Archive / News / 2009-01-12
 FDEP Proposed Residential Backflow Requirements
FROM THE FDEP
The Department of Environmental Protection is announcing it will soon begin the process of amending its current cross-connection control rules requiring backflow protection at residential premises with an auxiliary water system.
As you may know, the Department convened a technical workgroup to assist with developing recommendations for alternatives to the current requirement for a reduced-pressure principle assembly (RP) or double check valve assembly (DC) to be installed at the service connection to a residence with an auxiliary water system. A public meeting of the cross-connection control technical workgroup was held on August 7, 2008, in West Palm Beach. Based upon a careful consideration of comments received from the workgroup members and other interested parties at the public meeting, along with comments submitted since the meeting, the Department is proposing to amend the current rule requirements to allow a community water system (CWS) to choose from among a menu of backflow protection alternatives as discussed below and shown in Attachment I.
Background
Our current rules adopt the national standard of practice developed by the American Water Works Association (AWWA Manual M14), which specifies the types of backflow preventers to be used at CWS service connections depending on the types of public health hazards that may exist on customer premises.
The type of backflow preventer recommended by AWWA Manual M14 for service connections to premises with an auxiliary water system is an RP if the auxiliary water supply may be contaminated to a degree constituting a high/health hazard or a DC in other cases. This recommendation holds regardless of whether there is a known cross-connection between the customer’s potable and auxiliary water system because a CWS has little control over what happens on customers’ premises and, thus, the potable and auxiliary water systems on customers’ premises could be temporarily or permanently cross-connected at any time. These assemblies cost about $300-$600 to install and require testing at a cost of about $50-$100/year.
Proposed Revisions
After careful consideration of the comments received, we believe it would be appropriate to amend our current rules to allow a CWS to choose from among a proposed menu of backflow protection alternatives as shown in Attachment I. The proposed menu is split into two sections because auxiliary or reclaimed water systems supplied by private wells or ‘closed’ reuse systems are thought to pose a lower risk than those systems supplied by surface water or ‘open’ reuse systems.
Under each section of the menu, a CWS may select from among three different types of backflow preventers—an RP, a DC, or a dual check device—plus additional measures depending on the type of backflow preventer selected. For example, in Section A, at service connections to residential premises with an auxiliary water system supplied by a private well, a CWS may choose to require the use of either an RP or a DC, or may choose to allow the use of a dual check device together with another measure such as automated meter reading. Under Section B, connections to properties using stormwater for irrigation would install either an RP, a DC with one additional protective measure, or a dual check device with two additional protective measures. Regardless of the pathway selected, public education of residents about potential public health problems associated with cross-connections should be an element of every cross-connection control program.
You may find the following information about RPs, DCs, and dual check devices helpful in understanding the basis for Attachment I:
An RP or reduced-pressure principle assembly is a mechanical backflow preventer that includes two independently acting check valves with a mechanically independent pressure-differential relief valve located between the check valves. It also includes a shutoff valve at each end of the assembly and test connections so that it can be tested to verify whether it is working properly. It is considered more protective than a DC or dual check device; but it must be installed aboveground so that the relief valve cannot be submerged (which could allow contaminants to enter the RP), and it costs about $500-$600 to install and should be tested annually at a cost of about $50-$100 per year.
A DC or double check valve assembly is a mechanical backflow preventer that includes two independently acting check valves. It also includes a shutoff valve at each end of the assembly and test connections so that it can be tested to verify whether it is working properly. It is considered less protective than an RP and more protective than a dual check device; and it costs about $300-$400 to install and should be tested annually at a cost of about $50-$100 per year.
A dual check device is a mechanical backflow preventer that is similar to a DC in that it includes two independently acting check valves. However, it usually does not include shutoff valves or test connections and, thus, usually cannot be tested in-line to verify whether it is operating properly. It is considered less protective than an RP or DC; but it costs only about $100-$200 to install or less if it is installed together with a meter.
The Department feels that the menu of alternatives in Attachment I will provide commensurate public health protection and will offer CWSs flexibility and potential cost savings.
Next Steps
The Department will soon begin the formal process of amending its cross-connection control rules through publication of a Notice of Rule Development in the Florida Administrative Weekly (FAW). We plan to schedule a public workshop on the proposed revisions in February in the Orlando area. Both the FAW notice and the workshop are early steps in the rulemaking process.
We would appreciate receiving any comments you may have on the proposed revisions discussed above and in Attachment I. Comments should be submitted by January 15, 2009, to Dan Peterson so they can be taken into consideration before the public workshop.
Additional Information
Future notices and information on this rulemaking will be available on the Department’s Internet site at: http://www.dep.state.fl.us/water/rules_dr.htm#wasteFuture waste.
Also included as Attachment II is a form for you to fill out and return to us if you want to be placed on the mailing list for this rulemaking. If you have questions about the proposed rulemaking, please contact Dan Peterson at:
Dan Peterson
Department of Environmental Protection
Drinking Water Section, MS 3520
2600 Blair Stone Road
Tallahassee, Florida 32399-2400
E-mail: Daniel.Peterson@dep.state.fl.us
Telephone: (850) 245-8623
FAX: (850) 245-8669
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