Division of Water Supply August 8, 2008

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

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

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.

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.

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.

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.

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.

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.

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.

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.

Cross-Connection Control Present & Proposed Statutes, Regulations Statute: 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., § ]

Definition of Cross-Connection TCA 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. § ; Acts 1998, ch. 592, §§ 1-3.]

Cross-Connection Control Present Regulations Operation and Maintenance Requirements Pursuant to Section ,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.

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.

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.

Proposed Cross-Connection Control Regulations Paragraph (6) of Rule 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.

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.

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

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.

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.

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

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.

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.

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.

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.

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.

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.

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.

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.

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

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.

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.

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

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.

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.

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.

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.

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!

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.

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.

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.

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.

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.

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.

What wrong with these pictures?

Backflow Prevention Assemblies on Fire Lines All assemblies required by the water systems must be tested every 12 months by a person possessing a valid Certificate of Competency. Due to the liability involved with working on fire lines, the Division of Fire Prevention has passed regulations that only allows persons with a fire sprinkler contractor license to test, repair, or install on lines used exclusively for fire systems. The Division of Water Supply does not enforce this regulation, however, we do not condone this practice by someone not possessing the appropriate certifications.

Backflow Prevention Assemblies on Fire Lines (cont.) Commercial Fire Systems are tested annually by licensed professionals, and according to NFPA, these professionals are required to offer this backflow testing as a part of their contract. Fire sprinkler contractors are required to have a Certificate of Competency, just as any other tester. In order to stay in compliance with the Division of Water Supply and the Division of Fire Prevention, the water system may have to amend their plan and policy/ordinance to allow fire sprinkler contractors to test.

RULES OF DEPARTMENT OF COMMERCE AND INSURANCE DIVISION OF FIRE PREVENTION CHAPTER FIRE PROTECTION SPRINKLER SYSTEM CONTRACTORS DEFINITIONS. (g) "Point of Service" means the point immediately after the tap of the service main where water is used exclusively for fire protection purposes. (i) "Service" means to repair, test, or inspect INSTALLATION, INSPECTION AND SERVICE. (4) Inspection and service, where required, shall be conducted by a registered fire protection sprinkler system contractor in accordance with the standards. Written reports of inspections shall be completed and filed in accordance with paragraph (3) of this rule.

Which is Testable Without a Fire Sprinkler Contractor License? Fire Line Domestic

Residential Fire Protection Systems Many new subdivisions and towns across Tennessee are requiring new homes to have fire systems to help fire departments in rural areas and also at the request of insurance companies. There are 3 fire system options available to the home owner. Two of the options allow water to flow through the piping not allowing it to become stagnant. The closed loop system, similar to the commercial type systems, require at least a Double Check Valve.

Residential Flow-Through Fire Protection System No Backflow Preventer required.

Residential Protection System No Backflow Preventer required.

Residential Closed Fire Protection System Double Check Valve required at minimum.

Cross-Connection Control Program Audit Checklist For Sanitary Surveys Backflow Prevention Assemblies Testing: All existing assemblies and air gaps must be tested or inspected within a 12 month period. All assemblies must have a status of Passed as determined from testing procedure. Air gaps must pass inspection. Assemblies that have a status of Failed or have not been tested within the 12 month period, will be given a strict compliance date (90 days maximum, 14 days maximum for High Risk High Hazard). Each tester must have a current and valid Certificate of Competency and test kit certification. See document entitled: State Guidance for Certificate of Competency for Testing and Evaluating of Backflow Prevention Assemblies. Copies of Certificate of Competency and test kit certifications must be on file for each tester. All test reports must be approved and properly recorded (all required sections completed). Testers must use DWS procedures for testing RP and DC. See document entitled: State Guidance for Backflow Prevention Assembly Performance Evaluations. Enforcement: All premises with assemblies not tested or have a status of Failed in which the compliance date has passed are disconnected from the distribution system. All premises that have been documented and notified that protection is needed and the compliance date has passed have been disconnected from the distribution system. All enforcement issues have been resolved for premises that are not in compliance with the policy or ordinance (installation requirements, repairs, etc).

Records: Master List of all assemblies and air gaps used for premises isolation including location, assembly used, make, model, size, serial number etc. Test reports documenting assemblies have been tested annually and within the 12 month time period. Site inspection reports Copies of each tester’s Certificate of Competency and test kit certification Annual public education documents and pamphlets Notifications to customers regarding compliance Approved Plan Approved Policy/Ordinance Residential Written Surveys Public Education: Water System must provide public education about cross-connections and backflow prevention at least once annually to all customers. This may include bill inserts, public service announcements, pamphlet distribution, and consumer confidence report articles. Surveys/Site Inspections: Distribution system is broken down into two categories: Residential and Non-Residential Inspections: Nonresidential Inspections: Within a five year cycle all nonresidential establishments without backflow protection are inspected. The cycle is then repeated on the 6 th year.

Residential Surveys: A goal of 20% of the residential customers is surveyed each year (for larger systems Statistical population will be proposed). The actual percentage will be agreed upon by the Division of Water Supply and Water System. The same customer may not be surveyed within a five year period. Inspections are performed on all establishments that meet criteria. The cycle is repeated on the 6 th year. Residential Surveys/Inspections: Written surveys are sent to residential customers. Written surveys are reviewed and sites that meet criteria for possible cross-connections are inspected. Results from all Inspections are recorded on an approved field sheet with a determination of the need for backflow prevention assembly. New residential customers are given questionnaires at service request along with information about cross-connection and backflow prevention. Results of the questionnaires are reviewed and sites that meet criteria are inspected. Secondary meters: If secondary meters are issued, these are inspected. If this is not done presently, start with all new meters, list all existing secondary meters, and draft a schedule of inspection for existing (approved by DWS). Well systems: Premises without backflow prevention assemblies that also have well systems must be inspected for cross-connections and a well user agreement signed. If this is not performed presently, start with all new wells drilled within the distribution area in the last year, list all existing well systems within the distribution system, and draft schedule for inspection (approved by DWS).

Non-Residential Surveys/Inspections All non-residential establishments are initially inspected or required to have an assembly. All non- residential establishments not requiring an assembly will be inspected at least annually. If this is not done presently, start with all new non-residential establishments, list all existing non-residential establishment, prioritize according to hazard, and draft schedule for inspection. These establishments are prioritized into High Risk Health Hazards, Health Hazards or Non-Health Hazard. Results from all Inspections are recorded on an approved field sheet with a determination of the need for backflow prevention assembly. Sites Requiring Backflow Preventions Assemblies or Air Gaps: Sites that are deemed High Risk Health Hazard and Health Hazard by the water system must be protected by an approved RP, RP detector assembly, or an air gap (premises isolation only). Sites that are deemed Low Hazards may be protected by DC, RP, DC detector, RP detector, or air gap (premise isolation only). Only Class 1-3 Commercial fire prevention systems (non-chemical fire lines) may allow DC and DC detector assemblies. See document entitled: State Guidance on Residential and Commercial Fire Sprinkler Systems. Lawn Irrigation systems supplied by the water system must have an approved RP or RP detector assembly at minimum. See document entitled: State Guidance on Lawn Irrigation Systems. Residential Fire Systems: Flow-Through and Combination systems do not require the use of assemblies. Closed Residential Fire Systems require a DC at minimum.

Backflow Prevention Assembly Installation and Repair: All assemblies must be approved. See document entitled State Guidance for Approved Backflow Prevention Assemblies. Assemblies are installed in the approved orientation. Installation of assemblies should follow criteria set forth in State’s Cross-Connection Control Manual and in plan. RP assemblies must never be placed in a pit, vault, or area subject to flooding. The RP’s relief valve must have an approved air gap and can never be submerged or directly connected to a drainage system of any sort. The assembly must never be altered. After assembly is installed, it is must pass the initial performance evaluation and be inspected for satisfaction of all installation criteria. The inspection is documented. Assemblies must be repaired according to manufacturer’s procedures with approved parts. After repair, the assembly must be tested and have a status of Passed.

Division of Water Supply Staff-Johnson City Field Office Travis Aslinger Cross-Connection Control Division of Water Supply