To: Honorable Mayor and Members of Town Council
From: Mark Marlowe, P.E., Director of Castle Rock Water
Title
Update: Water Quality Protection for Residential Fire Sprinkler Systems
Body
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Executive Summary
We have around 120 plus residential customer accounts with dedicated fire suppression lines. These lines have been required for certain residential homes due to a host of factors (home size, location, etc.) because of the inability to cost effectively get adequate fire flow from fire hydrants located on the street to these homes.
Certain classes of fire line systems can contain chemicals or be designed in such a manner that there is the potential to contaminate the water distribution system as well as the customers’ internal drinking water plumbing if a cross connection control device is not in place and working properly. Colorado Department of Public Health and Environment (CDPHE) has mandated that each municipality providing water service have a Backflow Prevention and Cross Connection Control program. The Town has such a program, and as such, is required to ensure that cross connection control devices are installed, tested annually, and maintained for these fire service lines.
Staff will need to begin a process of reaching out to its customers for the purpose of identifying what kind of system the customer has and then depending on system type educating them on the requirements to test and maintain a cross connection control device. For customers with high hazard systems, annual testing of their backflow prevention device is required and could cost these customers anywhere from $50 to $150 annually. Protection of the public health and the water distribution system requires this testing be done.
Discussion
In 1992, the Town adopted an ordinance and subsequently implemented a cross connection control program manual. From that time forward, all new service connections (residential and commercial) to the water distribution system have been required to install backflow prevention assemblies. The type of backflow device is commensurate to the degree of hazard presented to the system by the service connection.
In January of 2016, an update to State Regulation 11.39 Backflow Prevention and Cross Connection Control Rule went into effect requiring all water providers to have a written backflow program which outlines their processes for surveying, installing, maintaining and testing of devices installed within their water system. Water providers were given until 2020 to show 100 percent compliance. As of December 31, 2016, Castle Rock Water achieved 100 percent compliance with the required annual testing and 95 percent compliance with the surveying of all commercial backflow devices. We should get to 100 percent compliance on the survey work well before the deadline. As part of the survey work and ultimately the annual testing requirement, Section 11.39(3)(c)(ii) of the rule requires water providers that are aware of single family residential connections with fire suppression systems, which are cross connections by definition, to survey those systems and ensure the appropriate backflow devices are in place and being tested and maintained. Additional descriptions of residential cross connections requiring survey are taken directly from the rule below:
Chapter 4.4, Section C
For single-family residential connections
There are types of cross connections at single-family-residential connections that may pose a greater risk than those addressed by local plumbing codes enforced by the local jurisdiction authority. These include but are not limited to:
i. Dedicated irrigation lines (from the water main);
ii. Dedicated fire suppression system lines and chemically enhanced fire suppression systems;
iii. Multi-purpose fire suppression systems are not required to be controlled where each branch of the suppression system terminates at a regularly used fixture;
iv. Auxiliary water sources (e.g. wells, ponds, lagoons, irrigation ditches), hot tubs or swimming pools piped with permanent plumbing, reclaimed water systems, gray water systems, or onsite water storage tanks with permanent plumbing; and
v. Connections to a home’s potable water supply system from home business and hobbies including but not limited to agricultural commerce and hydroponic systems, doctor’s offices, photo laboratories, hide tanning operations, and metal plating operations.
Castle Rock Water is aware of a significant number of single family residential customers which have fire suppression systems. Some of these systems (Class V and VI systems specifically) contain alternate water supplies and / or chemicals that pose a high hazard to the distribution system. Castle Rock Water needs to survey these customer systems and identify those that pose a high hazard to the distribution system and ensure those customers have the appropriate backflow prevention and are doing the correct annual testing.
Each of these customers will be contacted by telephone to set up appointments to explain the requirements on a one-to-one basis. We wanted you to be aware of these requirements and this effort in case you get questions from these customers.
History of Past Town Council, Boards & Commissions, or Other Discussions
Staff updated the Castle Rock Water Commission regarding the potential need to annually test some residential backflow preventers or certain types of fire suppression systems on April 26, 2017.
Budget Impact
Castle Rock Water has a staff member that is dedicated to our cross connection control program.
The Cross Connection Control Technician will do this outreach. This work can be handled within the existing budget for the cross connection control program.