history of california indoor dual plumbed codes and regulations
DESCRIPTION
Presentation from the San Diego County Water Authority’s workshop on Recycled Water and Dual Plumbing - Nov. 2010TRANSCRIPT
Toby RoyNovember 9, 2010
1991 - Critical Mass for Recycling
There is nothing like a drought to facilitate intelligent water resource planning Although there were a
few dual plumbed systems for toilet flushing, there was no regulatory paradigm
Water Use in Office Buildings
80% of water used in an office building is for toilet flushing 10% for HVAC cooling
tower 10% potable uses Dual plumbing costs
9% more than conventional plumbing
Jamboree Tower in Irvine
Four year effort to get approval
IRWD first regulatory approvals for dual plumbing in 1991
Prototype designed to create foolproof system
1991 - Marin County Jail
Drought and building moratorium in place Only water available
for proposed new 330-bed jail was recycled water County was nervous
about another lawsuit from jail inmates
Birth of AB 1698
MMWD sponsored with Bill Filante in 1991 Facilitated dual plumbing statewide and
eased concerns about lawsuits Declares that use of potable water for toilet
flushing is a waste if recycled water of adequate quality is available Empowers public agencies to require dual
plumbing in new construction
Marin Jail Architect Refused to Design Dual Plumbing
With no codes and standards, architect for the Marin Jail refused to design dual plumbing system So MMWD hired a consulting engineer to do the
job on behalf of the County Design followed IRWD approach at Jamboree
Tower No problems. No lawsuits.
Regulatory Framework
Legislation requires adoption of regulations/standards Recycled Water regulated by Title 22 CDPH sets standards/regulations Regional Board permits use
Indoor plumbing standards State Agency proposal IAPMO proposed standards California Building Standards Commission sets standards Regulatory authority enforcement
1992 California Ad Hoc Dual Plumbing Committee
Co-chaired by DWR and DHS, IAPMO input Intent to develop dual plumbing code Gov. Pete Wilson as directing state agencies to: “Ensure that new development make maximum use of
recycled water.” “Remove obstacles to reclamation activities.” “Create a streamlined process for the construction and
operation of both public and private reclamation facilities.”
Concerns Expressed in Ad Hoc Dual Plumbing Committee
Plumbing and Health Officials were uncertain if reclaimed water was suitable for toilet flushing Concern about children playing in toilets and
“catching something” Who would regulate dual plumbing? Subcommittee formed to create draft language
Tertiary Water Suitability for Toilet Flushing
CA tertiary water is virus free
MMWD bacterial testing of potable water in “clean” toilet bowls: No Big Surprise -- 50% of samples tested positive for Fecal Coliform bacteria
Toilets Pollute the Recycled Water
1994 – Uniform Plumbing Code (UPC)
UPC Appendix G for gray water UPC Appendix J for recycled water Sponsored by the DWR, Appendix G was adopted
into California Plumbing Code. For some reason, Appendix J was never adopted
by California!
Signs Required in Restrooms
Much discussion about language on signs and where to locate.
Fear of Cross Connections
Almost all cross connections occur because of unmarked pipe. Dual plumbing for recycled water has a
comprehensive marking system. Recycled water is held to a far more severe standard
than other piping. Embarrassed, the 1997 UPC now requires simple
labels for other piping systems.
1996 – Draft Title 22 Amendments
DHS wanted to restrict dual-plumbing to office buildings only.
Stated that legislative intent of AB1698 was unclear.
1997: WateReuse sponsored legislation to specifically enable: “commercial, retail, and office buildings, theaters, auditoriums, schools, hotels, apartments, barracks, dormitories, jails, prisons, reformatories, and other structures as determined by the DHS”
2000 – Title 22 Amendments
DHS updated to enable other types of structures
Prohibits “individually-owned residential units including free-standing structures, multiplexes, or condominiums.”
Prohibits use in facility that “produces or processes food products or beverages.”
Except that “cafeterias or snack bars in a facility whose primary function does not involve the production or processing of foods” is OK.
2001 – Recycled Water Task Force Formed
Created by legislation sponsored by WateReuse to look at obstacles and impediments to recycled water
Make recommendations to Legislature
Develop code language for the California Plumbing Code to replace Appendix J of the Uniform Plumbing Code
2003 - Task Force Plumbing Code
Cross Connection and Plumbing Code Sub-Committee co-chaired by Bob Hultquist and Bob Castle
Developed improvements to UPC Appendix J
Relaxed testing requirements for dual-plumbing
DHS has followed through with draft amendments to Titles 17 and 22 (December 8, 2005 still in draft)
Make recommendations to Legislature
Develop code language for the California Plumbing Code to replace Appendix J of the Uniform Plumbing Code
State Agency Needed to Submit Building Code Language
In 2004, DWR legal counsel decided they didn’t have to sponsor code changes.
In 2005, AB371 required DWR to act, if funds were budgeted.
2008 deadline came and went……
Graywater Legislation
Lowenthal: SB 1258 (2008) Housing and Community Development shall
develop standards for residential graywater use for adoption by the Building Standards Commission
2009 – DWR Finally Steps Up
In February 2009, HCD started development of graywater code
In late April 2009, DWR agrees to sponsor dual plumbing code development
Indoor Dual Plumbed Standards for Graywater
On-site treatment system approved by the enforcing agency. Title 22 tertiary quality (NSF and IAPMO proposing
standards) Must meet the same installation
and testing as recycled Tank sized to minimize storage
time Manual located on site
22
Elements of the 2011 California Plumbing Code for Recycled
Water
Consistent with California regulations Reduce unreasonable obstacles Embrace reasonable safeguards Relax unnecessary testing
Features of the New California Plumbing Code
Using recycled water to flush toilets and urinals is no longer at the whim of the local building official.
Recycled water quality criteria governed by the California DPH “statewide uniform criteria”
Features of the New California Plumbing Code
Installation: 10 foot separation of potable, sewage, and recycled water deleted. Routing: Requirement to install in separate wall
and ceiling spaces has been deleted. Installation is now same as UPC and CPC as for
other potable and non-potable piping.
Features of the New California Plumbing Code
Signs: Signs in each public restroom, equipment rooms, and in each valve access door. New Sign: Inside of tank-type toilets to warn that
water in tank is not a suitable emergency supply. Valve Seals: Same as before. Plastic break-away
seals on all valves.
Features of the New California Plumbing Code
Inspection and Testing: Annual visual inspection and testing per Title 22 (4 years) “Alternate inspection and testing requirements may
be allowed….. For residential, institutional or industrial buildings where shutting off the water is not practical.”
Title 17 and 22 Amendments Still a work in Progress
Task Force proceedings pointed out that shut-down testing is infeasible and unnecessary for many situations.
CA DPH draft amendments to Title 22 would eliminate testing if “the public water system or recycled water agency can document that there have been no plumbing changes in the dual-plumbed system”.
California Plumbing Code Effective Date: January 1, 2011
19 years for California to go from committee to officially-adopted building code
Persistence wins in the end
Next Evolution
Updates to Title 22 and Title 17 per Task Force recommendations Lowenthal SB 518: Graywater standards for non-
residential structures IAPMO recommendations on standards for all dual
plumbed recommendations regardless of source of non-potable