JB ENGINEERING AND CODE CONSULTING, P.C Cardinal Drive Munster, IN Phone: Fax:

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1 JB ENGINEERING AND CODE CONSULTING, P.C Cardinal Drive Munster, IN Phone: Fax: JULIUS A. BALLANCO, P.E. President July 9, Engineering Report - Analysis of Sure-Seal Trap Seal Protection Device Client: Scope: Abstract: Sure Seal, LLC P.O. Box Tacoma, WA (253) (253) facsimile Sure Seal LLC manufactures a line of floor drain trap seal protection devices. These devices are designed to prevent loss of the trap seal in a floor drain when the drain is infrequently used. Julius Ballanco, P.E., CPD, FASPE, President, JB Engineering and Code Consulting was asked to evaluate the floor drain trap seal protection devices for compliance with the IAPMO Uniform Plumbing Code, the ICC International Plumbing Code, and the ICC International Residential Code. Many floor drains are installed in a sanitary drainage system for emergency purposes. In the event of a leak, discharge of an emergency valve, or overflowing fixture, the floor drain provides drainage of the water. These floor drains are classified by the Plumbing Codes as emergency floor drains. When a floor drain is not used for an extended period of time, the water trap seal in the floor drain may evaporate. When the trap seal evaporates, sewer gas can leak into the building through this opening in the piping system. The purpose of a trap seal is to prevent the escape of sewer gas into the building. Originally, the method of addressing the evaporation of trap seals was the addition of water periodically to the floor drains. The plumbing industry developed a trap seal primer valve to automatically refill the trap seal. These valves are connected to the potable water supply and periodically discharge a small quantity of water to the trap. Page 1 of 7

2 A second style of trap primer connects to the waste pipe for a fixture. When the fixture is utilized, a small quantity of water is diverted to the trap seal for the floor drain. Sure Seal developed a floor drain trap seal protection device that neither relies on the connection to the potable water, nor the discharge of waste water. The Sure Seal has an elastomeric membrane that seals off the opening of the floor drain outlet, preventing the evaporation of the trap seal. The membrane opens to the drainage system when water or waste enters the floor drain. Sure Seal manufactures four different sizes of floor drain trap seal protection devices. The model numbers and size are, as follows: Model SS2009 Model SS3000 Model SS3509 Model SS inch 3 inch 3-1/2 inch 4 inch Standard Requirements: The national consensus standard regulating floor drain trap seal protection devices is ASSE This standard, entitled ASSE Standard Performance Requirements for Barrier Type Floor Drain Trap Seal Protection Devices, has performance requirements to determine the quality and performance of a product. The testing required in ASSE 1072 includes the following: Flow test Evaporation test Trap seal interference test Opening test Dirt and debris test Floor wax test Grease test Life cycle test Membrane material test Third Party Testing and Listing: Sure Seal had their floor drain trap seal protection devices tested to ASSE 1072 by SGS US Testing Company, Tulsa, OK. SGS US Testing Company issued three test reports on the Sure Seal products. Page 2 of 7

3 SGS US Testing Company Test Report No R2, dated March 18, 2008, was for a Model 3000 and The Model 3000 passed all of the test requirements of ASSE Both Models 3000 and 2000 were rated for all floors. SGS US Testing Company Test Report No. 654: R1, dated January 8, 2010, was for a Model The Model 2009 passed all of the test requirements of ASSE 1072 and was rated for all floors. SGS US Testing Company Test Report No. 654:031645, dated April 13, 2010, was for a Model SS4009. The Model SS4009 passed all of the test requirements of ASSE 1072 and was rated for all floors. A copy of the SGS US Testing Company, Inc. Test Reports are available on the Sure Seal website, The Sure Seal models are listed by IAPMO Research and Testing, Inc., File Number C-4165, as complying with ASSE The IAPMO listing can be reviewed on the IAPMO website, Plumbing Code Requirements: International Plumbing Code - Section requires all plumbing fixtures to have a separate liquid seal trap. This would include emergency floor drains. Section requires traps seals subject to loss by evaporation to have a trap seal primer valve installed. Section allows products to be approved as an alternative by the code official. A product must be proven to be equivalent to the requirements in the code to be accepted as an alternative material. Section allows an alternative engineered design. An alternative engineered design must conform to the intent of the code. International Residential Code - Section P requires all plumbing fixtures to have a separate water seal trap. Section P requires traps for floor drains to be fitted with a trap seal primer valve, or be of a deep seal design. Page 3 of 7

4 Section R allows products to be approved as an alternative by the code official. A product must be at least equivalent to the requirements in the code to be accepted as an alternative material. Uniform Plumbing Code - Section requires all plumbing fixtures to be separately trapped by an approved type of water seal trap. This would include all emergency floor drains. Section requires traps that are infrequently used to be protected with a trap seal primer, except where not deemed necessary by the authority having jurisdiction. Section allows a product to be approved as an alternate material. A product must demonstrate equivalency to the code to be approved. Section allows an alternative engineered design. An alternative engineered design must meet the intent of the code. Engineering Analysis: A trap seal is one of the most important parts of a sanitary drainage system. The trap seal isolates the sewer gas from the inside atmosphere. If the trap seal is lost, this level of protection of the inside atmosphere is also lost. Floor drains designed for emergency purposes rarely, if ever, have any water entering. Without periodic use, the trap seal can evaporate, allowing sewer gas to enter the inside environment. Some studies have shown that a trap seal evaporates approximately 1/16 of an inch a day. At this rate, a standard 2 inch trap seal will be lost in 32 days, allowing the escape of sewer gas. The Plumbing Codes require a trap seal primer when there is a possibility of a trap seal loss. Trap seal primers protect the trap seal by introducing a quantity of water into the trap. If a trap seal primer fails to discharge water for a period of time, the trap seal can still evaporate. This is why the design and installation of a trap seal primer is crucial to the protection of the trap seal. Some water supplied trap seal primers open based on the pressure loss in the piping system. Depending on the plumbing design, the trap seal primer may never open, or it may open many times in a given day. If the valve does not open, the trap seal is not protected. If the valve opens numerous times, there is a waste of potable water. Page 4 of 7

5 Similarly, drainage type trap seal primers rely on the use of the fixture to which they are connected. If the fixture is rarely used, the trap seal can still evaporate. Trap seal primers may require periodic maintenance to remain operational. Without this maintenance, the trap seal is not replenished, and protection of the trap seal is not provided. It is estimated that a high percentage, approaching 30 percent, of trap seal primers are either improperly installed, providing no protection of the trap seal, or malfunctioning, also providing no protection of the trap seal. The Sure Seal models provide protection from evaporation by closing off the opening to the trap seal. This prevents water in the trap seal from evaporating. If the trap seal is lost, the Sure Seal models prevent the escape of sewer gas into the interior environment. While this is not the purpose of the elastomeric membrane, it will provide this level of protection. The national consensus standard, ASSE 1072, provides a means of evaluating any product for its ability to protect a floor drain trap seal. The Sure Seal products meet all of the requirements in this standard and are so listed by IAPMO Research and Testing, Inc. This listing verifies that the products comply with the standard. Compliance with the ASSE 1072 standard also verifies that the Sure Seal models do not restrict the flow into a floor drain. The Sure Seal models allow the maximum flow permitted by the plumbing code to flow into the drain. The standard also verifies that the Sure Seal models will function properly under adverse conditions, such as the introduction of dirt, floor wax, or particles that could hold the membrane partially open. Under these conditions, the Sure Seal models prevent the evaporation of the trap seal while allowing the proper operation of the floor drain. The Sure Seal models are all equivalent to the Plumbing Code requirements for protection of the floor drain trap seal. The Sure Seal models will prevent evaporation of the trap seal. This is equivalent to providing a supply of water, or waste water, periodically to the trap seal, as provided by a trap primer. Unlike trap primers, when a failure occurs, the Sure Seal models provide a second line of defense against the escape of sewer gas. This level of protection exceeds the requirements in the Plumbing Code. Page 5 of 7

6 Section of the ICC International Plumbing Code requires any alternative product to be at least equivalent to the requirements in the code. The Sure Seal models are equivalent. Additionally, they provide an added level of health protection not currently required by code. The Sure Seal models can be accepted as an alternative product for protection of a floor drain trap seal. Section R of the ICC International Residential Code requires any alternative product to be at least equivalent to the requirements in the code. The Sure Seal models are better than a deep seal trap, hence they are more than equivalent. Additionally, they provide an added level of health protection not currently required by code. The Sure Seal models can be accepted as an alternative product for protection of a floor drain trap seal. Section of the IAPMO Uniform Plumbing Code requires any alternate product to demonstrate equivalency. The Sure Seal models have demonstrated equivalency to the requirements in the code by conformance to ASSE Additionally, they provide an added level of health protection not currently required by code. The Sure Seal models can be accepted as an alternate product for protection of a floor drain trap seal. The Sure Seal models can be used as a part of an engineered plumbing design since they provide a level of protection of the floor drain trap seal. This meets the intent of the Plumbing Codes. Conclusions: In my professional engineering opinion, after reviewing the product and the test reports, with my engineering knowledge in this field, to a reasonable degree of engineering certainty, the following conclusions are listed: 1. The Sure Seal Models SS2009, SS3000, SS3509, SS4009 provide an equivalent level of protection of a floor drain trap seal when properly installed in accordance with the manufacturer s instructions. 2. The Sure Seal Models SS2009, SS3000, SS3509, SS4009 comply with the requirements of the ICC International Plumbing Code and ICC International Residential Code as an alternative material. 3. The Sure Seal Models SS2009, SS3000, SS3509, SS4009 comply with the requirements of the IAPMO Uniform Plumbing Code as an alternate material. 4. The Authority Having Jurisdiction should accept the installation of the Sure Seal Models SS2009, SS3000, SS3509, SS4009 as an alternative material, meeting the intent of the code for protection of the floor drain trap seal. Page 6 of 7

7 Certification: This report was prepared by Julius Ballanco, P.E., President, JB Engineering and Code Consulting, P.C., registered as a Professional Engineer in the State of Indiana, license number PE JB Engineering and Code Consulting, P.C. is a registered Engineering Professional Corporation in the State of Indiana, license number PC Cordially yours, Julius Ballanco, P.E., CPD, FASPE President Page 7 of 7