer mountain runoff. This new city water is a combination of the soft water with the inclusion of harder ground water.
What does this mean for your property?
1. The following characteristics may change:
Color (brown water condition)
2. Water consumption increases due to HVAC equipment needs. Buildings with cooling towers or boilers will experience the following:
Cooling Towers – Used to operate 8-12 cycles*. (*How many times they reused the water until it was necessary to bleed.) Now they will operate 3.5-5 cycles. This is an increase of about 50-60% water consumption.
Steam Boilers – (using less than 95% return) These will use more water, proportionally, to the amount of condensate returning. Water softeners will need to be considered and if they already exist will need to be set to regenerate more often.
3. Water treatment – Cycles of Concentration will be greatly reduced. This will cause the usage of significantly more water make-up and Inhibitor Chemical that is not included in your contract. Conductivity limits will need to be set higher due to increased incoming conductivity, chlorides and hardness.
4. Domestic Water Filters – may need to be changed on a more frequent basis.
5. Reverse Osmosis Systems – These systems will need cleaning, filtering and membrane changes more frequently.
6. Water Softeners – These systems will need to be re-adjusted and recalculated due to the loading which is now about 5 times greater than it previously was. This will require five times the amount of salt for regeneration.
7. Glycol Systems – In the past, because of the extremely soft water conditions, we were able to mix 95% glycol down with NYC water. Now it will be necessary to consult with the glycol manufacturer before mixing or may require deionized water for make down.
8. Cooling tower Legionella Water management plans – Will need adjustment to account for higher conductivities and increased weekly chemical usage amount and dosages.
What should I do?
Verify that you do, in fact, have this condition. To do this, check your city water for elevated conductivity with your on-site meter
Normal Conductivity = 85-140 microSiemens
Elevated Conductivity= >150 microSiemens *
* Call your Tower Water Account Manager if an elevated condition is found.
Your Tower Water technical account manager should be testing your incoming water every visit.
Discuss the recommended course of action with your Tower Water person.
Plan to increase your budget due the increase in usage of water, chemicals, supplies, equipment etc.
Is this a permanent condition?
It is unclear how long it will last. The DEP reservoirs are not at or below normal condition (93.0%) at present. There is work being done on several water mains at this time. They have been working on this transmission main system for years.
As a company, Tower Water takes the approach that it is here to stay until we test otherwise. We will always do what is technically correct to provide the best protection to your HVAC systems while maintaining a competitive price.
If you have any further questions for concerns on your water treatment, please do not hesitate to contact Tower Water at 732-249-0990 or email Russell@towerwater.com.
If you have any further questions for the Department of Water, it is in reference to well water, it is referred to as the “In-City Resiliency Water Project” please contact 718-595-7000 or 311. See links below.
Cooling towers are an efficient way to cool water for air conditioning. During the hot and humid days you don’t want your air conditioning to be acting up. Cooling towers use a fan to move air through recycling water into open area. If the water gets dirty it can influence working productivity, system corruption, increase energy costs and potentially cause serious health issues.
During full system cleaning is important to remove all of the contaminant build-up and ensure that all of the components of tower’s are operating perfectly.
Here are a few tips in maintaining your cooling tower
Use chemical biocides to control microorganisms.
Keep sump water around 68°F or lower.
Inspect the cooling tower equipment monthly.
Clean and disinfect your facility’s cooling tower quarterly or twice a year if the unit is not in operation year-round.
New York City and New York State have some of the most comprehensive cooling tower regulations in the nation and in order to be fully compliant, your best bet to avoid cooling tower violations is to work with a reputable water testing company like Tower Water.
Regulations regarding water tower violations and rules are strictly enforced by both NYC and NYC agencies and violators are severely punished. But truthfully the full impact can’t be measured in the violation costs alone. Beyond just the violation cost comes a detrimental impact to your building’s reputation, as well as the possibility to legal recourse from tenants and businesses within the building.
Avoid the steep penalties of not properly maintaining your cooling tower properly. Tower Water can help you do that and we have the resources to help you. If you have any questions or concerns regarding your cooling tower give Tower Water a call!
While there are a number of potential violations cooling towers can encounter at both the City and State level, there are a few common missteps that businesses and building owners often encounter that can result in violations.
Since compliance is an essential part of protecting your business’s reputation and bottom line, here are the most common violations you can easily avoid.
1. Not Having a “Qualified Person” Perform Daily and Weekly Monitoring
According to City and State definitions, you can’t let just your average Joe perform your water treatment testing and monitoring. Instead, buildings must rely on a “qualified person” to assist with the development and implementation of a Maintenance Program and Plan. For the purpose of these laws, a “qualified person” is a New York State-licensed and registered professional engineer; a certified industrial hygienist; a certified water technologist with training and experience developing maintenance plans and performing inspections in accordance with current standard industry protocols including, but not limited to ANSI/ASHRAE 188-2015; or an environmental consultant with at least two years of operation experience in water management planning and operation.
2. Lacking the Proper Documentation or a Maintenance Program and Plan
This issue can be easily avoided but so often isn’t by disorganized building owners and property managers. All documentation regarding treatments, cleanings, or any other activities relating to each individual cooling tower must be kept for a minimum of three years. Additionally, Maintenance Programs and Plans must be developed and followed with the assistance of an onsite qualified person.
3. Not Paying Fines Associated With Violations or Failing to Appear at Scheduled Hearings
Obviously, not paying fines levied against you is a big no-no, especially when it’s the City and State you’re stiffing. Depending on the severity of the violation, you may have the option of mailing in the fines, which is essentially admitting to the infraction and waiving your right to appeal. Or, if the violation is severe, you may need to attend a hearing in person. During this hearing a Hearing Officer will issue a judgment based on the findings presented by the Inspector who initially reported the violation. Not paying these fines can result in a number of bad things, chief among them the fact that the Department of Finance, aka the agency responsible for collecting monies owed to the City, will likely issue a judgment through the New York Civil Courts and begin collections proceedings against you or your business.
For more information about water treatment services in New York City and to speak with a “qualified person” contact Tower Water.
If you’ve ever taken a look at Local Law 77 or Chapter 8 of the Rules of the City of New York, both of which revolve heavily around the subject of compliance, testing, and regulation of cooling towers in New York, you’ve probably noticed a vague reference amid the myriad of stipulations: a “qualified person” needed to perform daily and weekly monitoring, and help develop and implement a Cooling Tower Maintenance Program and Plan (MPP) in line with the American Society of Heating, Refrigeration and Air Condition Engineers Standard.
But exactly… who qualifies as a “qualified person” when it comes to NYC cooling tower compliance?
The answer is provided by the same legislation that regulates how frequently monitoring, testing, and cleanings need to be performed. According to the legislation, a “qualified person” is a New York State-licensed and registered professional engineer; a certified industrial hygienist; a certified water technologist with training and experience developing maintenance plans and performing inspections in accordance with current standard industry protocols including, but not limited to ANSI/ASHRAE 188-2015; or an environmental consultant with at least two years of operation experience in water management planning and operation.
What this means is that while there is some broad license in who a qualified person might be, the key takeaways of this passage are that it’s very likely that unless someone within your operation currently meets those credentials, there’s a good chance you’ll need to bring in a third-party consultant or consulting company to act as your qualified person.
Choose wisely because this qualified person will not only be keeping records for state and city agencies, but he/she will also assist in annual inspections by the Department of Buildings and manage any violations and remediation processes that need to take place after a violation.
A recent outbreak of Legionnaires’ disease was confirmed at Co-Op City in the Bronx. The outbreak turned fatal leaving one elderly resident dead while two others recovered at a nearby hospital.
The New York City Health Department said it is in the process of examining the water supply that is shared across the three affected buildings in the complex of 35 high-rises. Legionnaires’ disease is caused by breathing in water vapor containing the bacteria legionella. It is not contagious and is treatable with antibiotics.
Symptoms include fever, cough, chills, muscle aches, headache, fatigue, loss of appetite, confusion and diarrhea, officials said. Symptoms typically appear two to 10 days after exposure to Legionella bacteria.
The city started regular, mandatory inspections of cooling systems after a deadly Legionnaires’ outbreak in the South Bronx where 12 people died. To read more about Legionnaire’s disease and the legionella bacteria that causes the disease, read more here.
Cooling tower fines are steep, but they pale in comparison to the total impact and cost paid by those found responsible for a bacterial outbreak or Legionnaire’s clusters.
New York City and New York State have some of the most comprehensive cooling tower regulations in the nation and in order to be fully compliant, your best bet to avoid cooling tower violations is to work with a reputable water testing company like Tower Water. Regulations regarding water tower violations and rules are strictly enforced by both NYC and NYC agencies and violators are severely punished. But truthfully the full impact can’t be measured in the violation costs alone. Beyond just the violation cost comes a detrimental impact to your building’s reputation, as well as the possibility to legal recourse from tenants and businesses within the building.
After NYC’s worst outbreak of Legionnaire’s Disease in 2015, Local Law 77 (LL77) was put into place to help protect the public – particularly the most vulnerable populations like the elderly and those in poor health. Despite these strict regulations and their importance in protecting the public health, cooling towers in the NYC area are still found contaminated with Legionella bacteria on a regular basis, causing there to be several discussions about conduct independent Legionella testing.
As a result, Tower Water partners with Legionella Compliance Services to perform independent Legionella testing services to ensure your business avoids violations and maintains compliance with NYC and NYS regualtions.
Lopcal Law 77 comes with a lengthy list of potential fines for cooling towers not in compliance with the law. These fines are often severe and double after the first offense. One part of a cooling tower in non-compliance will likely result in several fines, not just one.
But the true cost of cooling tower violations and legionella growth is far greater. Due to the severity of the 2015 outbreak of Legionnaire’s Disease, smaller Legionnaire’s clusters in NYC are big news.
If your cooling tower is identified as a potential source, it’s not just the possible $25,000 in fines you’ll have to pay. You’ll also pay by having your business’s name dragged around the news cycle for weeks.
It won’t matter to viewers and neighborhood residents if you were doing everything you could to be in compliance – it will only matter that you did not do enough. Your business will be seen by the local community and the broader NYC area as poorly run and unsafe.
This can be especially harmful for health clubs, gyms, apartment buildings and retailers. These businesses are expected to provide healthy and safe experiences for customers, and the blow to their brand may never recover.
If you own a property in one of New York City’s five boroughs, you probably already know that NYC faces an abnormally high incidence of Legionnaires’ Disease – in fact, it’s one of the highest rates in the country. After the city’s worst outbreak in 2015, New York City cooling tower regulations called Local Law 77 (LL77) was implemented in the hopes of significantly reducing Legionella outbreaks.
While cooling towers are not entirely responsible for every single case of Legionnaires’ Disease, they have been identified as one of the primary sources of the 2015 and continued outbreaks through 2017.
In 2018, the need for cooling tower audits has never been more urgent. Building owners need to protect their businesses from the steep costs and liability of non-compliance.
A cooling tower audit can help protect your business from the heavy financial burden of failed inspections and non-compliance with City and State regulations. Even fully compliant cooling towers can fail inspections due to messy or improper documentation of procedures.
Even if your cooling tower is legionella-free there are still plenty of ways to fail an inspection and with that often come heft fines and a very tight window of time to remedy the issues.
So how can an audit help protect your business?
A cooling tower audit can reveal legionella growth, which is a worst-case scenario for any building owner. Not only is legionella a public health hazard, it’s expensive to get rid of and extremely damaging to your business if people start to get sick from your cooling tower (think about how many times your business would be dragged around the news cycle).
It’s best to be proactive when it comes to cooling tower compliance and legionella prevention, because those who are reactive and slow pay dearly for it.
Your business is at risk and outbreaks are still occurring. Contact the professionals at Tower Water to discuss how our cooling tower audits can help protect your business from the financial burden of non-compliance.
Cooling tower water treatment is closely regulated by New York City and New York State laws. Those laws mandate the strict maintenance and treatment requirements that were implemented after a fatal outbreak of Legionnaire’s Disease in 2015 in New York City.
While cooling tower problems may arise from corrosion, scaling or fouling, all of which are prevented by proper cooling tower water treatment, the biggest threat to your business is the threat of a legionella outbreak. Legionella can also be controlled through proper cooling tower water treatment.
Local Law 77 and Chapter 8 to Title 24 of the Rules of the City of New York outline the maintenance and inspection requirements, including water treatment, for all cooling towers in NYC. Following these regulations exactly will protect your business from the steep costs of non-compliance.
NYC requires all cooling towers to receive routine inspections and legionella testing by a qualified professional every 90 days. On top of this, cooling towers must be disinfected twice a year by a licensed pesticide applicator, regardless of whether there’s legionella or not. All cooling towers are also subject to random inspections – you can be sure this will happen to your cooling tower as Legionnaire’s Disease cases have been on the rise, despite cooling tower regulations.
One of the best ways to protect your business from non-compliance, which can lead to huge fines, is to hire a certified, independent third party to conduct cooling tower audits. These audits can help ensure everything is being done correctly to minimize the risk of legionella growth in your cooling tower.
With the uptick in inspections to combat legionella growth, a lot of cooling towers are failing inspections because of improper documentation. Every maintenance and inspection item performed on a cooling tower must be documented immediately. If maintenance isn’t documented properly, you will be fined as if you hadn’t performed it at all. Cooling tower audits can ensure all documentation is in order, too. That way, your business is better protected from costly fines.
Cooling tower water treatment is closely regulated by New York City. Implementing best practices includes understanding and closely following all cooling tower regulations, but also requesting cooling tower audits to ensure you’re in compliance and there’s no legionella growth in your cooling towers.
While scaling, corrosion or fouling can cause problems for cooling towers, there’s no greater threat to your business than legionella growth. Fines for non-compliance are high and remaining in compliance is not an easy task for anyone.
The Alliance to Prevent Legionnaires’ Disease (APLD) announced earlier this week that more than 1,000 cases of Legionnaires’ disease since New York State’s worst recorded outbreak in August of 2015. Despite emergency state and city wide regulations calling for all cooling towers to develop continued maintenance plans and register with health agencies at both state and city levels.
“Unfortunately we continue to see cases of Legionnaires’ disease climb in New York,” said APLD Spokesperson Daryn Cline. “This is especially troubling since New York is holding itself out as the leader in Legionnaires’ disease prevention. The truth of the matter is their emphasis on water management inside the building has not had an impact on decreasing the rate of disease.”
According to their latest report, New York led the nation with 1,009 reported Legionnaires’ cases reported to the Center for Disease Control. Of over a thousand cases reported in the state, nearly half that number, 441 cases were recorded within the Bronx, Manhattan, Brooklyn, Queens, or Staten Island.