William Gati - Examining New York City's DEP Back-Flow (RPZ) Device Program
July 08, 2011 - Spotlights
* The city of New York Department of Health and Mental Hygiene has taken the initiative from the NYS Health Department to implement the Back-flow Device Program. This program requires filing of plans by a registered architect or professional engineer with DEP and obtaining an approval. The owner must then hire a licensed plumber who is preferably also a certified RPZ tester to obtain a permit from the Building Department, install the device and test it. Once this is completed, the designing architect or engineer must inspect the device and file a Gen 215B form with DEP. This process can take up to 6 months and cost several thousand dollars.
* NYC DEP is now taking an aggressive approach to enforcement of 24,000 buildings many of which have hazardous water conditions.
* DEP is more willing to accept double check valves instead of RPZ devices than they were 10 years ago but I still prefer RPZ devices since they are more effective and easier to manage.
* Double check valves can be acceptable on the main water line as long as all internal hazardous fixtures are protected with internal RPZ devices.
* The advantage of double check valves over RPZ devices is that they are cheaper and there is no water discharge.
* The only official letter requiring RPZ device installation will come from DEP and give the owner a deadline for compliance.
* DEP enforces violations of the RPZ device program by referring the case to ECB. The fine for not complying is usually $1,000 if the defendant does not go to the hearing. If this issue is ignored for a long period of time, DEP may turn off the water to the violated building.
* DEP can and will turn off the water if there is no compliance so it is essential that plans are filed and the RPZ device is installed in a timely manner.
* Many of the buildings that have medical offices, laundromats, car-washes, funeral homes or other hazardous uses require a back-flow device.
In summary, the steps required to comply with the RPZ device mandate is to: retain an architect or engineer with substantial experience in designing RPZ device installation, file the application with DEP; hire a plumber with experience in installation and testing RPZ devices; file with the DOB for a permit; obtain the inspection from the designer and from the plumber; get the inspection and sign-off from the Building Department; have the device tested every year; have the device dis-assembled and re-assembled every five years.
William Gati, AIA, is the president of Architecture Studio, Kew Gardens, N.Y.