Establishing a Compliant Cross-Connection Control and Backflow Prevention Program

1. Establishing a Compliant Cross-Connection Control and Backflow Prevention Program By: Pennsylvania Water Specialties Company (PAWSC) Brian J. Preski, Vice- President PA Municipal Authorities Association Conference September, 2017

2. PUBLIC WATER SUPPLY MANUALPART VII CROSS-CONNECTION CONTROL/BACKFLOW PREVENTIONAuthority: Pennsylvania’s Safe Drinking Water Act (35 P.S. §721.1 et seq.) and regulations at 25 Pa. Code Chapter 109INTRODUCTION The Department of Environmental Protection (DEP) is authorized under the Pennsylvania Safe Drinking Water Act to establish standards for the construction of a water supply to assure compliance with the provisions of the act. Accordingly, Section 109.608 of DEP’s rules and regulations, requires that “a public water system may not be designed or constructed in a manner which creates a cross-connection.” In addition, Section 109.709(b) further requires that “At the direction of DEP, the public water supplier shall develop and implement a comprehensive control program for the elimination of existing cross-connections or the effective containment of sources of contaminations, and prevention of future cross-connections.” The purpose of this part of the Public Water Supply Manual is to provide the basic information needed to develop this program.

3. Cross-connection– An arrangement allowing either a direct or indirect connection through which backflow, including backsiphonage, can occur between the drinking water in a public water system and a system containing a source or potential source of contamination, or allowing treated water to be removed from any public water system, used for any purpose or routed through any device or pipes outside the public water system, and returned to the public water system. The term does not include connections to devices totally within the control of one or more public water systems and connections between water mains.

4. Types of Backflow - Backpressure • Backpressure • Backpressure incidents can occur when the pressure on an individual system exceeds the pressure in the distribution system, resulting in undesirable gasses or liquids being introduced into the drinking water supply. • Some examples include: ● A car wash that re-circulates soapy water ● A manufacturing plant that uses substantial water pressure for production

5. Types of Backflow - Backsiphonage • Backsiphonage • When a negative or reduced pressure is applied at a building’s tap, creating the potential for contaminants to be siphoned into the drinking water system. • A pressure change could be caused by: ● Heavy water usage on the system (i.e. fighting a large fire) ● Water main breaks ● Unauthorized use of a fire hydrant

6. The Law • In pertinent part, the Pennsylvania Safe Drinking Water Act, 25 PA Code Chapter 1090 states: • 1. No person may introduce contaminants into a public water supply through a service connection of a public water system: • 1. It shall be the responsibility of the customer to eliminate cross-connection or provide backflow devices to prevent contamination of the distribution systems from both backsiphonage and backpressure. Individual backflow preventers shall be acceptable to the public water supplier. • 2. If the customer fails to comply with paragraph (1) within a reasonable period of time, the water supplier shall discontinue service after reasonable notice has been made to the customer.

7. What are the consequences of having no program?

8. A: Comprehensive plan that helps to prevent, or at least significantly reduce, the threat of contamination of the potable water system from non-potable substances due to backflow caused by backpressure and/or backsiphonage. Q: What is a cross-connection control program or plan?

9. Qualified Personnel: You started that process today. Periodic quality training is required. Public Education: Education is essential for both preventing backflow incidents and to convince the public that backflow is a serious threat to the public water system and to public health. Sample Forms: Samples are available online or through agencies like the DEP. Legally Defensible Even a small public water system could have hundreds of backflow Record Keeping: assemblies in their system that they need to track. Certified Testers: Devices will never be tested properly without local certified testers. Enforcement: Consistent enforcement is an absolute, otherwise your plan will fall into non-compliance and subject your system to DEP fine or other action. Cross-Connection Control Plan Components

10. 10 Steps to a Cross-Connection Control Program Step 1: Understand Cross-Connection Control Concepts Step 2: Establish a Legal Foundation Step 3: Establish a Priority System Step 4: Estimate Customer Implementation Costs Step 5: Develop Implementation Timetable Step 6: Review your Proposed Plan with Government Agencies as required Step 7: Educate the Public Step 8: Notify Affected Customer Step 9: Monitor Program Progress Step 10: Initiate Installation & Testing Requirements

11. Step 1: Understand Cross-Connection Control Concepts • There must be a core of at least one or two people that are educated enough to create, implement, and enforce a program in order for it to be successful. This core person(s) will at least “spearhead” the CCC Administration Plan efforts and will be the main resource for backflow issues. • Eventually all involved parties operators, testers, administrators, plumbers, politicians, and the public should understand, at least, the basics of backflow and that it happens much more often that people think.

12. Containment Level Protection Containment protection is when the public water system is protected at the service connection only. Containment protection will ensure that backflow will not occur out into the public water distribution system. However, backflow could still occur inside the building, downstream of the backflow prevention device, putting occupants at risk. Containment protection usually means that a backflow preventer was installed just downstream of the meter. Many cross-connection control plans will only require containment protection. People need to understand that containment protection will not provide total protection.

13. ISOLATION LEVEL PROTECTION Isolation protection (point of use isolation) is protection at each cross-connection within the building. This means backflow protection of some kind must be installed on all cross-connections that are identified after (downstream) the meter. Air gaps and devices from the “vacuum breaker family”, as well as those devices that are used for containment, are commonly used for isolation protection. In most cases internal protection requirements are governed by plumbing codes like The International Plumbing Code (ITC) 2009.

14. Combining Protection Combining protection is often necessary for facilities that pose an extreme health risk. For example, a wastewater treatment facility may require protection at the point of use and at the service connection. Combining protection can often eliminate installation problems and can sometimes even save the customer money by avoiding having to install a large more expensive device on the service connection for containment only.

15. Step 2: Establish a Legal Foundation What should your ordinance contain to ensure it is complete? - Authority to enter customer’s premises - This authority will very between privately owned systems and municipal systems. Solicitor advice needed.. - Provisions for the discontinuance of service - You must have the legal authority to terminate water service to those customers that are non-compliant. Discontinuance of water service should be a last resort after at least 3 attempts have been made to gain compliance. - Inspector and Installer certification requirements - Inspection frequency – Annually. - Hydrant Use Restrictions.

16. Step 2: Establish a Legal Foundation (cont.) What should your ordinance contain to ensure it is complete? - Penalties for non-compliance – Beyond service termination (?). • Exterminator restrictions • Backflow prevention assembly installation specifications • Geothermal HVAC System restrictions - Auxiliary water system restrictions – Interconnections between systems.

17. Legal Basis

18. Chapter 109.608: Is your own house in order? • Ironically water plants often have inadequate cross-connection control at best. • Everything from chemical feed injection lines, chase water lines, raw water pump priming lines, laboratories, backwash water lines, and last but not least, hose bibbs and yard hydrants. • All devices should be tested by a qualified certified tester at least annually. • Water Treatment Facilities should be held to the highest standard and should set the example for everyone else to follow.

19. DEP Regulations Chapter 109.709 • (b) At the direction of the Department, the public water supplier shall develop and implement a comprehensive control program for the elimination of existing cross-connections or the effective containment of sources of contaminations, and prevention of future cross-connections. A description of the program, including the following information, shall be submitted to the Department for approval:

20. DEP Regulations Chapter 109.709 • A description of the methods and procedures to be used. • An implementation schedule for the program. • Legal authority for implementation of the program, such as, by ordinance or rules. • A time schedule for inspection of nonresidential customers’ premises for cross-connections with appropriate recordkeeping. • A public education program for residential customers. • A description of the methods and devices which will be used to protect the water system. • A program for the review of plans for new users to assure that no new cross-connections is developed. • Provisions for discontinuance of water service, after reasonable notice. To premises where cross-connections exist.

22. Backflow Ordinance Solicitor’s Advice Necessary

23. Step 3: Establish a priority system • To begin this process, use your billings and your properly trained distribution system maintenance personnel to develop three master lists with the following titles: A: Hazardous Facilities B: Aesthetically Objectionable Facilities C: Non-Hazardous Facilities • Then use distribution system records to identify areas that have been prone to main breaks, leaks, and low pressure. • The information gathered can be transferred to a distribution system map to locate customers in categories A and B. This may highlight more vulnerable areas of the distribution system.

24. Step 3: Establish a priority system (cont.) Now you can establish a priority list, which could be broken down into the following five levels: First Priority: Hazardous facilities located within the most vulnerable portion of the distribution system Second Priority: Hazardous facilities not within the most vulnerable area Third Priority:Aesthetically objectionable facilities located within the most vulnerable area (pollutants only) Fourth Priority: Aesthetically objectionable facilities not within the most vulnerable areas of the distribution system Fifth Priority: Non-hazardous residential connections A thoughtfully drafted priority system will make implementation much easier and will make efficient use of your time.

25. Degree of Hazard • Determining the degree of hazard of a given cross-connection is very important in ensuring that the correct backflow device is selected to control the cross-connection. Degree of Hazard is a way of assigning the level of risk that a given cross-connection creates. There are two degrees of hazard: • Low Hazard • High Hazard • * Some organizations also denote a lethal hazard which normally only applies to sewage and radioactive materials

26. Examples of HIGH HAZARD RISKS Mortuaries, morgues, autopsy facilities Hospitals, medical buildings, animal hospitals and control centers, doctor and dental offices Sewage treatment facilities, water treatment, sewage and water treatment pump stations Premises with auxiliary water supplies or industrial piping systems Chemical plants (manufacturing, processing, compounding, or treatment) Laboratories (industrial, commercial, medical research, school) Packing and rendering houses Manufacturing plants Food and beverage processing plants Automated car wash facilities Extermination companies Airports, railroads, bus terminals, piers, boat docks Bulk distributors and users of pesticides, herbicides, liquid fertilizer, etc. Metal plating, pickling, and anodizing operations Greenhouses and nurseries Commercial laundries and dry cleaners Film Laboratories

27. Examples of High Hazard Risks (cont’d) Automated car wash facilities Extermination companies Airports, railroads, bus terminals, piers, boat docks Bulk distributors and users of pesticides, herbicides, liquid fertilizer, etc. Metal plating, pickling, and anodizing operations Greenhouses and nurseries Commercial laundries and dry cleaners Film LaboratoriesPetroleum processes and storage plants Restricted establishments Schools and Educational Facilities Animal feedlots, chicken houses, and CAFOs Taxidermy facilities Establishments which handle, process, or have extremely toxic or large amounts of toxic chemicals or use water of unknown or unsafe quality extensively.

28. Step 4: Estimate Customer Implementation Costs Cost Factors of a Backflow Prevention Assembly Size:For example, your average 1” RP cost is a fractions of the cost of a 3.0” RP. Type:As a general rule abbreviated here is the order from most expensive to the least expensive: RPDA, DCDA, RP, DC, SVB, PVB, dual check, AVB, hose bib vacuum breaker. Material:Backflow assemblies are made of many different materials in order to tailor them for specific applications. For example, you may need a stainless steel device because you are handling a corrosive liquid. A stainless device will cost much more than a brass or bronze assembly. Installation: Installation costs could be as little as $100.00 for a residential dual check valve installation or it could be thousands of dollars for industrial installations of large devices. Thermal expansion costs must also be factored into the total cost equation. Multiple expansion tanks and/or pressure relief valves. Estimating cost may take a quite a bit of research.

29. Step 5: Develop Implementation Timetable Use the priority system created in step three, and a self-assessment of your systems resources to determine how your timetable should be set up. Factors to consider are: • Size of the system • Percentage of the system that is commercial customers • Other projects scheduled for completion over the next five years • Finances- Is their money for labor and data management costs? • Manpower- Implementing a CCC Administration Plan can be labor intensive After assessing these factors develop an implementation schedule. Most implementation timetables are set over a multi-year period; however, there is no state regulation that defines how long you have to implement a CCC Administration Plan.

30. Step 6: Review your proposed plan with Government Agencies • Communication with all of the stakeholders throughout the entire implementation process is essential. After setting your timetable the “paper part” of your CCC Administration Program should be nearly complete. At this point you should have a meeting with any governmental agency (DEP, local health department, code enforcement, etc…) that may be involved or affected by your CCC Administration Program.

31. Typical Forms for Implementing a CCC Program • Program Implementation Notice • Cross-Connection Control Survey Report Form • Inspection Results Notice, and need to install a backflow prevention assembly • Need to Conduct Periodic Test Notice with return report form • Follow-up Letter (Second Notice) for item D. • Discontinuance of Service Notice • Repair or Replace the Backflow Prevention Assembly Notice • New Service Investigation and Report Forms • Assembly / Installation Approval Form • Approved Backflow Prevention Assembly Testers List • Temporary Shutdown of Water Service Notice • Test Report Form

32. Step 7: Educate the Public This step could begin at any time during the implementation process. A good general public education flyer, brochure, or pamphlet would be the best way to start. Adding information onto the water system’s website is another way to facilitate educating the public..

33. Cross-Connection Control Public Education • Commercial customers should receive different public education documents than your residential customers. The commercial facility public education should still be simple but should be tailored to alert commercial customers about some the specific hazards that they face that residential customers typically don’t. • Public education should be done annually to continually remind residential customers of the hazards of backflow and to educate new residents. Public Education is an Ongoing Process! • Follow-up this general public education document with slightly more complex information. This might get into more detail of where cross-connections exist within their own home’s (could contain graphical illustrations) and what should be done to eliminate them to protect their family’s health.

34. What to include in public education • Start with a serious backflow incident • Define backflow and the two types of backflow • Define a cross-connection • Give examples of where cross-connections are likely to occur • Tell how they can eliminate cross-connections • Mention that at a minimum all service connections must use a hazard appropriate backflow valve or assembly to prevent backflow from people’s homes or business from contaminating the public water system • Strongly suggest that the effects of thermal expansion be addressed with an expansion tank or a relief valve

35. Public Education Example

36. Public Education Example

37. Step 8: Notify Affected Customer Send notice of program implementation and intent to conduct inspection letter to priority one and priority two customers (hazardous connections). Set up and conduct inspection, which will include a survey for cross-connections. Send notice of results of inspection and need to install a backflow prevention device or devices. For larger commercial customers you may want to have a follow-up meeting to set up an individual timetable for compliance. If the customer challenges your requirements refer to the ordinance, the plumbing code or to Chapter 109 requirements.

38. Step 9: Monitor Program Progress Follow-up monitoring of program progress should be done at least bi-annually during the implementation period and at least annually thereafter. Items you should be monitoring during the implementation • Follow-up on individual customer compliance agreements. • Are you on schedule to meet your timetable deadlines? • Are you maintaining your cross-connection control data- base? • Is enforcement being used consistently when necessary to achieve compliance?

39. Step 10: Initiate Testing Requirements For in-line testable devices, which mean devices with test cocks that can be tested with a differential pressure gauge, testing should be conducted annually. Annual testing of backflow prevention assemblies is industry standard. Most CCCP programs across the United States require annual testing because major certification organizations such as the American Society of Sanitary Engineers (ASSE) and the International Plumbing Code (IPC), require backflow prevention assemblies to be tested routinely at least on an annual basis.

40. Record Keeping How long are Cross-Connection Control Records kept? -5yrs? 7yrs, confer with your solicitor. Cross-Connection Control records can make or break a program. Must be accurate. The following are records that should be kept in order to show proof of adequate program.

41. Record Keeping • Master List of all Establishments with assemblies used for premise isolation, including location, assembly used, make, model, size, serial number etc.; • Correspondence between water system and its customers • Copy of Approved Plan • Copy of Approved Policy/ordinance • Test reports for each assembly • Copies of Certificates of Competency for each tester • Copies of test kit certifications • Site Inspection Reports • Residential written surveys • Backflow incident reports • Records on initial surveys, recommendations, follow-up, corrective action, routine reinspections, etc. • A file system designed to call to the attention of the cross-connection control personnel when testing and reinspections of premises are needed. • Public education pamphlets and information.

42. Key Points • Passing an ordinance or resolution is essential to establishing a cross-connection control program. • Remind customers through mailings that they are required to eliminate cross-connections as required by Chapter 109.709. • Public Education is an essential component of a CCC Program. • Establish a priority system for implementation to ensure system protection is achieved at the most vulnerable hazardous facilities first. • Every Public Water System must have at least some staff that are knowledgeable in cross-connection control and backflow protection. • A commitment to enforce the CCC Administration Program. • Examination of resources needed to fully implement a successful program.

43. Contact Information PA WATER SPECIALTIES COMPANY 1-888-843-7155 RALPH YANORA – President rvy@pawsc.com (570) 655-8633 Brian Preski - Vice President bpreski@pawsc.com (215) 740-7095