DEQ CROSS CONNECTION CONTROL UPDATE MAY 9, 2018

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1 DEQ CROSS CONNECTION CONTROL UPDATE MAY 9, 2018

2 Recent Changes Recent amendments to Act 399 included: Specific references to residential accounts. Reduction of device testing to 5 years (irrigation w/ no treatment) Starting 1/1/2018, device testing is ASSE 5110 certified. Ongoing Debates Michigan representatives continually debating the testing frequency Implementing cross connection in residential setting

3 Laws and Rules & Guidance Part 14 of Act 399 requires PWS s to have a ordinance and program to look for and eliminate cross connections Michigan Plumbing Code DEQ Cross Connection Manual

4 Other Cross Connection Terms Backflow Backpressure Backsiphonage High Hazard vs. Low Hazard Testable vs. Non-Testable Inspections vs. Testing

5 Backflow The undesirable reversal of flow of water or other substances into the potable water distribution supply. It can be caused by backpressure, backsiphonage or combination of both.

6 Backpressure Is the reversal of normal flow caused by the downstream pressure exceeding the upstream pressure in the potable water lines. Common Causes: Pumps Boilers Elevation differences Backpressure example

7 Backpressure - Boilers Boilers heat up water to produce steam increasing the pressure inside the vessel Boilers The increase pressure can lead to backflow by backpressure

8 Backsiphonage Is the reversal of normal flow caused by a vacuum or partial vacuum in a water supply system. Common Causes: Poor Hydraulic Capacity Water Main Breaks Fire Demands

9 Backpressure or Backsiphonage??

10 High Hazard vs. Low Hazard Health Hazard = High Hazard (Contaminant) Non-Health Hazard = Low Hazard (Pollutant)

11 High Hazard vs. Low Hazard Health Hazard = High Hazard (Contaminant) Non-Health Hazard = Low Hazard (Pollutant)

12 High Hazards VS Low Hazards

13 Facilities & Accounts Typical High Hazard WWTPs Funeral Homes Dentist Offices Car Washes Plating & Chemical Plants Laboratories Marinas Hospitals Restaurants & Taverns Typical Low Hazards Offices Fire Suppression Systems (with no additives) Residential (with no lawn sprinkling) Low Pressure Untreated Boilers

14 Testable vs. Non-Testable Testable Assemblies can and must be tested routinely to assure they are working properly. Assemblies will have test cocks and isolation valves for performing the test. RPZ, DCVA, PVB Non-Testable Devices are not designed to be tested and are not required to be tested. AVB, HBVB, Vented DCVA

15 Inspections vs. Testing Inspections: Usually done by municipal personnel or their contractor to identify potential cross connections. Testing: Usually done buy a plumbing company hired by the customer to ensure assemblies are working properly.

16 Five Means of Preventing Backflow Air Gap Separation Reduced Pressure Principle Assembly Double Check Valve Assembly Pressure Vacuum Breaker Atmospheric Vacuum Breaker

17 Air Gap The physical separation between the discharge end of a potable water pipe and the top (flood rim) of an open receiving vessel No more than 12

18 Reduced Pressure Principal Backflow Preventer Assembly (RPZ)

19 Double Check Valve Assembly (DCVA)

20 Non-testable Double Check Valve Devices Dual Check Valve for Carbonated Beverage Dispensers (ASSE #1022 Backflow Preventer with Intermediate Atmospheric Vent (ASSE #1012

21 Pressure Vacuum Breakers (PVB)

22 Atmospheric Vacuum Breakers (AVBs)

23 Backflow Prevention Summary Air Gap RPPBP DCVA PVB AVB High Hazard X X X X Low Hazard X X X X X Back pressure X X X Backsiphonage X X X X X

24 Isolation vs. Containment Two methods of protecting the public water supply: Containment: Separates the water user from the public water system by placing a back flow prevention device on the main service line. Cross Connections exist downstream of the backflow preventer. Isolation: Backflow Preventers / methods are provided throughout points in the private piping system where cross connections are located. However, no device exists on the main service line. Or you may do a combination of both.

25 Isolation vs. Containment ISOLATION Preferred because in plant personnel are protected. Smaller size devices or no devices are required Often cheaper Educational for plant personnel, managers, & owners CONTAINMENT Facility is contained (separated from public system) Frequent plumbing changes Untraceable or hidden plumbing Confusing plumbing Access to facility is refused or prohibited by owner Facility employees may not be protected

26 Containment Example Protects the water supply, but not the building occupants Treated boiler Lawn irrigation domestic Plating process RPZ Nontreated boiler water main meter service line

27 Isolation Example Protects the building occupants & the water supply Treated boiler RPZ PVB Lawn irrigation domestic Plating process RPZ DCVA Nontreated boiler water main meter service line

28 Recent Changes Recent amendments to Act 399 included: Specific references to residential accounts. Reduction of device testing to 5 years (irrigation w/ no treatment) Starting 1/1/2018, device testing is ASSE 5110 certified. Ongoing Debates Michigan representatives continually debating the testing frequency Implementing cross connection in residential setting

29 Testing Frequency 3 year minimum Act 399 requirement 5 years allowed for non-treated residential irrigation systems Plumbing Code?

30 Plumbing Code R Compliance with regulations and local codes. Rule A connection with a public water supply system shall comply with existing laws, ordinances, codes, and rules including: (a) All sections of the Michigan plumbing code or the Michigan residential code pertaining to backflow and cross connection control. The codes allow for existing plumbing systems to stay as currently installed, providing they were installed properly according to the code in effect at the time of installation and they do not currently present a safety hazard. (b) Local ordinances or rules providing acceptable protection against cross connections.

31 ASSE 5110 Certification Previously: Michigan Specific Certification Plumber license required. January 1, 2018: Nation-wide Certification No plumbers license required. Testing requirements changed. Conversion class Consequences: intended and otherwise

32 Residential Inspections Are water utilities expected to do Cross Connection Inspections at homes and other residential accounts?

33 Residential Inspections (cont) Yes! A cross connection is a cross connection, it doesn t matter if it s in a commercial building or a home. Water utilities have historically focused on commercial and industrial accounts, but residential accounts cannot be ignored.

34 Residential Inspections (cont) Examples of x-connections found in homes: lawn irrigation systems with and without chemical addition private wells pools or whirlpools recirculation pumps geothermal heat pumps solar panels driveway/sidewalk melting systems water assisted sump pumps

35 Residential Inspections (cont) In the past 5-10 years, DEQ has been actively reminding utilities of their residential x-conn obligations. Not expected to inspect every home, but some effort should be made. Many utilities are now doing some level of a residential program.

36 Residential Recommended Strategy Step 1 Provide education on the purpose and requirements Pamphlet with bills Information on CCR Information in newsletter Management support!!!

37 Residential Recommended Strategy Step 2 Inventory Testable Assemblies & Notify Use questionnaires Exterior inspections Billing records (Sprinkling meters)

38 Residential Recommended Strategy Step 3 Inspect residents When the opportunity arises Meter Replacement Water Quality Complaint Sewer Inspection When cross connections are suspected

39 Residential Inspections Wrap Up Do not ignore residential accounts! Severe or high hazards are commonly found in homes. Perform inspections as best possible. Use public education materials to your advantage. Enforce requirements consistently

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