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  1. #1
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    Red face Section 8 Water Heater Code Interpretation

    Hello,

    I need help from you experts. Recently Section 8 (Department of Community Affairs) inspected a rental property of mine and asked me to make a repair to the water heater that the current water drain line from the T&P valve cannot "go above" the water heater (see attached picture) and therefore needs to have an expansion task in between. I am completely puzzled by this code that I requested to be sent in the mail. I really do not see anything wrong in this water heater installation (the drain line goes up in the reverse L shape and into the wall and down outside the house). Plus the expansion tank to my knowledge is for a different purpose and should be installed on the cold water supply line if needed. But I sense I cannot reason with the government unless I have an expert explanation / defense of my case. I really appreciate your responses.

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  2. #2
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    Default Re: Section 8 Water Heater Code Interpretation

    IRC 2803.6.1 / UPC 608.5

    Requirements for discharge pipe. The discharge piping serving a pressure relief valve, temperature-relief valve or combination valve shall:
    1. Not be directly connector the the drainage system.
    2. Discharge through an air gap located in the same room as the water heater.
    3. Not be smaller than the diameter of the outlet of the valve served and shall discharge full size to the air gap.
    4. Serve a single relief device and shall not connect to piping serving any other relief device or equipment.
    5. Discharge to the floor, to an indirect waste receptor or to the outdoors. Where discharing to the outdoors in areas subject to freezing, discharge piping shall be first piped to an indirect waste receptor through an air gap located in a conditioned area.
    6. Discharge in a manner that does not cause personal injury or structural damage.
    7. Discharge to a termination point that is readily observable by the building occupants.
    8. Not be trapped.
    9. Be installed to flow by gravity.
    10. Not terminate more that 6 inches above the floor or waste receptor.
    11. Not have a threaded connection at the end of the piping.
    12. Not have valves or tee fittings.
    13. Be constructed of those materials listed in section P2904.5 or material tested, rated, and approved for such use in accordance with ASME a1132.2.4.1.

    Your pipe goes up. Water does not flow uphill. Had the pipe gone straight out the wall instead of first rising and then going out, it would have been OK (presuming it turns down once it passes through that wall).

    Yeah, the expansion tank is for the cold water in flow. Also a good idea to have one of those.

    The last "plumber" did a crappy job and slathered solder all over the pipes. Looks like past leaks on the wall under the shutoff valve.

    Is that just old age dust and dirt on top of the water heater or is it soot from backdrafting?

    "The Code is not a peak to reach but a foundation to build from."

  3. #3
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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by H Wang View Post
    Hello,

    I need help from you experts. Recently Section 8 (Department of Community Affairs) inspected a rental property of mine and asked me to make a repair to the water heater that the current water drain line from the T&P valve cannot "go above" the water heater (see attached picture) and therefore needs to have an expansion task in between. I am completely puzzled by this code that I requested to be sent in the mail. I really do not see anything wrong in this water heater installation (the drain line goes up in the reverse L shape and into the wall and down outside the house). Plus the expansion tank to my knowledge is for a different purpose and should be installed on the cold water supply line if needed. But I sense I cannot reason with the government unless I have an expert explanation / defense of my case. I really appreciate your responses.
    What you are talking about makes no sense.

    Expansion tanks are to be connected on the supply line.

    Now in your picture you show a TPR line that is installed wrong. TPR valves can not go up! They must go down so that gravity will drain any water from the line. The reason they can not go up is that water could accumulate in the pipe and prevent the valve from working properly. Then the tank could explode and demolish the house.

    Scott Patterson, ACI
    Spring Hill, TN
    www.traceinspections.com

  4. #4
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    Default Re: Section 8 Water Heater Code Interpretation

    Georgia has amended the code for the TPR drain line.
    This is the amendment, and a link to the amendment:

    504.6 Requirements for discharge piping. The relief valve shall discharge full size, separately to a safe place of disposal such as a concrete floor, outside the building, an indirect waste receptor, or other approved location. The discharge shall terminate in a manner that does not cause injury to occupants in the immediate area or structural damage to the building. When the relief valve discharge piping goes upward, a thermal expansion control device shall be installed on the cold water distribution or service pipe in accordance with Section 607.3.2. If the discharge pipe is trapped, provisions shall be made to drain the low point of the trapped portion of the discharge pipe.
    (Effective January 1, 2007)
    http://www.dca.state.ga.us/developme...IPC%202007.pdf


    The expansion tank goes on the cold water side between the water heater and the shutoff valve.



    ' correct a wise man and you gain a friend... correct a fool and he'll bloody your nose'.

  5. #5
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    Default Re: Section 8 Water Heater Code Interpretation

    I suspect 2 deficiencies.
    1. The TPR valve discharge tube needs to go straight out and down to within 6" of the floor. Period. (Why do people insist they need to have that thing dump outside? No water comes out unless there is a problem with excess pressure, or a faulty valve. If it's still a worry, place a pan under the end of the discharge tube, to catch the drip if there ever is a drip.)

    2. They want you to install an expansion tank. This is becoming the rule where check valves are installed on the water line. Pressure builds up in the household plumbing supply, so the expansion tank prevents burst pipes. Cheap insurance for you. If you need to go even cheaper, there is an expansion Valve that may be allowed. It uses a discharge pipe. If you mount it high, it can discharge out thru that hole in the wall. BTW, I am not a plumber, not even a scientist, so don't ask me for details.

    John Kogel, RHI, BC HI Lic #47455
    www.allsafehome.ca

  6. #6
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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by Rick Cantrell View Post
    Georgia has amended the code for the TPR drain line.
    This is the amendment, and a link to the amendment:

    504.6 Requirements for discharge piping. The relief valve shall discharge full size, separately to a safe place of disposal such as a concrete floor, outside the building, an indirect waste receptor, or other approved location. The discharge shall terminate in a manner that does not cause injury to occupants in the immediate area or structural damage to the building. When the relief valve discharge piping goes upward, a thermal expansion control device shall be installed on the cold water distribution or service pipe in accordance with Section 607.3.2. If the discharge pipe is trapped, provisions shall be made to drain the low point of the trapped portion of the discharge pipe.
    (Effective January 1, 2007)
    http://www.dca.state.ga.us/developme...IPC%202007.pdf


    The expansion tank goes on the cold water side between the water heater and the shutoff valve.

    Rick, I thought TREC rules were convoluted but that one takes the cake. For the life of me I cannot see why they would link a thermal expansion control device with the TPR when making an allowance for a wrong installation...???

    Jim Luttrall
    www.MrInspector.net
    Plano, Texas

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    Default Re: Section 8 Water Heater Code Interpretation

    For the ife of me I cannot see why they would link a thermal expansion control device with the TPR when making an allowance for a lwrong installation...???

    Is it wrong if it's been amended?

    ' correct a wise man and you gain a friend... correct a fool and he'll bloody your nose'.

  8. #8
    H Wang's Avatar
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    Default Re: Section 8 Water Heater Code Interpretation

    I appreciate very much the responses, especially Rick the DCA amendment you found for me. Now I feel like a complete fool as a) I did not ask the Section 8 inspector clearly why/what exactly the drain line is wrong, and to the worse, b) I could not/still can't connect the drain pipe with the expansion tank based on a couple of late night studies on internet. And the last thing I have to admit, my wife who does not know anything about plumbing outsmarted me once again (just be done with it while you have your Hispanic worker out there with you). And I did not a few days ago. Now I have to pay the guy again...

    Enough said, I think I should install an expansion tank on the cold water supply line for sure. Should I leave the drain pipe "wrong as is"? Should I even attempt to do the expansion tank myself (while not sure when to become handy)?

    By the way, Bruce, there should be dirt or dust on top of the water heater. But I'll double check since I wasn't at all pay attention to detail.

    I'll share more info once I receive it from DCA. Thanks again.


  9. #9
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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by Rick Cantrell View Post
    For the ife of me I cannot see why they would link a thermal expansion control device with the TPR when making an allowance for a lwrong installation...???

    Is it wrong if it's been amended?
    Still wrong if you follow the manufacturer's installation instructions... right?
    From Watts:
    WARNING: To avoid water damage or scalding due to valve operation, discharge line must be connected to valve outlet and run to a safe place of disposal. Discharge line must be as short as possible and be the same size as the valve discharge connection throughout its entire length. Discharge line must pitch downward from the valve and terminate at least 6" (152mm) above a drain where any discharge will be clearly visible. The discharge line shall terminate plain, not threaded. Discharge line material must conform to local plumbing codes or ASME requirements. Excessive length over 30' (9.14m), or use of more than four elbows or reducing discharge line size will cause a restriction and reduce the discharge capacity of the valve.


    Jim Luttrall
    www.MrInspector.net
    Plano, Texas

  10. #10
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    Default Re: Section 8 Water Heater Code Interpretation

    That offset in the vent connector shouldn't be so close to the draft hood, there should be uninterupted vertical rise for several inches more before offset or change in direction. The manufacturer's installation and owners manuals have references regarding same, and oftentimes refer to standards references regarding venting of same.

    Even if Georgia allows a TPRV discharge to go UP it shouldn't change direction immediately at its(valve's) outlet (90). The TPRV manufacturer's Listed instructions should prevail in this case (more restrictive than Georgia's plumbing requrements apparently). The mfg also limits the overall length and changes in direction, offsets.

    Apparently you are a "landlord" and you employ unskilled, non-professional plumbing "help" and DIY repairs on rental units, some of which are rented by those receiving subsidies for housing.

    Not aware of what restrictions may be specified in the law/codes in Georgia, regarding plumbing in rental occupancies by unskilled 3rd parties, but when it comes to essential appliances, and those as "dicey" as fuel fired appliance installations, especially water heaters or boilers, I'd suggest you employ a QUALIFIED PROFESSIONAL for your installations, remediations, repairs and servicing.


  11. #11
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    Default Re: Section 8 Water Heater Code Interpretation

    Jim
    I did not write the code, I just posted it.

    ' correct a wise man and you gain a friend... correct a fool and he'll bloody your nose'.

  12. #12
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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by H.G. Watson, Sr. View Post
    That offset in the vent connector shouldn't be so close to the draft hood, there should be uninterupted vertical rise for several inches more before offset or change in direction. The manufacturer's installation and owners manuals have references regarding same, and oftentimes refer to standards references regarding venting of same.

    Even if Georgia allows a TPRV discharge to go UP it shouldn't change direction immediately at its(valve's) outlet (90). The TPRV manufacturer's Listed instructions should prevail in this case (more restrictive than Georgia's plumbing requrements apparently). The mfg also limits the overall length and changes in direction, offsets.

    Apparently you are a "landlord" and you employ unskilled, non-professional plumbing "help" and DIY repairs on rental units, some of which are rented by those receiving subsidies for housing.

    Not aware of what restrictions may be specified in the law/codes in Georgia, regarding plumbing in rental occupancies by unskilled 3rd parties, but when it comes to essential appliances, and those as "dicey" as fuel fired appliance installations, especially water heaters or boilers, I'd suggest you employ a QUALIFIED PROFESSIONAL for your installations, remediations, repairs and servicing.
    See it on a daily basis with HUD HQS inspections. Joe the handyman making repairs when he has no clue as to what he is doing. Now that you know that the installation is not correct, your liability just went way up. If you ignore it and something terrible happens someone else will end up owning your properties. Hire a licensed professional and make it right.

    Galen L. Beasley
    Inspections Supervisor
    Housing Authority of Kansas City MO

  13. #13
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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by H Wang View Post
    Should I leave the drain pipe "wrong as is"? Should I even attempt to do the expansion tank myself (while not sure when to become handy)?
    No, you should not leave it "wrong as is". Thats just plain lazy. Hire a licensed plumber to fix it to meet plumbing code. Don't let some lame handyman foul it up even more. Fix it correctly.

    "The Code is not a peak to reach but a foundation to build from."

  14. #14
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    Default Re: Section 8 Water Heater Code Interpretation

    I wasn't clear on one issue. If you correct the relief valve piping, do you still need to install the expansion tank? Correcting the relief valve piping isn't too difficult of a job, depending on the position of the tank. Actually, neither job is that difficult for a plumber.

    Jim Robinson
    New Mexico, USA

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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by Rick Cantrell View Post
    Georgia has amended the code for the TPR drain line.
    This is the amendment, and a link to the amendment:

    504.6 Requirements for discharge piping. The relief valve shall discharge full size, separately to a safe place of disposal such as a concrete floor, outside the building, an indirect waste receptor, or other approved location. The discharge shall terminate in a manner that does not cause injury to occupants in the immediate area or structural damage to the building. When the relief valve discharge piping goes upward, a thermal expansion control device shall be installed on the cold water distribution or service pipe in accordance with Section 607.3.2. If the discharge pipe is trapped, provisions shall be made to drain the low point of the trapped portion of the discharge pipe.
    (Effective January 1, 2007)
    http://www.dca.state.ga.us/developme...IPC%202007.pdf


    The expansion tank goes on the cold water side between the water heater and the shutoff valve.


    The Georgia code does say : If the discharge pipe is trapped, provisions shall be made to drain the low point of the trapped portion of the discharge pipe.

    In my opinion this would be the least you could do to make the installation safe.


  16. #16
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    Default Re: Section 8 Water Heater Code Interpretation

    I found this interesting from Arilington TX City of Arlington, TX :: Government :: Community Development & Planning :: Building Inspections :: Frequently Asked Questions

    1. WATER HEATERS IN THE GARAGE: If I have an existing electric or gas water heater in or accessible from the garage, must I raise it 18 inches above the floor level when it is replaced?
    YES… At one time Arlington allowed electric water heaters to be installed on the floor of a garage, however codes have been changed to prevent accidents. The water heater thermostat energizes the heating element when the water temperature within the tank falls below a certain selected level. At the instant the thermostat activates, a spark results. This spark is a source of ignition for flammable or combustible vapors, (i.e., gasoline) that may have accumulated along the garage floor. The 18-inch elevation is intended to keep ignition sources above these vapors that are heavier than air and settle to the garage floor.


    Don Hester
    NCW Home Inspections, LLC
    Wa. St. Licensed H I #647, WSDA #80050, http://www.ncwhomeinspections.com

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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by Don Hester View Post
    I found this interesting from Arilington TX City of Arlington, TX :: Government :: Community Development & Planning :: Building Inspections :: Frequently Asked Questions

    1. WATER HEATERS IN THE GARAGE: If I have an existing electric or gas water heater in or accessible from the garage, must I raise it 18 inches above the floor level when it is replaced?
    YES… At one time Arlington allowed electric water heaters to be installed on the floor of a garage, however codes have been changed to prevent accidents. The water heater thermostat energizes the heating element when the water temperature within the tank falls below a certain selected level. At the instant the thermostat activates, a spark results. This spark is a source of ignition for flammable or combustible vapors, (i.e., gasoline) that may have accumulated along the garage floor. The 18-inch elevation is intended to keep ignition sources above these vapors that are heavier than air and settle to the garage floor.
    The "Point of Ignition" needs to be 18 inches above the floor. So the water heater may be less than 18 off the floor as long as the lower thermostat is at least 18 inches off the floor. Splitting hairs, I know. Easier just to use a standard 18 inch water heater stand than argue the finer point the thermostat needs to be 18 inches.

    "The Code is not a peak to reach but a foundation to build from."

  18. #18
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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by Bruce Ramsey View Post
    The "Point of Ignition" needs to be 18 inches above the floor. So the water heater may be less than 18 off the floor as long as the lower thermostat is at least 18 inches off the floor. Splitting hairs, I know. Easier just to use a standard 18 inch water heater stand than argue the finer point the thermostat needs to be 18 inches.
    Bruce,

    I point that same thing out fairly often, and as you indicated, a standard water heater stand height raises the water heater 18" off the floor - much cheaper to install a standard water heater stand than to custom make one that only raises the water heater 11" off the floor which raises the bottom element or thermostat to 18" off the floor.

    If they can enclose a gas water heater to not have to be raised off the floor, one would think that it would not take much to enclose an electric water to not have to raise it off the floor??

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  19. #19
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    Default Re: Section 8 Water Heater Code Interpretation

    I think I posted this on the wrong thread. Ooops Had two threads open.

    Don Hester
    NCW Home Inspections, LLC
    Wa. St. Licensed H I #647, WSDA #80050, http://www.ncwhomeinspections.com

  20. #20
    Loren Sanders Sr.'s Avatar
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    Default Re: Section 8 Water Heater Code Interpretation

    Quote Originally Posted by H Wang View Post
    Hello,

    I need help from you experts. Recently Section 8 (Department of Community Affairs) inspected a rental property of mine and asked me to make a repair to the water heater that the current water drain line from the T&P valve cannot "go above" the water heater (see attached picture) and therefore needs to have an expansion task in between. I am completely puzzled by this code that I requested to be sent in the mail. I really do not see anything wrong in this water heater installation (the drain line goes up in the reverse L shape and into the wall and down outside the house). Plus the expansion tank to my knowledge is for a different purpose and should be installed on the cold water supply line if needed. But I sense I cannot reason with the government unless I have an expert explanation / defense of my case. I really appreciate your responses.
    A poster below suggests you get a licensed plumber for this repair... if you do, your solder joints won't appear as if solder is cheap and to be wasted. Your copper piping shows a lack of knowledge of soldering. If it were my home I would have your plumber heat up those joints and remove them, clean them and re-solder so I could get a good nights sleep. You cannot imagine how many solder joints plumbers have taken apart to find voids where solder didn't filled the cup entirely....poor skills or carelessness. Soldering is a science more than an art. The plumber must create the conditions for a proper joint, beginning with cleaning the pipe and fittings and applying the proper flux to inside the fitting and outside the tubing... control of the flame with the right amount of heat to move the solder to where you want it is then necessary to complete a proper joint. Class dismissed.... sorry about that guys. Just got carried away....

    Last edited by Loren Sanders Sr.; 03-31-2014 at 09:24 AM. Reason: Answer not complete

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