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I. INTRODUCTION
Table of Contents
This document sets forth the District’s policy and procedures for
implementation of its Cross-Connection Control Program.
II. CONTROL METHOD –
CONTAINMENT
Table of Contents
A. General
There has been an ongoing debate concerning the method of
cross-connection control that should be implemented by water
utilities – containment or fixture isolation. In addition, there
have been increasing efforts by people specializing in
cross-connection control (primarily certification organizations and
testers) to pressure public water suppliers to adopt fixture
isolation as the preferred method for implementing cross-connection
control. The District employs the containment method.
Briefly, the containment method is implemented by installing a
backflow preventer at the service connection to prevent used water
from re-entering the public water system. Fixture isolation prevents
contamination of the public water system and the customer’s internal
plumbing system by requiring installation of a backflow preventer at
all plumbing fixtures within the building. Although cross-connection
professionals have stated this philosophy of cross-connection
control as a requirement, it has not been established by regulation.
This philosophy is based primarily on two arguments:
1. The lead and copper rule has established precedent by assigning
responsibility for water quality with respect to corrosivity at the
customer’s tap to the supplier. If the supplier is also responsible
to insure that all water quality standards are met at the tap, and
internal cross-connections can degrade water quality, then the
utility is also responsible to protect the internal plumbing system.
2. Customers are unfamiliar with cross-connections, their hazards,
and methods of control. Therefore, they cannot be relied upon to
insure that all plumbing fixtures are protected from
cross-connections. The supplier, however, is knowledgeable and its
position and resources make it suited to serving as the primary
enforcement agency for protection of internal fixtures. In addition,
the State Cross-Connection Rules give authority to the supplier to
enter private property to inspect the customer’s water supply
system. Therefore, the utility should be responsible for protecting
the customer’s water supply system.
A discussion of industry practice and governing regulations follows.
B. AWWA M14
American Water Works Association Manual of Water Supply Practices
M14, Recommended Practice for Backflow Prevention and
Cross-Connection Control”, “has been designed as a guide toward
uniformity for waterworks employees, plumbers, and others involved
in the detection and elimination of unprotected cross-connection”
(Section 1.1). Section 1.2 of the manual outlines the
responsibilities of the various parties involved in cross-connection
control.
Respective responsibilities are
excerpted below, with comment:
Water User (Owner or Customer):
“The water user has the primary responsibility to keep contaminants
out of the potable water system(s). This responsibility begins at
the user connection and includes any and all water distribution
piping on the premises.” In Maine, the user connection is defined as
the outlet end of the meter. “Water system(s)” is taken to mean the
public water system and the customer’s internal plumbing system.
Water Supplier:
“The water supplier has the responsibility to prevent contamination
of the public water system from backflow. This responsibility begins
at the source and includes the entire distribution system and ends
at the user connection.” Further it states, “In some jurisdictions,
such as Washington state and Massachusetts, legislation requires
that the water supplier conduct surveys of internal potable water
systems and implement programs to afford protection for both the
public water supply and the individuals on the premises”.
Health Agency
“The health agency also has the responsibility for promulgating and
enforcing laws, rules, regulations, and policies to be ollowed in
controlling cross-connections. The agency has the responsibility to
ensure that internal protection is provided and adequate
backflowprevention programs are maintained.” In Maine, the health
agency is the Department of Human Services, Bureau of Health. DHS
promulgates “Rules Relating to Drinking Water” (Chapter 231),
“Cross-Connection Rules” (Chapter 226), and “State of Maine Internal
Plumbing Rules” (Chapter 238).
Plumbing Official
“The plumbing official has the responsibility for the enforcement of
plumbing regulations concerned with preventing cross-connections.”
In Maine, the Local Plumbing Inspector is the designated plumbing
official.
C. USEPA Cross-Connection Control Manual
The “USEPA Cross-Connection Control Manual” was last revised in 1989
and is intended to serve as a technical reference in conducting
cross-connection control programs. In Chapter 6, Administration of a
Cross-Connection Program, the benefits and drawbacks of containment
and fixture isolation are discussed. The manual states that the
fixture isolation approach in large systems “is a virtual
impossibility to achieve and to police”. It further acknowledges
that “internal plumbing cross-connection control survey work is
generally foreign to the average water purveyor”. Also, “While it is
admirable for the water purveyor to accept and perform survey work,
he should be aware that he runs the risk of additional liability in
an area that may be in conflict with plumbing inspectors,
maintenance personnel and other public health officials.” Further
guidance is given with respect to survey work. “If ‘containment’ is
the prime objective of the survey, then only sufficient time need be
spent in the facility to determine the degree of hazard inherent
within the facility or operation.”
D. USC Foundation for Cross-Connection Control and Hydraulic
Research
USC conducts research, sets standards, and tests and approves
backflow preventers. In addition, it publishes the “Manual of
Cross-Connection Control” to provide responsible parties with
information and suggested practices to implement effective
cross-connection control programs. Section 3 of the manual lists the
responsibilities of the various parties. The manual is in agreement
with the responsibilities as assigned by AWWA. The plumbing
official’s responsibility is explicitly stated:
3.3 Responsibility: Plumbing Official
“The plumbing official’s responsibility begins at the point of
service (the downstream side of the meter) and carries throughout
the entire length of the customer’s water system.”
E. State Cross-Connection Rules
The State of Maine Cross-Connection Rules (CMR 10-144, Chapter 226)
does not assign responsibilities as explicitly as the preceding
manuals. It simply states in Section 2:
A. The supplier shall not permit any cross-connection at any point
within its system unless approved pursuant to a permit specifically
issued for the cross-connection.
B. The owner shall be responsible for insuring the proper operation
and maintenance of an anti-backflow device and the periodic testing
of the device.
F. State Plumbing Code
The State of Maine Internal Plumbing Rules (CMR 10-144, Chapter 238)
also addresses cross-connections. No specific responsibility is
assigned, except that the local plumbing inspector has the
responsibility of preventing cross-connections from being designed
or built into buildings within their jurisdiction.
G. Maine Public Utilities Commission
Maine PUC does not have any rules pertaining to cross-connection
control. Nevertheless, PUC considered the issue in re: Robert E.
Baldacci, Sr., et al., v. Bangor Water District, Docket No. 88-251.
The case considered whether or not the Bangor Water District’s
cross-connection control program was reasonable in that it required
all service connections to have a backflow preventer whether or not
an actual cross-connection existed. The staff recommendation for the
case discussed the containment method, and stated that, “The
rationale behind the containment method also implicitly recognizes
that anyone in Maine can do their own plumbing. Because unlicensed
and perhaps unqualified people are permitted to install and work on
their own plumbing, cross-connections may be inadvertently present.
Furthermore, as houses change owners over the years, plumbing may
also change, thereby making it difficult for a public water
supplier, such as the District, to keep track of individual
cross-connections”. PUC agreed with the staff recommendation and
dismissed the complaint, finding that the District’s
cross-connection control program was reasonable.
H. Conclusions
The rationale for assignment of responsibility of water quality
protection to the tap by the supplieris derived from the lead and
copper rule, which requires that the water be non corrosive at the
tap. Some people conclude that since this is required, the supplier
is also responsible for all water quality at the tap. Nevertheless,
the rule contains no provisions concerning other contaminants, and
nowhere mentions cross-connections. The 1986 Safe Drinking Water Act
Amendments included the following language within the definition for
Maximum Contaminant Level: “Contaminants added to the water under
circumstances controlled by the user, except those resulting from
corrosion of piping and plumbing caused by water quality, are
excluded from this definition.” (CFR 40, Paragraph 141.2, Section
C). Therefore, there is no reasonable basis to conclude that the
supplier is responsible for all water quality parameters at the tap.
The argument that the supplier’s position and resources establish
responsibility for water quality at the tap similarly has no basis.
It assumes that utility personnel are as knowledgeable as licensed
plumbers and ignores the responsibilities assigned to plumbers and
the local plumbing inspectors in the Internal Plumbing Rules. Water
utilities do not routinely employ licensed plumbers, nor is it
reasonable to expect that they should since it is not necessary for
the operation of a public water supply. The point is made in
Baldacci that the supplier cannot be expected to maintain control
over the internal plumbing of all of its customers. This is also
acknowledged in the EPA Cross-Connection Control Manual.
The organizations and documents cited above clearly show that the
responsibility of the District is to insure that connections to the
public water system are protected to prevent contamination. The
State assigns responsibility for internal protection to the water
user and the local plumbing inspector via the Internal Plumbing
Rules. The ability of the District to exercise and maintain control
over all customers’ plumbing systems is practically impossible and
the potential liability inherent with such a program is
incalculable. On the basis of these considerations, therefore, the
District shall continue to use the containment method of
cross-connection control.
III. IMPLEMENTATION POLICY
Table of Contents
A. Policy
The District recognizes that the containment method provides
protection of the public water system from existing or potential
cross-connections. Further, actual cross-connections may not exist
and, therefore, cross-connection control would theoretically be
unnecessary. Nevertheless, undetected cross-connections may exist,
and uncontrolled plumbing changes may be made subsequent to
inspection and without the District’s knowledge. These conditions
may result in a cross-connection, either knowingly or unknowingly,
and pose a public health threat. Therefore, in consideration of the
need to protect the public water supply from actual and potential
cross-connections, it shall be the policy of the District to
implement cross-connection control by the containment method.
B. Responsibilities
1. The General Superintendent/Operator shall have overall
responsibility to insure that the District’s Cross-Connection
Control Program is implemented.
2. The District Operator shall be designated as the Cross-Connection
Control Officer, and shall insure that the procedures set forth in
this policy and procedures are implemented. The District Operator
shall determine the degree of hazard present at all customer
facilities and shall specify the type of backflow preventer to be
installed.
3. The District Operator Technician shall be responsible for daily
operations related to the Cross-Connection Control Program,
including preparation of all correspondence and record keeping.
4. The General Business Manager shall be responsible to insure that
no new water meter or replacement meter is installed unless a
backflow preventer is in place.
C. Compliance Schedule
1. Industrial Customers:
The District recognizes that industrial operations using public
water in production processes represent a potential public health
threat by the nature of their operations. The District shall
therefore inspect and require installation of a backflow preventer
commensurate with the potential degree of hazard present for all
industrial customers by January 1, 2001.
All industrial customers shall be re-inspected every five years to
verify the degree of hazard assigned.
2. Commercial and Governmental Customers:
The District recognizes that commercial and governmental concerns
may use public water under conditions that would cause potential
nuisance or public health threats if a backflow incident were to
occur. The District shall therefore inspect and require installation
of a backflow preventer commensurate with the potential degree of
hazard present for all commercial and governmental customers by
January 1, 2003.
All commercial and governmental customers shall be re-inspected
every five years to verify the degree of hazard assigned.
3. Residential Customers:
District rules and regulations require that all customers shall
install a back flow prevention device when their meter is replaced,
their water service is renewed and when any change in the customers
internal plumbing occurs. This requirement shall be maintained for
all existing residential customers. All new customers shall install
a back flow prevention device on the outlet side of the water meter
before service is established.
D. Procedures for Implementation
1. General:
a. American Water Works Association Manual M14, “Recommended
Practice for Backflow Prevention and Cross-Connection Control”,
shall serve as the basis for practices concerning all aspects of the
District’s Cross-Connection Control Program relating to
administration, hazard classification, methods of control, and fire
protection system requirements.
b. All correspondence giving notice for inspection of premises,
inspection results, compliance requirements, and test requirements
shall be sent by registered mail, return receipt requested. All time
periods specified for giving notices and compliance requirements
shall be calendar days unless otherwise specified.
2. New Customers:
a. All new customers shall install an approved back flow prevention
device on the outlet side of the water meter.
1.) All residential customers shall install at a minimum a dual
check valve type backflow preventer.
2.) All non-residential customers shall install a device
commensurate with the degree of hazard.
b. Customers shall be informed of the device requirements and
receive an application for a cross-connection permit, if required,
when application for service is made.
c. Water service shall not be established until a backflow preventer
has been installed and, where required, has been tested and a permit
application has been received by the District.
3. Existing Non-Residential Customers
a. All non-residential customers’ premises shall be inspected to
determine the potential degree of hazard present. Until inspection
of premises is completed, all non-residential customers shall be
presumed to be Class II or higher hazards.
b. Notification of inspection of premises shall be done in
accordance with the District’s Cross-Connection Control Program.
c. District personnel or a District contractor shall perform
inspections.
d. Notification shall be provided to non-residential customers at
least 14 days in advance that the District intends to inspect their
premises.
e. Within seven days of the inspection, notice shall be sent to the
customer to inform them of the degree of hazard assigned and the
type of backflow preventer required.
f. The customer shall be given at least 30 days to comply with the
requirements of the Cross-Connection Control Program.
g. The facility shall be re-inspected not more than 45 days after
notification to verify the presence of a backflow preventer.
h. If compliance is not achieved, the customer shall be given an
additional 10 days to comply.
i. If the customer fails to comply following the second notice,
water service to the premises shall be terminated in
accordance with District Rules and Regulations and PUC rules.
4. Degree of Hazard
Different types of cross-connections constitute different degrees of
hazard which are classified as follows, listed with the approved
types of devices:
A. Class I - If backfiow were to occur, the resulting health
significance would be limited to minor changes in the esthetic
quality such as taste odor, or color. The foreign substance must be
non-toxic and non-bacterial in nature and have no significant health
effect. Allowed devices are air gap, non-pressure type vacuum
breaker, pressure type vacuum breaker, testable double check valve
assembly, or reduced pressure principle device.
B. Class 2 - If backflow were to occur, the resulting effect on the
water supply would be significant chance in esthetic qualities. The
foreign substance must be non-toxic and non-bacterial in nature.
Allowed devices are Air gap, pressure type vacuum breaker, testable
double check valve assembly, or reduced pressure principle device.
C. Class 3 - If backflow were to occur, the resulting effect on the
water supply could cause illness or death if consumed by humans. The
foreign substance may be toxic to humans either from a chemical,
bacteriological or radiological standpoint and may result from
either long or short-term exposure. Allowed devices are air gap or
reduced pressure principle device.
5. Existing Residential and Class I Hazard Non-Residential Customers
a. All residential customers shall be considered Class I hazards,
and shall be protected at a minimum by a dual check valve backflow
preventer.
b. Permits and annual testing for Class I devices will not be
required.
c. All new residential and Class I hazard non-residential customers
shall install at a minimum a dual check valve backflow preventer.
d. All residential customers shall be considered Class I Hazards,
and shall be protected at a minimum by a dual check valve backflow
prevention device installed on the outlet side of the water meter.
e. For customers requesting that their service be renewed, or any
service scheduled to be renewed as part of any main or service
replacement program, the District shall provide 30 days notice prior
to commencement of the work that the customer shall install a
backflow preventer.
f. The District shall verify that the backflow preventer has been
installed prior to commencement of the work. If a customer has
failed to install a backflow preventer, a second notice shall be
sent and the customer shall be given an additional ten days to
comply.
g. If the customer fails to comply, water service shall be
terminated in accordance with District Rules and Regulations and PUC
rules.
h. For all customers scheduled to have their meter replaced either
by customer request or District initiative, notification that a
backflow preventer shall be installed shall be given as outlined in
parts (e) through (g) above.
6. Testing
a. Testing shall be done in accordance with the District’s
Cross-Connection Control Program.
b. The District, a District contractor, the customer, or the
customer’s contractor may do testing.
c. The tester shall be recognized as competent to test backflow
preventers by holding a valid certificate from the New England Water
Works Association or American Backflow Prevention Association. The
District will consider other certification programs on a
case-by-case basis. The District shall maintain a list of certified
testers acceptable to the District for referral to customers.
d. Testable (Class II and III) devices shall be tested upon
installation and annually thereafter.
e. All tests shall be scheduled to be completed by September 30.
f. At least 10 but not more than 20 days after the test period
closes, the District will send written notice to customers who
failed to test their backflow preventer. The customer shall be given
30 days to complete the test.
g. If a customer fails to test their device following the first
notice, a second written notice will be given. The customer shall be
given an additional 10 days to complete the test.
h. If a customer fails to test their device after the second notice,
water service shall be terminated in accordance with
District Rules and Regulations and PUC rules.
i. The customer shall notify the District within 24 hours of any
device that fails a test, and shall endeavor to repair the device as
soon as possible. If the device fails after repairs have been made,
the District may require that the device be replaced. If an imminent
health hazard exists, the District may terminate service to the
premises immediately.
E. Related Issues
1. Responsibility with respect to internal cross-connections:
The District recognizes that cross-connections may exist in the
customer’s water supply system, and that the containment method does
not afford protection to internal plumbing fixtures. Therefore, the
District shall advise the customer in all correspondence that the
customer should retain a qualified professional to insure that
internal cross-connections are adequately protected from backflow.
2. Responsibility with respect to thermal expansion:
The District recognizes that installation of a backflow preventer
may prevent water that expands due to heating from moving back into
the public water supply system, and that resulting pressure
increases could cause safety and relief valves to operate, or
equipment or piping to fail. Therefore, the District shall notify
all customers required to install a backflow preventer that they
should retain the services of a qualified professional to insure
that their water supply system is adequately protected from the
effects of thermal expansion.
3. Education:
The District recognizes that customers may not be knowledgeable
concerning cross-connection control. Therefore, the District shall
periodically inform customers of the general concepts of
cross-connection control and the District’s program requirements
through mailings of brochures and other educational materials. In
addition, the District shall maintain a file of materials that may
be sent to customers upon request for more detailed or site-specific
information.
F. Program Review
The District Cross-Connection Control Program shall be reviewed and
amended as required in January every two years, beginning in 2002.
Revised programs shall be submitted to the Department of Human
Services for review and approval.
G. Record-keeping Requirements
1. Non-permit devices:
The District shall maintain records of all Class I devices.
2. Permitted devices:
The District shall maintain installation, test, and repair records
of all Class II and III devices.
APPENDIX A
DEFINITIONS
A. Antifreeze compounds: Any liquid,
chemical or other material used as an antifreeze or heat-exchange
medium. Use of antifreeze compounds is limited to propylene glycol
and food-safe glycerin; ethylene glycol (automobile antifreeze) is
prohibited.
B. Backflow: The flow of water or other foreign liquids, gases, or
other substances or materials of any kind in any form into the
distribution system of a public water supply from any source other
than the intended.
C. Backflow Prevention Device: A device to prevent backflow.
A. Air Gap: A physical separation sufficient to prevent backflow
between the free-flowing discharge end of the potable water system
and any other system.
B. Atmospheric Vacuum Breaker: A device which prevents back-siphonage
by creating an atmospheric vent where there is either a negative
pressure or sub-atmospheric pressure in a water system.
C. Backflow Prevention Device with Intermediate Atmospheric Vent: A
device having two check valves separated by an atmospheric vent.
D. Double Check Valve: A device having two independently acting,
approved check valves that are internally loaded with two resilient
seated shut-off valves and test cocks for periodic testing. Referred
to as a "testable" device by the District; requires permitting by
the Department.
E. Dual check valve: A device having two independently acting,
approved check valves. Used primarily in residential and low hazard
non-residential situations. Referred to as a "non-testable" device
by the District; does not require permitting by the Department.
F. Hose Bib Vacuum Breaker: A device which is permanently attached
to a hose bib and which acts as an atmospheric breaker.
G. Pressure Vacuum Breaker: A device containing a spring-loaded
check valve and a spring-loaded atmospheric vent which opens when
pressure approaches atmospheric. It contains valves and fittings
which allow the device to be tested.
H. Reduced Pressure Zone Backflow Prevention Device (RPZ): An
assembly of check valves and a reduced pressure zone which spills
water to the atmosphere in the event of the failure of the check
valves. It has valves and fittings which allow the device to be
tested, and is referred to as a "testable" device by the District.
It requires permitting by the Department.
I. Approved device: A backflow prevention device as approved by the
Dept. of Human Services, Division of Health Engineering.
D. Back-siphonage: Backflow resulting from negative or less than
atmospheric pressure in the water system.
E. Back-pressure: A condition in which the customer’s system
pressure is greater than the supplier's system pressure.
F. Containment: A method of backflow prevention which requires a
backflow Prevention Device (containment device) at the water service
entrance.
G. Containment device: An approved backflow assembly that may
include a strainer as recommended by the manufacturer.
H. Contaminant: Any chemical, biological, or radiological substance
or matter which is an impairment of the water quality which creates
an actual hazard to the public health through poisoning or through
the spread of disease by sewage, industrial fluids, or waste.
I. Cross-Connection: A cross-connection is any connection or
arrangement, physical or otherwise, between a potable water supply
system and any plumbing fixture, tank, or any receptacle, through
which it may be possible for non-potable, used, unclean, polluted,
contaminated water, and/or other substances to enter into any part
of such potable water system under any condition. It is not
necessary for contamination or backflow to have actually occurred. A
cross-connection is simply the connection through which it may be
possible for backflow or contamination to occur.
J. Cross-connection Survey: An inspection conducted by the District
in order to identify any actual or potential
cross-connections, to determine the degree of hazard or potential
hazard and appropriate means of backflow prevention, or to confirm
compliance with the District's Cross-Connection Program.
K. Customer: A person, firm, corporation, or governmental division
which has applied for and been granted service, and is responsible
for payment of the service.
L. Department: Maine Department of Health and Human Services
M. District: Winterport Water District
N. Domestic service: A water line which supplies potable water for
non-fire protection uses such as drinking, bathing, culinary,
heating, and process water purposes.
O. Fire service: A water line which supplies water for fire
protection to a fire sprinkler or life safety system.
P. Fixture isolation: A method of backflow prevention in which a
backflow prevention device is located to correct a cross-connection
in any in-plant unit rather than at the water service entrance.
Fixture isolation alone is not deemed an acceptable method of
backflow prevention by the District within its distribution system.
Q. Industrial Fluids: Any fluid or solution which may be chemically,
biologically or otherwise contaminated or polluted in a form or
concentration such as would constitute a health, system, pollutional,
or plumbing hazard if introduced into the water supply. This may
include but is not limited to :
# polluted or contaminated used waters
# all types of process waters and “used waters” originating from
public potable water systems which may # # # deteriorate in
# sanitary quality
# chemicals in fluid form
# plating acids and alkalies
# circulated cooling waters connected to an open cooling tower
# cooling waters that are chemically or biologically treated or
stabilized
# contaminated natural waters such as from wells, springs, streams,
rivers, etc. or from irrigation systems or canals
# oils, gases, glycerine, paraffines, caustic, and acid solutions or
other liquid/gaseous fluids used in industrial or
# other processes solutions used for fire fighting purposes or
systems
R. Owner: One in whom the legal title to real estate is vested, or
who is recognized and held responsible by law as the Owner of real
property.
S. Permit: A document issued by the Department with the approval of
the District which requires the use of a specified backflow
Prevention Device based on degree of hazard. A cross-connection
permit application must be completed by the District and submitted
to the Department.
T. Person: Any individual or entity including, without limitation, a
partnership, company, public or private corporation, association,
political subdivision or agency of the State, Department, Agency, or
instrumentality of the United States.
U. Plumbing System: All potable water supply and distribution pipes,
all plumbing fixtures and traps, all drainage and vent pipes, and
all building drains, including their respective joints and
connections, devices, receptacles and appurtenances within the
property lines of the premises and shall include potable water
piping, potable water treating or using equipment, and water heater.
V. Seasonal Meter Set: A meter which is set for a limited amount of
time (such as for the summer) for a specific purpose (such as a
swimming pool or fountain).
W. Water Service Entrance: That point in the Customer’s water system
beyond the sanitary control of the District. This will normally be
the outlet end of the meter and will always be before any
unprotected branch.
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