MassDEP, Environmental Analyst Cross Connection Control Program Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring Training Massachusetts Department of Environmental Protection Drinking Water Program

Why Are These Updates Necessary? Guidelines clarify interpretations of the Massachusetts Drinking Water Regulations (310 CMR 22.00) Establish protocols for addressing site-specific problems encountered in the field Set the regulatory framework necessary to maintain or improve public health and welfare Massachusetts Department of Environmental Protection Drinking Water Program

9.10.2 Adoption of Local Controls Successful promotion of a cross-connection control and backflow prevention program will be dependent upon legal authority to conduct such a program MassDEP recommends that a municipality adopt an ordinance, by-law, or have a policy statement on cross-connections that will establish a program for inspection and strategies for the elimination of cross connections within the community

9.10.3 Chemical Dispensers A PWS may allow the installation of chemical dispensers provided: approved by the Board of State Examiners of Plumbers and Gas Fitters installation of a backflow prevention device is installed based on the degree of hazard To view the entire Plumbing Board’s policy: http://www.mass.gov Board of State Examiners of Plumbers and Gas Fitters Board Policies (PL) Regarding Chemical Cleaning Dispensers

Floor Drain Trap Primer Valve

Floor Drain Trap Primer Valve Approved by Massachusetts Board of Examiners of Plumbers and Gas Fitters to be installed on domestic water lines Must be installed with a minimum 12 inches elevation above the finished floor MassDEP not requiring additional backflow protection at this point in time

9.10.4 Containment Policy Locally mandated & more stringent than MassDEP regulations Differs from MassDEP high hazard facilities containment requirement as stated in 310 CMR 22.22(8)(a)(3) Must be included in PWS Program Plan

9.10.5 Cross-Connection Control Program Plan Community PWS ≥ 3,300 must include: staff profile, a strategy for testing, surveying, compliance and enforcement, fees structure, all forms required by the state, and a registration and tracking system Community PWS <3,300 must complete Cross- connection Control Program Plan for Small Community Public Water Systems Non-community PWS must complete the Cross-connection Program Plan Questionnaire for Non-community Public Water Systems

9.10.5 Cross-Connection Control Program Plan With 2012 ASR MassDEP will be requiring re-submission of updated program plans systems that can not produce current program plan systems that have Plan older than 5 years

9.10.6 Cross-Connection Tester and Surveyor Certification Eligible to apply for a MassDEP certification if: Inspecting and testing backflow prevention devices: pass a MassDEP approved written and practical examination Surveying: pass a MassDEP approved written examination Certification from a MassDEP approved teaching institution does not constitute a MassDEP Certification

9.10.7 Emergency Reporting Contamination of water in the distribution system from a backflow or cross connection incident must be reported to MassDEP within 24 hours After action report must be filed within 30 days of the incident as required DEP 24-hour emergency number: 888-304-1133 Drinking Water Program Emergency Contacts http://www.mass.gov/dep/about/organization/contdwp.htm Emergency Requirement regulations: http://www.mass.gov/dep/service/regulations/310cmr22.pdf

9.10.8 Use of Fire Hydrants for Unauthorized Non-Firefighting Activities Establish system for controlling hook-up to a fire hydrant by un-authorized persons Locally mandated regulation, ordinance or bylaw Permit with associated fee Damage deposit

9.10.8 Use of Fire Hydrants for Unauthorized Non-Firefighting Activities Provide: hydrant meter and a wrench upon payment of deposit backflow/meter assembly (BMA) unit or a meter assembly (MA) with an approved air gap Establish fine for using a fire hydrant without the appropriate permit and deposit

9.10.9 Fire Protection – Substantially Modified System Any change or modification to an existing fire protection system installed prior March 21, 1997 for which the cost of the backflow prevention device including installation is equal to or more than five percent of the cost of the fire protection system modification; or Total cost of the fire protection system modification excluding the cost associated with the installation of a backflow prevention device equals or exceeds $100,000.00

9.10.9 Fire Protection – Substantially Modified System Continued: 9.10.9 Fire Protection – Substantially Modified System New, existing or substantially modified fire protection system, including residential fire protection systems must be evaluated to determine if a cross connection exists. If existing fire protection systems must be modified to meet new occupancies, storage changes, increase in building size, or differing building uses.

9.10.10 Testing of Inaccessible Non-Residential Backflow Preventers Entry and testing not required if: hazard(s) has been removed device has been removed - physical separation between the potable and non-potable piping PWS must gain access if existing fire protection system continues to be operational and is equipped with a backflow prevention device Even if building is not occupied owners must have suitable arrangements made so that inspections of backflow prevention devices and cross connection surveys can be made during regular business hours.

9.10.11 Lawn Irrigation Installation of a backflow prevention device on lawn irrigation systems can prevent contamination from fertilizers, chemicals and pesticides. MassDEP recommends PWS have a written residential lawn irrigation system cross connection control policy that:

9.10.11 Lawn Irrigation Identifies type of backflow prevention device required on low hazard residential lawn irrigation systems Establishes schedule for testing of testable backflow assemblies Addresses high hazard residential lawn irrigation systems chemical additions connected to an unapproved water source

9.10.12 Preparing for a Cross Connection Control Program Audit Conducted to ensure PWS is adhering to their approved program plan and provide maximum public health protection. Minimum reviewed: MassDEP approved CCCP plan and letter of approval List of staff and their cross-connection certifications

9.10.12 Preparing for a Cross Connection Control Program Audit Samples of all the official correspondence Backflow prevention device test results Cross-connection survey reports Other documents, such as: Residential educational/informational material Local ordinances/bylaws related to the CCCP

9.10.13 Record Keeping PWS must maintain a list of ALL cross connections that are being protected by a reduced pressure backflow preventer or a double check valve assembly PWS must be able to provide to MassDEP within two hours the list of cross connections as described above List must be available in an electronic format.

9.10.14 Residential Fire Sprinkler Systems Residential Sprinkler Systems position statement jointly developed by MassDEP, Massachusetts Fire Chiefs Association, MWWA, and NEWWA First Choice Option - Flow through Connections: Sprinkler system supplies a household item, such as a toilet Piping must be for potable water No backflow preventer will be necessary

9.10.14 Residential Fire Sprinkler Systems Second Choice Option - Closed System: Separate piping system Requires a minimum of a residential dual check backflow preventer, as long as NO chemicals or anti-freeze is used. Reduced pressure backflow prevention device (RPBP) required if chemical or anti-freeze is added

Cross Connection Control Program Additional Information MassDEP DWP website: http://www.mass.gov/dep/water/index.htm DWP Guidelines http://www.mass.gov/dep/water/laws/policies.htm#dwguid

MassDEP CCCP Contacts WERO - James Gibbs 413.755.2299 James.Gibbs@state.ma.us CERO - Lynda Laine 508.849.4027 Lynda Laine@state.ma.us NERO - Nicholas Zessoules 978.694.3230 Nicholas.Zessoules@state.ma.us SERO - Giliane Tardieu 508.946.2789 Giliane.Tardieu@state.ma.us BOSTON - Anita Wolovick 617-292-5920 Anita.Wolovick@state.ma.us Otavio Paula-Santos 617.556.1085 Otavio.Paula-Santos@state.ma.us