July’s Newsletter reviews Deficiency #1 under the Water Heater Standard – this will be a long Newsletter. Deficiency #1 is considered a Severe Health & Safety – a 24-hour repair for MF and PHAs and a 30-day repair for HCV/PBV/CPD Programs.
For properties that get a REAC score, this works out to be 0.59 points PER UNIT on a 100-unit property. If every Unit is cited, the property would lose 14.75 points. Properties with less than 93 total units, the scoring would be higher than 0.59 each.
What is a TPR Valve?!
It stands for Temperature and Pressure Relief Valve. It’s a VERY important safety valve that makes sure you water heater/boiler stays within its designed temperature and pressure limits. If the temperature or pressure exceeds a certain threshold, the valve will open and discharge the steam/water! The valve has a discharge pipe attached to it that is plumbed to the waste receptor, the floor, or outside (code varies on this – it’s dependent on which state your property is in).
MythBusters ran a bunch of tests on water heaters by plugging the TPR Valve and increasing the temperature and pressure. You can see their videos here (these are older videos – don’t full-screen them):
https://www.youtube.com/watch?v=rGWmONHipVo
https://www.youtube.com/watch?v=JmJoyuUJj2Q
Deficiency Criteria – Breaking it down:
1. TPR Valve has an active leak It is interesting that HUD wants a leak cited under the Water Heater Standard because if you look at the Leak-Water Standard (which is a MODERATE H&S), it states:
So why would HUD want the inspector to cite a leaky TPR Valve under the Water Heater Standard instead of Leak-Water? I can only surmise that it’s because a leaky TPR Valve should be taken very seriously. It can leak for a number of reasons, but ultimately it is not supposed to leak, and you do NOT want this valve to fail!
2. TPR Valve is obstructed such that the TPR Valve is unable to be fully actuated.
First – it’s a really good idea to activate the TPR valve on your water heaters at least once a year.They can malfunction or become stuck after years of non-usage.Inspectors are NOT instructed by HUD to activate the valve, but since it’s one of the most important safety valves, you would not want to wait until if failed to find out there is a problem!
Otherwise, make sure that the other pipes/walls do not interfere with the valve function.
3. Relief valve discharge piping is damaged, capped, has an upward slope, or is constructed of unsuitable material. This is where it starts getting a little complicated.
There are 2 plumbing codes accepted in the United States – the Uniform Plumbing Code (UPC) and the International Plumbing Code (IPC).Then you have states adopting only parts of each or making up their own!This map is pretty fantastic, although dated 2015, I believe there is very little variation today:
The main difference between the 2 codes (regarding TPR Valve discharge pipes) is on the termination point – we’ll discuss that more when I feature Water Heater Deficiency #3, or you can always just reach out to me via phone/email/text. I included the code requirements for discharge pipes at the bottom of this Newsletter, for your reference.
“Damaged Piping”
I do not like the fact that HUD stated a “damaged” discharge pipe should be cited because it’s not objective enough. The only other information HUD gives is that to be damaged, it must be “visibly defective and/or impact functionality.” With that description in mind, let me give you an example.
Example: Both codes prohibit valves and tee fittings connected to the discharge pipe itself…would an inspector consider that “damaged?” Does it impact functionality? Absolutely! If you do not agree – but the inspector cited it – how could you possibly appeal and win the points back when it doesn’t meet code?
“Capped”
Pretty self-explanatory. You cannot BLOCK the TPR Valve in any way (see MythBusters links above).
“Upward Slope”
The discharge must be sloped to drain. This means it must be able to use gravity to discharge or flow. You do not want water to just sit inside the discharge pipe because it will cause deposits to build up blocking flow or corroding the pipe. Additionally, if the valve is leaking – you’re going to want to know that sooner rather than later.
“Constructed of Unsuitable Material”
Fortunately, HUD got specific here and copied part of the code:
Personally, I like this one better because it gives you specific references to the ASTM (American Society of Testing Materials) Standard:
If PEX is used…it must be 1-inch (not 3/4″) and must be secured. I have never seen braided or corrugated flex piping approved by ASTM for the use of discharge piping from the TPR Valve. Most of the time, even though listed as 3/4″, it reduces inside the pipe, which is strictly prohibited. Additionally, it’s too easy to crimp or flex the pipe into configurations that are also prohibited!
I have literally thousands of water heater pictures with improperly installed TPR Valve discharge piping. It is MUCH more common than you may think! Let’s see some pictures…
UPC = Uniform Plumbing Code
IPC = International Plumbing Code
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