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HomeMy WebLinkAbout2022-12-15; Non-testable Backflow Prevention Assemblies Update (Districts - All); Gomez, PazTo the members of the: CITY COUNCIL Date 12/15/22 CA ✓ CC ✓ CM ✓ACM ✓ DCM (3) ✓ Carlsbad Municipal Water District Memo ID# 2022121 CMWD Board Memorandum December 15, 2022 To: Carlsbad Municipal Water District Board of Directors From: Paz Gomez, Deputy City Manager Public Works Vicki Quiram, General Manager Via: Scott Chadwick, Executive Manager Re: Non-testable Backflow Prevention Assemblies Update (Districts - All) This memorandum provides an update on a previous Carlsbad Municipal Water District (CMWD) Board Memorandum dated June 3, 2021, regarding privately owned backflow prevention assemblies in the CMWD potable water distribution system that are non-testable and therefore not compliant with state requirements. Background Assembly Bill 1671, which the Governor signed on October 6, 2017, requires the State Water Resources Control Board (State Board) to revise standards for backflow protection and cross- connection control and authorizes the State Board to do so through adoption of a policy handbook. The proposed Cross-Connection Control Policy Handbook (handbook) is intended to replace the Code of California Regulations Title 17 requirements to allow for more timely updates. Backflow prevention assemblies are valve and piping assemblies that prevent back siphonage of water and potential pollutants and contaminants from private water services into the public water system, thereby protecting the public water supply. Because of the potential health risk to water systems if a backflow event occurs, both state law and CMWD ordinance require that backflow prevention assemblies be tested annually. Approximately 7,200 total backflow prevention assemblies within CMWD's service area are testable and in compliance with regulations. In CMWD's service area, there are currently 239 known backflow prevention assemblies (owned by 181 CMWD customers) on fire protection systems that are non-testable and therefore not in compliance with state regulations or CMWD Ordinance No. 47. A white paper on non-testable backflow prevention assemblies dated June 28, 2022, is provided as Attachment A, which includes the CMWD Board Memorandum dated June 3, 2021, and earlier memoranda on the subject. Carlsbad Municipal Water District 5950 El Camino Real I Carlsbad, CA 92008 I 442-339-2722 t Board Memo - Non-testable Backflow Prevention Assemblies Update (Districts - All) December 15, 2022 Page 2 Discussion On November 2, 2022, the State Board released a second draft of the handbook and solicited comments on this revised draft through December 9, 2022. In summary, the changes included more detail in the six elements contained in Title 17 cross-connection regulations and the addition of four new elements including: • more specific requirement for cross-connection certified testers and specialists • more specific and immediate incident response • requirements for public outreach • required local entity coordination In addition to these changes that the State Board highlighted, the CMWD staff noted that a compliance t ime frame of 10 years to replace non-testable backflow preventions assemblies on fire protection systems was added to the text. On December 5, 2022, a public hearing was held during which the State Board provided a brief presentation of the revised document and allowed for public comments. Several of the regional water organizations and agencies provided verbal comments inclusive of requesting: • a technical advisory committee be formed to work with State Board staff on further revisions and implementation of the handbook • the State Board's technical staff report be included in the handbook as an appendix • a template and guidance for cross-connection control plans to assist in statewide consistency The following background and regulatory timeline for the proposed handbook is provided: • January 1, 2020 - Regulatory deadline for completion of the handbook • Summer 2020 - The State Board published its intent to release a draft handbook • February 26, 2021 - The State Board published a preliminary draft handbook • February 26, 2021-April 27, 2021 - The State Board requested public comments on draft handbook • April 26, 2021 - The CMWD staff submitted written comments in concert with local suppliers via the Technical/Field Regional Advisory Group, as a separate agency, and as a member of the San Diego County Water Authority • April 27, 2021 - The State Board hosted a virtual public hearing to receive verbal comments on the draft handbook • November 2, 2022 - The State Board released a second draft of the handbook • December 5, 2022 - The State Board hosted a second public hearing • December 9, 2022 - Close of the public comment period on the draft handbook • Mid to late 2023 - The State Board anticipates adoption of the handbook Board Memo - Non-testable Backflow Prevention Assemblies Update (Districts - All) December 15, 2022 Page 3 Following adoption of the handbook, water suppliers will have one year to make necessary administrative changes to their cross-connection control programs, including the new requirement for development of a local cross-connection control program that will include additional requirements to comply with the State Board regulations. In absence of the anticipated handbook, the CMWD staff continue to work on getting non- testable assemblies replaced to protect the CMWD water supply system and comply with Ordinance No. 47. Staff have completed a detailed inventory update for sending CMWD notices to device owners who need to replace non-testable backflow prevention assemblies. The inventory update will also assist in prioritization of device replacement based on location, risk of failure and operational shutdowns for replacement. Replacement of the four city-owned non-testable assemblies was completed in 2021. Additionally, other private devices have been replaced as ancillary to the CMWD capital improvement program projects. Of the 264 non-testable assemblies that were initially identified in the Board Memo dated June 18, 2020, replacements, inventory updates and field verifications have decreased the current number of non-testable assemblies that still need to be addressed to 239. Ongoing CMWD plan review for proposed land development projects have also identified non-testable devices for which the CMWD is requiring their replacement. Those assemblies are included in the total current number of 239. The CMWD staff have been coordinating with other city departments/divisions including the Building Division, Land Development Engineering Division and Fire Inspection Division to facilitate communication and coordinated review once notification letters are sent to customers that own these non-compliant backflow prevention assemblies. Because these devices are located on fire service lines upstream of fire protection systems, the private owners must ensure the new assembly does not reduce the flow of water to their fire system. This requires hydraulic flow calculations and must be reviewed and approved by the city's fire inspection staff. Staff are also drafting edits to the cross-connection control language in Ordinance No. 47 and will bring an ordinance update to the CMWD Board in 2023 to align with anticipated handbook requirements and provide a realistic timeline for the steps necessary to replace non-compliant assemblies. Next Steps Staff will continue to participate in the Technical/Field Regional Advisory Group and comment collectively on any future drafts of the handbook. Staff will continue to track the regulatory process and timeline for handbook revision and eventual adoption, which is anticipated to be in mid to late 2023. Staff will continue to provide updates to the Board as additional information becomes available. Board Memo - Non-testable Backflow Prevention Assemblies Update (Districts - All) December 15, 2022 Page 4 Attachment: A. White Paper on Non-testable Backflow Prevention Assemblies dated June 28, 2022 cc: Geoff Patnoe, Assistant Executive Manager Cindie McMahon, General Counsel Ron Kemp, Senior Assistant General Counsel Gary Barberio, Deputy City Manager, Community Services Laura Rocha, Deputy City Manager, Administrative Services Michael Calderwood, Fire Chief Jeff Murphy, Community Development Director Kristina Ray, Communication & Engagement Director John Maashoff, Public Works Manager Randy Metz, Fire Marshal Dave Padilla, District Engineer Eric Sanders, Utilities Manager Keri Martinez, Utilities Senior Engineer Ccarlsbad Municipal Water District ATTACHMENT A Memorandum June 28, 2022 To: Paz Gomez, Deputy City Manager, Public Works From: Vicki Quiram, General Manager Re: White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) This memorandum presents a white paper regarding the backflow prevention devices in the Carlsbad Municipal Water District (CMWD) potable water distribution system that are non- testable and non-compliant. CMWD staff again recommend a proactive program for the replacement of non-testable backflow prevention devices to protect the public water system and comply with State regulations and CMWD Ordinance 45. Backflow Prevention Device Definition Backflow prevention devices are typically privately-owned valve and piping assemblies that prevent back siphonage of private water and potential contaminants into the public water system, thereby protecting the public water supply. Backflow prevention devices are required by State and County public health laws and the city's Engineering Standards. Backflow failures present a risk to public health. If one fails, immediate corrective action is required, including shutting off large areas of the public water system and boil water orders1. Back siphonage may be caused when the pressure in the public water system decreases, which may be caused by water main breaks, flushing, pump failure, emergency firefighting water demand, etcetera. Backpressure may occur when heating, cooling, waste disposal, fire protection or industrial manufacturing systems are connected to potable supplies and the pressure in the private system exceeds the pressure in the distribution system. Backpressure can result from an increase in downstream pressure, a reduction in the potable water supply pressure or both. Back siphonage and backpressure situations change the direction of water flow. If a backflow prevention device is not working, potentially contaminated water can flow back into the public distribution system. 1 Chemical and biological contaminants have caused illness and deaths during known incidents of backflow. Nationally, the number of incidents reported is believed to be a small percentage of the total number of backflow incidents that occur. The public health risk depends on the type and amount of contaminants, and the health effects of the contaminants. Carlsbad Municipal Water District 5950 El Camino Real I Carlsbad, CA 92008 I 442-339-2722 White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) June 28, 2022 Page 2 Regulatory Environment The California Health and Safety Code (CHSC) requires public water systems to control cross- connections and distribute reliable healthy potable water {CHSC 11637(c)). This code also requires any person who owns a public water system to ensure that the system "complies with primary and secondary drinking water standards, will not be subject to backflow under normal operating conditions and provides a reliable and adequate supply of pure, wholesome, healthful, and potable water" (CHSC 116555 (a)). California Code of Regulations Title 17, section 7605, which became effective on June 25, 1987, and CMWD Ordinance No. 45, which was adopted on June 2, 2009, requires that backflow prevention devices be tested to ensure that they function properly. Testing is required annually, by a certified third-party backflow tester that is hired by the private owner. In CMWD's service area, customers must use backflow testers on the CMWD approved list and the private owner must provide results to CMWD. In the CMWD service area there are 241 non-testable backflow devices, or four percent of total backflows, that continue to be out of compliance with this testing requirement. Policy Handbook Assembly Bill 1671, which the Governor signed on Oct. 6, 2017, requires the State Water Resources Control Board {State Board) to revise standards for backflow protection and cross- connection control and authorizes the State Board to do so through adoption of a policy handbook. The Bill imposed a state-mandated local cross-connection control program. The proposed Cross Connection Control Policy Handbook (CCCPH) is intended to replace the Code of California Regulations Title 17 requirements to allow for more timely updates. The deadline for completion of the new standards handbook was Jan. 1, 2020. The State Board published its intention to release a draft policy handbook in summer 2020. On Feb. 26, 2021, the State Board issued a preliminary draft policy handbook and opened the public comment period. Along with many agencies and water purveyors across the state, the CMWD submitted comments on the draft handbook. Staff has participated in workshops and discussions with the State Board, and much of the feedback and comments requested the State Board include technical advisory from academic, industry and field experts for assistance with revisions to the handbook. As of May 31, 2022, the State Board has not issued a second draft but has suggested it may be published later in 2022. The draft policy handbook currently includes language stating that upon adoption of the handbook, the water supplier must submit a comprehensive cross-connection control plan within 12 months following adoption. The plan must adopt enforceable ordinances, designate a Cross Control Connection Program Coordinator, conduct systemwide hazard assessments, require backflow prevention, use of certified backflow assembly testers, implement backflow preventer testing, ensure accurate record keeping, ensure incident response and notification procedures, conduct public outreach, and coordinate with local entities (permitting, health officials, fire departments, etc.). White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) June 28, 2022 Page 3 Non-testable Backflow Prevention Devices in the CMWD Water Distribution System Approximately 7,200 total backflow prevention devices within CMWD's service area are testable and in compliance with regulations. There are currently 241 known backflow prevention devices owned by 181 private owners on fire protection systems at sites in CMWD's service area that are non-testable and therefore, not in compliance with state regulations or CMWD Ordinance 45. These non-testable backflow prevention devices were installed prior to the current State of California and CMWD regulations. Less than 4% of the total backflow prevention devices are non- testable. The non-testable backflow prevention devices are located at a range of sites as shown below. About 28% are owned by small or local businesses. Non-testable Backflow Prevention Device Ownership (based on 2019 data) 28%1%3%6%13%19%30% ■ Vacant ■ School or Church ■ Hotel ■ National corporation ■ Investment group ■ Owners of multiple devices ■ Small or local business CMWD's Ordinance 45 requires backflow preventers to be tested and if they cannot pass the test, the Public Works Director will notify the customer of required corrective action within 30 days followed by a second notice with 14 days for resolution and a final notice with 10 days for resolution. The State Board's draft policy handbook also has a 30-day deadline to repair failed devices. However, in 2019 staff found that the non-compliant backflow prevention devices had been "grandfathered" and CMWD had not required the owners to comply with state regulations or the city ordinance. Current Situation In October 2019, CMWD began the process of educating city leaders about the non-compliant backflow prevention devices and the potential health risk to the public water system. The cost to replace these devices ranges from $2,500 to $100,000 depending on the device size and location. Staff recognized that replacement of these devices, and in some cases the service piping, requires a standardized process and realistic timelines for compliance because of the cost impact, the potential for work to occur in the public right-of-way and the need to isolate the White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) June 28, 2022 Page 4 public water main. In some cases, the replacement of domestic water services will be triggered by replacement of fire service piping, at additional cost, to comply with current standards. The 181 businesses that need to replace their devices are listed in Attachment A. Some businesses have more than one device on site. Attachment B is a map of non-testable backflow prevention device locations. Currently, CMWD is requiring replacement of non-testable backflow devices on existing fire protection assemblies on a case-by-case basis. Since 2019, the city has replaced all four of its non-testable backflow prevention devices with testable devices. The current replacement process is triggered when the Utilities Department learns of planned or ongoing construction at relevant sites. For example, CMWD has requested the County of San Diego to require tenants to replace two non-testable backflow devices at the Palomar Airport in advance of a CMWD CIP pipeline replacement project. CMWD is also conditioning development projects during utility plan checks. CMWD staff proposed a citywide approach to replace the approximate 244 devices that are not in compliance over a period of between 1 to 5 years and would like to develop a plan and initiate a process as soon as possible. Memoranda on this subject were sent to the CMWD Board on June 18, 2020, October 1, 2020, and June 3, 2021 (Attachment C), indicating that the CMWD is waiting for the State Board to adopt final standards. While the State Board adoption date is unknown, the current draft language in the policy handbook requires water agencies to develop and submit a plan to address these devices within 12 months of policy handbook adoption. Action is needed to uphold the legal responsibilities of professional engineers and certified water system operators and for compliance with state regulations. Neighboring Agencies CMWD has researched the work of several neighboring water purveyors with similar non- testable backflow devices. Oliven ha in Municipal Water District and the City of San Diego have backflow ordinances and policies in place and are currently implementing education via website and published literature. The City of San Diego Department Instruction 55.21 provides the basis for policies regarding backflow prevention. San Diego city staff notice approximately 38,000 customers for annual testing of their backflow devices. They estimate that the total backflow device inventory will increase by 15,000 in the coming years. San Diego believes that about ten percent of the current inventory of backflow devices are non-testable. The City of San Diego currently requires replacement of non-complaint devices during tenant improvement project reviews by their cross-connection review staff. They have implemented a weekly coordination meeting with fire inspection staff to coordinate device replacement requirements. They also conduct some enforcement via their cross-connection code enforcement including use of citations when annual testing is not submitted. White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) June 28, 2022 Page 5 Olivenhain Municipal Water District's (OMWD) Cross Connection Control Ordinance 429 provides regulations for non-complaint backflow prevention devices. Sections E, F and G of this ordinance specifically address non complaint single check valves on fire protection systems. Section G allows for a 5-year grace period beginning Aug. 8, 2012, for owners to replace these devices. The OMWD initially sent letters to all owners of these devices and then followed up annually. Beginning in 2015 OMWD staff began working to get their inventory of 87 non complaint devices replaced through frequent site visits referencing both State requirements in Title 17 and their local ordinance. Their current remaining devices to be replaced is 16, as replacements were not required during the COVID-19 pandemic. Per OMWD staff, while costs are burdensome, customers are generally moving towards compliance within two months following notices and follow-up site visits. The OMWD waived inspection and testing costs for their customers to encourage partnering on compliance. The OMWD collaborates with fire inspections to review all replacements as their Ordinance language specifically requires Fire Marshall approval of replacement plans prior to submittal to OMWD for review. Non-testable devices Plan review Water Supplier as percent of total triggers Code enforcement inventory replacement Carlsbad MWD 4% Yes No partnership at present. Code enforcement provides uneven support when testing City of San Diego 10% Yes certificates are not turned in to the cross-connection division. Annual letter to non- compliant device owners and Olivenhain MWD <4% Yes frequent site visits. OMWD waived inspection costs to encourage replacement with testable devices. City of Oceanside Has program, but no data is available Proposed Process The CMWD staff present the following procedure to work with customers to replace non- testable backflow prevention devices, protect the public water system and avoid potential fines or litigation. This process will address the risk to the public water supply in three years. Customers will be given time to plan and budget for the replacements. Rolling out the requirement over three years will allow CMWD staff to provide sufficient support to customers as their deadline nears. The CMWD will have the time to develop an ordinance and training to strengthen enforcement capabilities. The process may need revision as staff move forward. Staff has reached out to the Fire and Planning Department, who will need to be involved in the process in certain replacement situations. White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) June 28, 2022 Page 6 1. The CMWD will review and update its current inventory of non-testable devices including field inspection of some of the devices (located above grade, in a vault, serving multiple customers, etc.). 2. The CMWD will send a letter to each non-compliant business to provide educational information on the issue and inform them they will be receiving additional information regarding replacement requirements (protection of public water supply, regulatory compliance, submittals, deadlines, etc.). 3. The CMWD will prioritize each non-testable backflow device based upon a score that uses the following three factors: o Likelihood of Failure - considers data such as the estimated device age, pipe age, and pipe material o Consequence of Failure - considers data such as the size of device, size of water line that could be contaminated, the type of business and potential contaminants, the area affected, shutoff capability, and the impact to institutional settings, schools, and multi-family housing. o Other - considers data such as unique business situations, street paving moratoriums, logistics of water shutdowns, and CIP project coordination 4. Communicate information, state requirements and resources to water customers who own non-testable backflow prevention devices via certified letters. Based on prioritization scoring, require construction plans for replacement be submitted within three months to one year and replacement per plans within 18 months to three years based on the priority scoring. Beginning this process will result in a significant reduction of non-compliant backflow devices over the next three years to better protect the public water system and reduce public health risks and assist CMWD in State regulatory compliance. Attachments: A. List of businesses with non-testable backflow devices B. Map of non-testable backflow prevention device locations C. CMWD memorandums date June 18, 2020, Oct. 1, 2020, and June 3, 2021 (Due to the size of Attachment C, these documents are not included as they have previously been distributed to City Council) Non-testable Backflow Business Name Attachment A 110 KNOLL LLC 2035 EQUICAP CARLSBAD 2500 NAVARRA HOA 2719 LOKER AVE WEST OWNERS ASC 505 OAK AVENUE PARTNERS LLC 5050 CARLSBAD LLC 5816 DRYDEN LLC 5838 EDISON PLACE LLC 5960 PASCAL CT LLC 5TH AXIS INC ALEJANDRA'S COCINA AN MOTORS OF FT LAUDERDALE INC ARGONAUT MANUFACTURING INC AVENIDA ENCINAS LP BECKMAN CARLSBAD I LLC BECKMAN COULTER INC BEMER USA BIG FUTURE PRESCHOOL BIKES ONLINE INC BKM DEL ABETO #242 LLC BLUEHAT LLC BOB BAKER AUTOMOTIVE INC BOND RANCH BRIAN SIPE BROOKWOOD CARLSBAD EXEC PLAZA BROOKWOOD PACIFIC OFFC II LLC BUDDHA TEAS BUFFINI AND COMPANY CALLAWAY GOLF CAP INVESTORS LLC CARLSBAD 2200 LLC CARLSBAD COMM CHURCH CARLSBAD COMMERCE CNT INVST LP CARLSBAD COMMERCE CTR CARLSBAD POINT CORPORATION CARLSBAD TECHNOLOGY INC CARLSBAD UNIFIED SCHOOL CCSD LLC CEI OFFICE FUND 8 LLC CHELSEA INVESTMENT CORP CORTE DEL NOGAL PROPERTY LLC COSTA VERDE HOA COSTCO WHOLESALE CORP Non-testable Backflow Business Name Attachment A CVS PHARMACY STORE #09479 DOLLAR TREE STORES INC #02521 DOLLINGER PALOMAR OAKS LLC DONAHUE SCHRIBER GROUP DRAFT REPUBLIC CARLSBAD DR'S OWN INC DULCES REALTY LLC ECOLINK INTELLIGENT TECH INC EDISON PLACE LLC EEVELLE LLC EL CEDRO PROPERTIES LLC EL FUERTE BUS PK INVESTORS LP ENRICO PINAMONTI PROPERTY MANAGMENT EXOTIC PEBBLES AND AGGREGATES EXP 2290 COSMOS, LLC FARADAY PROPERTIES LLC FASHIONPHILE FERGUSON ENTERPRISES INC FINISHING TOUCH MILLWORK FIRST INDUSTRIAL LP FORECAST PRODUCT DEVELOPMENT FRIARS RIVERDALE LTD GILDRED DEVELOPMENT GLENDORA MOTORCARS CO GUNTHER LLC H & P MOBILE GEOCHEMISTRY HARSCH INVESTMENTS CORP HAY HOUSE INC HEDDA MAROSI LIVING TRUST HOEHN ASSOCIATES IMPERIAL SPRINKLER SUPPLY INDUSTRIAL STRENGTH CORP IONIS PHARMACEUTICAL ISLAND BATIK JAZZERCISE JC PENNEY 0566-0 JUDY JONES Kl SPEED KAISER HEALTH PLAN KRC PROP MANAGEMENT I INC L-3 PHOTONICS LA COSTA GREENS HOA LA COSTA LIMOSINE Non-test able Backflow Business Name Attachment A LDVF LA PLACE LLC LEBRUNS LLC LEGOLAND CALIFORNIA LLC LLEWELLYN SHORES LTD LV PRIESTLY DR LLC M & P INDUSTRIAL PROPERTIES M6 CARLSBAD LLC MACY'S WEST V173333932 #17902A MAJI INVESTMENTS INC MARK THOMPSON MARSHALLS INC #314 MCMURPHY DEVELOPMENTS MCWIN CORPORATION MEANS FAMILY TRUST MERCOTAC METROPOLITAN LIFE INS CO MIGUELS CUCINA MITCHELL LAND MODUS ADVANCED MOTEL 6 -SITE 000471 NATEL ENGINEERING NATURAL ALTERNATIVE INTL NELLI-REGEN THREE, LLC NOB HILL HOA NRG/CARLSBAD ENERGY CENTER OLIVE GARDEN/DARDEN REST OLIVE POINT HOA OMNI LA COSTA LLC OSTENDO TECHNOLOGIES PACIFIC SALES PACIFIC VIEW PLAZA PALOMAR 14 CONDO ASSOC PALOMAR AIRPORT CENTER LLC PALOMAR OAKS POINTE PALOMAR TRANSFER STATION INC PARK HYATT AVIARA RESORT PAYLESS/RITE AID #5622 PGP CARLSBAD SENIORS PGP CARLSBAD SENIORS II PHILIP ESBENSEN PK 1 NORTH COUNTY PLAZA LP PLAZA ENCINA PARTNERS PLAZA FAMILY DENTAL Non-testable Backflow Business Name Attachment A PLAZA PASEO REAL ASSOC LLC PREMIER BUICK CADILLAC GMC OF CARLSBAD PU ESTA DEL SOL QOOLABS INC RAF PACIFICA GROUP/FUND 4 RALPH'S #175 CARLSBAD RBCO REEF LIFESTYLE LLC REXFORD INDUSTRIAL REAL TY LP RIF Ill IMPALA LLC RIF Ill YARROW DR LLC RIF Ill YARROW II LLC RISING GLEN LP ROMBOTIS BROS RONIN HOLDINGS LLC ROWAN ELECTRIC SD C PROPERTIES LLC SM AC PARTNERS LP SABRINA GREENS HOA SAM MYS WOODFIRED PIZZA SAN DIEGO HAT CO SCROOSCOOP FASTENER SENDX MEDICAL INC SEVEN 8 FIVE GRAND LLC SINCERI SENIOR LIVING SKATEOPLEX SMART & FINAL CARLSBAD 239 SOLANA BEACH BAKING CO ST PATRICKS CHURCH STREET PROPERTIES INC SUPER 8 MOTEL SVF LLC SYMBIENT PRODUCT DEVELOPMENT SYNERGEYES INC SYNTRON BIORESEARCH TAMARACK SHORES II HOA TECH Bl LT CONST CORP THE ALCHALEL REAL ESTATE INVESTMENT TRUST THE GARDENS NURSING FACILITY THE SHOPPES AT CARLSBAD THOMAS RAGLAND TRUST THRIFTY/RITE AID #5621 TORREY PINES SCIENTIFIC INC Non-testable Backflow Business Name Attachment A TOTAL SOURCE MANUFACTURING TOYOTA CARLSBAD TRANSBORDER KIFFMAN LLC TRUE DIAGNOSTICS, INC TYLER COURT APTS VANGUARD INDUSTRIES WEST INC VERSUM MATERIALS US LLC VONS STORE #62343 FAC #95-5732 WEIBOWANG WELLS FARGO BANK WESTERN FLIGHT INC WILLIAM J KOTOFF ATTACHMENT B -Map of Non-Compliant Backflow Prevention Devices 1P~@~F.•!E·W©Fi.A81 Legend • Non-Compliant Single Check Valves (~ 241, doesn't include vacant) □ Carlsbad Municipal Boundary . 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