Good Afternoon, I would like to address GM Loupassi's petition request that the State Board of Health to amend the regulations governing corss connection control and backflow prevention, contained in Virginia's Waterworks Regulations.

I am a licensed backflow device worker.  By years end, I will have tested over 400 backflow devices.  Of those 400 about 5% have failed and had to either be repaired or replaced.  My company contracts with the customer before the backflow device is tested to let them know how their backflow is testing before I leave the premises.  All of our customers have come into compliance with repairs and replacements, once the seriousness of a bad backflow is explained to them. 

The life expectancy of a backflow is between 5 - 10 years.  They are composed of metal springs, plastic parts and rubber seals, brass covers.  The life of the backflow also depends on location.  One that is kept out of the weather in a crawl space may last longer than one that day after day is subject to hot summers and cold winters, rain and snow.  One of the most important things that helps the longevity of the backflow is winterization. 

I was suprised to read in the petition that lawn irrigation sprinkler systems were considered by the petitioner a "low risk connection".  The reason Chesterfield County only allows RPZ and PVB backflow preventers to be installed in irrigation systems is because a lawn irrigation sprinkler system is a high risk connection.  A lawn irrigation sprinkler system is tied into the main of the home, unless a companion meter is installed on the line.  Lawns are fertilized, pesticides are put down, and then watered in.  Sprinkler heads work with water pressure.  Once the controller has told the valve to shut down fluid pressure is stopped and the head is sucked back down into the turf taking whatever is in the immediate vicinity with it.  That water should be contained by a properly maintained  backflow device.  In the event of a water main break or large fire in an area, the possibility of backsiphonage through a improperly working backflow could bring all of the undesirable chemicals in the lawn into the drinking water of a home.

What I have found as a tester and a business person is that what upsets people the most is not that they have to have their backflows tested but their neighbor does not come into compliance as they have done.  This frustrates the homeowner who is trying to do the right thing.  Unfortunately, at this point, there is no real penalty for not coming into compliance.  As for the "onerous burden", backflow testing can run from $25 to $125.  Usually people who have lawn irrigation sprinkler systems are aware of the service that is required to keep them functioning correctly.

Backflow Prevention is important to the health and welfare of all who drink public water.  I commend Chesterfield County for taking the initiative to make testing annual and caring enough about their populace to enact efforts to protect them.

Respectfully,

Michelle Wilkerson

President, Virginia Irrigation Association

The requirement and enforcement of annual inspection on back flow preventers is an unnecessary financial burden for homeowners when there is almost no risk.  For instance without the enforcement of the annual inspection there have not been, to my knowledge any incident in Chesterfield County of a back flow preventer failing.

The Chesterfield County Director of Utilities states the risk of contamination is low from private homes.

Please change the regulation by removing the requirement for an annual inspection of back flow preventers on private homes.

As a water purveyor I am amazed by the proposed petition to lower the testing frequency. This is a critical part of a water purveyors opertaions and responsibility . One back flow can result in contamination of  the system resulting in violations and possible health risks. We have a duty to our customers to make sure they are protected and recieve safe water. The cost associated with the test is well worth the trouble.

 October 13, 2011

In response to petitioner GM Loupassi’s request that the State Board of Health amend the Virginia Waterworks regulations governing backflow prevention and cross connection control, I offer the following comments.

As the water purveyor for the City of Virginia Beach, citizens’ safety and confidence in the public water supply system are Public Utilities’ biggest concerns.  First, I would like to address the petitioner’s reference to irrigation systems being at a “low risk of contamination” to the water system.  There are two key possibilities that would induce contamination from an irrigation system; at the time the system is shut off and/or if there is a reduction in pressure in the public waterline.   When irrigation systems are turned off, a vacuum is created thereby pulling whatever elements and contaminates are present into the irrigation piping. This introduces the possibility of not only chemical fertilizers and pesticides but also parasites, animal feces, and water borne virus invading the citizen’s home or drinking water system.  When a water main break or fire hydrant is in use, a drop in main line pressure occurs creating a backsiphonage throughout the water system. If a backflow device is not installed or if it is not working properly, these contaminants can enter the public drinking water system. A properly working backflow device can protect the citizen and the system from contamination.  Due to these possibilities, irrigation systems are considered high risk hazards and require a testable backflow prevention device, a reduced pressure device, or a pressure vacuum breaker to be installed.

The following is a list of contamination incidences due to improperly working irrigation backflow prevention devices¹:  (¹www.nobackflow.com/pnw-awwa.htm)

·         1991 Michigan - Two homeowners found parasitic worms, or nematodes, in their water. One homeowner found the worms swimming around in his bathtub when he started filling the tub for his child. He also found rust and other debris in his water. The Wayne County Health Department determined that water had backflowed through a residential irrigation system into the public water system.

·         1969 Connecticut - University football team members stricken with infectious hepatitis through irrigation water backsiphonage.

·         1976 Texas - A faulty DCVA permitted lake water to be pumped through an irrigation system into the public water supply.

·         1979 Arizona - An outbreak of diarrheal illness in campground residents resulted from a cross connection with an irrigation system containing sewage effluent.

·         1982 Oregon - Backflow though an irrigation hose resulted in insect larvae entering a food processing vat.

·         1985 Washington - A cross connection with an irrigation system resulted in the pesticide contamination of a well supplying four residences.

·         1988 Arizona - An interconnection between an irrigation system and a decorative pond may have resulted in non-potable water being pumped into the public water system.

·         1995 Washington – A cross connection permitted untreated irrigation water to flow into domestic water lines causing 11 cases of giardiasis

Backflow devices are mechanical devices and can fail for many reasons. The majority of the residential irrigation devices in our jurisdiction are located outside and are exposed not only to all the natural elements and weather occurrences but also physical damage from lawn maintenance equipment and other machinery. As such, these devices are the most common to fail or need repair.

The City of Virginia Beach has a vigorous backflow and cross control prevention program and tracks the testing of all recorded backflow devices. Notification letters are mailed in advance of the testing due date and followed through with each device to ensure they are in compliance with ASSE Guidelines, AWWA, USC Cross Connection Control Foundation, Virginia Waterworks Regulations and the Virginia Maintenance Code Section 505. There are several reasons behind the need for annual testing and include:

·         Assurance that the device is working properly

·         Assurance that the device has not been by-passed

·         Assurance that the device has not been removed

·         Assure that the internal checks have not been removed to increase line pressure

 We are privileged to have one of the safest drinking water systems in the world and people take for granted that they can drink straight from the faucet in the United States; people in other countries including Europe are not so lucky.  This is due in large part to the water regulations that are in place and should remain in place. Waterworks regulations are used to provide for the health, safety and welfare for all citizens and should not be tailored to meet the desires of one specific group.

For the above reasons, the City of Virginia Beach does not support changing the annual testing requirement for backflow devices associated with irrigation systems.  If you have any questions or would like to discuss further, please do not hesitate to contact me at (757) 385-8654 or via email at tleahy@vbgov.com.

With pride in our city,

Thomas M. Leahy, III, P.E.

Director of Public Utilities

Please consider a formal study to quantify the actual rate of contamination from faulty backflow preventers at private homes in Virginia to verify the degree of the problem and most reasonable solution.

As a tester for these devices we feel the inspection schedule is at a minimum now, these devices are very important to the life safety for the citizens in any given area.  This seems a simple task that has no negative consequences, but anyone who would look into what has and could happen if back flow did occur on a domestic water supply system. Please when considering this change use your time to understand these safety devise’s,  what they protect the citizen from, consider the lives that it could/will affect should the unimaginable happen.

This letter is to communicate my support of  Delegate Loupassi’s request that the State Board of Health reconsider its regulations overseeing Cross Connection Control and Backflow Prevention in Waterworks. Over the past few months, I have had constituents approach me regarding their concern for what they view as an unnecessary and costly burden. In Chesterfield County alone, around 14,000 homeowners have irrigation systems installed on their property. At the tune of $50 per inspection, per year, the total cost is $700,000; a figure that greatly exceeds the total figure paid for any “incident related” cleanup in the state, in the last several decades.