To the member s of the:
CITY COUNCIL
Date/~CA£CC /
CM ✓AcMLDcM(3)~
December 15, 2022
CMWD Board Memorandum
To: Carlsbad Municipal Water d of Directors
From: Paz Gomez, Deputy City M ic Works
Vicki Quiram, General Managet-J-~~-
Via: Scott Chadwick, Executive Ma a
Ccarlsbad
Municipal Water District
Memo ID# 2022121
Re: Non-testable Backflow Preven · Assemblies Update (Districts - All) This memorandum provides an update on a previous Carlsbad Municipal Water District (CMWD) Board Memorandum dated June 3, 2021, regarding privately owned backflow prevention assemblies in the CMWD potable water distribution system that are non-testable and therefore not compliant with state requirements.
Background
Assembly Bill 1671, which the Governor signed on October 6, 2017, requires the State Water Resources Control Board (State Board) to revise standards for backflow protection and cross connection control and authorizes the State Board to do so through adoption of a policy handbook. The proposed Cross-Connection Control Policy Handbook (handbook) is intended to replace the Code of California Regulations Title 17 requirements to allow for more timely updates.
Backflow prevention assemblies are valve and piping assemblies that prevent back siphonage of water and potential pollutants and contaminants from private water services into the public water system, thereby protecting the public water supply. Because of the potential health risk to water systems if a backflow event occurs, both state law and CMWD ordinance require that backflow prevention assemblies be tested annually.
Approximately 7,200 total backflow prevention assemblies within CMWD's service area are testable and in compliance with regulations. In CMWD's service area, there are currently 239 known backflow prevention assemblies (owned by 181 CMWD customers) on fire protection systems that are non-testable and therefore not in compliance with state regulations or CMWD Ordinance No. 47.
A white paper on non-testable backflow prevention assemblies dated June 28, 2022, is provided as Attachment A, which includes the CMWD Board Memorandum dated June 3, 2021, and earlier memoranda on the subject.
Carlsbad Municipal Water District
5950 El Camino Real I Carlsbad, CA 92008 I 442-339-2722 t Board Memo - Non-testable Backflow Prevention Assemblies Update (Districts -All) December 15, 2022
Discussion
On November 2, 2022, the State Board released a second draft of the handbook and solicited comments on this revised draft through December 9, 2022. In summary, the changes included more detail in the six elements contained in Title 17 cross-connection regulations and the addition of four new elements including :
• more specific requirement for cross-connection certified testers and specialists • more specific and immediate incident response
• requirements for public outreach
• required local entity coordination
In addition to these changes that the State Board highlighted, the CMWD staff noted that a compliance t ime frame of 10 years to replace non-testable backflow preventions assemblies on fire protection systems was added to the text.
On December 5, 2022, a public hearing was held during which the State Board provided a brief presentation of the revised document and allowed for public comments . Several of the regional water organizations and agencies provided verbal comments inclusive of requesting:
• a technical advisory committee be formed to work with State Board staff on further revisions and implementation of the handbook
• the State Board's technical staff report be included in the handbook as an appendix • a template and guidance for cross-connection control plans to assist in statewide consistency
The following background and regulatory timeline for the proposed handbook is provided:
• January 1, 2020- Regulatory deadline for completion of the handbook • Summer 2020 - The State Board published its intent to release a draft handbook • February 26, 2021- The State Board published a preliminary draft handbook • February 26, 2021-April 27, 2021 - The State Board requested public comments on draft handbook
• April 26, 2021 - The CMWD staff submitted written comments in concert with local suppliers via the Technical/Field Regional Advisory Group, as a separate agency, and as a member of the San Diego County Water Authority
• April 27, 2021- The State Board hosted a virtual public hearing to receive verbal comments on the draft handbook
• November 2, 2022 -The State Board released a second draft of the handbook • December 5, 2022 - The State Board hosted a second public hearing • December 9, 2022-Close of the public comment period on the draft handbook • Mid to late 2023 - The State Board anticipates adoption of the handbook Board Memo - Non-testable Backflow Prevention Assemblies Update (Districts - All) December 15, 2022
Following adoption of the handbook, water suppliers will have one year to make necessary administrative changes to their cross-connection control programs, including the new requirement for development of a local cross-connection control program that will include additional requirements to comply with the State Board regulations.
In absence of the anticipated handbook, the CMWD staff continue to work on getting non testable assemblies replaced to protect the CMWD water supply system and comply with Ordinance No. 47. Staff have completed a detailed inventory update for sending CMWD notices to device owners who need to replace non-testable backflow prevention assemblies. The inventory update will also assist in prioritization of device replacement based on location, risk of failure and operational shutdowns for replacement.
Replacement of the four city-owned non-testable assemblies was completed in 2021.
Additionally, other private devices have been replaced as ancillary to the CMWD capital improvement program projects. Of the 264 non-testable assemblies that were initially identified in the Board Memo dated June 18, 2020, replacements, inventory updates and field verifications have decreased the current number of non-testable assemblies that still need to be addressed to 239. Ongoing CMWD plan review for proposed land development projects have also identified non-testable devices for which the CMWD is requiring their replacement. Those assemblies are included in the total current number of 239.
The CMWD staff have been coordinating with other city departments/divisions including the Building Division, Land Development Engineering Division and Fire Inspection Division to facilitate communication and coordinated review once notification letters are sent to customers that own these non-compliant backflow prevention assemblies. Because these devices are located on fire service lines upstream of fire protection systems, the private owners must ensure the new assembly does not reduce the flow of water to their fire system. This requires hydraulic flow calculations and must be reviewed and approved by the city's fire inspection staff.
Staff are also drafting edits to the cross-connection control language in Ordinance No. 47 and will bring an ordinance update to the CMWD Board in 2023 to align with anticipated handbook requirements and provide a realistic timeline for the steps necessary to replace non-compliant assemblies.
Next Steps
Staff will continue to participate in the Technical/Field Regional Advisory Group and comment collectively on any future drafts of the handbook. Staff will continue to track the regulatory process and timeline for handbook revision and eventual adoption, which is anticipated to be in mid to late 2023. Staff will continue to provide updates to the Board as additional information becomes available.
Board Memo - Non-testable Backflow Prevention Assemblies Update (Districts - All) December 15, 2022
Attachment: A. White Paper on Non-testable Backflow Prevention Assemblies dated June 28, 2022
cc: Geoff Patnoe, Assistant Executive Manager
Cindie McMahon, General Counsel
Ron Kemp, Senior Assistant General Counsel
Gary Barberio, Deputy City Manager, Community Services
Laura Rocha, Deputy City Manager, Administrative Services Michael Calderwood, Fire Chief
Jeff Murphy, Community Development Director
Kristina Ray, Communication & Engagement Director
John Maashoff, Public Works Manager
Randy Metz, Fire Marshal
Dave Padilla, District Engineer
Eric Sanders, Utilities Manager
Keri Martinez, Utilities Senior Engineer
Ccarlsbad
ATTACHMENT A Municipal Water District
Memorandum
June 28, 2022
To:
From:
Re:
Paz Gomez, Deputy City Manager, Public Works
Vicki Quiram, General Manager
White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) This memorandum presents a white paper regarding the backflow prevention devices in the Carlsbad Municipal Water District (CMWD) potable water distribution system that are non testable and non-compliant. CMWD staff again recommend a proactive program for the replacement of non-testable backflow prevention devices to protect the public water system and comply with State regulations and CMWD Ordinance 45.
Backflow Prevention Device Definition
Backflow prevention devices are typically privately-owned valve and piping assemblies that prevent back siphonage of private water and potential contaminants into the public water system, thereby protecting the public water supply. Backflow prevention devices are required by State and County public health laws and the city's Engineering Standards. Backflow failures present a risk to public health. If one fails, immediate corrective action is required, including shutting off large areas of the public water system and boil water orders 1.
Back siphonage may be caused when the pressure in the
public water system decreases, which may be caused by
water main breaks, flushing, pump failure, emergency
firefighting water demand, etcetera. Backpressure may
occur when heating, cooling, waste disposal, fire
protection or industrial manufacturing systems are
connected to potable supplies and the pressure in the
private system exceeds the pressure in the distribution system. Backpressure can result from an increase in
downstream pressure, a reduction in the potable water
supply pressure or both. Back siphonage and backpressure situations change the direction of water flow. If a backflow prevention device is not working, potentially contaminated water can flow back into the public distribution system. 1 Chemical and biological contaminants have caused illness and deaths during known incidents of backflow . Nationally, the number of incidents reported is believed to be a small percentage of the total number of backflow incidents that occur. The public health risk depends on the type and amount of contaminants, and the health effects of the contaminants.
Carlsbad Municipal Water District
5950 El Camino Real I Carlsbad, CA 92008 I 442-339-2722 White Paper on Non-testable Backflow Prevention Assemblies (Districts -All) June 28, 2022
Regulatory Environment
The California Health and Safety Code (CHSC) requires public water systems to control cross connections and distribute reliable healthy potable water {CHSC 11637{c)). This code also requires any person who owns a public water system to ensure that the system "complies with primary and secondary drinking water standards, will not be subject to backflow under normal operating conditions and provides a reliable and adequate supply of pure, wholesome, healthful, and potable water" {CHSC 116555 (a)).
California Code of Regulations Title 17, section 7605, which became effective on June 25, 1987, and CMWD Ordinance No. 45, which was adopted on June 2, 2009, requires that backflow prevention devices be tested to ensure that they function properly. Testing is required annually, by a certified third-party backflow tester that is hired by the private owner. In CMWD's service area, customers must use backflow testers on the CMWD approved list and the private owner must provide results to CMWD. In the CMWD service area there are 241 non-testable backflow devices, or four percent of total backflows, that continue to be out of compliance with this testing requirement.
Policy Handbook
Assembly Bill 1671, which the Governor signed on Oct. 6, 2017, requires the State Water Resources Control Board {State Board) to revise standards for backflow protection and cross connection control and authorizes the State Board to do so through adoption of a policy handbook. The Bill imposed a state-mandated local cross-connection control program. The proposed Cross Connection Control Policy Handbook {CCCPH) is intended to replace the Code of California Regulations Title 17 requirements to allow for more timely updates. The deadline for completion of the new standards handbook was Jan. 1, 2020.
The State Board published its intention to release a draft policy handbook in summer 2020. On Feb. 26, 2021, the State Board issued a preliminary draft policy handbook and opened the public comment period. Along with many agencies and water purveyors across the state, the CMWD submitted comments on the draft handbook. Staff has participated in workshops and discussions with the State Board, and much of the feedback and comments requested the State Board include technical advisory from academic, industry and field experts for assistance with revisions to the handbook. As of May 31, 2022, the State Board has not issued a second draft but has suggested it may be published later in 2022.
The draft policy handbook currently includes language stating that upon adoption of the handbook, the water supplier must submit a comprehensive cross-connection control plan within 12 months following adoption. The plan must adopt enforceable ordinances, designate a Cross Control Connection Program Coordinator, conduct systemwide hazard assessments, require backflow prevention, use of certified backflow assembly testers, implement backflow preventer testing, ensure accurate record keeping, ensure incident response and notification procedures, conduct public outreach, and coordinate with local entities (permitting, health officials, fire departments, etc.).
White Paper on Non-testable Backflow Prevention Assemblies (Districts -All) June 28, 2022
Non-testable Backflow Prevention Devices in the CMWD Water Distribution System Approximately 7,200 total backflow prevention devices within CMWD's service area are testable and in compliance with regulations. There are currently 241 known backflow prevention devices owned by 181 private owners on fire protection systems at sites in CMWD's service area that are non-testable and therefore, not in compliance with state regulations or CMWD Ordinance 45.
These non-testable backflow prevention devices were installed prior to the current State of California and CMWD regulations. Less than 4% of the total backflow prevention devices are non testable. The non-testable backflow prevention devices are located at a range of sites as shown below. About 28% are owned by small or local businesses.
Non-testable Backflow Prevention Device Ownership
(based on 2019 data)
1%/ 3% 6%
■ Vacant ■ School or Church
■ Hotel ■ National corporation
■ Investment group ■ Owners of multiple devices
■ Small or local business
CMWD's Ordinance 45 requires backflow preventers to be tested and if they cannot pass the test, the Public Works Director will notify the customer of required corrective action within 30 days followed by a second notice with 14 days for resolution and a final notice with 10 days for resolution. The State Board's draft policy handbook also has a 30-day deadline to repair failed devices. However, in 2019 staff found that the non-compliant backflow prevention devices had been "grandfathered" and CMWD had not required the owners to comply with state regulations or the city ordinance.
Current Situation
In October 2019, CMWD began the process of educating city leaders about the non-compliant backflow prevention devices and the potential health risk to the public water system. The cost to replace these devices ranges from $2,500 to $100,000 depending on the device size and location.
Staff recognized that replacement of these devices, and in some cases the service piping, requires a standardized process and realistic timelines for compliance because of the cost impact, the potential for work to occur in the public right-of-way and the need to isolate the White Paper on Non-testable Backflow Prevention Assemblies (Districts - All) June 28, 2022
public water main. In some cases, the replacement of domestic water services will be triggered by replacement of fire service piping, at additional cost, to comply with current standards. The 181 businesses that need to replace their devices are listed in Attachment A. Some businesses have more than one device on site. Attachment B is a map of non-testable backflow prevention device locations.
Currently, CMWD is requiring replacement of non-testable backflow devices on existing fire protection assemblies on a case-by-case basis. Since 2019, the city has replaced all four of its non-testable backflow prevention devices with testable devices. The current replacement process is triggered when the Utilities Department learns of planned or ongoing construction at relevant sites. For example, CMWD has requested the County of San Diego to require tenants to replace two non-testable backflow devices at the Palomar Airport in advance of a CMWD CIP pipeline replacement project. CMWD is also conditioning development projects during utility plan checks. CMWD staff proposed a citywide approach to replace the approximate 244 devices that are not in compliance over a period of between 1 to 5 years and would like to develop a plan and initiate a process as soon as possible.
Memoranda on this subject were sent to the CMWD Board on June 18, 2020, October 1, 2020, and June 3, 2021 (Attachment C), indicating that the CMWD is waiting for the State Board to adopt final standards. While the State Board adoption date is unknown, the current draft language in the policy handbook requires water agencies to develop and submit a plan to address these devices within 12 months of policy handbook adoption. Action is needed to uphold the legal responsibilities of professional engineers and certified water system operators and for compliance with state regulations.
Neighboring Agencies
CMWD has researched the work of several neighboring water purveyors with similar non testable backflow devices. Oliven ha in Municipal Water District and the City of San Diego have backflow ordinances and policies in place and are currently implementing education via website and published literature .
The City of San Diego Department Instruction 55.21 provides the basis for policies regarding backflow prevention. San Diego city staff notice approximately 38,000 customers for annual testing of their backflow devices. They estimate that the total backflow device inventory will increase by 15,000 in the coming years. San Diego believes that about ten percent of the current inventory of backflow devices are non-testable. The City of San Diego currently requires replacement of non-complaint devices during tenant improvement project reviews by their cross-connection review staff. They have implemented a weekly coordination meeting with fire inspection staff to coordinate device replacement requirements. They also conduct some enforcement via their cross-connection code enforcement including use of citations when annual testing is not submitted.
White Paper on Non-testable Backflow Prevention Assemblies (Districts -All) June 28, 2022
Olivenhain Municipal Water District's (OMWD) Cross Connection Control Ordinance 429 provides regulations for non-complaint backflow prevention devices. Sections E, F and G of this ordinance specifically address non complaint single check valves on fire protection systems. Section G allows for a 5-year grace period beginning Aug. 8, 2012, for owners to replace these devices. The OMWD initially sent letters to all owners of these devices and then followed up annually.
Beginning in 2015 OMWD staff began working to get their inventory of 87 non complaint devices replaced through frequent site visits referencing both State requirements in Title 17 and their local ordinance. Their current remaining devices to be replaced is 16, as replacements were not required during the COVID-19 pandemic. Per OMWD staff, while costs are burdensome, customers are generally moving towards compliance within two months following notices and follow-up site visits. The OMWD waived inspection and testing costs for their customers to encourage partnering on compliance . The OMWD collaborates with fire inspections to review all replacements as their Ordinance language specifically requires Fire Marshall approval of replacement plans prior to submittal to OMWD for review.
Non-testable devices Plan review
Water Supplier as percent of total triggers Code enforcement inventory replacement
Carlsbad MWD 4% Yes No partnership at present.
Code enforcement provides
uneven support when testing
City of San Diego 10% Yes certificates are not turned in to the cross-connection
division.
Annual letter to non-
compliant device owners and
Olivenhain MWD <4% Yes frequent site visits. OMWD
waived inspection costs to
encourage replacement with
testable devices.
City of Oceanside Has program, but no data is
available
Proposed Process
The CMWD staff present the following procedure to work with customers to replace non testable backflow prevention devices, protect the public water system and avoid potential fines or litigation. This process will address the risk to the public water supply in three years.
Customers will be given time to plan and budget for the replacements. Rolling out the requirement over three years will allow CMWD staff to provide sufficient support to customers as their deadline nears. The CMWD will have the time to develop an ordinance and training to strengthen enforcement capabilities. The process may need revision as staff move forward . Staff has reached out to the Fire and Planning Department, who will need to be involved in the process in certain replacement situations.
White Paper on Non-testable Backflow Prevention Assemblies (Districts -All) June 28, 2022
1. The CMWD will review and update its current inventory of non-testable devices including field inspection of some of the devices (located above grade, in a vault, serving multiple customers, etc.).
2. The CMWD will send a letter to each non-compliant business to provide educational information on the issue and inform them they will be receiving additional information regarding replacement requirements (protection of public water supply, regulatory compliance, submittals, deadlines, etc.).
3. The CMWD will prioritize each non-testable backflow device based upon a score that uses the following three factors:
o Likelihood of Failure - considers data such as the estimated device age, pipe age, and pipe material
o Consequence of Failure - considers data such as the size of device, size of water line that could be contaminated, the type of business and potential contaminants, the area affected, shutoff capability, and the impact to institutional settings, schools, and multi-family housing.
o Other - considers data such as unique business situations, street paving moratoriums, logistics of water shutdowns, and CIP project coordination
4. Communicate information, state requirements and resources to water customers who own non-testable backflow prevention devices via certified letters. Based on prioritization scoring, require construction plans for replacement be submitted within three months to one year and replacement per plans within 18 months to three years based on the priority scoring.
Beginning this process will result in a significant reduction of non-compliant backflow devices over the next three years to better protect the public water system and reduce public health risks and assist CMWD in State regulatory compliance.
Attachments: A. List of businesses with non-testable backflow devices B. Map of non-testable backflow prevention device locations C. CMWD memorandums date June 18, 2020, Oct. 1, 2020, and June 3, 2021 (Due to the size of Attachment C, these documents are not included as they have previously been distributed to City Council)
Non-testable Backflow Business Name
110 KNOLL LLC
2035 EQUICAP CARLSBAD
2500 NAVARRA HOA
2719 LOKER AVE WEST OWNERS ASC
505 OAK AVENUE PARTNERS LLC
5050 CARLSBAD LLC
5816 DRYDEN LLC
5838 EDISON PLACE LLC
5960 PASCAL CT LLC
5TH AXIS INC
ALEJANDRA'S COCINA
AN MOTORS OF FT LAUDERDALE INC
ARGONAUT MANUFACTURING INC
AVENIDA ENCINAS LP
BECKMAN CARLSBAD I LLC
BECKMAN COULTER INC
BEMER USA
BIG FUTURE PRESCHOOL
BIKES ONLINE INC
BKM DEL ABETO #242 LLC
BLUEHAT LLC
BOB BAKER AUTOMOTIVE INC
BOND RANCH
BRIAN SIPE
BROOKWOOD CARLSBAD EXEC PLAZA
BROOKWOOD PACIFIC OFFC II LLC
BUDDHA TEAS
BUFFINI AND COMPANY
CALLAWAY GOLF
CAP INVESTORS LLC
CARLSBAD 2200 LLC
CARLSBAD COMM CHURCH
CARLSBAD COMMERCE CNT INVST LP
CARLSBAD COMMERCE CTR
CARLSBAD POINT CORPORATION
CARLSBAD TECHNOLOGY INC
CARLSBAD UNIFIED SCHOOL
CCSD LLC
CEI OFFICE FUND 8 LLC
CHELSEA INVESTMENT CORP
CORTE DEL NOGAL PROPERTY LLC
COSTA VERDE HOA
COSTCO WHOLESALE CORP
Atta chmen t A
Non-testable Backflow Business Name
CVS PHARMACY STORE #09479
DOLLAR TREE STORES INC #02521
DOLLINGER PALOMAR OAKS LLC
DONAHUE SCHRIBER GROUP
DRAFT REPUBLIC CARLSBAD
DR'S OWN INC
DULCES REALTY LLC
ECOLINK INTELLIGENT TECH INC
EDISON PLACE LLC
EEVELLE LLC
EL CEDRO PROPERTIES LLC
EL FUERTE BUS PK INVESTORS LP
ENRICO PINAMONTI PROPERTY MANAGMENT
EXOTIC PEBBLES AND AGGREGATES
EXP 2290 COSMOS, LLC
FARADAY PROPERTIES LLC
FASHIONPHILE
FERGUSON ENTERPRISES INC
FINISHING TOUCH MILLWORK
FIRST INDUSTRIAL LP
FORECAST PRODUCT DEVELOPMENT
FRIARS RIVERDALE LTD
GILDRED DEVELOPMENT
GLENDORA MOTORCARS CO
GUNTHER LLC
H & P MOBILE GEOCHEMISTRY
HARSCH INVESTMENTS CORP
HAY HOUSE INC
HEDDA MAROSI LIVING TRUST
HOEHN ASSOCIATES
IMPERIAL SPRINKLER SUPPLY
INDUSTRIAL STRENGTH CORP
IONIS PHARMACEUTICAL
ISLAND BATIK
JAZZERCISE
JC PENNEY 0566-0
JUDY JONES
Kl SPEED
KAISER HEALTH PLAN
KRC PROP MANAGEMENT I INC
L-3 PHOTONICS
LA COSTA GREENS HOA
LA COSTA LIMOSINE
Attachment A
Non-tes t able Backflow Business Name
LDVF LA PLACE LLC
LEBRUNS LLC
LEGOLAND CALIFORNIA LLC
LLEWELLYN SHORES LTD
LV PRIESTLY DR LLC
M & P INDUSTRIAL PROPERTIES
M6 CARLSBAD LLC
MACY'S WEST V173333932 #17902A
MAJI INVESTMENTS INC
MARK THOMPSON
MARSHALLS INC #314
MCMURPHY DEVELOPMENTS
MCWIN CORPORATION
MEANS FAMILY TRUST
MERCOTAC
METROPOLITAN LIFE INS CO
MIGUELS CUCINA
MITCHELL LAND
MODUS ADVANCED
MOTEL 6 - SITE 000471
NATEL ENGINEERING
NATURAL ALTERNATIVE INTL
NELLI-REGEN THREE, LLC
NOB HILL HOA
NRG/CARLSBAD ENERGY CENTER
OLIVE GARDEN/DARDEN REST
OLIVE POINT HOA
OMNI LA COSTA LLC
OSTENDO TECHNOLOGIES
PACIFIC SALES
PACIFIC VIEW PLAZA
PALOMAR 14 CONDO ASSOC
PALOMAR AIRPORT CENTER LLC
PALOMAR OAKS POINTE
PALOMAR TRANSFER STATION INC
PARK HYATT AVIARA RESORT
PAYLESS/RITE AID #5622
PGP CARLSBAD SENIORS
PGP CARLSBAD SENIORS II
PHILIP ESBENSEN
PK 1 NORTH COUNTY PLAZA LP
PLAZA ENCINA PARTNERS
PLAZA FAMILY DENTAL
Attachment A
Non-testable Backflow Business Name
PLAZA PASEO REAL ASSOC LLC
PREMIER BUICK CADILLAC GMC OF CARLSBAD
PU ESTA DEL SOL
QOOLABS INC
RAF PACIFICA GROUP/FUND 4
RALPH'S #175 CARLSBAD
RBCO
REEF LIFESTYLE LLC
REXFORD INDUSTRIAL REAL TY LP
RIF Ill IMPALA LLC
RIF Ill YARROW DR LLC
RIF Ill YARROW II LLC
RISING GLEN LP
ROMBOTIS BROS
RONIN HOLDINGS LLC
ROWAN ELECTRIC
SD C PROPERTIES LLC
SM AC PARTNERS LP
SABRINA GREENS HOA
SAM MYS WOODFIRED PIZZA
SAN DIEGO HAT CO
SCROOSCOOP FASTENER
SENDX MEDICAL INC
SEVEN 8 FIVE GRAND LLC
SINCERI SENIOR LIVING
SKATEOPLEX
SMART & FINAL CARLSBAD 239
SOLANA BEACH BAKING CO
ST PATRICKS CHURCH
STREET PROPERTIES INC
SUPER 8 MOTEL
SVF LLC
SYMBIENT PRODUCT DEVELOPMENT
SYNERGEYES INC
SYNTRON BIORESEARCH
TAMARACK SHORES II HOA
TECH Bl LT CONST CORP
THE ALCHALEL REAL ESTATE INVESTMENT TRUST
THE GARDENS NURSING FACILITY
THE SHOPPES AT CARLSBAD
THOMAS RAGLAND TRUST
THRIFTY/RITE AID #5621
TORREY PINES SCIENTIFIC INC
Attachment A
Non-testable Backflow Business Name
TOTAL SOURCE MANUFACTURING
TOYOTA CARLSBAD
TRANSBORDER KIFFMAN LLC
TRUE DIAGNOSTICS, INC
TYLER COURT APTS
VANGUARD INDUSTRIES WEST INC
VERSUM MATERIALS US LLC
VONS STORE #62343 FAC #95-5732
WEIBOWANG
WELLS FARGO BANK
WESTERN FLIGHT INC
WILLIAM J KOTOFF
Attachment A
ATTACHMENT B - Map of Non-Compliant Backflow Prevention Devices 1P~@~F.•!E·W©Fi.A81
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