Cross-Connection Control Program Administration Basic Workshop

1. Cross-Connection Control Program Administration Basic Workshop Division of Water Supply August 8, 2008

2. Feel like your hands with Cross-Connection Control are tied?

3. Cross-Connection Control Program: Guidelines and Recommendations • Active and ongoing. • Backflow Assembly Testing Program • Approved Cross-Connection Control Plan • Approved Cross-Connection Control Policy/Ordinance • Distribution System Surveys and Inspections • Public Education • Enforcement of Policy/Ordinance

4. Cross-Connection Control Program:Active and Ongoing • Program must be active- Continuous detection and elimination of cross-connections through inspections and surveys. • As changes occur within the distribution system-for example , growth, a plan is developed to effectively prevent cross-connections pertaining to either nonresidential or residential customers. • Plans and ordinances should be reviewed at least every 5 years to ensure accurately represent the needs of the system and requirements of the State.

5. Cross-Connection Control Program:Backflow Assembly Testing • All backflow preventers required by the water system for protection are required to be tested every 12 months by a person possessing a valid State of Tennessee Certificate of Competency. • The assembly must be tested using the latest DWS approved procedure (DC and RP) • Water system may add more stringent requirements • Test kits must be certified annually. • Testers may be either the water system personnel or third party, but never owner.

6. Cross-Connection Control Program:Approved CCC Plan • According to DWS regulations, every community water system must have an approved plan • For approval, the plan will meet recommendations and requirements as listed in the 2008 Cross-Connection Control Manual under the Design Criteria for Plans • The plan acts as an agreement between the water system and DWS of the activities that the water system will perform to prevent and eliminate cross-connections.

7. Cross-Connection Control Program:Approved CCC Policy/Ordinance • According to DWS regulations every community water system will have an approved policy/ordinance. • A policy refers to the document from a utility or private water system, an ordinance refers to the document from a city or municipality, essentially they are the same. • A Policy/Ordinance is basically the requirements, codes, or agreement that the water system demands of the customer in regards to cross-connection in order to retain water service.

8. Cross-Connection Control Program:Distribution System Surveys • The CCC program must have a effective procedure for finding cross-connections. • The distribution system is composed of two categories: Nonresidential and Residential. • The method for finding cross-connections will different for Residential than it will be for Nonresidential. • Residential establishments, due to the large percentage, will surveyed. • A Survey is composed of listing simple criteria that would require a physical inspection if it was determined to meet the criteria. If the establishment did not meet the criteria, no on-site inspection is required.

9. Cross-Connection Control Program:Distribution System Surveys (cont.) • Nonresidential sites would include commercial, industrial, agriculture, or anything other than Residential establishments. • Nonresidential establishments, will require onsite inspections due to the nature of most businesses to change owners or type of business. A goal should be set to inspect each business every 5 years or whenever the business changes piping or ownership if no assembly is required. • The water system may take the option of requiring all Nonresidential establishments to install an assembly to reduce the time-consuming onsite inspections.

10. Cross-Connection Control Program:Public Education • Public education regarding cross-connections and backflow will help tremendously to provide awareness on the Residential side of the distribution. • Providing information to the customers and requiring water-use questionnaire at the request of water service is highly suggested. • Some of the items to discuss may include lawn irrigation systems, well systems, thermal expansion, etc. • A brochure sent to all customers or a clip in the Consumer Confidence Report on cross-connection and backflow prevention would satisfy this CCC plan requirement.

11. Cross-Connection Control Program:Enforcement of Policy/Ordinance • The policy/ordinance is legal agreement or local regulations that customers or citizens must comply. • A policy/ordinance restricting cross-connections is worthless without enforcement. • Warning letters, fines, penalties, and even discontinuance of water service may be necessary to prevent cross-connections and backflow which may ultimately lead to sickness or death.

12. Cross-Connection Control Present & Proposed Statutes, Regulations • Statute: 68-221-711. Prohibited acts. The following acts are prohibited: The installation, allowing the installation, or maintenance of any cross connection, auxiliary intake, or bypass, unless the source and quality of water from the auxiliary supply, the method of connection, and the use and operation of such cross connection, auxiliary intake, or bypass has been approved by the department; [Acts 1983, ch. 324, § 12; T.C.A., § 68-13-711.]

13. Definition of Cross-Connection TCA 68-221-703. Definitions. As used in this part, unless the context otherwise requires: "Cross connection" means any physical arrangement whereby a public water supply is connected, directly or indirectly, with any other water supply system, sewer, drain, conduit, pool, storage reservoir, plumbing fixture or other device which contains, or may contain, contaminated water, sewage or other waste or liquid of unknown or unsafe quality which may be capable of imparting contamination to the public water supply as a result of backflow. Bypass arrangements, jumper connections, removable sections, swivel or change-over devices through which, or because of which, backflow could occur are considered to be cross-connections; [Acts 1983, ch. 324, § 4; 1988, ch. 583, § 2; T.C.A. § 68-13-703; Acts 1998, ch. 592, §§ 1-3.]

14. Cross-Connection Control Present Regulations 1200-5-1-.17 Operation and Maintenance Requirements • Pursuant to Section 68-221,711(6) the installation, allowing the installation, or maintenance of any cross-connection, auxiliary intake, or bypass is prohibited unless the source and quality of water from the auxiliary supply, the method of connection, and the use and operation of such cross-connection, auxiliary intake, or bypass has been approved by the Department. The arrangement of sewer, soil, or other drain lines or conduits carrying sewage or other wastes in such a manner that the sewage or waste may find its way into any part of the public water system is prohibited.

15. Cross-Connection Control Present Regulations (cont.) • All community water systems must adopt an ordinance or policy prohibiting all of the above and submit a copy of the executed ordinance or policy to the Department for approval. All community water systems shall develop a written plan for a cross-connection control program to detect and eliminate or protect the system from cross-connections. The written plan must be approved by the Department.

16. Cross-Connection Present Regulations • After adoption and approval of the cross-connection ordinance or policy and plan, each community water system must establish an ongoing program for the detection and elimination of hazards associated with cross-connections. Records of the cross-connection control program must be maintained by the water supplier and shall include such items as date of inspection, person contacted, recommendations, follow-up, and testing results.

17. Proposed Cross-Connection Control Regulations • Paragraph (6) of Rule 1200-5-1-.17 Operation and Maintenance Requirements is amended by adding new subparagraphs (a) and (b) to read as follows:(a)   Public water systems must develop and implement an ongoing cross-connection program.  Cross-connection plans and policies shall present all information in conformance with the Design Criteria for Community Public Water Systems as published by the Department. 

18. Proposed Cross-Connection Control Regulations • b)  The public water system shall ensure that cross-connections between the distribution system and a consumers plumbing are surveyed and/or inspected and determined not to exist or contain significant risk or eliminated or controlled by the installation of an approved backflow preventer commensurate with the degree of hazard.

19. Basic Elements of a Cross-Connection Control Plan • Introduction • Authority for Cross-Connection Control • Program to be Pursued • Procedures for Inspections • Premises Requiring RPs and Air Gaps • Premises Allowing DCs • Inspection and Testing of Assemblies • Parallel Units • Records • Backflow Contamination Procedures • Modifications to Plans

20. Introduction • Basically outlines the goal of preventing backflow and unprotected cross-connections. • Introduces a plan of action to be followed in order to prevent backflow and contamination. • Nothing very life altering, but necessary to state goals and support of cross-connection control.

21. Authority for Cross-Connection Control • In order to follow the plan, a document that acts a legal binding contract is needed to encourage customers and to keep them on the straight and narrow- Ordinance, if the system is municipality. Policy if it is utility or private water system. • Who is responsible for the water in distribution-yep, the water system!!! • Water service is a privilege and service to the customers, not a right. Some customers will abuse this privilege and their must be some consequence for noncompliance with the policy or ordinance.

22. Program to be Pursued • Staffing- Determining the Cross-Connection Control Manager and the amount of people and time dedicated to the cause. It is highly recommended that someone in the system have a valid Certificate of Competency. • Inspections and Surveys • Residential Surveys • Nonresidential Inspections • Well User Agreements • Public Education • Customer Responsibility • Enforcement

23. Inspections and Surveys-Residential • Residential Customers will make up the bulk of the customers in the water system • Unless the system is very small, it would be very difficult to inspect all customers. • A survey of the Residential customer- either by driving by or written questionnaires is helpful to determine problems. • A goal of 20% of customers should be surveyed. However, this negotiable, depending on the system. • A definite written plan of surveying the system is needed to be effective.

24. Residential Red Flags • Lawn irrigation systems • Residential fire protection systems (closed loop systems will require a double check valve minimum) • Pools, Saunas, Hot Tubs, Fountains • Auxiliary Intakes and Supplies-wells, cistern, ponds, streams, etc. • Home water treatment systems • Hobbies that require extensive amounts of toxic chemicals (taxidermy, metal plating, biodiesel, ethanol production, etc.) • Any other situations or conditions listed in the manual or conditions deemed a threat by the water system.

25. NonResidential Customers-Inspections • Nonresidential customers hold the largest chance of contamination if backflow occurs. • Nonresidential Customers should have an initial onsite inspection with a goal of having an inspection every 5 years. This negotiable, depending on the water system, but a plan must be written out. • For larger systems, it is suggested that ordinance or policy require that all new nonresidential customers must have an RP or DC depending on situation and that existing customers not required to have one are inspected every 5 years. This will greatly reduce work load.

26. Well User Agreements • Any customer with an auxiliary water supply such as a well, should never be connected with the public water supply. • The well user should be required to sign an agreement not to connect to public water supply without a backflow preventer and if they do, the possibility of fines, penalties, and discontinuance of service may occur if uncorrected. • It is suggested to start inspecting all new wells drilled within the system within the last year. Then draft a plan of existing wells that do not have an agreement.

27. Public Education and Awareness • For Residential Customers, this is one of the most effective way to help prevent cross-connections. • At minimum, a brochure or pamphlet to each of customers should be sent. • A clip in the Consumer Confidence Report about backflow and cross-connections would also suffice. • It is suggested that information be sent about using air gaps and vacuum breakers when filling pools and other information about lawn irrigation. • See CD for examples of brochures.

28. Enforcement • The dirty word- How do we make the customers comply ? • The usual answer is through warnings, fines, penalties, and ultimately discontinuance of service. • High and Low Hazards should be protected within 90 days of identification. • High Risk High Hazards –immediate or within 14 days. • Some tact may be required, depending on situation and if needed waivers or variances can be given if there in no chance of contamination.

29. Premises Requiring Air Gaps and RPs • High Risk High Hazards-These are establishments that the pose an extreme health hazard or is of immediate concern. • High Risk High Hazards should be protected within 14 days or immediate correction. • High Hazards- These are health hazards that do not pose an immediate concern. • High Hazards should be protected within 90 days.

30. High Hazards • Water system must accurately define the situations that pose a high hazard. • It is recommended that the water system use the state’s Cross-Connection Control Manual as a basis and add other situation unique to their system. • The list of high hazards or description should be in the plan and policy/ordinance.

31. Determination of High Risk High Hazards • 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

32. High Risk High Hazards (cont.) • 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.

33. Premises allowing Double Check Valve Assemblies • In the Tennessee, only low hazards may be protected by DCs • This means only nonchemical fire lines (Classes 1-3) • Testing backflow preventers on fire lines is explained a little later in presentation.

34. Approval of New Installations • Assembly must be inspected for compliance with installation criteria including correct orientation. • The backflow preventer is tested and has a status of Passed. • Backflow preventer is added to master list of assemblies and continued to be tested annually

35. Routine Inspection and Testing of Assemblies • Backflow preventers accepted for premise isolation are tested at least every 12 months. • The Tester must have a valid Certificate of Competency. • The tester may be a representative of the water system or could be a third party tester. • Tester must perform the latest procedure from the Division of Water Supply with an annually certified test kit gauge.

36. Third Party Testers • Must have a valid Certificate of Competency-kept on file by water system. • Must have a certificate showing annual certification of test kit-kept on file by water system. • A quality control effort should be made by water system to determine if third party testers are performing as desired. This should be outlined in the plan.

37. Additional Items Tester Should Record • That cross-connections, actual or potential, have not been added ahead of the protective assemblies, • The assembly meets all installation criteria; and • The assembly has not been bypassed or altered in some other way to compromise the backflow protection.

38. Backflow Preventer Annual Test Report • The annual testing report for backflow preventer is a legal document. • The document must be completed fully and accurately. • All parts and sections tested on the assembly must be recorded on the test report. • Address of assembly, testers information, and assembly info must be listed to accurately identify the assembly and tester. • The status of the assembly must also be recorded –Passed or Failed. • Items of notice or concern should be listed in the comment section of the report.

40. Installation Requirement-General • All new installations must be on the approved list and in the correct orientation. • Accessible to repair and testing • No unprotected bypasses in front of the backflow preventer-exceptions are lawn irrigation systems on residential. • Conditions are within approval of assembly-pressure, temperature, etc. • RPs can never, ever, never be put in a pit or be allowed to submerge. Not even if there is a drain! Sorry!

41. Records • How long are Cross-Connection Control Records kept? -5yrs • 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.

42. Records Needed! • 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.

43. Backflow Contamination Procedures • Isolate the lines containing any contaminant from the distribution system; • Inform customers with contaminated lines not to consume or use the water; • Report contamination to the Local Field Office; • Determine and separate the cross-connection allowing the backflow and contamination; • Remove contamination from lines; • Test and ensure that lines meet Division of Water Supply regulations for safe water; • Return service to customers affected customers once water is safe; • Document the details of the incident including cause, isolation, and correction, and send report to Local Field Office; • Continue to survey and inspect system for similar situations that may allow backflow.

44. Plan Revisions and Updates • Plans, Policies, and Ordinances become outdated over time and should be updated. • Plans, policies, and ordinances should reviewed every 5 years to ensure that they are in agreement with DWS criteria, requirements, and recommendations. • All revisions must be approved by DWS before following.

45. Sanitary Survey Audit List • At the end of the presentation is a Sanitary Survey Audit List. • It is designed to inform the water system of the plan requirements that were agreed upon by DWS and the system. • It is a quick summary of the items that could be inspected during the survey. • This audit list could be used to find deficiencies in the system and could be used among water systems as way to check each for problems.

46. New Installation Inspections • All new assembly installations are inspected for compliance with policy or ordinance. • Many situations in which a backflow preventer is installed may create a cross-connection or cause the backflow prevention assembly to fail. • Remember – RPs can never, ever, never, - well I think you got it.

47. What wrong with these pictures?