Cross Connection Control Rules

Transcription

1 Source & Drinking Water Program Cross-Connection Control for Public Water Systems 2015 Focus on Change Seminars Introduction FL Department of Environmental Protection (FDEP) has had cross-connection control (CCC) rules for public water systems (PWSs) since 11/9/1977 With 1 exception, FDEP CCC rules relied mostly on reference to AWWA Manual M14, & remained largely unchanged, between 11/9/1977 & 5/5/ exception = FDEP amended CCC rules on 1/3/91 to allow dual check device (DuC) to be used as backflow protection at residential service connections (SCs) to premises with reclaimed water system Effective 5/5/2014, FDEP amended FL Administrative Code (FAC) Rule , "CCC for PWSs," to make numerous clarifications, modifications, & additions May Focus on Change Seminars 2 Agenda Purpose & effect of 5/5/2014 amendments to FAC Rule , "CCC for PWSs" Subsection-by-subsection review of current FAC Rule Subsection (1) Subsection (2) Subsection (3) Table Table Applies to all PWSs. Applies to only community water systems (CWSs). Where to get current FAC Rule Focus on Change Seminars 3 1

2 Purpose & Effect of 5/5/2014 Amendments to FAC Rule (1 of 2) Provide increased flexibility, & potential cost savings, for CWSs & their residential customers by Allowing DuC to be used at residential SCs to premises with any type of auxiliary or reclaimed water system A DuC is allowed only if there is no known crossconnection between the auxiliary/reclaimed water & plumbing systems on the premises. Thus, this is consistent with CSA Standard B Allowing biennial instead of annual testing of backflow preventer (BP) assemblies required at residential SCs This might lead to a 10% or greater increase in the rate of failure of these assemblies to meet specifications when tested. However, this is unlikely to significantly affect the rate of failure of these assemblies to prevent backflow, which is likely to remain < 1%. FL CWS-Served Single-Family Homes With Auxiliary water system using private well Auxiliary water system using surface water Auxiliary water system using another source Reclaimed water system No auxiliary or reclaimed water system 64% 28% 4% 1% 3% Source: Whitcomb, PhD, John B.; "Florida Water Rates Evaluation of Single-Family Homes;" July 13, Focus on Change Seminars 4 Purpose & Effect of 5/5/2014 Amendments to FAC Rule (2 of 2) Clarify CCC requirements to achieve more consistent compliance Add requirement for large CWSs i.e., CWSs serving > 10,000 persons to submit CCC program annual reports using 2-page form so FDEP can Better ascertain operational adequacy of large CWSs More efficiently conduct sanitary surveys of large CWSs There are about 240 large CWSs in FL, which is only about 14% of the total number of CWSs in FL. However, large CWSs serve about 91% of those FL residents who obtain their drinking water from a CWS Focus on Change Seminars 5 Subsection (1) (1 of 3) Cross-connections are prohibited unless appropriate backflow protection is provided to prevent backflow into PWS Cross-connection is defined in FAC Rule "Cross-connection means any physical arrangement whereby PWS is connected, directly or indirectly, with any other water To Building system, sewer, drain, conduit pool, storage reservoir, plumbing fixture, or other device that contains or may contain contaminated Cross-Connection water, sewage or other waste, or liquid of unknown or unsafe quality "By-pass arrangements, jumper connections, removable sections, swivel or changeable devicesare considered cross-connections" 2015 Focus on Change Seminars 6 2

3 Subsection (1) (2 of 3) Appropriate backflow protection is described in 3 rd Edition of AWWA Manual M14 as clarified & modified in paragraphs (1)(b) & (c) & Table Paragraphs (1)(b) & (c) & Table supersede AWWA Manual M14 Paragraphs (1)(b) & (c) say air gap (AG) shall be maintained between any PWS & any wastewater or reclaimed water system except as follows:» PWS may temporarily cross-connect to new wastewater or reclaimed water main for flushing or testing purposes, in which case double check valve assembly (DC) shall be provided» PWS may temporarily cross-connect to new reclaimed water main not yet connected to reclaimed water supply, in which case reducedpressure principle assembly () shall be provided» PWS justification, & provides, alternative equal to AG e.g., 2 semiannually tested s in series 2015 Focus on Change Seminars 7 Subsection (1) (3 of 3) Typical cross-connections & backflow protection at PWS treatment, storage, & distribution facilities are described on pages in AWWA Manual M14» AG on tank drains & waste discharges» Hose-bibb vacuum breaker on hose-bibb connections»etc. PWS may be interconnected to another PWS of same type without backflow protection CWS no BP required CWS CWS NTNCWS* NTNCWS* no BP required NTNCWS* CWS TWS^ TWS^ no BP required TWS^ NTNCWS* TWS^ * NTNCWS = Non-Transient Non-Community Water System. ^TWS = Transient Non-Community Water System Focus on Change Seminars 8 Subsection (2) (1 of 2) Each CWS shall establish & implement CCC program utilizing backflow protection at SCs This program is to protect CWS from contamination caused by crossconnections on customers' premises This program shall include written plan developed using recommended practices in 3 rd Edition of AWWA Manual M14 as clarified & modified in Tables & Tables & supersede AWWA Manual M Focus on Change Seminars 9 3

4 Subsection (2) (2 of 2) Each CWS serving > 10,000 persons shall prepare & submit CCC program annual reports First report shall cover calendar year 2016; subsequent reports shall cover each calendar year thereafter These reports shall be prepared using Form (13) These reports shall be submitted to appropriate FDEP district office or Approved County Health Department These reports shall be submitted within 3 months after end of calendar year covered by report 2015 Focus on Change Seminars 10 Subsection (3) Upon discovery of prohibited or inappropriately protected cross-connection, PWSs shall do one of following: Ensure cross-connection is eliminated Ensure appropriate backflow protection is installed to prevent backflow into PWS Discontinue water service If discovered cross-connection is on premises of customer of CWS & if customer category is described in Table , CWS shall: Ensure appropriate backflow protection is provided at SC regardless of whether cross-connection is eliminated or internal backflow protection is installed CWS Water Main Residential Premises DuC required Crossconnection discovered & eliminated Potable Water System Auxiliary Water System 2015 Focus on Change Seminars 11 Table (1 of 3) This table: Lists & describes five minimum components each CWS shall include in written CCC plan Includes clarifications & modifications to 3 rd Edition of AWWA Manual M14 Minimum Components Each CWS Shall Include in Written CCC Plan Component Number & Description I. Legal authority for CWS CCC program i.e., ordinance, bylaw or resolution, or water service rules & regulations. II. CWS policy establishing where backflow protection at SCs is mandatory. A. B. Policy shall be no less stringent [but may be more stringent] than Table Focus on Change Seminars 12 4

5 Table (2 of 3) Component Number & Description III. CWS policy regarding ownership, installation, inspection/testing, & maintenance of backflow protection CWS is requiring at SCs. A. Policy shall specify whether CWS or customer is responsible for installation, testing B. Policy shall specify design & performance standards, & installation criteria, for new backflow protection required at SCs. C. D. Policy shall specify frequency for testing BP assemblies required at SCs, qualifications for persons testing such assemblies, & test procedures for such assemblies. Assemblies required at non-residential SCs 2 pursuant to Table shall be tested after installation or repair & at least annually thereafter.assemblies required at residential SCs 2 pursuant to Table shall be tested after installation or repair & at least biennially thereafter. E. Policy shall specify frequency for refurbishing or replacing DuCs required at SCs. DuCs required at SCs pursuant to Table shall be refurbished or replaced at least every 5-10 years. 2 Residential SC means any SC, including any dedicated irrigation or fire SC, that is 2 inches or less in diameter & that supplies water to premises containing only dwelling units; & non-residential SC means any other SC Focus on Change Seminars 13 Table (3 of 3) Component Number & Description IV. CWS procedures for evaluating customer premises to establish customer category & backflow protection required at SC. 3 A. CWSs shall evaluate customer premises at newly constructed SC before CWS begins supplying water to SC. B. CWSs shall evaluate customer premises at existing SC: Whenever customer connects to reclaimed water distribution system, Whenever auxiliary water system is discovered at customer premises, Whenever prohibited or inappropriately protected cross-connection is discovered at customer premises, & Whenever customer premises is altered under building permit. V. CWS procedures for maintaining CCC program records. 4 A. CWS shall maintain current inventory of backflow protection being required at SCs. B. CWS shall maintain records of installation, inspection/testing, & repair of backflow protection being required at SCs. 3 CWS may evaluate customer premises using questionnaires, reviews of construction plans or pertinent records, on-site inspections, or any combination thereof 4 CWSs may maintain all records in electronic or paper format. In IV.B., discovered is intended to mean discovered during routine CWS operation & maintenance activities, such as during water quality complaint investigations, during meter changeouts, during water main or service line repairs, etc Focus on Change Seminars 14 Table (1 of 6) This table Lists customer categories for which each CWS shall ensure backflow protection is provided at SC Includes clarifications & modifications to 3 rd Edition of AWWA Manual M Focus on Change Seminars 15 5

6 Table (2 of 6) Customer Categories for Which Each CWS Shall Ensure Minimum Backflow Protection Is Provided at SC... Cannery,or any facility where fruit, vegetable, or animal matter is processed, excluding any premises where there is only restaurant or food service facility Hospital; medical research center; sanitarium; autopsy facility; medical dental or veterinary clinic where surgery is performed; or plasma center Laboratory, excluding any laboratory at elementary, middle, or high school Premises where oil or gas is produced, developed, processed, blended, stored, refined, or transmitted in pipeline, excluding any premises where there is only fuel dispensing facility 2015 Focus on Change Seminars 16 Table (3 of 6) Premises where there is auxiliary or reclaimed water system 4,5 A. Residential SC: DuC 7 B. Non-residential SC: DC if auxiliary or reclaimed water is low hazard 8,9 ; or if auxiliary or reclaimed water is high hazard 8,9 4 Auxiliary water system means pressurized system of piping & appurtenances using auxiliary water. 5 FDEP shall allow exception to requirement for backflow protectionif all of following conditions are met: CWS is distributing water only to land owned by CWS; Owner of CWS is also owner of entire auxiliary or reclaimed water system up to points of auxiliary or reclaimed water use; & CWS conducts at least biennial inspections of CWS & entire auxiliary or reclaimed water system to detect & eliminate any cross-connections between systems. 7 DuC may be provided only if there is no known cross-connection between plumbing system & auxiliary or reclaimed system on customer premises. Upon discovery of any cross-connection between plumbing system & any reclaimed water system on customer premises, CWS shall ensure cross-connection is eliminated. 8 Reclaimed water regulated under Part III of FAC Chapter is low hazard unless stored with surface water in pond that is part of stormwater management system, in which case it is high hazard; well water is low hazard unless determined otherwise by CWS;...are high hazards. 9 Upon discovery of any cross-connection between plumbing system & any reclaimed water system on customer premises, CWS shall ensure cross-connection is eliminated Focus on Change Seminars 17 Table (4 of 6) Premises where there is irrigation system that is using potable water & that I. Is connected directly to CWS distribution system via dedicated irrigation service connection II. Is connected internally to customer plumbing system I. PVB if backpressure cannot develop in downstream piping 10 ; or if backpressure could develop in downstream piping 10 II. None DC may be provided if both of following conditions are met: Dedicated irrigation service connection initially was constructed before 5/5/2014. No chemicals are fed into irrigation system. 11 CWS may rely on internal backflow protection required under Florida Building Code or predecessor State plumbing code. CWS may, but is not required to, ensure such internal backflow protection is inspected/tested & maintained same as backflow protection provided at SCs Focus on Change Seminars 18 6

7 Table (5 of 6) Premises where there is wet-pipe sprinkler, or wet standpipe, fire system that is using potable water & that: I. Is connected directly to CWS distribution system via dedicated fire service connection 12 II. Is connected internally to customer plumbing system I.A. Residential SC: DuC if fire system contains no chemical additives & is not connected to auxiliary water system; or if fire system contains chemical additives or is connected to auxiliary water system 13 I.B. Non-residential SC: DC if fire system contains no chemical additives & is not connected to auxiliary water system; or if fire system contains chemical additives or is connected to auxiliary water system 13 II. None CWS may rely on internal backflow protection required under Florida Building Code or predecessor State plumbing code. CWS may, but is not required to, ensure such internal backflow protection is inspected/tested & maintained same as backflow protection provided at SCs. 12 FDEP shall allow exception to requirement for backflow protectionif both of following conditions are met: Fire system was installed & last altered before 5/5/2014. Fire system contains no chemical additives & is not connected to auxiliary water system. 13 Upon discovery of any cross-connection between fire system & any reclaimed water system on customer premises, CWS shall ensure cross-connection is eliminated Focus on Change Seminars 19 Table (6 of 6) Tall building i.e., building with 5 or more floors at or above ground level Customer supplied with potable water via temporary or permanent SC from CWS fire hydrant Varies CWS shall ensure backflow protection commensurate with degree of hazard is provided at SC from fire hydrant Focus on Change Seminars 20 Where to Get Current FAC Rule View or download current FAC Rule , including Form (13), at following FL Department of State webpage: Focus on Change Seminars 21 7

8 Contact Information Florida Department of Environmental Protection Source & Drinking Water Program 2600 Blair Stone Road, MS 3520 Tallahassee, FL (850) Administrator: Trevor Noble 2015 Focus on Change Seminars 22 8