Mike Eisenhauer, Chair
Another great Watercon has ended and, on behalf of the ISAWWA Backflow Committee, I would like to thank everyone who participated in this year's event. A very special thank you goes out to Laurie, Lisa and Sandi as well as all the volunteers; they all comprise the most amazing, hardest working group in all of AWWA.
In the last issue of Splash I asked each water purveyor to seriously take a look at your current cross-connection control program and answer honestly to yourself the following three questions.
· Do you know where all of the backflow assemblies are located in your water system?
· Have all cross-connections in your water system been removed or protected by an approved backflow assembly?
· Have all testable backflow prevention assemblies in your water system been tested by licensed CCCDI in the last twelve months?
These questions represent the three key elements to all effective cross-connection control programs. In this issue let's explore in more detail the first of these questions. For some water systems the answer to the question, "do you know where all of the backflow assemblies are located in your water system” is, unfortunately, no. The reason that this question is one of the big three is that, in order to effectively track (record keeping) backflow preventers, one must first know where they are located.
The Illinois Environmental Protection Agency, through its rules and regulations, requires each water system in Illinois to create and maintain records and keep track of the cross-connection program. The first requirement is to perform what is referred to as a bi-annual survey. So there is no misunderstanding as to the language in Title 35 here is the actual verbiage from section 653.801(a)
"An active cross-connection control program shall be adopted and shall include the following:
a) A cross-connection control survey of the distribution system shall be conducted at least every two years by the official custodian or an authorized delegate.
1) The purpose of this survey is to compile and update an inventory of devices; the survey must consist of pencil and paper collection of information conducted by telephone, mail or personal visit to the manager or owner of a specific property.
So, that is what Title 35 says, but the true question, on a practical level, is what does it mean and how do I comply with it?
First let's all understand that Title 35 makes absolutely no distinction between types of water service connections in your distribution system, meaning that ALL water connections, commercial, industrial and, YES, residential are all treated equally and all are subject to the applicable EPA rules and regulations.
Simply put, Section 653.801 is asking the water purveyor to find the location of the backflow prevention assemblies and record their information at least every two years. The data collected from this survey should be used with data from Section 653.802(c), which requires specific information to be kept for backflow assembly records and that reads:
C) Cross-Connection control programs shall include a record system which will maintain data on inspection, reinspections, repairs, alterations and tests.
There is a whole host of other information that must be managed by the water purveyor to maintain an effective cross-connection control program but that is for a future article.
One of the more effective ways to comply with the survey requirements is to send a returnable postcard to each water connection on your distribution system asking the utility customer for the specific information required. With the information received from the postcards you will then be able to incorporate the findings of the survey into the backflow assembly record keeping system and, thereby, use the data from the survey as a baseline and a means of updating the backflow assembly inventory.
Of course there is always a but, and here it is. The water department actually has to work together with the plumbing department!!! For some this will be quite simple and for others, well, not so much. Investor-owned utilities and rural water districts or water co-ops, for example, do not have an in-house plumbing department, but must coordinate with local plumbing authorities in the counties and municipalities they serve.
After you have initially, successfully determined where all of the existing backflow prevention assemblies are located, gathered all of the pertinent information and incorporate all of this information into your record keeping system, you should then receive backflow test reports for each of these backflow prevention assemblies on an annual basis. Now for the tricky part. This only works if your plumbing department requires that all newly installed backflow prevention assemblies require a permit for installation and that final plumbing inspection of these installations is not completed until the newly installed backflow prevention assemblies are tested, and those results incorporated into the water purveyor's survey and record keeping system. At this point you have completed the survey cycle. If there is no plumbing permit program, you will have to wait until the next survey is completed and the new backflow assembly reported to require submission of the initial test results.
I hope that this article will shed some light on some perceived difficulties in moving forward with your cross-connection control program as well as, maybe, debunking some old myths.
Please visit the ISAWWA Backflow Committee website blog for any questions about backflow prevention and cross-connection control at: http://www.backflowblog.blogspot.com/