PART 2 - COMMENTS BY THE VIRGINIA CHAPTER OF THE AMERICAN BACKFLOW PREVENTION ASSOCIATION

12VAC5-590 Definitions, concerns and recommendations:

1. Add definition: “ASSE” means American Society of Sanitary Engineering.
2. “Backflow Prevention Assembly” CONCERNS:  The definition oversimplifies and makes assemblies seem equivalent for all backflow conditions, but they are designed to control specific cross-connections; industry-accepted nomenclature and abbreviations should be used for all assemblies herein; and gate valves are no longer universally used on DCVA’s. 
   1. RECOMMENDATION: Rephrase: “Backflow prevention assembly” means a mechanical unit designed to control various cross-connections and stop the reversal of flow, that includes an inlet and outlet shutoff valve and test cocks to facilitate testing of the assembly.  Backflow prevention assemblies include the reduced pressure principle or reduced pressure zone (or RPZ) assembly, the double check valve (or DCVA) assembly, and the pressure vacuum breaker (or PVB) assembly.
3. “Backflow Prevention Device”  CONCERNS are like those noted above, and verbiage should include important limitations.
   1. RECOMMENDATION: Rephrase: “Backflow prevention device" means  a mechanical unit designed to control cross-connections and stop the reversal of flow, that is not testable because it does not have inlet and outlet shutoff valves or test cocks. A backflow prevention device is not generally designed or constructed to withstand backpressure, or continuous pressure over 12 hours, or to control high hazards. A backflow prevention device generally includes atmospheric type vacuum breakers and the dual check valve type devices.

4. Add definition: “CCCP” means Cross-Connection Control Program.

5. “Cross-connection”:  After “contamination” add “or pollution” for consistency.

6. “Double gate-double check valve assembly”  CONCERNS are like those noted for assemblies; gate valves are not universally used; “pet cocks” are actually “test cocks”; “test gauges” are not part of the assembly, and are used to test water-tightness and differential pressure, but no other assembly definition has such verbiage.
   1. Recommendation: Rephrase, for example: “"Double check valve assembly" (or DCVA) means an assembly composed of two single independently acting check valves including tightly closing shutoff valves located at each end of the assembly and test cocks to facilitate testing of the assembly.”

7. “Pressure Vacuum Breaker Assembly”:  CONCERNS are like those noted above.
   2. RECOMMENDATION: Add “(or PVB)” and the phrase “to facilitate testing of the assembly.” 

8. “Reduced pressure principle backflow prevention assembly”:  CONCERNS are like those above.
   3. RECOMMENDATIONS: After “principle” add the phrase “or reduced pressure zone” and add “(or RPZ)”; and add “to facilitate testing of the assembly” at the end of the definition.

9. “Service connection”  CONCERNS: the definition lacks examples where the waterworks generally ends.  The phrase “and to all other points where finished water is delivered…to a consumer” seems to extend the waterworks beyond the actual service to all fixtures in the building. Many of the proposed regulations assume and rely on a clear definition of “service connection.” Eliminating verbiage referring to the meter or distribution main is inadvisable, and goes against the USBC (see 2015 VPC definition of “Water Service Pipe”) and the Memorandum of Agreement of 2013 between VDH & DHCD, Item 2, which states the USBC governs all buildings, structures and equipment up to the point of connection to the water meter or to the waterworks main.  But flexibility is needed when exceptions exist.  The proposed regulations should uphold these general distinctions, while retaining jurisdictional flexibility for containment backflow preventers installed downstream of a service connection, as approved by the owner. 
   4. RECOMMENDATION: Rephrase:  "Service connection" means the point of delivery of finished water from a waterworks to a consumer's water system.  Generally, the service connection occurs at the water meter, or at the distribution main if no water meter is installed, but may extend to a consumer’s water system, fire protection system, or irrigation system and to all other points where finished water is delivered through the distribution system to a consumer’s system.  Service connections may be permanent, temporary, or emergency. 

10. MISSING DEFINITION: “Service line” CONCERN: Undefined terms present a loophole for interpretation and lawsuits.  12VAC5-590-55 B refers directly to “water service piping from the service connection” identifying a service line, and 12VAC5-590-360 B and C refer directly to the “service line” as do many other of these regulations; and “service pipe” is used by the USBC.
    5. RECOMMENDATION: add a definition, for example: “’Service Line’ means the pipeline or service pipe between the service connection and the building connection.”

11. Add definition: “USC” means the University of Southern California Foundation for Cross-Connection Control and Hydraulic Research.”

12. “Waterworks”  CONCERN: As noted in “service connection” above, the phrasing “except inside the building where such water is delivered” extends the waterworks up to the building in all cases, rather than as an exception, conflicting with 12VAC5-590-55-B, the USBC, and the Memorandum of Agreement of 2013 between VDH & DHCD.  The waterworks should be clearly defined as stopping at the service connection. 
    6. RECOMMENDATION: rephrase by ending the definition with: “…and distribution of potable water up to the service connection.”  

REFERENCE MATERIALS: 

While training and experience for CCCP personnel is a needed addition to the regulations, the department should direct owners to authoritative resources, to aid in development and implementation of the CCCP.  We recommend incorporating VDH documents by way of reference, and including the others recommended below on a “Suggested Reference Materials” list or as an Appendix:     

1. VDH - Working Memo 801 (WTR-801) – This document contains invaluable commentary and experience in backflow prevention and issues that impact CCCPs.  Some information is outdated due to regulatory and USBC changes, however most of its content remains applicable and valid.  WTR-801 and any future revisions should be incorporated by way of reference, and included in any suggested reference materials list. 
2. VDH – Effective Cross Connection Control Programs (current and future revisions).  This “Hip Pocket Tool for Operators” also contains valuable information and experience concerning backflow prevention.  Like WTR-801, it contains some outdated information, but much of it is practical and useful for CCCPs.  It and any future revisions should be incorporated by way of reference, and included in any suggested reference material list. 
3. M-14 Backflow Prevention and Cross-Connection Control: Recommended Practices (4^th and subsequent editions) by the American Water Works Association (AWWA).  These regulations incorporate many AWWA standards, and including Manual-14 is appropriate, as it provides practical general and technical guidance for CCCPs. 
4. Backflow Prevention Theory and Practice (3rd and subsequent editions) by the University of Florida TREEO Center (UF-TREEO).  Like AWWA M-14, UF-TREEO provides practical general and technical guidance for CCCPs.
5. Manual of Cross -Connection Control (10^th and subsequent editions) by the University of Southern California Foundation for Cross-Connection Control and Hydraulic Research (USC).  Like AWWA M-14, USC provides practical general and technical guidance for CCCPs.