How to Comply with New York City’s Cooling Tower Start-Up Regulations

By: Morgan Nankivell, Environmental Group Manager
ASSE 12080 Legionella Water Safety and Management Specialist

Springtime marks the beginning of seasonal cooling tower start-up in the Northeast. Since the implementation of Local Law 77 of 2015 of the City of New York, Cooling Tower owners have been required to comply with numerous regulatory requirements regarding the maintenance and operation of their cooling towers. As seasonal cooling towers start-up, here is a comprehensive list of requirements for start-up.

How to Comply with New York City’s Cooling Tower Start-Up Regulations:

  • Clean and Disinfect
    • Tower systems must undergo a mechanical cleaning to remove biofilm, scale, or debris, followed by the application of a New York State registered biocide.
  • Fill System and Circulate with Water
    • Following the cleaning and disinfection, the tower system is filled with water and circulated with biocide.
  • Resume Maintenance and Monitoring
    • The system is considered operational once it is filled and circulating with biocides, at which time all monitoring and maintenance must resume (i.e. logs, inspections, and dip slides).
  • Perform Compliance Inspection
    • The qualified person, as defined by the NYC DOH, is to conduct an inspection prior to the fan being turned on.
  • Take Legionella Sample
    • Legionella bacteria sample must be taken prior to the fan being turned on, to validate the start-up procedure.
  • Detailed Documentation
    • Records of all start-up activities should be available upon request and kept for at least 3 years.

Tower owners must not only make sure these tasks are completed but that each are done within a certain time frame. According to the New York City Department of Health and Mental Hygiene (NYC DOHMH), the inspection and Legionella sample must be completed within 14 days of cleaning the tower, before the fan is turned on and the tower is put under load.

With a relatively short window of time for a coordinated effort by tower owners and those responsible for each task, excellent communication and a comprehensive understanding of the rules and regulations are essential in a successful and compliant start-up.

Barclay has been involved in hundreds of compliant tower start-ups in New York, applying industry-leading best practices that give peace of mind to cooling tower owners. Contact Barclay Water Management today to ask how Barclay can help you comply with New York Cooling tower regulations.

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