Cooling Towers, Legionellosis, and

Water Management Programs

Christopher J. Nagle
EVAPCO, Inc.
October 1, 2020
World Health Organization

“Legionellosis is a generic term describing the pneumonic and

non-pneumonic forms of infection with Legionella.”

“The public health threat posed by legionellosis can be

addressed by implementing water safety plans by authorities
responsible for building safety or water system safety.”

https://www.who.int/news-room/fact-sheets/detail/legionellosis
 Why the Focus on Cooling Towers?
• First recognized outbreak occurred
in Philadelphia, PA in 1976.
• Named Legionnaires' disease
based on American Legion
Convention being held at a Hotel in
Philadelphia.
• The Hotel’s Cooling Tower was
suspected as the source of the
outbreak.

https://www.cdc.gov/os/wewerethere/blog.html
Why Was the Cooling Tower ‘Suspected’?
“Five months after the convention, [CDC
microbiologist Joseph McCade] took another
look at some red sausage-shaped bacteria
and concluded that they were the culprits,”
TIME later explained, in a 1983 cover
story about the CDC. “They had festered in the
water of the hotel’s cooling tower and had
been carried through the air as the water
evaporated.”
https://time.com/3994453/legionnaires-disease-name-history-1976/
One Victim Was Not in ‘Hotel A’ for
Legionnaires’ Convention

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5042515/table/pone.0164074.t001/?report=objectonly
40 Years Later
“Legionella was not recovered from hotel A or the surrounding area despite a wide-ranging
environmental investigation following the 1976 epidemic, thus it was not possible to confirm
the precise source(s) of infection. Case epidemiology and our newly resolved phylogeny
may, however, provide valuable insight: Philadelphia strains -2, -3, and -4 were recovered
from American Legion conventioneers or relatives who entered hotel A on more than one
occasion, but strain CDC Philadelphia-1 was isolated from a person with Broad Street
pneumonia who never entered the convention hotel. By genetic comparison, the Broad
Street pneumonia case was infected by a similar, yet distinct strain of L. pneumophila sg1
compared to the bacteria infecting the 3 hotel-associated victims. Collectively, these data
suggest that multiple potential exposure sources could have existed in this urban
environment, as observed in recent outbreaks and reports.”

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5042515/
What About Cooling Tower Regulations?
Outbreak of Legionnaires
disease initially linked to
cooling towers occurred in
Pas-de-Calais, France,
between November
2003–January 2004.
“France suggested that any industrial
systems generating aerosols could be
potential sources of contamination for
sporadic LD cases. After the present
outbreak, the national authorities
issued new regulations concerning the
installation and maintenance of
Cooling Towers..”
Nguyen, TM.; Ilef, D.; Jarraud, S.; et al.
J Infect Diseases. 2006; 193(1):110
Order of 13 December 2004 relating to
water dispersal cooling facilities
• Art. 6.c – ‘A preventative
maintenance, cleaning and
disinfection plan for the facility,
aimed at maintaining concentration
of legionella in the water of the
circuit at a level of less than 1,000
units forming colony per liter of
water, is implemented under the
responsibility of the operator.’
(<1.0 CFU/ml)
Order of 13 December 2004 relating to
water dispersal cooling facilities
• Art. 8.1 – ‘If, for a period of at least 12 continuous months, the
results of the monthly analyses are lower 1,000 units forming
colonies per liter of water, the frequency of Samples and analyses of
Legionella specia NF T90-431 may be at least quarterly.’
• Art. 9.2 – ‘If the results of analyses…concentration of more than
1,000 units forming colonies per liter of water and less than 100,000
units forming colonies per liter of water, the operator makes
arrangements to clean and disinfect the facility to ensure a
concentration of Legionella specie less than 1,000 units forming
colonies per liter of water.’ (1 to 100 CFU/ml)
French Cooling Tower Focused Regulation
• Drift eliminators capable of limiting drift from the tower to 0.01%
of circulation rate.
• Monthly testing of Legionella bacteria levels until 12 continuous
tests come back at 1 CFU/ml or less.
• Clean and disinfect the tower for any LB test result >1 CFU/ml
and less than 100 CFU/ml.
• Immediately shut down, drain, clean, and disinfect for any LB
test result ≥ 100 CFU/ml.
Impact of French Tower Regulation on
Incidence of Disease
Multiple Outbreaks in New York City - 2015
• December ‘14 to January ‘15 July to August -1st of three
• Co-op City Bronx Outbreaks
• April to May
• Flushing area of Queens • New York City Department of
• July to August Health focused on Cooling
• South Bronx Towers
• September • August 6, 2015 - Health
• Melrose House South Bronx Commission ordered inspection
• September and disinfection of all cooling
• Morris Park East Bronx towers in NYC.
NYC Health Commissioner Dr. Mary Bassett
• “New York City’s drinking water supply is safe and unaffected by the
Legionella.”
• “the Administration strongly supports the registration of cooling towers and
reaching inspection and testing for microbes in order to help prevent and
investigate future outbreaks of Legionnaires’ Disease.”
• “Legionella exists in the environment, and we will continue to see sporadic
cases of Legionnaires’ Disease in New York City, but we believe that this
important legislation will go a long way towards reducing the number and
severity of these outbreaks.”
“TRANSCRIPT OF THE MINUTES Of the COMMITTEE ON HOUSING AND BUILDINGS.
August 11, 2015.” City Council City of New York.
NYC Local Law 77 Fast Tracked
• Passed by City Council on August 13, 2015.
• Signed by the Mayor on August 18, 2015.
• Requires Cooling Tower Registration.
• Requires annual inspections & disinfections of Cooling Towers.
• Referenced new Administrative Code 17-194.
• Includes a small part of ASHRAE 188 without full adoption.
• Mandates Legionella specific testing for CT only.
• Prescribes low, one-size fits all action levels for positive LB results.
Impact of NYC Tower Regulation
on Cases of Legionnaires’ Disease
104.6% Increase in Avg. Cases per Year
‘Tower Only’ Regulations Have Not
Proven Effective at Reducing Disease
Should Not be a Surprise to AWT or AWT Member Companies
“While cooling towers and evaporative condensers are also a potential
source related to Legionnaires’ disease, and long thought to be the
major source of Legionella-causing disease, current data suggest that
domestic (potable) water plumbing systems are responsible for an
even larger number of cases of legionellosis.”
AWT - Legionella 2019:
A Position Statement and Guidance Document
‘Tower Only’ Impacts a Small Slice of
Pie
Reducing Legionellosis
Requires a Bigger Bite
Outbreaks

• Testing and Tracking

Consistency of Supply Water

• ASHRAE 188
Sporadic
Not Investigated
Myopic Focus on Evaporative Cooling
Slows Progress to Reduce Legionellosis
ASHRAE 188 Focuses on All
Building Water Systems and Endpoints
• building water systems: potable and nonpotable water
systems in the building or on the site.
• water-use end points: the points at which water exits from all
potable and nonpotable building water systems, fixtures, and
equipment.
• The presence of Legionella bacteria in building water systems
is not in itself sufficient to cause LD.
• …and exposure of susceptible persons to LD colonized water
that is inhaled or aspirated into the lungs.
Cooling Towers Are Only One-Part
of a Water Management Program
What information should a water treatment professional
understand and document to assess the risk
and corresponding control limits for their customer’s
specific evaporative cooling system?
Visible Plume is Primarily Pure H2O
• Heat is removed from the
system via evaporation of
pure water.
• This pure water plume
expands and is dispersed as
it moves away from the tower.
• Risk decreases as distance
from tower increases.
 1994 Hospital Cooling Tower Outbreak
• Demonstrates the ‘pattern’ of a
single, point-source aerosol
outbreak.
• “The risk of illness decreased by
20% for each 0.1-mile increase
in distance from Hospital A up to
one mile from hospital.”
• Duplicate sampling showed LB Brown, c.; Nuorti, P.; Breiman, R.; et al.
Int. Journal of Epidemiology 1999;28:356
test results in the thousands of
CFU with test variation of >33%.
Microbial Risk From Evaporative Cooling
Systems is Related to Drift Not Plume
“Baffles, called drift eliminators, are placed between the nozzles and
the fans to minimize (through inertial impaction) the amount of
entrained water droplets that leave the cooling tower and are
discharged into the atmosphere. The escaping droplets are called drift.
An important distinction between drift and the normally visible
condensing plume is that the drift contains the same chemicals and
solids present in the circulating water, whereas, the condensation is
pure water vapor.”
Hennon, K.; Wheeler, D. Cooling Technology Institute (CTI) TP03-08
Improved Drift Eliminators
Significantly Reduce Risk
2004 French Regulation Current Generation with Drift
Drift Rates of 0.01% or less Rates as low as 0.001%

Old Style Blade Drift Eliminator Cellular Drift Eliminator

If All Drift Was Respirable
(Data from IWC 08-21)
Tower Type Drift Rate Legionella Milliliter Drift Legionella per Minutes to
Concentration per Liter of Liter of Inhale 1
Exhaust air Exhaust Air Legionella
Bacteria

1988 Forced 0.02% 9,000 CFU/ml 0.000316 2.8 3 seconds

Draft
Condenser
2020 Induced 0.005% 100 CFU/ml 0.0000768 min 0.00768 min 17 minutes
Draft Crossflow 0.0000860 max 0.00860 max 15 minutes

2020 Forced 0.001% 100 CFU/ml 0.0000126 min 0.00126 min 106 minutes
Draft 0.0000189 max 0.00189 max 70 minutes
Counterflow
The Majority of Drift Droplets Exiting a
Tower are Too Large to be Respirable
“The bacteria contained
in those droplets can
cause disease only if the
droplets evaporate to a
respirable size before
failing to the ground.”
Bulger, T.; Lane, J.; Miller, R.; et al.
The International Water Conference
(IWC). IWC 08-21.
Is 50 CFU/ml a Meaningful Action Level
or Cause for Tower Remediation?
• “An unfortunate regulatory trend in recent years is to establish
expectations(e.g., specifications, limits, levels) for data generated by
the plate count method that the accuracy of the method cannot
support.”
The Analyst Technology Supplement 2013; 17
Quoting Sutton from Journal of Validation Technology, 2011

• A 50 CFU/ml test result in a cooling tower with 0.02% drift rate

represents a higher risk than a cooling tower with a 0.001% drift rate
and 500 CFU/ml test result.
Understanding Drift Rate & Drift Size

Creates a framework to develop control limits and corrective

actions based on system risk instead of an arbitrarily low CFU/ml.
Inspect Drift Eliminators & Limit Feed of
Supplemental Dispersants to Avoid Excessive Drift
• “Most of the cases with abnormal drift
levels are due to incorrect installation or
use of the drift eliminator panels.”
• “Surfactants can have a significant
impact on the drift rate depending on
their concentration and their ability to
migrate to new interface air/liquid (fast or
slow response surfactant).”
Ganzitti, V.; Rincones, J.
Cooling Technology Institute (CTI) TP20-19.
Closed Circuit Coolers & Evaporative
Condensers ≠ Open Cooling Tower
Heat Exchange Occurs in Coil
• Closed Circuit Coolers have water
or glycol & water as the fluid in the
coil.
• Evaporative Condensers have
ammonia or another refrigerant in
the coil.
• Coils are often galvanized steel
requiring initial passivation.
Closed Circuit Coolers & Evaporative
Condensers ≠ Open Cooling Tower
Condensers & Coolers with
Integral Spray Water Pumps
• Low water volumes with high water turnover
rates. 100% turnover may occur in a minute
or less.
• Lower retention times impact biocide
selection, volume per feed, and frequency
of feed schedule.
• Wet-dry cycling, no field piping, and no
dead-legs combine to reduce the potential
for sessile growth.
Closed Circuit Coolers & Evaporative
Condensers ≠ Open Cooling Tower
• Spray water pressure is quite low (≤5
psi) which should be considered when
designing side-stream feed and control
loops.
• Condenser refrigerant inlet temperatures
can be quite high in the top few rows of
the coil bundle.
• Inlet coil temperature should be
considered when selecting inhibitors and
calculating operating cycles of
concentration.
Open Cooling Towers
• Typically connected to separate
heat exchanger (chiller, plate &
frame, shell & tube).
• Heat from the exchanger is
cooled as water falls through a fill
pack designed to maximize
contact with air.
• Systems tend to have larger
water volumes and longer
retention times compared to
coolers and condensers.
Crossflow Cooling Towers
Crossflow Design
• Air moves through the fill pack
perpendicular to the direction of
water flow.
• Drift rates typically down to
0.005% of recirculation rate.
• Algae may be a treatment
concern due to potential for
sunlight in wetted areas.
Counterflow Cooling Towers
Counterflow Design
• Air moves up through the fill
pack counter to the direction of
water flow.
• Drift rates typically down to
0.001% of recirculation.
• Design blocks sunlight from
wetted areas reducing Algae as
a treatment concern.
Adiabatic Coolers
• Dry Cooler with a pre-cooling
system that lowers the air’s dry
bulb temperature entering the
coil.
• These units deliver the leaving
fluid temperature in a smaller
footprint and/or lower fan motor
horsepower compared to a
completely dry unit.
Adiabatic Coolers
• Systems are designed to run dry
for most of the year.
• Water is typically supplied to the
pads as once through for
approximately 200-hours per
year.
• Designs which capture and
recirculate water off the pads
may require water treatment.
Cooling Towers Are Only One-Part
of a Water Management Program

Keeping Legionella bacteria out of all water systems

in buildings is the only way to reduce Legionellosis.
Wastewater Likely Source in
Pas-de-Calais
• “The level of contamination was high (106-1010 cfu/L) in plant A as
well as Plant B. Plant B supplied biological sludge for the Plant A
waste basin and was located ~40 km away, in another district.”
• “a considerable amount of Legionella bacteria in the wastewater
basin of the plant might have become airborne in aerosol produced
by surface ventilators, since air samples collected after final closure
of the CTs and as far as ~300 m from the basin demonstrated Lp-1
Lens in aerosolized, respirable (≤5 µm) water droplets.”
Nguyen, TM.; Ilef, D.; Jarraud, S.; et al.
J Infect Diseases. 2006; 193(1):107
New York City Drinking Water Supply
Can Be Affected by Legionella
Melrose House September 2015
• “The Health Department, in • Drinking water is sanitary,
consultation with the Centers for but not sterile.
Disease Control and Prevention, • Biofilm likely exists on all
decided to turn off the hot water in the
drinking water supply pipes.
Courtlandt Avenue building. Water
filters will be installed in every unit in • Pressure surges can
the building to eliminate the bacteria, disturb biofilm and
and the hot water will be turned back release bacteria
on afterward, the department said.” downstream to building
https://newyork.cbslocal.com/2015/09/02/legionna water systems.
ires-melrose-houses-south-bronx/
Water-Distribution Systems as the Primary
Source of Legionella bacteria is Not a New Idea
“In institutional outbreaks of Legionnaires' disease,
epidemiologic investigation has usually focused on
nearby cooling towers and evaporative condensers.
This study now indicates that attention should be
directed to the water-distribution system within the
institution.”
- New England Journal of Medicine, 1982

40
Water Management Programs Should Monitor
from Pre-Premise Through All End Points
• Water Management Programs should
include written requests for supply water
service disruptions including ‘tie-ins,
replacement of valves, hydrants, pumping
failures, pipeline breaks; and other system
repairs or emergency conditions.’
• The most likely way for Legionella
bacteria to get into a building water
system is with the supply water.
ASHRAE Agrees
• “However, treated drinking water is not required to be free of all
microorganisms. The treated water flows through the water
utility distribution system, including water transmission mains,
where it is subject to biofilm formation and microbial
colonization. As a result, water entering the building is a source
for Legionella in building water systems.”
ASHRAE Guideline 12-2020; 4.2.2
ASHRAE and CDC Focus on ‘All Water’
Causes and Common Sources of Infection
• Legionella is a type of bacterium found naturally in freshwater
environments, like lakes and streams. It can become a health concern
when it grows and spreads in human-made building water systems like
• Showerheads and sink faucets
• Cooling towers
• Hot tubs that aren’t drained after each use
• Decorative fountains and water features
• Hot water tanks and heaters
• Large plumbing systems
https://www.cdc.gov/legionella/about/causes-transmission.html#causes-sources
 You Need More Than a Cooling Tower
to Reduce Legionnaires’ Disease
• 1976 outbreak likely had more than one source.
• ‘Tower Only’ regulations in France and NY City have failed to reduce
the incidence of disease.
• ‘Point Source’ risk diminishes with distance.
• Advances in Drift Eliminator technology have significantly reduced the
potential for outbreaks.
• One-size fits all control limits don’t correlate to system risk.
• Treatment designed for Coolers or Condensers can be different than
Open Towers.
• Water Management Programs should cover supply water through all
building water endpoints.
Questions

ASHRAE Guideline 12-2020