DRAFT/EXAMPLE CROSS-CONNECTION CONTROL PROGRAM
Recommendations:
Review and change the program plan to meet the needs of your agency. The attached draft plan is not intended to restrict the content of an agency's program documents. Have your legal consultant review the document. Ensure that authorization to disconnect services exists. Provide staff with formal training in cross-connection control survey work. This will provide credibility in both the on-site inspections and in any legal action that may be brought as the result of determinations. Allow time in addition to the estimated time needed for program implementation. Adjust schedule accordingly.
List of Attachments Needed:
Cross-Connection Control/Backflow Prevention Ordinance Standard Forms and Letters: Form for conducting surveys Assembly test form Drawings showing assembly installation and air gap requirements Example of the type of tracking report intended for use (for example, a computerprintout) Example form letters List of approved backflow prevention assembly testers (if used).
Nevada Rural Water Association
(AGENCY/GID/TOWN, ETC.) CROSS-CONNECTION CONTROL PROGRAM
This program exists in order for (AGENCY) to fulfill its responsibilities under the federal Safe Drinking Water Act, State of Nevada regulations for the design, construction, operation and maintenance of public water systems, (County name) County ordinances and (LOCALITY NAME) ordinances. (AGENCY) has both the responsibility to ensure that unsafe connections to the water system are mitigated, and the authority to take action, including discontinuance of water service, necessary to carry out that responsibility.
The (AGENCY) plan for inspecting the properties served by the (AGENCY) to determine the potential risk of cross-connection and backflow.
(AGENCY) PROPERTIES: Survey (AGENCY)-owned assemblies and establish compliance. (AGENCY) staff will conduct a detailed survey of all (AGENCY)-owned and operated water production, storage and distribution systems to identify potential cross-connections, and evaluate the degree of hazard. Where needed, approved backflow assemblies will be installed and tested or air gaps will be installed. Implement a public information program, which may include the following: Public meetings, information included with water bills; newspaper articles, press releases; information meetings with interested parties such as engineers, landscape contractors, and plumbing contractors. To the extent feasible, these activities will be coordinated with the County Health Department.
NEW CONSTRUCTION: Require that new construction comply with current State regulations and (AGENCY) rules. (AGENCY) inspects new construction for compliance with the Uniform Plumbing Code, including cross connection control requirements. (AGENCY) approval is a prerequisite to final building inspection and approval. New or relocated mechanical backflow prevention assemblies will not be approved until acceptable documentation of testing is received by (AGENCY).
RECORD REVIEW AND PRIORITY LIST: (AGENCY) staff will perform a review of service connection records to evaluate user activities to determine which service connections require protection from cross-connection. An internal priority will be assigned to each connection reviewed based on the degree of hazard (health / non-health). First priority connections are those where a health hazard is determined to exist, or that require protection from cross-connection in accordance with NAC 445A or the Uniform Plumbing Code. Second priority connections are all other service connections.
ON-SITE WATER USE SURVEYS: (AGENCY) staff will conduct on-site water use surveys of customer facilities, beginning with the highest priority users identified in the record review. The surveys will include residential service connections. The attached Field Survey Form, or equivalent, will be used. The (county name) County Public Health official may be requested to conduct joint surveys.
COMPLIANCE NOTIFICATION LETTERS: Those service connections determined to require protection from cross-connection, or present potential health hazards will receive a standardized letter requiring compliance within 60 days. The letter will specify the required type(s) of protection against cross-connection. The notification will state that service will be disconnected if compliance is not achieved and documented within 90 days. In addition, the compliance notification letter will outline the initial testing and ongoing maintenance and periodic testing requirements. The letter will state that (AGENCY) may test, or cause to be tested, any backflow prevention assembly or air gap installation connected to the water system, at any reasonable time.
COMPLIANCE REVIEW AND FINAL NOTIFICATION: Sixty days after mailing the compliance notification letter, (AGENCY) staff will review records to determine progress toward compliance. Lack of progress will result in a letter, mailed 'return receipt requested' referencing the original notification and stating that service will be disconnected from the water system if compliance is not achieved by the designated date.
ON-SITE SURVEYS: (AGENCY) staff will conduct an on-site survey of second priority connections. A compliance notification letter will be sent to those service connections that are determined to require protection from cross-connection.
(AGENCY) plan for testing and tracking all primary assemblies. Plan for the annual testing of those assemblies and for the retention or records from the testing.
RECORD KEEPING DATABASE: When conducting the initial system service connection review, (AGENCY) will establish a database for program record keeping. (AGENCY) plans to use dedicated commercial software for tracking assemblies, testing schedules, and assembly repairs.
TESTING COMPLIANCE NOTIFICATION: At least each year, a test record for each assembly or an air gap inspection report is to be submitted to the (AGENCY). If determined to be necessary, (AGENCY) may require a more frequent testing schedule. Thirty days prior to the anniversary date for air gap inspection or testing of each backflow prevention assembly, notification of the need to test will be transmitted to the service connection. A standard inspection or test and repair form will be attached to the letter. The letter will stipulate that all testing, repairs and re-testing be accomplished, and documentation of air gap inspection or backflow prevention assembly testing be received by (AGENCY) within 45 days of mailing. The standard test form requires identification of the currently certified backflow prevention assembly tester. Testing performed under this program will be spot-checked; (AGENCY) may access and test, at its own expense, any assembly at any reasonable time.
REPAIR RECORDS: When an assembly is moved, or removed and replaced, or an assembly is repaired, the assembly must then be tested. The standard test and repair form must be completed and provided to (AGENCY) within 10 calendar days following the move or repair. Details to be included are listed below. Parts replaced, with part number and manufacturer name; Name, address, telephone number of the person who performed the repair or moved the assembly, or of the responsible person at the customer service; Copy of post-repair or move assembly test with information on the testers' current valid AWWA backflow assembly tester certification. RECORD RETENTION: Assembly test and repair records will be retained by (AGENCY) for a period of at least three years.
III. List of the particular assemblies for the prevention of backflow that may be used in the (AGENCY) or on service connections to the (AGENCY):
For new or replacement installations, the assembly must be included in the FCCCHR list of approved assemblies in effect on the date of installation.
For existing assemblies, the owner must provide (AGENCY) with documentation showing that the assembly is included in the current FCCCHR list of approved assemblies or was included in the FCCCHR list of approved assemblies on the original installation date. Approval must be obtained from (AGENCY) before a backflow prevention assembly is removed, relocated or replaced.
Existing assemblies which were included in the FCCCHR list of approved assemblies upon installation, but which are no longer listed may continue to be used in the same application and location, for as long as annual test results indicate that the assembly is functional. De-listed assemblies that fail must be replaced. De-listed assemblies may not be moved. Air gaps must comply with Uniform Plumbing Code requirements. If desired, this is an appropriate section to include a list of approved assembly testers...
IV. Measures the (AGENCY) will take to enforce the program if any customers of the system fail to comply with the program.
Should any customer fail to comply with any requirement of this program within the allowed time frame, service will be disconnected. Program requirements include: Installation and testing of approved assemblies, or air gaps at the location or locations determined by the (AGENCY) within 90 days following mailing of the initial compliance notification. Annual testing of assemblies or air gap inspection report and (AGENCY) receipt of results within 45 days of mailing of the testing compliance notification letter. Backflow assembly testers must hold a current Backflow Assembly Tester certificate issued by the American Waterworks Association. All repairs needed must be accomplished, and re-test completed within the 45 day time period. Maintenance of installed assemblies in good working condition. Notification of (AGENCY) upon repair of an assembly, including (AGENCY) receipt of test results within 10 days following the activity. Approval must be obtained from (AGENCY) before a backflow prevention assembly is removed, relocated or replaced. (AGENCY) must receive test results within 10 days following the activity.
Schedule for Program ImplementationSchedule for Program Implementation
New Construction: The program is currently effective. (AGENCY) Internal Survey: Will be completed within six months following program approval. Record Review: Will be completed within one year following program approval. Site Surveys: Surveys of first priority connections will be will be completed within one year following program approval. Surveys of second priority connections will be completed within two years following program approval. Tracking Program: The tracking program will be implemented concurrent with site surveys. Assembly Testing: New backflow assemblies are tested upon installation as a prerequisite to construction permit sign-off. Existing assemblies are to be tested within 90 days following mailing of the compliance notification.