Thank you for the opportunity to comment and listening previously to Chesterfield County Utilities' and Chesterfield County Fire Department's concerns regarding plugging fire hydrant drains. The Chesterfield County Utilities Department offers the following regarding the Waterworks Regulations Amendments and Updates. 

12VAC5-590-1170 Hydrants:

The Chesterfield County Utilities Department is concerned that the proposed additional language will require fire hydrant drains, aka weep holes, to be plugged unnecessarily due to high groundwater and surface flooding and ponding.  These are frequently seasonal conditions or happen periodically when there are periods of heavy precipitation.  These conditions do not present a hazard of contaminating the fire hydrant barrel.  If the groundwater were to become contaminated, once the fire hydrant is utilized, the pressurized water system would quickly force the water from the barrel.  If the hydrant drains are plugged and water remains in the hydrant, it would be susceptible to a complete blockage by ice during periods of below freezing temperatures.  Relying on manual removal of the water from the hydrant is not a practical solution. The weep holes are an engineered solution to automatically remove water from the fire hydrant barrel to prevent freezing.  Frozen hydrants are believed to be a higher risk to public safety. The plugging of fire hydrants drains also may cause the fire hydrant to become pressurized if the hydrant foot valve were to have a leak.  This puts utility workers and fire fighters at risk if they remove the hydrant cap and are not aware the hydrant was pressurized.  In conclusion, the risk of contamination through a fire hydrant drain to the water system does not out way the risk of a fire hydrant freezing and not being functional when needed to serve its primary purpose of protecting life and property from damage by fire.

The Chesterfield County Utilities Department 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 dry wells provided exclusively for this purpose. (Leave language as-is; no change recommended)
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. (Agree with proposed language change)

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

The Chesterfield County Utilities Department requests that the proposed regulations provide the owner an educational program option to satisfy requirements for residential customers of their Cross-Connection Control Program.  This program is reviewed periodically by the Virginia Department of Health’s Office of Drinking Water.  Residential customers are generally required to adhere to the cross-connection control program due to their landscape and lawn irrigation systems.  We believe that the best use of our resources should be dedicated to protecting the utility system from the commercial/non-residential users with complex plumbing systems or are suspected to be high hazards.  An educational program should be allowed for residential customers at the owner’s discretion rather than at the Office of Drinking Water’s discretion.

The Chesterfield Utilities Department suggests 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.

In conjunction with the proposed changes requested to section 12VAC5-590-600 D., the Chesterfield County Utilities Department suggest that section 12VAC5-590-600 G. be changed to read:

G. Except for options allowed in 12VAC5-590-600.D., the owner shall maintain an inventory and records of testing, repairs, and maintenance of all backflow prevention assemblies, backflow elimination methods, and backflow prevention devices required and installed under 12VAC5-590-610.