1. Your Public Water System’s Cross-Connection Control Program
Al Fuentes
Technical Review and Oversight Team
Water Supply Division
Your Cross-Connection Control Program
Al Fuentes
Technical Review and Oversight Team
Public Drinking Water Section

2. Outline of this Presentation
Authority
Plumbing Code
Enforcement
Containment vs. Internal
Special considerations
Record Retention
Auxiliary Water Systems
New Lead Rule
This presentation covers relevant issues regarding a Cross-Connection Control Program:
Authority- Plumbing Code, Enforcement
Containment vs. Internal; Special Considerations
Record Retention
Auxiliary Water Systems
New Lead Rule
Pictures: Girl drinking from water fountain; Water flowing from a faucet into a glass with ice.

3. Authority Authority: The Plumbing Code Enforcement
Testing Requirements
Customer Service Insp.
The Plumbing Code
Enforcement
TCEQ’s Plumbing Ordinance regulation requires that PWSs adopt an authority to implement a Cross-Connection Control Program. It requires the adoption of a plumbing ordinance, plumbing regulations, or Customer Service Agreement. Many local jurisdictions use this opportunity to require more stringent testing requirements.
The adoption of a Plumbing Code is not the same as adopting a Plumbing Ordinance.
Make it clear what the penalties are for non-compliance: warning letters, fines, termination of service.
Picture: Cross-connections using hoses at a toilet in a morgue.

4. The Three C’s Coordination, Communication, Cooperation
City, utility, or district management
Plumbing Inspector
Building Official
Environmental Services
Water department management and staff
Fire Marshall’s Office
Industry professionals
The Cross-Connection Control Program should reside between the water utility and the building/plumbing inspection departments and be composed of staff from both departments. The building/plumbing inspection department administers the plumbing code, which has its own backflow prevention and cross-connection control requirements and the water utility administers the TCEQ’s backflow prevention and cross-connection control requirements, so their responsibilities naturally overlap.
Because of the shared responsibility for cross-connection control, it is important for everyone involved to develop written protocols for sharing information, storing records, and delineating where one department’s jurisdiction ends and another department’s jurisdiction begins. Open lines of communication and good working relationships are essential.

5. Backflow Cases
Manufacturing facility in Texas uses river water for some of their processes.
During a repair, they accidentally cross-connected to the potable water supply.
Management was notified, alerted the people in the facility.
Ice machines, reverse osmosis systems and under-sink filtration.
Manufacturing facility in Texas using river water accidentally cross-connected to the potable water supply. Management was notified and the people in the facility were told not to drink the water. The system was flushed and Bac-T samples were taken and found to be negative. Ice machines, reverse osmosis systems, and under sink filtration were not used until they could be serviced.

6. Backflow Preventers Containment vs Internal Cross-Connection Control
Special considerations
Approved backflow preventers.
Containment means a backflow preventer at the meter. It isolates the customer and requires the fewest number of BPAs. How about the people on the other side of the meter? Internal Cross-Connection Control means BPAs internally at any contamination hazards. This requires more CSIs and increased tracking. How will you know if something changes?
If you only require containment backflow prevention, you should consider those locations like schools, hospitals, and nursing homes.
Pictures: A picture of two backflow preventers; A picture of two backflow preventers installed on cement slabs with protective wire screens.

7. Record Retention TCEQ requirements Key data on a form
Required to use the forms in the state regulations or an approved alternate forms. Request for approval must be in writing and the changes made included in the request. Using an approved alternate form is an opportunity to make your program better by customizing your form and capturing additional information if necessary (electronic record keeping). Keep CSIs for 10 years and BPAT forms for 3 years.
If you use an alternate form, make sure none of the key data is missing: Date tested for accuracy, date BPA was tested, location of BPA, lead piping or solder.
You should consider getting copies of licenses for verification and tracking expiration dates. Here is the URL for TCEQ licensing database:

8. Auxiliary Water Systems
What the rule says.
How do you address these?
Teamwork
290.47(i) lists private wells and rainwater harvesting systems as health hazards and requires backflow prevention in the form of an Reduced Pressure Principle Backflow Preventer (RP) or an air gap.
If an RP is installed then you need to verify that it has been tested and you need to track due dates for future testing. If an air gap is used then you will need to periodically monitor the location to make sure that air gap has not been compromised.
Utilize other city staff that does field work to help: meter readers, plumbing inspectors, repair technicians, etc.
Pictures: A picture of a floating pump set-up in a lake for an irrigation system; A picture of a rainwater harvesting system in a private residence, blue barrels connected to the rain gutter.

9. Backflow Event City park irrigation system
RPZ was installed but, not tested.
The nearby residents started complaining of small worms in their water.
Backflow from irrigation system, zero chlorine residual.

10. New Lead Requirements
Definition of lead free for pipes and plumbing changed from 8% to 0.25%. Solder and flux remain the same at 0.2%.
Exemptions for non-potable use and main gate valves 2” or larger.

11. Questions?

12. Contact Info:
Al Fuentes
Technical Review and Oversight Team
Richard Bosch
The toll free reporting number at TCEQ is
Al Fuentes
Technical Review and Oversight Team