Presentation from the San Diego County Water Authority’s workshop on Recycled Water and Dual Plumbing - Nov. 2010

1. Toby Roy
November 9, 2010

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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.

8. 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

9. 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.”

10. 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

11. 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

12. 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!

13. Signs Required in Restrooms
 Much discussion
about language on
signs and where to
locate.

14. 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.

15. 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”

16. 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.

17. 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

18. 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

19. 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……

20. Graywater Legislation
 Lowenthal: SB 1258 (2008)
 Housing and Community Development shall
develop standards for residential graywater use
for adoption by the Building Standards
Commission

21. 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

22. 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

23. Elements of the 2011 California
Plumbing Code for Recycled
Water
 Consistent with California regulations
 Reduce unreasonable obstacles
 Embrace reasonable safeguards
 Relax unnecessary testing

24. 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”

25. 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.

26. 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.

27. 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.”

28. 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”.

29. 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

30. 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