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