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Building code questions resulting from the 12Feb technical meeting

Posted by Frank Burdick on 20 Feb, 2014
Category: Category 1 - SSWWEP Questions and Presentations


During the 12Feb Tech meeting, Ralph Welton, the code official promised to get back with us on the following issues.  Per Robert C:
1.  Check on any proximity setbacks between a sump pump and a floor drain.  
2.  Check on venting distance requirements for a floor drain. Indicate code requirements for plumbing vents thru the roof for these floor drains.
3.  Check on any issues with depressing the floor by an inch or two between the sump and a floor drain
4.  Provide a look-up table for service lead size requirements. This is to help verify curb drain sizes with multiple connected sump pumps running concurrently.
5.  Ask his inspectors about their experience with the reliability of a check valves.  Do they prevent back ups? Do the prevent the use of the sanitary system in the house?  How often do they need maitenance?


Ralph Welton responded to my question about his enforcement of retroactive codes.  He indicated that his charter or obligation is to enforce the codes and "regulations" of the city. He indicated that he is using the 2001 City Ordinance for his justification.

He indicated that if we could change the Ordinance than he would enforce the language of the change.  Robert C. directly asked him if the ordinance was changed, is there anything in the State Plumbing Code that would not allow the gravity supported back up system.  Mr. Welton said that there was not anything in the Code that would prevent this.  (Note, it is possible, that Mr. Welton misunderstood the question and thought that Robert was referring to the idea of installing a sanitary floor drain within a few feet of the sump pump.  At this point I am not sure how R. Welton interpreted the question.  It will be encouraging if the sketch that I drew in Aug of 2013, may, in fact, be a viable code approved option, if all we need to do is modify the city ordinance. I will be totally flabbergasted iand disappointed if this 8/13 option took until 3/14 to be resolved.

Will the city consider a modification to the ordinance?  Will the gravity supported back up system meet State Code?

Can we request that we receive all of these answers not later than 3/3/14?

Joe, Michelle, Pat, Cressen: Please add any questions that you recall from that 12FEB meeting.

Comments

Robert Czachorski on 20 Feb, 2014:

Frank - I think this is a critical question to get answered.  At that point in the meeting that the question was asked, I was not entirely sure whether Ralph was following the question I was asking or not - it was towards the end of the meeting, and we were finishing up and had changed topics several times.  We should get a clear answer.  Subsequent to the meeting, I was discussing this issue with others, and we suspected that the design would be a violation of the State Building Codes, because it creates a direct connection between the sump and sanitary sewer. But this is speculation.  We should get a definitive answer to this - it should be simple enough to do.  

Lori - please add to the Q&A log and coordinate with the City to get this question to Ralph.

Take care,
Robert

Michelle Lovasz on 20 Feb, 2014:

My take from talking with Ralph was that he was not the one, in any of our queries, who could change any obstacles to implementing.  He was simply responsible for ensuring adherence to Code.  Modifications are to be directed elsewhere.  Whether or not there were, in fact, any obstacles (i.e. distance of drain from sump) he was looking into.

Frank Burdick on 22 Feb, 2014:

Standing by for these answers from the 12Feb meeting..... it's 21Feb today..........  

Frank Burdick on 25 Feb, 2014:

It has now been over 2 weeks from the date we asked these questions.

How about we add a Cultural Norm about being respectful by responding to simple questions such as these in a timely manner.  By not responding it has appearence of rudeness and a lack of respect for the mission of this cac.  I guess the city doesn't have to live by the same rules.

Patricia Marten on 26 Feb, 2014:

I was not at the Feb 12 meeting.  But at the Feb 17 meeting, we discussed # 1 & 3, as issues to be looked into, since they had been brought up previously.

Michelle Lovasz on 7 Mar, 2014:

Charlie, Robert, Nick?  Can anyone prompt Ralph on this?

Michelle Lovasz on 8 Mar, 2014:

I don't want this to get lost in the fray.

Michelle Lovasz on 9 Mar, 2014:

Charlie, Robert, Nick?  I would like an update on this please.  If Ralph hasn't yet gotten an answer then could we put a deadline?  It has been since February 12.

Judy Hanway on 9 Mar, 2014:

I am echoing Michelle's request for an answer to this question.

Nick Hutchinson on 10 Mar, 2014:

We just received answers on Friday. We will get them posted shortly.

Michelle Lovasz on 10 Mar, 2014:

Thanks Nick!

Lori Byron on 21 Apr, 2014:

As a follow up from the February 12 Tech Briefing, Frank Burdick submitted a number of code-related issues for follow up. Following are the questions and responses from Ralph Welton, City of Ann Arbor's Chief Development Official, citing applicable codes. The responses have already been sent to Mr. Burdick. 

Unless identified as a reference to the 2009 Michigan Plumbing Code, references below to TABLES and SECTIONS beginning with “P” are references to the 2009 Michigan Residential Code. Per the Stille-Derossett-Hale Single State Construction Code Act, the 2009 Residential and Plumbing Codes are part of Michigan’s Uniform State Construction Code. See MCL 125.1504.

Q1. Check on any proximity setbacks between a sump pump and a floor drain.

There are no measurement restrictions. A floor drain is a Plumbing Fixture. See SECTION P2719. Under Section P2601.2, a floor drain must be connected to the sanitary sewer system:

P2601.2 Connection. Plumbing fixtures, drains and appliances used to receive or discharge liquid wastes or sewage shall be connected to the sanitary drainage system of the building or premises in accordance with the requirements of this code. This section shall not be construed to prevent indirect waste systems.

The floor drain cannot be set up to act as a sump pit overflow drain because 2009 Michigan Plumbing Code section 1104.2 states:

The sanitary and storm drainage systems of a structure shall be entirely separate except where combined sewer systems are utilized. Where a combined sewer is utilized, the building storm drain shall be connected in the same horizontal plan through a single-wye fitting to the combined sewer not less than 10 feet (3048 mm) downstream from any soil stack.

The flow from the sump pump cannot flow into the sanitary drainage system. Sanitary drainage system is defined in the Plumbing Code as:

A drainage system that carries sewage and excludes storm, surface and ground water.

In addition, City Code Chapter 28, Section 2:42.3(8) prohibits both direct and indirect discharge from footing or foundation drains into the sanitary sewer system:

(8) No person(s) shall make connection of roof downspouts, foundation drains, areaway drains, or other sources of surface runoff or groundwater to a building sewer or building drain which in turn is connected directly or indirectly to the POTW [Publicly Operated Treatment Works].

City Code Chapter 28, Section 2:41.2f(1) defines the City’s sanitary sewer system as “a sewer which carries wastewater and to which storm water and ground water are not intentionally admitted.”

City Code Chapter 28, Section 2:43.2(1)(m) also prohibits discharge to the POTW of,

(m) . . . stormwater, groundwater, or surface water, unless separate POTW facilities are available and identified for the discharges or unless the Administrator gives written permission to the user for a temporary discharge of the waters based on hydraulic capacity and treatment impacts.

City Code Chapter 33, Section 2:203(16) defines “stormwater” to include “footing drain discharges.”

Q2. Check on venting distance requirements for a floor drain. Indicate code requirements for plumbing vents thru the roof for these floor drains.

See attached TABLE P3105.1, venting distance from trap to vent. SECTION P3101.2.1, Methods of venting required.

P3101.2.1 Venting required. Every trap and trapped fixture shall be vented in accordance with one of the venting methods specified in this chapter.

Q3. Check on any issues with depressing the floor by an inch or two between the sump and a floor drain. 

See the response to Question #1, above. A floor drain is a plumbing fixture, which must connect to the sanitary sewer and may not be a means for a foundation or footing drain to discharge to the sanitary sewer system.

Q4. Provide a look-up table for service lead size requirements. This is to help verify curb drain sizes with multiple connected sump pumps running concurrently.

The attached TABLE P3005.4.2 contains maximum DFUs allowed down drains, by size. TABLE P3201.7 has some info about maximum GPMs flowing down certain size traps.

However, Plumbing Code is not appropriate to use for the design of curb drains. Please refer to the Q.1.35 of the Q and A log for curb drain basis of design.

Q5. Ask his inspectors about their experience with the reliability of a check valves. Do they prevent back ups? Do they prevent the use of the sanitary system in the house? How often do they need maintenance?

City plumbing inspectors indicated they only have experience in new installation inspections. Longevity, maintenance and reliability questions would need to be directed to plumbing contractors. The Plumbing Code requires that they conform to certain standards upon installation. SECTION P3008.

In the event that there is a sanitary sewer surcharge situation causing the check valve to close to prevent back-ups as designed, any plumbing fixture or appliance upstream of the check valve will not be able to drain until the surcharge has ended and the check valve has once again opened; and in the case of a home with a whole house check valve, no plumbing fixture will be able to drain until the surcharge has subsided and the valve has once again moved to the open position.

Q6. Ralph Welton responded to my [Frank Burdick's] question about his enforcement of retroactive codes. He indicated that his charter or obligation is to enforce the codes and "regulations" of the city. He indicated that he is using the 2001 City Ordinance for his justification.

Mr. Welton clarified the above statement by stating the City’s Construction Services only oversees installation methods based on City system requirements.

R102.2 Other laws. The provisions of this code shall not be deemed to nullify any provisions of local, state or federal law.
City Code Chapter 28, Section 2:42.3(8), added in 1994, prohibits foundation or footing drain discharge to the sanitary sewer system. Statutes, regulations and City Code provisions governing sanitary and storm sewer systems govern those connections and discharges. The Chapter 28 amendment in 1994 was to bring City Code provisions into compliance with federal regulations.

Comment 7. He [Ralph Welton] indicated that if we could change the Ordinance than he would enforce the language of the change. Robert C. directly asked him if the ordinance was changed, is there anything in the State Plumbing Code that would not allow the gravity supported back up system. Mr. Welton said that there was not anything in the Code that would prevent this. (Note, it is possible, that Mr. Welton misunderstood the question and thought that Robert was referring to the idea of installing a sanitary floor drain within a few feet of the sump pump.) At this point I am not sure how R. Welton interpreted the question. It will be encouraging if the sketch that I drew in Aug of 2013, may, in fact, be a viable code approved option, if all we need to do is modify the city ordinance. I will be totally flabbergasted and disappointed if this 8/13 option took until 3/14 to be resolved. 

Q8. Will the city consider a modification to the ordinance?

As it is documented that the City has recognized the negative impacts of footing drains flows to the sanitary sewer system dating back to at least 1987, it is unlikely that City staff will support a modification to the City ordinance that would allow footing drain flows to enter the sanitary system.

Q9. Will the gravity supported back up system meet State Code?

The 2009 Michigan Plumbing Code’s section 1104.2 requires “entirely separate” sanitary and storm drainage systems within a structure, thus disallowing the use of the discussed gravity supported back-up system.