Mike Eisenhauer, Chair
· 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 a licensed CCCDI in the last twelve months?
In the spring issue we discussed the first of the three key elements that comprise all effective cross-connection control programs, "Do you know where all of the backflow assemblies are located in your water system”. This question is covered in IEPA title 35 Section 653.801 where cross-connection control surveys are detailed. We learned that what a survey really means is the accumulation of, or gathering of, specific data on backflow assemblies; i.e. make, model, size, serial number, location and test date of testable backflow assemblies that currently exist in your distribution system. We also learned that a survey "is not intended to include an actual or visual inspection of piping or plumbing systems”.
If a survey is not intended to be an inspection of piping or plumbing systems, then the question that must be asked is: how do we find all of the existing direct cross-connections that were installed prior to the plumbing code changes in the early 1980's? Since then the Illinois Plumbing Code has required the installation of backflow prevention assemblies. The answer can be found in IEPA Title 35 Section 653.802:
a) Complete removal of the cross-connection or installation of an approved cross-connection control device is required for control of backflow and back-siphonage.
b) Cross-connection control devices shall be installed in accordance with the manufacturer's instructions.
c) Cross-connection control devices shall be inspected at least annually by a person approved the Agency as a cross-connection control device inspector (CCCDI). The inspection of mechanical devices shall include physical testing in accordance with the manufacturer's instructions.
Because almost all cross-connections are found within the plumbing system of any building, the most effective way of identifying these cross-connections and causing them to be removed or backflow prevention installed is to perform a cross-connection inspection of the building's plumbing system. Illinois law requires that only Illinois licensed plumbers can inspect plumbing, so how does the water operator cause these inspections to take place? For most, the answer lies within the city's own plumbing inspector. Working together with your local plumbing inspector you should establish a program that allows for the cross-connection inspection to be performed under the authority of the water department and performed by the plumbing professional. Remember that, ultimately, the city itself is the responsible party, not just the water department or the plumbing department. In the case of a privately run water system you will, of course, need to elicit the services of the plumbing professional in the communities that you serve. Once these cross-connection control inspections are completed and the corrective actions required have been performed, you can be reasonably assured that your water distribution system is free from actual or potential cross-connections.
The only thing left to do now to ensure that you have a complete and effective cross-connection control program is the development and implementation of your tracking or record keeping requirements. In the next issue we will begin to dissect those requirements and offer some sure fired ways of accomplishing those tasks.