The Regulatory Challenge
The EPA’s “Clean Water Act” (33 U.S.C. §1251) sets wastewater standards for industry and regulates polluted discharge from “point sources” (pipes, for example) into surface water. They operate a permit program to control these discharges.
In September 2011, the California State Fire Marshal’s office, in cooperation with the California Water Board Division of Water Quality Storm Water Section, produced the “Water-Based Fire Protection Systems Discharge Best Management Practices Manual” (BMP). This document states that “Turbid water due to rust and musty stagnation would be subject to BMP for containment and sediment control.” (page 10, paragraph 6) The regulations also insist that the water be de-chlorinated before entering a storm drain (paragraph 7, according to the MS4 general National Pollution Discharge Elimination System (NPDES)). Failure to follow this procedure could result in death of aquatic animals and legal liability.
“An inspection of the piping and branch line conditions shall be conducted every five years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting for the presence of foreign organic and inorganic materials”
- National Fire Protection Standards 25-states in section 14.2, 14.2.1 Obstruction Investigation & Prevention
“If an obstruction investigation indicates the presence of sufficient material to obstruct pipe or sprinklers, a complete flushing program shall be conducted by qualified personnel”
- NFPA 14.3.3