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Home My WebLink About2020-10-01; Non-testable Backflow Preventions Assemblies Update; Quiram, VickiTo the members of the: CllY COUNCIL Date '0/./'JD CA _.£_ CC V CM v ACM V DCM (3) ✓ --- Oct. 1, 2020 CMWD Board Memorandum . To: Carlsbad Municipal Water District Board of Directors From: Vicki Quiram, General Manager Via: Geoff Patnoe, Assistant Executive Manager @) Re: Non-testable Backflow Prevention Assemblies Update (carlsbad Municipal Water District Memo ID #2020202 This memorandum provides an update on non-testable backflow prevention assemblies (backflows) in the Carlsbad Municipal Water District (CMWD) potable water distribution system, which is an update to the attached June 18, 2020, CMWD Board Memorandum. Background Assembly Bill (AB) 1671, which was signed by the Governor on Oct. 6, 2017, requires that the · State Water Resources Control Board (State Board) adopt standards for backflow protection and · cross-connection control and authorizes the State Board to meet the requirement through adoption of a policy handbook. Discussion The State Board published.its intention to release the draft standards and policy handbook in summer 2020. Unfortunately, the State Board has not yet published the draft documents or updated the expected t'ime frame. Next Steps Once the draft standards and policy handbook are released, there will be two rounds of public review and comment. Staff continues to monitor the situation and will provide a follow-up memorandum when the draft documents are complete. Attachment: A. CMWD Board Memorandum dated June 18, 2020, Memo ID# 2020128 cc: Scott Chadwick, Executive Manager Celia Brewer, General Counsel Paz Gomez, Deputy City Manager, Public Works Gary Barberio, Deputy City Manager, Community Services Laura Rocha, Deputy City Manager, Administrative Services Cindie McMahon, Assistant General Counsel Robby Contreras, Assistant General Counsel David Graham, Chief Innovation Officer John Maashoff, Public Works Manager Dave Padilla, Interim District Engineer Carlsbad Municipal Water District 5950 El Camino Real I Carlsbad, CA 92008 I 760-438-2722 To the members of the: CllY COUNCIL Date6/i~/ooCA ✓ ~c ✓ CM _\L ACM y_ DCM (3) 7 June 18, 2020 CMWD Board Memorandum To: Carlsbad Municipal Water Distr From: Vicki Quiram, General Manage Via: Scott Chadwick, Executive Ma g Re: Update on Non-Testable Backfl ATTACHMENT A Ccarlsbad Municioal Water District Memo ID# 2020128 This memorandum provides information related to backflow prevention assemblies (backflows) that are non-testable in the Carlsbad Municipal Water District (CMWD) potable water distribution system. Background Backflows are mechanical piping systems that isolate CrvlWD's public water system from private onsite water systems to protect the public's water supply by mitigating cross-contamination · potential and ensuring compliance with potable water quality standards. California Code of Regulations (CCR) Title 17, section 7605, which became effective C?n June 25, 1987, and CMWD . Ordinance No. 45, which was adopted on June 2, 2009, require that backflows be tested at least annually by a certified third-party backflow tester hired by the private owner. Results would then be provided by the private owner to CMWD. · There are currently 264 backflows in CMWD's potable water distribution system that are non- . testable (i.e., are an outdated design that does not have testing ports to test that the backflow is functional). These backflows are not owned by CMWD and were installed prior to State of California and CMWD regulations implementing updated standards for backflows. Four.of these non-testable backflows belong to the city. CMWD has approximately 7,200 total backflows t 0 hat are testable and in compliance with the regulations, so less than 4% of the total backflows are non-testable. As~embly Bill (AB) 1671, which was signed by the Governor on Oct. -6, 2017, states that the bill, on or before Jan. 1, 2020, would require the State Water Resources Control Board (State Board) to adopt standards for backflow protection and cross-connection control and would authorize the State Board to do so through adoption of a policy handbook. By authorizing the State Board to adopt standards, the violation of which would be a crime, the bill would create a· new crime and impose a state-mandated local program. The State Board did not meet the Jan. 1, 2020, date. CMWD staff has been engaged with state staff to keep apprised of status. The State Board plans to release the draft standards and draft policy handb°ook in summer 2020 . . Carlsbad Municipal Water District 5950 El Camino Real I Carlsbad, CA 92008 I 760-438-2722 Carlsbad Municipal Water District Board of Directors June 18, 2020 Page 2 · Discussion This issue affects all public water agencies, including CMWD. A nearby water agency adopted an enforcement program, making it mandatory to upgrade non-testable backflows. Implementing such a program is challenging because implementation guidelines including timelines and standards have not yet been provided by the state. Within the region, water agencies are not consistent on program implementation. · Currently, CMWD Ordinance No. 45 states that if a private customer does not turn in CMWb's · annual backflow recertification form with results meeting the form's passing criteria,. CMWD shall, after three notices, terminate the water service to the affected customer. This recourse is not realistic to enforce since the water service is used for fire protection and public health, and the cost and time required to upgrade the backflow can be a significant burden to customers_. The cost of upgrading a non-testable backflow depends on the existing piping size, condition and configuration. The cost is estimated to range between $2,500 and $100,000 each with a median cost of approximately $10,000 each. · Four of the 264 non-testable backflow prevention assemblies are owned by the city, located at three facilities. CMWD is coordinating with the City of Carlsbad Facilities Division to upgrade these backflows, which are estimated to cost over $50,000 each. City staff plans to complete the work this summer or fall, depending on funding availability. The remaining 260 non-testable backflow prevention assemblies belong t<:> private businesses. These business~s will need to upgrade their assemblies, which could cost them between $2,.500 and $100,000 per system, depending on the existing piping size, condition and configuration of the assemblies. Both state law and the CMWD Ordinance require that backflows be tested at least annually by a certified third-party backflow tester hired by the private owner. All private owners must therefore comply with this state-mandated requirement. Next Steps The State Board is working to adopt new standards and a policy ha'ndbook for backflow protection and cross-connection control, as prescribed by AB 1671. As communicated through correspondence with State Board staff, the new standards and policy handbook are expected to be drafted by the State Board in late summer 2020. CMWD staff is engaged in the public review for this process. Once the State Board adopts the standards described above, CMWD will propose amendments to CMWD Ordinance No. 45 that implement the updated standards and codify a program to upgrade all non-testable backflows. Staff anticipates the new program will include a tlmeframe for compliance that gives customers time to plan for the expense and installation of a new Carlsbad Municipal Water District Board of Directors June 18, 2020 Page 3 ba_ckflow. This program will also include public outreach to educate and assist prope'rty owners on achieving compliance. Attachment: A. Photos of backflow prevention assemblies ' .. cc: Geoff Patnoe, Assistant City Manager Celia Brewer, General Counsel Paz Gomez, Deputy City M·anager, Public Works Laura Rocha, Deputy City Manager, Administrative Services · Cindie McMahon, Assistant General Counsel Robby Contreras, Assistant General Counsel David Graham, Chief Innovation Officer John Maashoff, Public Works Manager Ken Knatz, District Engineer Photos of Backf/ow Prevention Assemblies Reduced Pressure Detector Assembly ----. --.... -~: -... --;w----- Ccarlsbad Municipal Water District