12VAC5-590-1170 Hydrants:

Hanover County is concerned that the proposed changes will lead to fire hydrant drains being plugged regularly. The plugging of fire hydrants drains will lead to operational issues for the utility as hydrants will have to be regularly pumped to avoid freezing and posing extreme danger to the community and fire fighters when hydrants are found frozen much more when they are used for firefighting activities.  Weep holes are an engineered solution to prevent the potential for hydrants to freeze and minimize the risk of backflow. Once that engineered solution is bypassed, the likelihood for problems increases dramatically.  The risk of contamination through a hydrant drain to the water system does not out way the risk of a hydrant freezing and not being functional when needed to serve its primary purpose.

Hanover County recommends that 12VAC5-590-1170 be changed to read:

1. Where hydrant drains are not plugged, they shall be drained to the ground surface or to subsurface stone filled wells or other engineered solutions provided exclusively for this purpose.
2. Hydrant drains shall not be connected to sanitary sewers or storm drains.
3. Fire hydrants shall be connected only to water mains adequately designed for fire flows in accordance with the requirements of 12VAC5-590-1120 B.

12VAC5-590-600 Cross-Connection Control Programs:

Hanover County is concerned that that the proposed regulations require that all waterworks track annual testing for backflow devices for residential irrigation systems unless ODW approves a public education program. We estimate that Hanover would need to add 2-3 employees to move from our current public education program to a tracking program as proposed. We don’t believe this is the best use of limited resources with the many challenges that we face. We recommend that waterworks have the option to choose whether to track the annual testing of backflow devices for residential customers or utilize a public education system at their discretion rather than the ODW discretion. We suggest that section 12VAC5-590-600 D. be changed to read:

D. Instead of annual operational tests (12VAC5-590-600 C) and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), the owner has the option to provide a public education program to residential consumers.  The owner may also provide a public education program, instead of annual operational tests and the related records and inventory of backflow prevention assemblies, backflow elimination methods, and backflow prevention devices (12VAC5-590-600 G), to commercial consumers whose premise plumbing is not complex and where there are no known or suspected high hazards as identified in Table 630.1.