Hanover County Fire-EMS supports initiatives aimed to increase the safety of the community to include safeguards from water contamination.  Consumers yield to the Utility and the regulatory authority to establish comprehensive laws that do not increase known risks.  Although 15 VAC5-59-1170 – Hydrants is intended to increase safety, the proposed language change decreases safety by increasing system failure.  Not to mention, a decrease in reliability and in overall increase in maintenance. 

The proposed language requires the Utility to either remove, relocate, or prevent contaminants from entering the water system by plugging the hydrants’ drain valve.  In many cases, removal or relocation is not an option as it may affect system maintenance or even service demand by emergency responders. Moreover, plugging of drain valve has an increased risk to the system.  Drain valve are engineered on dry barrel hydrants to protect the system and improve reliability during freezing conditions by allowing the hydrant drain.  Thus, returning the hydrant to its native “dry” barrel.  If the drain valve is plugged, water will remain in the barrel which will create an environment to freeze during winter months.

Another consequence to plugging the drain valve is the increase maintenance demand.  The maintenance demand will increase as plugged hydrants will need to be pumped out after each use to prevent freezing.  Currently, the drain valve is engineered as a self-maintaining feature that allows for automatic water drainage.  Inevitability, the increased maintenance cost will be passed to the consumer.  Furthermore, drain holes are designed to be located on the dry side of the main valve.  Therefore, decreasing the risk of contaminants entering the water system. 

In conclusion, Hanover County Fire-EMS does not support the proposed language change to 15 VAC5-59-1170 – Hydrants.  The proposed language change creates an unsafe environment by circumventing an engineered feature designed to maintain reliability in all environments.  Thus, decreasing the reliability and unnecessarily increasing the risk to the community.  Hanover County Fire-EMS echo’s the recommended language to read: “Where hydrant drains are not plugged, they shall be drained to the ground surface or to subsurface stone filled wells or other engineered solutions provided for this purpose”.

Respectfully,

Jethro H. Piland, III, Fire Chief

Christopher J. Anderson, Chief Fire Marshal