17-0712 v3.1/PVC in Cooling Tower Heat Exchange Medium


Our project includes an open cooling tower in which PVC is used for the fill, or heat exchange medium. The fill is a major component of the cooling tower, in contrast with a small gasket or valve. However, given that the fill is a honeycomb-like structure composed primarily of air, PVC represents less than 10% of the assembly by weight or volume. Does this meet the letter and intent of the Small Mechanical Components Exception?  Please note, the entire cooling tower arrives to site as a single unit, so the fill isn't a separately procured product that is assembled as part of the cooling tower on site.


The cooling tower fill appears to be an unavoidable ingredient in the product, but based on its large scale, is not a "small component" as intended by Exception I10-E2. If the team is unable to eliminate the cooling tower from the project, and cannot, through due diligence, find another cooling tower that meets the project requirements without PVC, exception I10-E1 General Red List can be used for the PVC fill. 

Post ID 6583

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