Backflow Prevention and Cross Connection Control Annual Report. Jorge Delgado, PE Senior Field Engineer November 22, 2016

Transcription

1 Backflow Prevention and Cross Connection Control Annual Report Jorge Delgado, PE Senior Field Engineer November 22, 2016

2 Overview Background Inspection Year 2016 Requirements and Expectations Inspection year 2017, and beyond

3 State of Colorado Backflow Prevention and Cross-connection Control Annual Report Background

4 Acronyms Backflow Prevention and Cross-connection Control (BPCCC) Colorado Department of Public Health and Environment (Department) Colorado Primary Drinking Water Regulations (CPDWR) Safe Drinking Water Program (SDWP) Public Water Systems (Supplier or PWS) Reduced Pressure Zone Backflow Prevention Assembly (RPZ), Air Gap (AG), Double Check Backflow Prevention Assembly (DC), Pressure Vacuum Breaker (PVB)

5 Background Colorado Revised Statutes (1962) C.R.S (1)(h) Colorado Department of Public Health and Environment (Mid 1980s) Colorado Primary Drinking Water Regulations, Article 12 Readability rulemaking, Regulation CPDWR (2014) Currently Regulation CPDWR (2015)

6 Regulation 11.39(4) Regulation states that: (a) Beginning in 2017, the supplier must develop a written backflow prevention and cross-connection control program report for the previous calendar year

7 Regulation 11.39(6) Violations Regulation states that: (b) The following constitute backflow prevention and crossconnection control violations: (ii) The supplier fails to complete an annual backflow prevention and cross-connection control program report as specified in 11.39(4). Public notice of BPCCC violations required.

8 Inspection Year 2016 (IY 2016)

9 By the Numbers Since first report is not due till May 1, of 2017, not many reports were reviewed in IY Department has reviewed approximately 15 reports in IY Some suppliers completed a survey and submitted reports, or reports were evaluated during sanitary survey.

10 Requirements & Expectations

11 First Steps Delegate and assign staff which is responsible for report Read regulation Evaluate data base Complete report

12 Resources Regulation Report templates and sample data base can be found online at: Department s Field Services Section Staff Department s Local Assistance Unit and Coaches

13 Regulation 11.39(4)(a) Regulation states that: (a) Beginning in 2017, the supplier must develop a written backflow prevention and cross-connection control program report for the previous calendar year that includes all of the following information: Department Involvement Reports will be reviewed during sanitary surveys, site visits and may be requested by the Department at any time.

14 Regulation 11.39(4)(a)(i) Regulation states that: (i) Total number of non-single-family-residential-connections to the public water system and connections within the supplier s waterworks. This number includes all known commercial, agricultural, industrial, and multi-family service connections (duplexes and larger) This number includes the total number of waterworks such as treatment plants, storage tanks, and pump stations. For suppliers such has campsites, ymcas, campgrounds, restaurants, offices, resorts, recreation, etc., where the supplier owns or operates the building where water is supplied, the Department considers the internal premise plumbing and water supply systems part of the distribution system. In these cases the internal building water supply systems must be surveyed to the point of use by the water system.

15 Reg 11.39(4)(a)(i) Small Community and Non-Community Water Systems For suppliers such has HOA, campsites, ymcas, campgrounds, restaurants, offices, resorts, recreation, etc., where the supplier owns or operates the building where water is supplied, the Department considers the internal premise plumbing and water supply systems part of the distribution system. In these cases the internal building water supply systems must be surveyed to the point of use by the water system.

16 Regulation 11.39(4)(a)(i) *Note Many water systems have stated that the number of all nonsingle-family residential connections is unknown due to various reasons or issues with classification type such as: residential vs. multi-family, duplex vs. multi-family, multi-family vs. commercial, inadequate data base and record keeping, etc. For May 1, 2017 the survey ratio calculated will need to be based on the known number of non-single-family-residential connections. Suppliers that suspect unknown non-single-family-residential connections will need to update is written BPCCC program to address how the supplier intends to discover unknown nonsingle-family-residential connections.

17 11.39(4)(a)(i) *Note cont. For suppliers with internal building water supply requirements each separate building counts as one service connection for the survey ratio calculations. Supplier may find more than one cross connection per service connection. Supplier may find no cross connection at a service connection.

18 Non-single-family-residential Connections Questions

19 Non-single-family-residential Connections Sample Calculation, Example 1: PWS has 1050 total service connections. Supplier has determined that 850 connections are single family residential connections which do not require survey. Supplier operates three storage tank sites, one water treatment plant and two pump stations (6 waterworks sites). Supplier has determined that there are: 55 commercial connections which require survey or are already controlled, 25 industrial connections which require survey or are already controlled, 120 multi-family-residential connections which require survey (total service connections) (single-family residential connections) + 6 waterworks = 206 non-single-family-residential connections and waterworks which require survey. 55 (commercial connections) + 25 (industrial connections) multi-family connections + 6 waterworks sites = 206 non-single family connections and waterworks which require survey.

20 Non-single-family-residential Connections Sample Calculation, Example 2: PWS has 2100 total service connections. Supplier has determined that 1750 connections are single family residential or multi family connections. Supplier operates three storage tank sites, two water treatment plants and two pump stations (7 waterworks sites). Supplier has determined that there are: 295 commercial connections which require survey or are already controlled, 55 industrial connections which require survey or are already controlled (total service connections) Unknown (single-family service connections) + 7 waterworks = Unknown. 295 (commercial connections) + 55 (industrial connections) + Unknown multi-family connections + 7 waterworks sites = 357 non-single family connections and waterworks which require survey for 2016 Department expects that supplier identify multi-family residential connections. This process will need to be addressed in the survey portion of the BPCCC program.

21 Non-single-family-residential Connections Sample Calculation, Example 3: PWS has 100 total service connections. Supplier has determined that 100 connections are single-family-residential connections. Supplier operates one water treatment plant. (1 waterworks sites). Supplier has determined that there are: 0 commercial connections which require survey, (no parks or community buildings) 0 industrial connections which require survey, 0 multi-family connections which require survey. 100 (total service connections) 100 (single-family service connections) + 1 waterworks = 1 waterworks which require survey. 0 (commercial connections) + 0 (industrial connections) + 0 multi-family connections + 1 waterworks sites = 1 waterworks which require survey.

22 Non-single-family-residential Connections Sample Calculation, Example 4: PWS is a ski resort and has 100 total service connections. Supplier has determined that 10 connections are single-family-residential connections which do not require survey. Supplier operates one water treatment plant, two storage tanks and three pump stations. (6 waterworks sites). Supplier has determined that there are: 10 commercial accounts which require survey, (ski lodges and restaurants) 10 industrial accounts which require survey, (snow making, maintenance buildings, irrigation) 70 multi-family connections which require survey. 100 (total service connections) 10 (single-family service connections) + 6 waterworks = 96 non-single-family-residential connections and waterworks which require survey 10 (commercial connections) + 10 (industrial connections) + 70 multi-family connections + 6 waterworks sites = 96 non-single-family-residential connections and waterworks which require survey.

23 Regulation 11.39(4)(a)(i)(A) Regulation states that: (A) The supplier is not required to include any non-single-familyresidential connections identified after October 31 of the calendar year in the total number of non-single-family-residential connections to the public water system until the following calendar year. For 2017 Report, the survey ratio calculation must be based on all known non-single-family-residential connections identified before October 31, (Supplier can chose to include any newly discovered service connection from through if so inclined). For 2018 Report, the survey ratio calculation must include all newly discovered non-single-family-residential connections from November 1, 2016, to October 31, 2017.

24 Non-single-family-residential Connections Calculation Questions

25 Regulation 11.39(4)(a)(ii) Regulation states that: (ii) Total number of connections surveyed to determine if cross connections are present. Department Involvement Department will review survey documentation procedure and results. Database or records need to indicate whether or not a survey has been performed.

26 Regulation 11.39(4)(a)(iii) (iii) Survey compliance ratio. SURVEY COMPLIANCE RATIO means the total number of connections surveyed, including the number of all nonsingle-family-residential connections to the public water system with the most protective backflow prevention assembly or method that was not surveyed as specified in 11.39(3)(c), divided by the total number of non-singlefamily-residential connections to the public water system and connections within the supplier s waterworks.

27 11.39(4)(a)(iii) *Note Service connections controlled with an air gap, reduced pressure zone assembly or controlled appropriately for the identified contaminant can be considered surveyed. Scenario 1. A supplier s database and records indicate that an irrigation system without chemical is controlled with a pressure vacuum breaker, the supplier can consider the connection surveyed and controlled appropriately. Scenario 2. A supplier s database and records indicate that an fire suppression system without chemical is controlled with a double check assembly, the supplier can consider the connection surveyed and controlled appropriately.

28 11.39(4)(a)(iii) *Note cont. Scenario 3. A supplier s database and records indicate that an irrigation system with chemical injection is controlled with a pressure vacuum breaker, the supplier can consider the connection surveyed but cannot consider the connection controlled appropriately. Supplier has 120 days to appropriately control cross connection. Scenario 4. A supplier s database and records indicate that a commercial account is controlled with a double check valve backflow prevention assembly, the supplier cannot consider the connection surveyed or controlled appropriately. Scenario 5. A supplier s database and records indicate that a commercial account is controlled with a reduced pressure zone backflow prevention assembly, the supplier can consider the connection surveyed and controlled appropriately.

29 Survey Compliance Ratio TABLE I Survey Compliance Ratio* Compliance Date Compliance Ratio By December 31, 2016 Greater than 0.60 By December 31, 2017 Greater than 0.70 By December 31, 2018 Greater than 0.80 By December 31, 2019 Greater than 0.90 By December 31, 2020 and each year after 1.0 If the survey s compliance ratio for 2016 is lower than 0.6 and the supplier is currently not moving forward with its BPCCC implementation issue a Tier 2 violation will be deemed to have occurred. Supplier can apply for alternative compliance ratios. *Department approved alternative survey compliance ratios allowed

30 Survey Ratio Sample Calculation, Example 5: Compliant PWS has 1050 total service connections. Supplier has determined that 850 connections are single family residential connections which do not require survey. Supplier operates three storage tank sites, one water treatment plant and two pump stations (6 waterworks sites). Supplier has determined that there are 206 non-single family connections and waterworks which require survey Supplier has surveyed or controlled with an RPZ or AG: 25 commercial connections, 10 industrial connections, 100 multi-family-residential connections, & 6 waterworks. 25 (commercial connections) + 10 (industrial connections) multi-family connections + 6 waterworks sites = 136 non-single family connections and waterworks which are surveyed. 206 non-single-family-residential connections and waterworks which require survey. Survey Ratio = 136 (total connections surveyed) / 206 (non-single-family-residential connections and waterworks which require survey = Greater than 0.60 for 2016.

31 Survey Ratio Sample Calculation, Example 6: Non-compliant PWS has 1050 total service connections. Supplier has determined that 850 connections are single family residential connections which do not require survey. Supplier operates three storage tank sites, one water treatment plant and two pump stations (6 waterworks sites). Supplier has determined that there are 206 non-single family connections and waterworks which require survey Supplier has surveyed or controlled with an RPZ or AG: 25 commercial connections, 10 industrial connections, 10 multi-family-residential connections, & 6 waterworks. 25 (commercial connections) + 10 (industrial connections) + 10 multi-family connections + 6 waterworks sites = 51 non-single family connections and waterworks which are surveyed. 206 non-single-family-residential connections and waterworks which require survey. Survey Ratio = 51 (total connections surveyed) / 206 (non-single-family-residential connections and waterworks which require survey = is less than 0.60 for 2016 which is a violation.

32 Alternative Survey Ratio Applications can be found online at: Submit through Drinking Water Portal:

33 Survey Ratio Calculations Questions

34 Regulation 11.39(4)(a)(iv) Regulation states that: (iv) Total number of identified cross connections. Supplier may have more cross connections than non-single family residential connections. Needs to include all connections controlled but not surveyed with an RPZ or AG.

35 Total Cross Connections Sample Calculation, Example 7: PWS has reviewed date base and surveyed 250 connections. Based on existing data base review Supplier has determined that 200 cross connections were controlled appropriately for the identified contaminant: 140 connections controlled with an RPZ, 10 connections controlled with an AG, 30 irrigation systems connections controlled with a PVB, 20 fire suppression systems without chemical controlled with a DC. Based on survey results for 2016 Supplier discovered that 100 new cross connections. 200 (controlled x-con) (new controlled x-con) = 300 total cross connections.

36 Regulation 11.39(4)(a)(v) Regulation states that: (v) Number of uncontrolled cross connections identified during the calendar year. (A) Number of identified uncontrolled cross connections that were controlled within 120 days of discovery. (B) Number of identified uncontrolled cross connections that were not controlled within 120 days of discovery. If (B) is greater than 1 a Tier 2 violation may be deemed to have occurred, unless the supplier has received a department approved compliance extension 120 day control extensions.

37 Regulation 11.39(4)(a)(v) cont. Department Involvement: Need to know so Department can determine if suppliers are controlling cross connections in a timely manner in accordance with the regulation.

38 Total Uncontrolled Cross Connections Sample Calculation, Example 8: Compliant PWS has reviewed date base and has identified 300 cross connections. Based on existing data base review Supplier has determined that 200 cross connections were controlled appropriately for the identified contaminant: Based on survey results for 2016 Supplier discovered 100 new cross connections. Supplier determined that 50 new cross connections controlled appropriately for the identified contaminant. 300 (total cross connections) 200 (previously controlled x-cons) 50 (discovered x-cons) = 50 uncontrolled cross connections. (11.39(4)(a)(v)) Supplier has found 50 uncontrolled cross connections were not controlled appropriately: 29 where controlled within 120 days. Supplier suspended service to one service connection. 30 total controlled within 120 days (11.39(4)(a)(v)(A)). 20 where not controlled within 120 days but Supplier has received a Department extension for all 20 uncontrolled cross connections. (11.39(4)(a)(v)(B)).

39 Total Uncontrolled Cross Connections Sample Calc., Example 9: Non Compliant PWS has reviewed date base and has identified 300 cross connections. Based on existing data base review Supplier has determined that 200 cross connections were controlled appropriately for the identified contaminant: Based on survey results for 2016 Supplier discovered 100 new cross connections. Supplier determined that 50 new cross connections controlled appropriately for the identified contaminant. 300 (total cross connections) 200 (previously controlled x-cons) 50 (discovered x-cons) = 50 uncontrolled cross connections. (11.39(4)(a)(v)) Supplier has found 50 uncontrolled cross connections were not controlled appropriately: 30 where controlled within 120 days. Supplier suspended service to 10 service connection. 40 total controlled within 120 days (11.39(4)(a)(v)(A)). 10 where not controlled within 120 days, Supplier has not received a Department extension for all 10 uncontrolled cross connections. (11.39(4)(a)(v)(B)) If 11.39(4)(a)(v)(B) is greater than 1 a Tier 2 violation may be deemed to have occurred, unless the supplier has received a department approved compliance extension 120 day control extensions.

40 Alternative Extensions Applications can be found online at: Submit through Drinking Water Portal:

41 Total Controlled and Uncontrolled Cross Connection Questions

42 Regulation 11.39(4)(a)(vi) Regulation states that: (vi) Number of backflow prevention assemblies installed at cross connections that were used during the calendar year. BACKFLOW PREVENTION ASSEMBLY means any mechanical assembly installed at a water service line or at a plumbing fixture to prevent a backflow contamination event, provided that the mechanical assembly is appropriate for the identified contaminant at the cross connection and is an in-line field-testable assembly. Department Involvement Department and Supplier need the total number of assemblies used to protect the distribution system in order to calculate assembly testing ratio. This needs to include assemblies used at temporary service connections.

43 Total Backflow Prevention Assembly Sample Calculation, Example 10: PWS has reviewed date base and surveyed 450 connections. Based on existing data base review Supplier has determined that for 2016 the following cross connections were controlled with backflow prevention assemblies appropriately for the identified contaminant: 310 commercial connections controlled with an RPZ, 50 irrigation systems connections controlled with a PVB, 40 fire suppression systems without chemical controlled with a DC, 5 temporary connections controlled with an RPZ. 310 (RPZ) + 50 (PVB) + 40 (DC) + 5 (RPZ) = 405 total cross connections controlled with assemblies.

44 Regulation 11.39(4)(a)(vii) (vii) Number of backflow prevention methods installed at cross connections that were used during the calendar year. BACKFLOW PREVENTION METHOD means any method and/or nontestable device installed at a water service line or at a plumbing fixture to prevent a backflow contamination event, provided that the method or non-testable device is appropriate for the identified contaminant at the cross connection. Department Involvement Department and Supplier need the total number of methods used to protect the distribution system in order to calculate method inspection ratio. This needs to include methods used at temporary service connections.

45 Total Backflow Prevention Method Sample Calculation, Example 11: PWS has reviewed date base and surveyed 450 connections. Based on existing data base review Supplier has determined that for 2016, 11 cross connections were controlled with backflow prevention method appropriately for the identified contaminant: 9 connections controlled with an AG, 1 cross connection at water plant controlled with a block and bleed. 1 temporary connection controlled with an AG. 9 (AG) + 1 (block and bleed) + 1 (AG)= 11 cross connections controlled with a method.

46 Total Backflow Prevention Assembly and Method Questions

47 Regulation 11.39(4)(a)(viii) (viii) Number of connections where service was suspended as specified in 11.39(3) during the calendar year. Department Involvement This number is needed to calculate the number of identified uncontrolled cross connections that were controlled within 120 days of discovery (11.39(4)(a)(v)(A)) Department and Supplier need the total number of suspended accounts to evaluate effectiveness of practice.

48 Regulation 11.39(4)(a)(ix) (ix) Number of backflow prevention assemblies used to control cross connections that were tested by a Certified Cross Connection Control Technician during the calendar year. Department Involvement Department and Supplier need the total number of assemblies used to protect the distribution system in order to calculate assembly testing ratio. This needs to include assemblies used at temporary service connections.

49 Total Backflow Prevention Assembly Tested by a Certified Tester Sample Calculation, Example 12: Based on existing data base review Supplier has determined that 405 cross connections were controlled with backflow prevention assemblies appropriately for the identified contaminant: Supplier data base reflects that: 350 assemblies were tested by a certified tester in 2016, 20 assemblies were lasted tested in 2015, 10 assemblies were lasted tested in 2014, 25 assemblies there is no record of a test. For 2016 annual report regulation requires that supplier only include assemblies tested in Therefore in Example 12 the total tested by a certified tester is 350.

50 Regulation 11.39(4)(a)(x) (x) Backflow prevention assembly annual testing compliance ratio. BACKFLOW PREVENTION ASSEMBLY ANNUAL TESTING COMPLIANCE RATIO means the number of backflow prevention assemblies tested during the calendar year divided by the number of backflow prevention assemblies installed at a cross connection that were used during the calendar year.

51 Annual Testing Compliance Ratio TABLE II Backflow Prevention Assembly Annual Testing Compliance Ratio Compliance Date Annual Compliance Ratio By December 31, 2016 Greater than 0.50 By December 31, 2017 Greater than 0.60 By December 31, 2018 Greater than 0.70 By December 31, 2019 Greater than 0.80 By December 31, 2020 and each year after Greater than 0.90 If the Backflow Prevention Assembly Annual Testing Compliance Ratio is lower than 0.5 the supplier must contact CDPHE. A Tier 2 violation will be deemed to have occurred.

52 Backflow Prevention Assembly Annual Testing Ratio Sample Calculation, Example 13: Compliant Based on existing data base review Supplier has determined that in 2016, 405 cross connections were controlled with backflow prevention assemblies appropriately for the identified contaminant: Supplier data base reflects that: 350 assemblies were tested by a certified tester in 2016, 20 assemblies were lasted tested in 2015, 10 assemblies were lasted tested in 2014, 25 assemblies there is no record of a test. 350 (assemblies tested) / 405 (total assemblies) = For 2016, 0.86 is greater than 0.50.

53 Backflow Prevention Assembly Annual Testing Ratio Sample Calculation, Example 14: Non-Compliant Based on existing data base review Supplier has determined that in 2016, 405 cross connections were controlled with backflow prevention assemblies appropriately for the identified contaminant: Supplier data base reflects that: 150 assemblies were tested by a certified tester in 2016, 300 assemblies were lasted tested in 2015, 10 assemblies were lasted tested in 2014, 25 assemblies there is no record of a test. 150 (assemblies tested in 2016) / 405 (total assemblies) = is less than 0.50 for 2016 which is a violation.

54 No Alternative Extensions for Control Ratio Requirements

55 Total Backflow Prevention Assembly Testing Ratio Questions

56 Regulation 11.39(4)(a)(xi) (xi) Beginning January 1, 2021, the number and location of backflow prevention assemblies not tested during the calendar year covered by the report.

57 Regulation 11.39(4)(a)(xii) (xii) Number of backflow prevention methods used to control cross connections that were inspected during the calendar year.

58 Total Backflow Prevention Methods Sample Calculation, Example 15: Based on existing data base review Supplier has determined that for 2016, 20 cross connections were controlled with backflow prevention method appropriately for the identified contaminant: 15 connections controlled with an AG inspected by a certified tester, 3 waterworks connections controlled with an AG inspected by supplier staff. 2 block ands bleed methods at waterworks inspected by supplier staff. 15 (service connection AG) + 3 (waterworks AG) + 2 (block and bleeds) = 20 cross connections controlled with a method inspected by staff.

59 Regulation 11.39(4)(a)(xiii) (xiii) Backflow prevention method annual inspection compliance ratio. BACKFLOW PREVENTION METHOD ANNUAL INSPECTION COMPLIANCE RATIO means the number of backflow prevention methods inspected during the calendar year divided by the number of backflow prevention methods installed at a cross connection that were used during the calendar year. If the Backflow Prevention Method Annual Inspection Compliance Ratio is less than 0.90 the supplier must contact CDPHE. A Tier 2 violation will be deemed to have occurred.

60 Backflow Prevention Method Annual Inspection Ratio Sample Calculation, Example 16: Complaint Based on existing data base review Supplier has determined that for 2016, 20 cross connections were controlled with backflow prevention methods appropriately for the identified contaminant: 15 connections controlled with an AG and inspected by a certified tester, 3 connections controlled with an AG and inspected by Supplier staff. 2 block ands bleeds were not inspected. 15 (AG inspected) + 3 (AG Inspected) = 18 methods inspected in (methods inspected) / 20 (total methods) = For 2016, 0.90 equal to or greater than 0.90.

61 Backflow Prevention Method Annual Inspection Ratio Sample Calculation, Example 17: Non-Complaint Based on existing data base review Supplier has determined that for 2016, 20 cross connections were controlled with backflow prevention methods appropriately for the identified contaminant: 15 connections controlled with an AG and inspected by a certified tester, 3 connections controlled with an AG and were not inspected. 2 block ands bleeds were not inspected. 15 (AG inspected) = 15 methods inspected in (methods inspected) / 20 (total methods) = For 2016, 0.75 is less that 0.90 for 2016 which is a violation.

62 Backflow Prevention Method Annual Inspection Ratio Sample Calculation, Example 18: Complaint Based on existing data base review Supplier has determined that for 2016, 55 cross connections were controlled with backflow prevention methods appropriately for the identified contaminant: 5 connections controlled with an AG and inspected by a Supplier staff, 45 connections controlled with hose-bib vacuum breakers and inspected by Supplier staff. 5 vacuum breakers were not inspected by Supplier staff. 5 (AG inspected) + 45 (AG Inspected) = 50 methods inspected in (methods inspected) / 55 (total methods) = For 2016, 0.91 equal to or greater than 0.90.

63 Total Backflow Prevention Method Inspection Ratio Questions

64 Regulation 11.39(4)(a)(xiv) (xiv) Beginning January 1, 2017, the number and location of backflow prevention methods not inspected during the calendar year covered by the report.

65 Regulation 11.39(4)(b) (b) For each calendar year, the supplier must complete the annual backflow prevention and cross-connection control program report no later than May 1 of the following calendar year.

66 Annual Report Questions Questions

67 Inspection Year 2017 & Beyond

68 Public Notice For the past several years we have been identifying and discussing violations of Article 12, Regulations and now Regulation during sanitary survey site visits. All violations require public notice. The public s right to know about drinking water violations has been part of by the act since congressional re-authorization in Due to long-standing software and staffing constraints, the department has not cataloged and managed field-identified violations in the state s database. Therefore, the public notice requirements were not noted in the sanitary survey letters or tracked.

69 Public Notice Requirements Since January 1, 2016 public notice requirements have been included in the sanitary survey letters and will appear automatically in the draft consumer confidence report for the year following the sanitary survey. There are two types of violations associated with Regulation A treatment technique violation has been deemed by the department to impact public health (Tier 2). A BPCCC violation is generally a paperwork or record keeping violation (Tier 3), but can be elevated to Tier 2 based on severity.

70 BPCCC Public Notice Requirements In the event of a BPCCC treatment technique violation, the supplier must: (i) Notify the Department no later than 48 hours after the violation occurs. (ii) Distribute Tier 2 public notice as specified in In the event of a BPCCC violation, the supplier must: (i) Notify the Department no later than 48 hours after the violation occurs. (ii) Distribute Tier 3 public notice as specified in

71 Sanitary Survey IY 2017 Suppliers need to; Have annual report completed by May 1, Supplier is required to report any violations of the regulation within 48 hours. Annual Reports will be review thoroughly during sanitary surveys moving forward and other site visits. In the future it may be possible that Department may request reports to perform analysis of cross connection throughout the state.

72 Guidance Regulation 11 SDWP Policy 7 CDPHE Website: Report and database templates

73 CDPHE BPCCC Contact Jorge Delgado, P.E., Senior Field Engineer, , Tyson Ingles, P.E., Drinking Water Lead Engineer, ,

74 Questions & Comments?