Council Member Maloney on Intro 1006 cleaning frequency and summer best practices

relied upon, what are some of the best practices around scheduling, phasing, and redundancy ahead of summer months so we can catch these violations before the outbreak begins, and wanting to learn a bit more

more about intro 1006 and your concerns there with the implementation.

We want to increase the frequency, but make these practical.

And thank you, Chair.

Let me start with intro 10006 and then hand it to Deputy Commissioner Schiff on the first part of that.

So I think the term cleaning can mean a number of different things.

And so I think we're eager to follow up with you to really get into some of the details there.

But for instance, if we were to define cleaning as doing more of the hyperhalogenation, which is applying that caustic

and corrosive material, that biocide, it can actually wear out the inside of the metal, which then potentially creates more Legionella infestation and contamination in the cooling tower.

So there are ways of doing cleaning that can reduce that risk.

So getting into the details is probably the next best step.

Let me hand it over to Deputy Commissioner.

Sure.

Thank you, Commissioner.

There's a couple of ways to think about your question.

First is that the law that the council has enacted and then the regulations that we have issued set out very, very specific timing and frequency of certain kinds of monitoring and maintenance activities.

And it is literally some things have to happen three times a week.

Some things have to happen weekly, monthly, biannually, annually.

But also, critically, every cooling tower operator is required to develop its own protocol.

And monitoring and maintenance plan that is specific to its cooling tower and its cooling tower system and how it operates in its building and what are the requirements for that particular system to maintain it.

And the system, we want the system to remain in balance.

So that is why we require a visual inspection at certain points, ongoing biocide at other times, and

the operators are collecting multiple indicators to see if their monitoring and maintenance plan is working to keep that system in balance and reduce the risk that that bacteria is going to grow

and to do that monthly sampling so that if it is growing, they will catch it early.

We know that this bacteria can grow quickly.

They catch it early.

They may catch it at a later stage, and depending on what those sample results show, if that bacteria is growing, there's very specific details on the corrective action that they're required to take, the confirmatory sampling timing,

and ongoing remediation if it doesn't work.

And I will say that the schedule that we have set out as the default schedule is based in the scientific literature.

It is the best practice and what the evidence shows us are our best practices.

We are, and they apply year-round, but there are some additional, there is one additional

precautionary measure that we require owners to take during the summer because we know that there is additional risk and that is for that hyperhalogenation that the commissioner mentioned.

Let me just share one more piece of information as an update to the council.

Council member you referenced the

website not including the 11 deaths it does include the 11 deaths it was updated last week

the information basically that we get comes in as you heard from dr howard when we can get it when we can verify it and when we have that information we update the site and so it is updated now