Cross Connection Compliance

Avondale Borough is pleased to announce that it has joined with Pennsylvania Water Specialties Company (PAWSC) to establish a cross-connection control administration and backflow prevention program for its commercial customers to insure that our focus on quality and accountability provides a proven source of drinking water that you can count on.

The United States Environmental Protection Agency (EPA) and the Department of Environmental Protection (DEP) in Pennsylvania define a “cross-connection” as any point in the water supply system where non-potable, or non-drinkable, water can be introduced to potable or clean sources. All service lines connected to public water systems are therefore potential “cross-connections”.

The Borough’s water distribution system is designed to ensure that water flows from the water main through a service line to the premises of its customers. Certain conditions-such as frozen pipes, a water main break, or even extreme and unexpected demand on the system-can cause water pressure to fail. When that happens, water from customer service lines can flow back into the distribution system, potentially contaminating the local public water supply, and thereby creating a hazardous situation which is commonly referred to as “backflow.” To avoid such dangerous incidents, and as a matter of public safety, federal and state laws require certain customers to install backflow prevention (“BFP”) assemblies on their water services and to test and maintain these assemblies periodically.

Accordingly, Avondale Borough is responsible for adopting and implementing a Cross-Connection Control (“CCC”) Program for its commercial customers to survey the water distribution system and communicate with customers to determine the existence of cross-connection hazards and to enforce rules for the customers to install BFP assembles and have those assemblies tested on a regular basis.

At no cost to the Borough, we have joined with PAWSC, a knowledgeable provider about state and federal CCC Programs requiring installation, testing and maintenance of BFP assemblies. PAWSC will administer the program which involves the professional day-to-day administration, tracking and record-keeping functions of a properly established CCC Program.

PAWSC will be in contact with those commercial customers who are required to install and properly maintain these BFP devices through letters about the requirement of the program.

10 Most Frequently Asked Questions About This Program

1. What is cross connection control and backflow prevention all about concerning containment and isolation?

A “cross-connection” as defined by the Environmental Protection Agency, is “any actual or potential connection between the public water supply and a source of contamination or pollution”. Such cross-connections constitute a hazard to the building occupants and can jeopardize the cleanliness and potability of the public water system, in the event of a backflow or backsiphonage event. A cross connection control program is an organized, legally implemented and structured program to eliminate and contain the hazards to the municipal potable water supply. These programs have been implemented and are typically passed by local ordinance, and enforced by the local water purveyor and the local building department.

2.   What is the legal basis for a local cross connection control program?

Generally, the Federal Government requires the enforcement of the Safe Drinking Water Act in the state through OSHA and the EPA.   There are also state laws on this subject.

If a customer seeks a specific reference it must be communicated that there simply is no “one-stop shop” to find the applicable statues and regulations in this area. They are found within various places and within various statutes and regulations.

Oversight of cross-connection control is shared by multiple agencies and jurisdictions, including the Department of Environmental Protection (DEP), the Department of Labor and Industry, local municipalities, and the Public Utility Commission (PUC). The Department of Labor and Industry and local municipalities regulate cross connections through the Uniform Construction Code, which includes the International Plumbing Code. The PUC plays a role because additional details about cross-connection control are often specified in the water system’s Tariff.

The most basic legal basis can be found within DEP’s cross-connection control requirements which are found in regulations at Title 25, Pa Code Chapter 109 (Safe Drinking Water) as follows:

109. 608. Cross-connections. A public water system may not be designed or constructed in a manner which creates a cross-connection.

and

109.709. Cross-connection control program. (a] No person may introduce contaminants into a public water supply through a service connection of a public water system.

• It shall be the responsibility of the customer to eliminate cross-connections or provide backjlow devices to prevent contamination of the distribution system from both Back-

siphonage and backpressure. Individual bacliflow preventors shall be acceptable to the public water supplier.

• If the customer fails to comply with paragraph (1) within a reasonable period of timeJ the water supplier shall discontinue service after reasonable notice has been made to the customer.

3.     What is my liability as a building Owner, property manager and water purveyor?

Legally, the “purveyor” of the water supply is responsible for the cleanliness and potability of the water supply, and for implementing and maintaining a cross-connection control program in order to prevent the contamination of the public water supply. The water purveyor is the public water department, up to and including the service connection from the public water main. From the outlet of the water meter or service connection including all piping downstream, to the furthest extent of the piping system inside the owners premises, the legal purveyor of the water supply is actually the property Owner.

4.     Do I currently have adequate backflow prevention for containment and isolation?

The adequacy of current backflow prevention methods installed at a site are typically determined by a field survey by qualified personnel. Many times, these surveys are performed by the local water purveyor. However, since the municipal water supplier’s liability stops at the meter, surveys for isolations within the building are the responsibilities of the building owner. Having multiple buildings or with multiple water service taps are frequently required to be performed by qualified, licensed independent cross connection control technicians. If the facility in question is relatively new, chances are that backflow preventers have been installed in accordance with the requirements of the applicable Plumbing Codes in the area. However, in older facilities, in industrial plants and other sites having multiple process water connections, or at facilities with multiple buildings on a single site, only a thorough field survey can determine the adequacy of existing backflow prevention measures.

5.   Who is legally qualified to perform maintenance and repair services for containment and isolation problems?

Backflow preventers fall under the definition of a “plumbing appurtenance”, as defined and addressed in the local applicable Plumbing Code. Depending on the jurisdiction, these devices can legally be disassembled, maintained and repaired only by a Certified Technician or a licensed Master Plumber. Additionally, the certified technician or plumber

must complete training and hold current certification by a recognized authority, such as the American Society of Sanitary Engineers (ASSE) or American Backflow Prevention Association (ABPA), specifically for the maintenance and repair of these devices. Please note that not all plumbers hold this certification, and not all certificate holders are Licensed Master Plumbers. National Water Specialties Company maintains the necessary certificates

and licenses for testing of containment and isolation and checks that those working on these systems in your jurisdiction are properly certificated.

6.   Who is legally qualified to perform testing and certification services?

In addition to maintaining a standard business license, persons performing testing and certification for backflow preventers are required to hold current certification for testing such devices by a recognized authority, such as the American Society of Sanitary Engineers (ASSE) or the American Backflow Prevention Association (ABPA). These testers are also required to maintain annually calibrated testing equipment. The local water authority typically maintains a list of currently qualified and approved testers. National Water Specialties Company maintains the necessary certificates and licenses for testing of containment and isolation and checks that those working on these systems in your jurisdiction are properly certificated.

7.   How often must certifications be performed?

Certification or testing intervals vary, depending upon the type of device, manufacturer, and local regulations. Typically, double check valves and pressure type vacuum breakers are required to be tested at the time of installation, repair, replacement and annually thereafter. Since reduced pressure zone backflow preventers protect more severe hazards (from contaminants), most local ordinances require that reduced pressure zone backflow preventers be tested at the time of installation, repair or replacement and every 6 – 12 months thereafter.

8.    Will my water service be interrupted for containment and isolation service?

The ASSE standard testing procedures require that the water service be interrupted during the course of the testing process. These service interruptions are scheduled at the Owner’s convenience, and normally do not unduly disrupt business operations or domestic water usage. Test periods for devices 2″ and smaller can usually be performed in less than 10 minutes. Test periods for larger devices usually take from 15 minutes to 30 minutes. Repair periods vary with the manufacturer of the device, but can usually be performed in a maximum of 20 minutes for small devices. Larger devices requiring repairs may take from one half hour to 1-1/2 hours.

9.   How much does a test and certification cost for containment and isolation?

Testing and certification costs vary with the type and manufacturer of device installed, the existing condition of the device and installation, bearing in mind adequate access and service clearances. Devices installed in underground vaults may require dewatering, the execution of a Confined Space Entry Permit, and additional personnel for safety.

1. Definitions and abbreviations

Cross connection

A “cross-connection” as defined by the environmental protection agency, is “any actual or potential connection between the public water supply and a source of contamination or pollution”.

Purveyor

Legally, the “purveyor” of the water supply is responsible for the cleanliness and potability of the water supply, and for implementing and maintaining a cross-connection control program in order to prevent the contamination of the public water supply. The water purveyor is the public water department, up to and including the service connection from the public water main. From the outlet of the water meter or service connection including all piping downstream, to the furthest extent of the piping system inside the owners premises, the purveyor of the water supply is actually the property owner.

Backflow prevention by containment

Typically a program which is designed to protect the public water system from contamination through the use of a “containment” device, or backflow preventer. This device is installed at the consumers service connection, usually immediately downstream of the water meter, but upstream of any branches of the owners piping system. This device separates all of the owners’ water supply piping from the public water main, thereby theoretically containing any contamination which may occur on site, and protecting the public water supply.

Backflow prevention by isolation

A program designed to isolate any cross-connections which exist within the owners’ premises, through the use of adequate backflow prevention devices, thereby isolating any hazard to that particular location, and protecting the remainder of the owner’s potable water system from contamination.

Backsiphonage

A backsiphonage condition can occur whenever there is a lowered pressure between the potable and non-potable supply piping. Such conditions typically occur during periods of high demand in the public water main, lowering the supply pressure. For instance during the demands imposed by fire fighting operations, or in the event of a water main break, which suddenly and significantly lowers the city water pressure below that of the non-potable system. This results in a partial vacuum being drawn on the non-potable system, and siphons the pollutants or contaminants into the potable water system through an unprotected cross connection, such as a hose bibb or hydronic system make-up connection. Backsiphonage may also occur when a high velocity stream of water passes by a small pipe outlet, such as a residential service tag due to the “venturi” effect.

Backpressure

A backpressure condition occurs whenever an elevated pressure exists between the potable and non-potable source. These pressures can be imposed by the installation of pumps which

increase pressures above the city water supply pressure, thereby forcing non-potable water in the opposite direction of normal flow into the potable water line. The installation of boilers or other equipment which heat water, causing thermal expansion and resulting inpressures in excess of the incoming water pressure, also can force non-potable water into the potable piping system.

Pollutants

A “pollutant” is any substance which may affect the color, taste or odor of the potable water, but which does not pose a direct threat to human health through exposure or consumption of the water. Pollutants may impose an objectionable odor or appearance to the water, but do not in themselves pose a health threat, and therefore, are considered to be a lesser hazard, when compared to contaminants.

Contaminant

A “contaminant” is any substance which, when introduced into the potable water system, constitutes a direct threat to life or health of a human, if the substance was ingested through consumption, or if the substance came in contact with the skin. A contaminant can therefore be a caustic chemical, a fluid containing bacteria or disease, or any other substance which could threaten human health. Therefore, contaminants compose the highest degree of hazard to the potable water system.