Cooling tower water treatment is the equipment and chemistry that keep an evaporative cooling system from scaling, corroding or growing bacteria. A tower cools water by evaporating part of it, so every mineral in the makeup water stays behind and concentrates. Treatment holds that concentration where the program sets it with controlled blowdown, protects metal with scale and corrosion inhibitors, keeps biology in check with biocide, and manages Legionella under a written water management plan. Paul Industries designs, installs and services the cooling tower water treatment system those programs run on: makeup treatment, chemical feed, conductivity-controlled blowdown, side stream filtration, monitoring and the condenser water piping itself.
What is cooling tower water treatment?
An open recirculating cooling tower is a heat exchanger that works by evaporation. Warm water from a chiller condenser, process heat exchanger or evaporative condenser is spread over fill, air is pulled through it, and a small fraction of the water evaporates, taking heat with it. The rest falls to the basin and is pumped back to the load. Because the tower is open to the air, the water also picks up dust, pollen and microorganisms, and it sits warm and aerated against steel, copper and galvanized surfaces.
What is cooling tower water treatment, then? It is the set of controls that keeps four failure modes in check at the same time: scale on heat transfer surfaces, corrosion of the tower and condenser water piping, fouling from suspended solids, and microbiological growth, including Legionella. None of them can be fixed by chemistry alone. Each depends on working equipment: a conductivity controller with a clean probe, chemical feed pumps that actually deliver, filters that are changed, and piping without stagnant sections. That is why we treat cooling tower water treatment as a mechanical scope as much as a chemical one.
Where the water goes: evaporation, blowdown, drift and makeup
The U.S. EPA’s WaterSense at Work guidance describes four ways water leaves a cooling tower: evaporation, blowdown (also called bleed-off), drift, and leaks or overflows. Everything that leaves is replaced by cooling tower makeup water.
| Water loss | What it is | Typical size | How it is controlled |
|---|---|---|---|
| Evaporation | The heat rejection itself | Roughly 1% of recirculating flow for every 10°F of temperature drop across the tower | Set by the cooling load; reduced only by reducing the load |
| Blowdown | Water deliberately drained to remove concentrated dissolved solids | Depends on cycles of concentration | Conductivity controller and a blowdown valve |
| Drift | Droplets carried out of the tower in the airstream | 0.05% to 0.2% of circulating flow; under 0.005% with modern drift eliminators | Drift eliminators in good condition |
| Leaks and overflows | Unintended losses | Should be zero | Float valve, level control and piping maintenance |
Evaporation is the one loss you cannot treat away, because it is how the tower works. Blowdown is the one you control, and it is where nearly all of the water savings in a treatment program come from.
Cycles of concentration: the number the whole program is built on
Cycles of concentration compare the dissolved solids in the circulating water with those in the makeup. The DOE Federal Energy Management Program and EPA both define it the same way, as the ratio of the concentration of dissolved solids in the blowdown to that in the makeup, and in practice it is measured with conductivity. Because dissolved solids enter only with makeup and leave mainly with blowdown, cycles also approximately equal the ratio of makeup volume to blowdown volume.
The cycles of concentration formula has two forms, and an operator should run both:
- By chemistry: cycles = conductivity of blowdown water ÷ conductivity of makeup water.
- By volume: cycles = makeup volume ÷ blowdown volume, read from meters on both lines.
When the two answers disagree, something is wrong. EPA’s guidance notes that if the volume-based result runs more than 10% above the conductivity-based result, the tower is probably losing water to a leak, an overflow or excessive drift. Flow meters on the makeup and blowdown lines, which FEMP recommends, are what make this check possible.
The practical limit on cycles of concentration, cooling tower to cooling tower, is set by the makeup water. EPA and FEMP both note that many systems run at two to four cycles while six or more may be possible. Hardness, alkalinity, silica and chlorides each put a ceiling on it: run past the point where calcium carbonate, calcium sulfate or silica comes out of solution and the condenser tubes scale. Softening or other makeup pretreatment raises that ceiling, which is why cooling tower makeup water treatment is often the most effective water-saving investment on the system.
Cooling tower blowdown: what it is and how to calculate it
What is cooling tower blowdown? It is circulating water deliberately removed from the system so that fresh makeup can dilute what remains. Without it, dissolved solids would climb with every gallon evaporated until scale formed. With too much of it, the tower wastes water, chemical and sewer capacity.
The cooling tower blowdown calculation follows from the water balance. If drift and leaks are small, makeup equals evaporation plus blowdown, and cycles equal makeup divided by blowdown. Solving the two together gives:
Blowdown = Evaporation ÷ (Cycles − 1), and Makeup = Evaporation + Blowdown.
A worked example: a tower circulating 1,000 gallons per minute with a 10°F range evaporates roughly 10 gallons per minute, using EPA’s rule of thumb. At 4 cycles, blowdown is 10 ÷ 3, about 3.3 gpm, and makeup about 13.3 gpm. At 6 cycles, blowdown falls to 2 gpm and makeup to 12 gpm. Moving the same tower from 3 cycles to 6 cuts makeup by a fifth and blowdown by more than half, which matches the makeup reduction EPA cites for that change.
Blowdown is controlled by a conductivity controller that opens a cooling tower blowdown valve when the set point is exceeded and closes it when conductivity falls back. FEMP recommends automatic conductivity control over manual or timed bleed because it holds a steadier set point, and a steadier set point lets the program run closer to its true limit. The valve, the probe and the drain path are hardware: a fouled probe reads low, the tower over-concentrates, and the inhibitor program is blamed for scale that the controller caused.
Cooling tower chemicals: what each one does
What chemicals are used in cooling tower water treatment? A typical cooling tower chemical treatment program combines several products, and each cooling tower water treatment chemical is aimed at one failure mode. The chemical supplier selects the cooling tower water treatment chemicals and doses from the makeup water analysis and the cycles target; the feed equipment delivers them.
| Function | Common chemistries | What it prevents | How it is fed and checked |
|---|---|---|---|
| Cooling tower scale inhibitor | Phosphonates and polymers | Calcium carbonate, calcium phosphate and silica deposits at higher cycles | Metering pump on a bleed-and-feed or proportional signal; residual tested |
| Cooling tower corrosion inhibitor | Phosphate and polymer blends, plus an azole where copper is present | General and pitting corrosion of steel, copper alloys and galvanized surfaces | Metering pump; corrosion coupons and residual tests |
| Oxidizing cooling tower biocide | Chlorine or bromine compounds | Bacteria, algae and biofilm, including Legionella | Continuous or slug feed; free halogen residual, ideally monitored automatically |
| Non-oxidizing biocide | Products such as isothiazolinones or glutaraldehyde, alternated with the oxidizer | Organisms that tolerate the oxidizer; established biofilm | Periodic slug dose per the product label |
| Dispersant | Polymers | Silt and suspended solids settling as basin sludge and under-deposit corrosion | Fed with the inhibitor blend |
| pH control | Sulfuric or other acid where justified | Carbonate scale, allowing more cycles | pH controller or timer with interlocks |
Cooling tower biocides are antimicrobial pesticides, registered with the U.S. EPA under FIFRA, and the product label governs how they may be used. In August 2024 EPA issued final guidance on testing antimicrobial products for efficacy against Legionella pneumophila in cooling tower water, so check that a product’s label actually carries a Legionella claim before relying on it for that purpose. Acid feed deserves particular care: FEMP notes that operators need training in safe handling and that pH must be monitored or controlled, because overdosing damages the system.
The cooling tower water treatment system: equipment we install and service
Every cooling tower chemical treatment system is the same handful of components arranged around the tower. These are what Paul Industries designs, fabricates, installs and services:
- Makeup water treatment: water softeners where hardness limits cycles, reverse osmosis or blending where dissolved solids, silica or chlorides do, and pretreatment for reclaimed or well water.
- Makeup and blowdown metering: totalizing meters on both lines so cycles can be checked by volume as well as conductivity.
- Controller and sensors: conductivity, pH and oxidizer residual probes in a flow assembly, wired to a controller that runs blowdown and chemical feed and logs the trend.
- Chemical feed: metering pumps, day tanks with secondary containment, injection quills and the tubing runs between them, often built as a single cooling tower water treatment skid in our shop.
- Blowdown assembly: a motorized or solenoid cooling tower blowdown valve, isolation valves, and an air-gapped drain connection.
- Corrosion monitoring: a cooling tower corrosion coupon rack piped so water flows past the coupons at a representative velocity.
- Side stream filtration: a filter loop off the basin or return, sized as a fraction of circulating flow.
- Condenser water piping: the supply and return between tower and load, drained and free of dead legs.
That cooling tower water treatment equipment is where most programs fail in practice. A pump that has lost prime, a probe coated in scale or a filter that has not been backwashed in a month will undo a well-designed program within weeks. Our work is to build the system so it is serviceable, and to keep it working.
Side stream filtration for cooling towers
A cooling tower scrubs the air that passes through it, so it collects dust, pollen, insects and debris continuously. Those solids settle in the basin as sludge, coat heat exchanger surfaces, shelter bacteria from biocide, and cause corrosion underneath the deposits. Side stream filtration pulls a portion of the circulating water through a filter and returns it clean. EPA and FEMP both recommend it, especially where the tower sits in a dusty environment.
Cooling tower side stream filtration is usually a centrifugal separator, a sand or multimedia filter, or a cartridge or bag filter, sized to treat a fraction of the circulating flow continuously. The choice depends on particle size and density: separators handle heavy grit, media filters catch finer silt, and both need a backwash or purge path to drain that is accounted for in the water balance. Basin sweeper piping, which directs filtered return water across the basin floor toward the suction, keeps solids moving to the filter instead of settling.
Legionella cooling tower risk and the water management plan
Cooling towers are a well-documented source of Legionnaires’ disease outbreaks because they combine warm water with an aerosol. The CDC identifies the favorable growth range for Legionella as 77 to 113°F (25 to 45°C), squarely where condenser water runs for much of the year, and names sediment and biofilm, temperature, water age and disinfectant residual as the key factors in its growth.
Legionella cooling tower water treatment therefore works on all four factors at once:
- A disinfectant residual maintained throughout each day, which the CDC recommends monitoring and adjusting with an automated system.
- Scale, corrosion and sediment control, because deposits shelter biofilm from biocide.
- High-efficiency drift eliminators, which the CDC recommends, to limit the aerosol leaving the tower.
- Piping without dead legs or stagnant bypasses, so no section of the system holds water long enough for growth. See dead leg elimination.
- Cleaning and disinfection at the intervals and events the plan specifies.
The framework for all of this is ANSI/ASHRAE Standard 188-2021, Legionellosis: Risk Management for Building Water Systems, which establishes minimum risk management requirements for building water systems, with ASHRAE Guideline 12-2023 as its companion guidance. An ASHRAE 188 water management plan identifies the tower and its hazardous conditions, sets control limits for each control measure, says who monitors what and how often, and states the corrective action when a result falls outside its limit. A legionella water management plan is only as good as the equipment that carries it out, which is why we build the monitoring and feed hardware to the plan’s control points rather than the other way round.
Cooling tower legionella testing requirements
Nationally, the CDC recommends that owners consider Legionella testing as part of routine validation of a water management program, and that testing be done with public health officials during any outbreak investigation. Several jurisdictions go further and make cooling tower legionella testing mandatory. New York is the best-known example:
- New York State, under 10 NYCRR Subpart 4-1: cooling towers must be registered with the state, inspected at intervals not exceeding 90 days while operating, sampled for bacteriological analysis at intervals not exceeding 30 days, sampled for Legionella at intervals not exceeding 90 days, and certified by November 1 each year, with records kept on site for at least three years.
- New York City, under 24 RCNY Chapter 8: beginning May 8, 2026, Legionella sampling must be conducted monthly with no more than 31 days between samples, towers must undergo summertime hyperhalogenation, and the water must be retested for Legionella 3 to 31 days after it.
Requirements differ by state and city, so the water management plan should name the rules that apply at the site. In every jurisdiction, results that cross a plan’s action limit trigger the corrective steps the plan defines, typically increased biocide, cleaning and disinfection, and resampling until results return to normal.
Cooling tower cleaning and disinfection
No chemical program keeps a tower clean indefinitely. The CDC recommends offline cleaning and disinfection at least once a year, and also before commissioning a new tower, before seasonal start-up, after a shutdown or extended idle period, and following manufacturer recommendations.
The cooling tower cleaning process generally runs: pre-disinfect the circulating water with an elevated oxidizer dose while circulating; drain; remove sludge and debris from the basin; clean the fill, drift eliminators, distribution deck and nozzles; inspect for corrosion and damaged components; refill; re-disinfect and hold the residual for the specified time; then return to normal treatment and confirm with sampling. Cooling tower scale removal, where deposits have already formed on fill or in heat exchanger tubes, is done with an inhibited acid cleaning matched to the materials, followed by neutralization and passivation of the metal where needed. Cooling tower disinfection after an out-of-limit Legionella result follows the corrective action written into the plan.
Cooling tower corrosion and how it is measured
Cooling tower corrosion attacks the basin, the structure, the condenser water piping and the condenser tubes. Galvanized towers are prone to white rust, a porous zinc corrosion product that typically appears while a new tower is being commissioned, especially if it runs at a pH above about 8 before the zinc has formed its protective layer. New galvanized towers are therefore run through a controlled passivation period with tight pH control before normal treatment begins. Copper and copper alloy condenser tubes need an azole to stay protected, and steel piping needs a corrosion inhibitor matched to the water.
Corrosion coupons, pre-weighed metal specimens of the system’s alloys, are mounted in a coupon rack, exposed for a set period, and weighed again to give a corrosion rate. They tell you what is happening to the metal, which residual tests alone cannot. Coupon results trended against chemistry are the clearest evidence that a cooling tower corrosion inhibitor program is working.
Cooling tower water treatment parameters to monitor
EPA lists the critical water chemistry parameters for a cooling tower as pH, alkalinity, conductivity, hardness, microbial growth, biocide and corrosion inhibitor levels. Most programs track them as follows.
| Parameter | Why it matters | How it is usually measured |
|---|---|---|
| Conductivity | Drives blowdown; the practical measure of cycles | Continuous probe on the controller, verified with a handheld meter |
| pH and alkalinity | Determine scaling and corrosion tendency | Continuous pH probe; alkalinity by titration |
| Calcium hardness, silica, chlorides | Set the maximum cycles the water will hold | Periodic lab or field tests of makeup and tower water |
| Oxidizer residual | Primary biological control | Continuous ORP or free halogen probe, plus field tests |
| Inhibitor residual | Confirms the feed is delivering the target dose | Field test for the inhibitor or its tracer |
| Bacteria and Legionella | Confirms biological control is working | Dip slides or plate counts for general bacteria; culture analysis by an accredited lab for Legionella |
| Corrosion rate | Confirms metal protection | Corrosion coupons exposed for a set period |
Cooling tower water treatment conductivity readings should be logged alongside makeup and blowdown meter readings, so cycles can be checked both ways every time the system is visited.
Cooling tower maintenance service and checklist
A cooling tower maintenance service on the water side keeps the system doing what the program assumes. A practical cooling tower maintenance checklist covers:
- Controller: calibrate and clean the conductivity, pH and oxidizer probes; confirm blowdown opens and closes at set point.
- Feed: confirm each metering pump is primed and delivering; check day tank levels, containment and injection points.
- Meters: read makeup and blowdown totals and calculate cycles both ways.
- Filtration: check differential pressure; backwash, purge or change elements.
- Tower: inspect basin for sludge, fill for scale or biological growth, drift eliminators for gaps or damage, and distribution nozzles for blockage.
- Coupons: pull and replace on schedule; trend the results.
- Records: log tests, sampling dates and results, and any corrective action, as the water management plan requires.
Paul Industries services cooling tower water treatment equipment under preventive maintenance and service contracts, and responds to failures through emergency repair service.
Cooling tower blowdown water treatment, discharge and reuse
Blowdown carries the minerals that arrived with the makeup water, concentrated several times, plus residual treatment chemicals. Cooling tower blowdown to sewer is the usual route, discharged under the local utility’s permit, which applies the federal pretreatment rules in 40 CFR Part 403 along with local limits. Some utilities restrict biocide residual, pH, temperature or specific metals, so cooling tower blowdown water treatment before discharge can include dechlorination, pH adjustment or solids removal. EPA also suggests asking the water utility whether the facility qualifies for a sewer charge deduction for water lost to evaporation, which a metered makeup and blowdown makes straightforward to document.
Cooling tower blowdown recycling is possible where water is scarce or expensive: blowdown can be filtered and treated, often with reverse osmosis, and returned as makeup or used elsewhere on site. It is a designed system with its own pretreatment, concentrate disposal and monitoring, and it belongs alongside the plant’s other process wastewater and effluent systems.
Closed loop, evaporative condenser and HVAC cooling tower water treatment
Not every tower is the same. Closed loop cooling tower water treatment applies to closed-circuit fluid coolers, where process water runs inside a coil and only the spray water over the coil evaporates. The coil fluid is a closed loop, treated with a corrosion inhibitor and sometimes glycol, and should never need significant makeup; the spray water side is treated like any open tower. Evaporative condenser water treatment is similar, with refrigerant inside the coil, and the coil surface scales quickly if spray water cycles are not controlled.
HVAC cooling tower water treatment serves the condenser water side of water-cooled chillers in commercial and institutional buildings. Condenser water treatment there has the same priorities as in a plant, plus the public health exposure of a tower on a roof near air intakes; the CDC recommends locating towers at least 25 feet from building air intakes. On the industrial side, towers serving process heat exchangers, compressors and process chillers see higher heat loads and often dirtier environments, which raises the value of side stream filtration and makes reliable feed equipment more critical. Towers are part of the wider plant utilities scope we build.
Data center cooling tower water treatment
A data center cooling tower carries the same chemistry as any other open tower, with two differences: the load runs every hour of the year, and an interruption is not acceptable. That makes redundancy in the treatment equipment, automatic monitoring with remote alarms, and a water management plan that allows cleaning without taking the cooling plant down part of the design. Water use is also scrutinized more closely at a data center, so holding the highest cycles the makeup will support, and proving it with metered makeup and blowdown, matters more than it does on most sites. For the full picture of facility water, closed technical cooling loops and coolant distribution units, see data center water treatment and cooling loops.
Choosing a cooling tower water treatment company
A cooling tower water treatment program needs two roles filled. A chemical supplier selects inhibitors and biocides, sets doses from the water analysis, and reports on chemistry. A mechanical contractor builds and maintains the equipment that delivers that program: makeup treatment, feed, controls, filtration, blowdown and piping. Some cooling tower water treatment companies cover the chemistry, some the equipment; the program only works when both are covered and someone owns the interface.
When evaluating cooling tower water treatment services, ask for: a written water management plan or a commitment to work under yours; a makeup water analysis and a stated cycles target with the reasoning behind it; metered makeup and blowdown; automated conductivity and oxidizer control with data logging; a corrosion coupon program; a cleaning and disinfection procedure; and service visit reports that show tests, readings and any corrective action. Paul Industries builds and services the system side of that program and works with the owner’s chemical supplier, so the program on paper and the equipment in the field match.
We work nationwide on industrial plants, data centers, pharmaceutical and food facilities, and commercial buildings, often alongside high-purity water systems, heat exchangers and the process piping that connects them. Oil and gas sites with tower and boiler chemistry are covered on our oil and gas page. To scope a new system or a retrofit of an existing tower, request a quote or call 201-450-8280.
Standards referenced: ASHRAE 188 · ASHRAE Guideline 12 · 10 NYCRR Subpart 4-1 · 24 RCNY Chapter 8 · FIFRA · 40 CFR 403
Frequently asked questions
What does a cooling tower water treatment program include?
A cooling tower water treatment program includes a makeup water analysis and a cycles target, a scale and corrosion inhibitor, an oxidizing biocide usually alternated with a non-oxidizing one, a dispersant, conductivity-controlled blowdown, side stream filtration where solids are a problem, corrosion coupons, routine testing, and a written water management plan for Legionella.
How do you calculate cooling tower blowdown?
Blowdown equals evaporation divided by cycles of concentration minus one. Evaporation is roughly 1% of recirculating flow for every 10 degrees F of range. A 1,000 gpm tower with a 10 degree range evaporates about 10 gpm, so at 4 cycles blowdown is about 3.3 gpm and makeup about 13.3 gpm.
What is a good cycles of concentration for a cooling tower?
As high as the makeup water allows without scaling. Many systems run at two to four cycles and six or more is possible, according to EPA and DOE guidance. Hardness, alkalinity, silica and chlorides set the limit, and softening or other makeup pretreatment raises it.
How do I check cycles of concentration?
Two ways, and they should agree. Divide tower water conductivity by makeup conductivity, and divide metered makeup volume by metered blowdown volume. If the volume result runs more than 10% higher than the conductivity result, EPA guidance points to a leak, an overflow or excessive drift.
What does a cooling tower blowdown valve do?
It drains concentrated tower water when the conductivity controller sees conductivity above its set point, letting fresh makeup dilute the system. A sticking valve or a fouled conductivity probe is a common cause of scale that gets wrongly blamed on the chemical program.
Why does a cooling tower need side stream filtration?
A tower scrubs dust and debris from the air it moves, and those solids settle as sludge, coat heat exchangers, shelter bacteria and cause under-deposit corrosion. Side stream filtration cleans a portion of the circulating flow continuously; EPA and DOE both recommend it, particularly in dusty locations.
What temperature does Legionella grow at in a cooling tower?
The CDC gives the favorable growth range for Legionella as 77 to 113 degrees F, or 25 to 45 degrees C, which is where condenser water runs for much of the year. Sediment, biofilm, water age and a lapsed disinfectant residual all increase the risk.
What is ASHRAE 188?
ANSI/ASHRAE Standard 188-2021, Legionellosis: Risk Management for Building Water Systems, establishes minimum legionellosis risk management requirements for building water systems, including cooling towers. It calls for a water management program with identified hazards, control limits, monitoring, corrective actions and documentation. ASHRAE Guideline 12-2023 is the companion guidance.
How often should a cooling tower be tested for Legionella?
It depends on the jurisdiction and the water management plan. New York State requires Legionella sampling at intervals not exceeding 90 days while a tower operates, and New York City requires monthly sampling, no more than 31 days apart, beginning May 8, 2026. Elsewhere the CDC recommends considering Legionella testing to validate the program.
How often should a cooling tower be cleaned and disinfected?
The CDC recommends offline cleaning and disinfection at least once a year, and also before commissioning, before seasonal start-up, and after a shutdown or extended idle period. A water management plan may require more, and an out-of-limit Legionella result triggers disinfection as a corrective action.
Are cooling tower biocides regulated?
Yes. Cooling tower biocides are antimicrobial pesticides registered with the U.S. EPA under FIFRA, and the label controls how they are used. EPA issued final guidance in August 2024 on testing products for efficacy against Legionella pneumophila in cooling tower water, so check the label for a Legionella claim.
How is cooling tower corrosion measured?
With corrosion coupons: pre-weighed specimens of the system's metals mounted in a coupon rack, exposed to flowing tower water for a set period, then cleaned and reweighed to calculate a corrosion rate. Trending coupon results against chemistry shows whether the inhibitor program is protecting the metal.
Where does cooling tower blowdown go?
Usually to the sanitary sewer under the local utility's discharge permit, which applies the federal pretreatment rules in 40 CFR Part 403 and local limits. Some sites dechlorinate, adjust pH or remove solids first. Where water is scarce, blowdown can be treated, often with reverse osmosis, and reused.
Can I get a sewer credit for water evaporated by a cooling tower?
Many utilities offer one. EPA suggests asking the water utility about a sanitary sewer charge deduction for water lost to evaporation. Meters on the makeup and blowdown lines provide the evidence, since the difference between them is water that never reached the sewer.
What is the difference between open tower and closed loop cooling tower water treatment?
In an open tower the circulating water itself evaporates and needs full scale, corrosion and biological treatment. In a closed circuit fluid cooler the process fluid stays sealed inside a coil and is treated with a corrosion inhibitor and sometimes glycol, while only the spray water over the coil is treated like an open tower.
Does softening the makeup water reduce cooling tower water use?
It can, substantially. Removing calcium and magnesium lets the tower run more cycles before carbonate scale forms, and more cycles means less blowdown and less makeup. EPA recommends a softener on the makeup line where hardness is what limits cycles.
Why is scale in a cooling tower such a problem?
Scale insulates heat transfer surfaces, so a chiller condenser with scaled tubes runs at higher head pressure and uses more energy for the same cooling. It also restricts flow, shelters bacteria and corrosion underneath it, and is costly to remove once formed, requiring an inhibited acid cleaning.
What does Paul Industries do in cooling tower water treatment?
Paul Industries designs, fabricates, installs and services the cooling tower water treatment system: makeup softening and reverse osmosis, chemical feed skids, conductivity, pH and oxidizer control, blowdown assemblies, metering, side stream filtration, corrosion coupon racks and condenser water piping, working with the owner's chemical supplier and water management plan.
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