Backflow Prevention and Cross-connection Control Year in Review. Jorge Delgado, PE Senior Field Engineer November 22, 2016

Transcription

1 Backflow Prevention and Cross-connection Control Year in Review Jorge Delgado, PE Senior Field Engineer November 22, 2016

2 Overview Background Impact to Public Health Discovered Cross Connections CDPHE Programmatic Observations Inspection Year 2017 & Beyond

3 State of Colorado Backflow Prevention and Cross-connection Control 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 System (Supplier or PWS)

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 Overall Rule Requirements Backflow contamination event reporting requirements Written backflow prevention and cross-connection control program Distribution system survey and waterworks survey to identify cross connections Installation of backflow prevention assemblies or methods on uncontrolled cross connections Testing and inspection requirements for backflow prevention assemblies and methods Annual backflow prevention and cross-connection control program report, first report due May 1, 2017

7 Impact to Public Health

8 Impact to Public Health No known or suspected water borne disease outbreaks at public waters systems from cross connections in million residents (U.S. Census Bureau) 77.7 million visitors (Colorado Tourism Office)

9 Colorado Contamination Events Last confirmed backflow contamination event was in June 8, A portion of the a PWS distribution system, which was without water due to a line break, was charged by a customer with a private well. The customer accessed the distribution system via the service connection. A portion of the PWS distribution system was supplied by an unregulated water source which is a cross connection. Last known waterborne disease outbreak from cross connection 2012 HVAC, propylene glycol.

10 PSA Backflow Contamination Event Reporting Requirements If the 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. Please report any suspected backflow contamination event to:

11 PSA Backflow Contamination Event Reporting Please have available as much of the following information as possible: Date and time of incident, location of incident, type of threat or incident, Public Water System Name and Identification Number, water supplier contact name and phone number, Method of discovery (complaint, witness, employee report), Response actions taken and status of threat to public (water quality parameter testing, isolation of affected water), Recovery actions taken, notifications made (customers, law enforcement, news media, etc.),

12 Show and Tell

13 Discovered Cross Connections Dump Station Campground PWS

14 Discovered Cross Connections Powder Activated Carbon Feed PWS

15 Discovered Cross Connections Funeral Home Embalming Water Supply

16 Discovered Cross Connections Funeral Home Embalming Water Supply

17 Discovered Cross Connections PWS Contact Time Bypass

18 Discovered Cross Connections PWS Fill Station No Air Gap or Assembly

19 Discovered Cross Connections PWS Uncontrolled Irrigation System

20 Discovered Cross Connections PWS New Source Discovered

21 Discovered Cross Connections Heat Transfer System

22 Discovered Cross Connections HVAC System Bypass

23 Discovered Cross Connections Inappropriately Controlled Chemical Feed Systems

24 Discovered Cross Connections Boiler With Chemical Not Appropriately Controlled

25 Discovered Cross Connections Block and Bleed Around Contact Time Bypass

26 Impact to Public Health & Discovered Cross Connections Questions

27 Inspection Year 2016 (IY 2016)

28 By the Numbers For IY 2016 the Department evaluate 432 Public Water Systems and their BPCCC programs (approximately 2000 Public Water Systems in Colorado). 291 total observations, 46 violations for no plan, 51 significant deficiencies, 166 incomplete or general plan recommendations.

29 Alternative Extensions Approved seven 120 day control extensions for 41 discovered service connections. Approved two alternative schedule request for PWS. Approved five 60 day repair extensions for 110 failed assemblies. Approved six Alternative Survey Ratio request.

30 CDPHE Programmatic Observations

31 What We ve Learned Generally improved, statewide implementation. More cross connections discovered and controlled. More non-single-family-residential connections being evaluated. Improved performance evaluation during sanitary surveys. Improved documentation and implementation by suppliers. Assemblies tested by certified testers. Suppliers are still requiring that most assemblies be tested.

32 What We ve Learned Suppliers need to: Evaluate ordinances and authority, (outdated, inadequate survey requirements, old references, no survey requirements), Evaluate control standards and specifications, (inappropriate control standards), Evaluate data base for survey, control, and testing components, Better distinguish between multi-family and residential service connections.

33 What We ve Learned Many small water system not implementing programs (approximately 10 % of water systems). Public Notice of violations is not a favorable topic or action. CDPHE needs to provide additional guidance for annual report, survey & control requirements and fire suppression systems.

34 Written Program Status Some suppliers do not have programs (approx. 10 % of water systems). Some suppliers have plans and ordinances but have not implemented program (approx. 10 % of water systems). Many suppliers are implementing programs which need to be updated to reflect change in regulation (approx. 55 % of water systems). Some suppliers need to make changes or improvements to programs (approx. 15 % of water systems). Few supplier do not need to make any more changes (approx. 10 % of water systems). All suppliers need to ensure that waterworks are part of the BPCCC program.

35 Written Program Status cont. Further develop program to work with building department and billing process to identify multi-family residential connections for surveys. Further develop program to work with building department and billing process to identify change in use or change in customer at already evaluated facilities for a re-survey process. Department recommends that suppliers evaluate all suppliers buildings water supply systems to ensure that there are no uncontrolled cross connections and that all assemblies are tested annually and all methods inspected annually. Need to further evaluate integrated system agreements and BPCCC implementation.

36 Legal Authority Status Some observations about ordinances and legal authority: If supplier assumes responsibility program such include a statement such as; The supplier is responsible for all service connections and internal water supply systems. The supplier takes responsibility for identifying cross connections, controlling identified cross connections and ensuring that assemblies and or methods are tested annually by a Certified Cross-Connection Control Technician or were allowed by the suppliers designated staff. The supplier will evaluate Regulation 11, Safe Drinking Water Program Policy 7, the Colorado Plumbing Code and developed guidance to determine which assemblies or methods can be used for appropriate control and may consult the Department for any additional information. Definitions and references to older regulations and control standards may need to be updated including but not limited to cross connection, control, Certified Cross- Connection Control Technician, Article 12, outdated plumbing code references, etc. Ordinances should include testing requirements for newly installed assemblies.

37 Legal Authority Status Additional observations about ordinances and legal authority: Some ordinances did not specify time frames or pathways for resolution. Some ordinances do not allow the use of the use of pressure vacuum breaker backflow prevention assemblies or double checks, if appropriate for the identified contaminant. Some ordinances allowed uncontrolled cross connections from fire suppression systems. Some ordinances mandated strictly a containment program and did not allow for containment by isolation. Some ordinances did not address potential residential service connection cross connections or multi-family cross connections.

38 Survey Status Suppliers need to better identify all non-single-family-residential connections; Commercial, Industrial, Agricultural, Multi-family, etc. Suppliers need to review complete data base for all non-singlefamily-residential connections. Needs to include, water treatment plants, storage tanks, pump stations, etc. Survey ratio needs to be calculated based on number of known nonsingle-family-residential connections. If the supplier is aware that there are non-single-family residential connections which have not been surveyed but the supplier does not know the total number, the ratio for 2016 is based on the known total. BPCCC program will need to address strategy moving forward for identifying connections which require survey.

39 Survey Status cont. Survey does not mean control. The regulation requires that all service connections must either be controlled or surveyed for cross connections. If the results of a survey determine that no cross connection is present the Department does not require control of the service connection. During surveys of multi-family service connections Suppliers do not need to survey individual private residences. Suppliers need to evaluate the service connection and common areas such as: mechanical rooms, fire suppression systems, irrigation systems, swimming pools etc.

40 Sanitary Survey Takeaways Ordinances can be improved. Suppliers need to ensure that their legal authority allows for survey, control, testing, removal of connection or suspension of service and applicable action. Control requirements need to be updated. Supplier need to allocate adequate resources, time and economic. If supplier utilizes a third party to administer its program, supplier is still fully responsible for data base and implementation requirements. Surveys can be outsourced and can be performed by phone, internet, and paper questionnaires.

41 Sanitary Survey Takeaways cont. Consecutive systems service connections to regulated public water systems are not cross connections and do not require control. Emergency inter-connects to public water systems do not require control, however suppliers may need to exercise inter-connects for improved water quality and to increase chlorine residual. Department still identifies uncontrolled cross connections and identifies assemblies which have not been tested or repaired at water treatment plants and building water supply systems.

42 General Takeaways Urban communities anticipate doubling the number of assemblies and methods being tracked. Department and PWS anticipates that the number of surveys at non-single family service connections will double. Rural Communities have increased their BPCCC Program strength and implementation. Large impact to small water systems such as campgrounds, restaurants, hotels, and office parkways.

43 Inspection Year 2016 & CDPHE Programmatic Observations Questions

44 Inspection Year 2017 & Beyond

45 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.

46 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.

47 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

48 CDPHE Expectations Supplier must have a written program. If the supplier does not have a written program a violation has occurred. This is a Tier 3 violation which requires public notice as specified in Supplier must address all the components of the written program. If the suppliers program is specified in other documents please compile into one document. Evaluate if documents such as ordinance and standards need to be updated due to changes in regulation.

49 Survey Compliance Ratio System survey requirements to determine if cross connections are present 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 Identified cross connections must be controlled in 120 days* 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. *Department approved alternative compliance schedules allowed

50 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 Assemblies that fail testing: repair/replace assembly in 60 days* Inadequate prevention method, Air Gap, Block and Bleed: correct the problem in 60 days* *Department approved alternative compliance schedules allowed for failed assemblies

51 Annual Testing Compliance Ratio 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. 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.

52 Report Rule Requirements By May 1, 2017, Suppliers must develop a written backflow prevention and cross-connection control program report for the previous calendar year that includes all of the following information***: Total number of non-single-family-residential connections to the public water system and connections within the supplier s waterworks Total number of connections surveyed Survey compliance ratio, total number of identified cross connections Number of uncontrolled cross connections identified Number of backflow prevention assemblies & methods installed and tested Backflow prevention assembly annual testing compliance ratio. * **Additional reporting requirements specified in Regulation 11.39

53 CDPHE Expectations Supplier must have an annual report. If the supplier does not have a written report a violation has occurred. This is a Tier 3 violation which requires public notice as specified in Supplier must address all the components of the annual report. If the suppliers report does not include all the required information a violation may have been deemed to occur.

54 Inspection Year 2017 Questions

55 Guidance Regulation 11 SDWP Policy 7 CDPHE website: Program and report templates for various system types Survey questionnaires CDPHE Sanitary Survey Assistance Revised alternative survey compliance schedules, compliance schedules for retro fits that exceed 120 days and assembly repairs that exceed 60 days.

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

57 Questions & Comments?