Shannon Water and Sanitation District Backflow Prevention and Cross-Connection Control Program

Transcription

1 Shannon Water and Sanitation District Backflow Prevention and Cross-Connection Control Program V4_Dec

2 TABLE of CONTENTS GOAL and OBJECTIVES... 3 ASSUMPTIONS... 3 LEGAL AUTHORITY... 3 POLICY STATEMENT... 3 BACKGROUND and TERMINOLOGY... 4 What is Backflow?... 4 What causes backflow?... 4 What is a cross-connection?... 4 Sources of Backflow... 4 What is a prevention device?... 4 Type of Backflow Preventers... 5 REGULATIONS... 6 Federal regulations... 6 State regulations... 6 City regulations... 6 REQUIREMENTS... 7 Containment Device Requirements... 7 COMPLIANCE PLAN... 8 Public Outreach to the Community... 8 Identifying and Reporting Cross-Connections... 8 Reporting Backflow Events... 9 Addressing Backflow Event

3 GOAL and OBJECTIVES Goal: The goal of this document is to provide a written Backflow Prevention and Cross-Connection Control (BPCCC) program in order to meet and comply with Section of Regulation 11 of the revised Colorado Primary Drinking Water Regulations, 5 CCR Objectives: 1. Develop and Implement a written BPCCC plan for the District. 2. Outline the process by which the Department shall be notified of any suspected or confirmed backflow events. 3. Outline the process by which the District shall keep records to track compliance with the BPCCC Rule. ASSUMPTIONS The Shannon Water and Sanitation District (SWSD) comprises 159 single-family households within Boulder County. As such, the District must comply only with those sections of the revised Regulation 11 that affect single-family households. LEGAL AUTHORITY SWSD shall administer a BPCCC program in the form of implementation of user agreements. The SWSD program implies a legally-enforceable mechanism to implement the BPCCC program as described in Regulation 11.39(2). Specific provisions identifying customer requirements under 11.39(2)(a)(ii, iv) and associated remedies that SWSD shall utilize in the case of failure of customer compliance are outlined in this document. POLICY STATEMENT This program has been developed according to the Colorado Department of Public Health and Environment s (Department) interpretation of Article and Article of Title 25 of the Colorado Revised Statues and of Section 39 of 5 CCR Colorado Primary Drinking Water Regulations (Regulation 11) effective May 1,

4 BACKGROUND and TERMINOLOGY In 2015 the State of Colorado Water Quality Control Commission (WQCC) revised Section and Regulation 11, which became the Backflow Prevention and Cross-Connection Control Rule, located in Section of Regulation 11, effective January What is Backflow? Water normally flows straight to your faucet, but pressure changes in a home or the public water supply can cause the water to flow backwards. Backflow is the undesired, reversed flow of water in water lines from the private property to the water distribution system that can contaminate drinking water. The Shannon Water and Sanitation District controls water quality up to the point of a private property. After this point, water quality can be degraded or contaminated within a private property. When backflow occurs, water from inside a private property can be pushed or pulled back into the community's drinking water supply. What causes backflow? Backflow results primarily from a pressure differential. Backflow occurs when water is pushed (backpressure) or pulled (backsiphonage). Backpressure is caused when the force of water at a private property overcomes district water pressure. Generally, backpressure is attributed to pumps, swimming pools, lawn irrigation systems and hose bibs. Backsiphonage occurs when a "reverse siphon" is caused due to pressure loss or fluctuation. Generally, water main breaks or large water uses, like operating fire hydrants, can cause backsiphonage to occur. Backflow prevention assemblies are used to help prevent backpressure and/or backsiphonage. Backflow can be isolated within a single property when water from a source, like a sprinkler system, pushes or pulls water back into the public drinking water supply. What is a cross-connection? A cross-connection is a direct physical connection between a potable water source and a nonpotable water source. A cross-connection is a point where backflow can occur. The terms "cross-connection" and "backflow prevention" are often used interchangeably, despite their subtle differences in meaning. Sources of Backflow Backflow can occur wherever there are potential cross-connections in a water system. Potential cross- connections include: Kitchen: dishwashers, garbage disposals Bathroom: toilets, hand-held shower heads, steam bath generators, bath whirlpool devices Faucets: hose bibbs, sill cocks, or any faucet where a hose can be attached Outdoors: swimming and wading pools, fish ponds, fountains, lawn irrigation systems What is a prevention device? Also known as a containment device, a backflow preventer is an assembly installed at the entry point of water into a private property and anywhere a potential cross- connection exists. The 4

5 devices prevent the backflow of water, and associated contaminants, from the customer s house back into the drinking water supply distribution system. This is especially important with regards to maintaining public health. Liquids that can backflow may include toxic chemicals, sewage and other dangerous substances, which have the potential to be ingested causing life threatening illnesses. It is very important that an appropriate backflow prevention device be installed to protect all consumers of the public water. Type of Backflow Preventers Several different types of backflow preventers exist. Three of the most common types are air gaps, hose bibb vacuum breakers and pressure type vacuum breakers. An air gap is the unobstructed vertical distance through the free atmosphere between the lowest opening from any pipe or faucet supplying water to a tank or plumbing fixture and the flood-level rim of the receptacle. A hose bibb vacuum breaker is an inexpensive device installed on a faucet or sill cock to protect against backflow from a garden hose or other type of hose. Pressure type vacuum breakers are used primarily on pipes supplying water to underground lawn sprinkler systems. They prevent the backflow of soil bacteria, animal wastes, fertilizers, and pesticides. A B Figure 1. Examples of Backflow Prevention Assemblies and Cross-Connections. A) Backflow prevention device on irrigation systems (source: Tigard Org. 016); B) Atmospheric vacuum breaker on outside faucet (source: Carson- Dunlop 2010); and C) Pressure vacuum breaker on a toilet valve (source: Carson-Dunlop 2010). C 5

6 REGULATIONS Federal regulations In 1974, the United States Congress, passed the Safe Drinking Water Act to help ensure that water distributed to households as tap water is safe to drink. Under the provisions of the Act, the water supplier is the primary responsible party to ensure water quality meets national standards of safe drinking water established through the Environmental Protection Agency (EPA). These provisions include a warranty that the water quality provided by the supplier is in conformance with EPA standards at the source, and that the water is delivered to the customer without compromising its quality. State regulations The Colorado Hazardous Cross-Connection Control Program was developed to implement Article 12 of the Colorado Primary Drinking Water Regulations. The regulation states: "A public water system or consecutive water distribution system of a public water system will have no uncontrolled cross-connections to a pipe, fixture or supply, any of which contain water not meeting provisions of the drinking water regulations." "Under Article 12 of the Colorado Primary Drinking Water Regulations, The Public Water Supplier has primary responsibility to develop and maintain a program to prevent or control contamination from water sources of lesser quality or other contamination sources from entering into the public water system." The Colorado Department of Public Health and Environment, Water Quality Control Division (CDPHE, WQCD) asks for compliance from all public water systems to protect public health by developing an effective individual cross-connection control program. Backflow prevention assemblies must be tested on a yearly basis by a certified tester and adequate records must be maintained. In 2015, the State of Colorado Water Quality Control Commission (WQCC) revised Section and of Regulation 11 which became the Backflow Prevention and Cross-Connection Control Rule, located in Section of Regulation 11, effective January 1, City regulations The Shannon Water and Sanitation District is working with its customers to protect the drinking water supply from pollution and contamination caused by cross-connections and backflow. Both the Boulder Revised Code and State of Colorado regulations (Article 12 of the Colorado Primary Drinking Water Regulations) require that backflow prevention assemblies be installed and tested annually by a certified backflow prevention tester. The Shannon Water and Sanitation District shall send letters notifying customers of their duty to test their assemblies and report any non-conformities or contamination issues. If no action is taken, the SWSD may shut off water service until a backflow test can be scheduled, passed and verified by the Department. 6

7 REQUIREMENTS Containment Device Requirements Orientation: Devices must be installed in the given orientation that they were tested for as allowed by ASSE. Installations of BFPAs not approved for the given orientation will have to be replaced or re-plumbed such that the assembly is in its approved orientation. USC FCCC&HR Approved Shannon Water and Sanitation District only allows devices approved by the ASSE. SWSD does not provide a list of approved devices. However, each manufacturer should be able to tell you which of their devices are ASSE approved and for what orientation. All manufacturer specifications must be met. Utility, City, and State Standards Installation of devices must meet all applicable requirements of: o City of Boulder Design and Construction Standards o Local plumbing and building codes o Article 12 of the Colorado Department of Health and Environment s Colorado Primary Drinking Water Regulations. The Backflow Prevention Program cannot recommend testers. However, a customer may find a backflow prevention tester by contacting their current plumber or contractor, looking in the phone book under "Backflow" or by searching online. The American Backflow Prevention Association has a list of certified Colorado backflow prevention testers available on its website. Testing costs will vary between the different testing companies. 7

8 COMPLIANCE PLAN Although a water utility serving a district composed of single-family households alone is not required to survey the community for potential cross-connections, it is required to survey its own facility and distribution system. In addition, not reporting or properly permitting an uncontrolled cross connection in the context of Regulation means the supplier has allowed their customers to continue to have an uncontrolled cross-connection past the regulatory-defined timelines (120 days). If the regulatory-defined timelines have elapsed and the supplier has not taken appropriate action, then the supplier is allowing, or permitting, the cross connection to exist and is in violation of Regulation 11. The Compliance Plan proposed by SWSD includes four primary components clearly outlining the procedures and duties associated with the implementation of the BPCCC program: 1. Public outreach with the community regarding the BPCCC Rule. 2. Identifying and reporting known cross-connections to the Department. 3. Reporting backflow events to the Department. 4. Addressing backflow events. Public Outreach to the Community In adherence to Colorado's regulations, the Backflow Prevention and Cross-Connection Control program shall protect the SWSD public water system from cross-connection contamination by requiring customers to: 1. Identify potential for cross-connections within the property that may affect the public drinking water supply. 2. Install approved backflow prevention devices. 3. Have containment devices tested at the time of installation and every year thereafter by a certified contractor to ensure their proper functioning. 4. Submit completed test reports to Shannon Water and Sanitation District Board of Directors. It is the customer's responsibility to hire a qualified and certified plumber to install and test a device. SWSD shall retain maintenance records of all containment devices and testing results. These records shall be available for inspection by Department personnel, per section 1.3 of these regulations. All maintenance records shall be kept for three years. The customers shall be notified of the BPCCC program through the provision of an electronic copy of this BPCCC plan and through regular District newsletters. Further, a written provision shall be provided to new residents in the District upon signing up for the water utility. Identifying and Reporting Cross-Connections If SWSD s public water system consists only of single-family-residential-service connections, the public water system does not have to perform surveys. However, if SWSD becomes aware of a single-family-residential connection to the public water system that is a cross-connection, the SWSD shall control the cross-connection in the same manner required in Regulation 11. 8

9 Further, SWSD shall survey its waterworks and identify if there are any direct connections to the public water system s distribution system. SWSD shall notify the Department of any cross-connections, as defined by Section (10) of the drinking water regulations, within 10 calendar days of its discovery. The cross-connection shall be corrected within 10 days of being ordered in writing by the Department to correct the problem. Failure to do so may result in an enforcement order. Single-Family Residential properties have been excluded from any annual testing requirement but may still need backflow prevention devices based on plumbing code. However, upon testing every 2 years, Regulation 11 section 11.39(2)(a)(vi) referring to the process the supplier will use to ensure backflow prevention assemblies are tested by a Certified Cross- Connection Control Technician shall be followed. The Department will determine the adequacy of SWSD process to ensure that testing has been completed by a certified professional. SWSD shall comply with section 11.39(2)(a)(vi) of Regulation 11 by doing the following: 1. SWSD shall use a documented process that ensures it receives a test report directly from the Certified Cross-Connection Control Technician or their associated company. 2. Test reports used to document compliance with Regulation 11 shall include all of the following: 2.1. Assembly or method information: Assembly or method type; Assembly or method location; Assembly make, model and serial number; Assembly size; Test date; and, Test result (pass/fail) Certified Cross-Connection Control Technician information: Certified Cross-Connection Control Technician certification agency; Certification number; Certification expiration date or statement that certification is current; and As an alternative to a-c, provide an alternative validation process such as electronic login to reporting software where only current, certified crossconnection control technicians (or their companies) are given a login. Reporting Backflow Events Regulation 11.39(3) requires that if a supplier learns of a suspected or confirmed backflow contamination event, the supplier must notify and consult with the Department on any appropriate corrective measures no later than 24 hours after learning of the backflow contamination event. The notification shall be made to the 24-hour Environmental Release and Incident Report Hotline at In the interest of public health, the Department encourages anyone aware of a backflow event, which may have contaminated a 9

10 public water system through a cross connection, to call the Department as soon as possible after necessary emergency response calls have been made. When reporting the event, as much of the following information as possible shall be provided: 1. Date and time of event; 2. Location of event; 3. Type of threat or incident (bacteriological chemical, radiological, physical, etc.); 4. SWSD Name and Identification Number; 5. SWSD personal contact name and phone number; 6. Method of discovery (consumer complaint, witness, perpetrator, employee report); 7. Response actions taken (water quality parameter testing, isolation of affected water); 8. Recovery actions taken; 9. Notifications made (customers, law enforcement, news media, etc.); 10. Assessment of threat, if possible. Once the Department has gathered the necessary information the Department will provide assistance to ensure the safety of the public and the integrity of the public water system. Addressing Backflow Event 1. SWSD shall meet compliance with Regulation 11 by completing one of the following actions within 120 days of identification and reporting of backflow event: 1.1. Control the cross connection Remove the cross connection Suspend service to the connection. Before suspension of service can be considered appropriate action the Department expects that the supplier will confirm the following: The connection downstream of the valve used to suspend the service does not remain pressurized because the customer has access to an alternative source of water or a storage tank onsite If the cross connection is to a fire suppression system; suspension of service would not result in the building being inadequately protected from loss of life through fire. If there are service connections at the property separate from the fire suppression system causing the cross connection, a supplier may suspend service to one or all of those other service lines (e.g. domestic or irrigation) as an appropriate action Receive a Department-approved alternative compliance schedule Department-approval of an alternative compliance schedule means either an or other written communication from the Department. After 120 days, the supplier is only in compliance with Regulation 11 if the supplier is following an approved alternative compliance schedule. 10