Cross-Connection Control: - PowerPoint Presentation

Cross-Connection Control: Lessons learned TCEQ Water Supply Division (WSD)Drinking Water Advisory Work Group (DWAWG)Austin, Texas | April 16, 2019 1

OutlineImportance of cross-connection controlHistory: 1854 to presentWhat is a Cross-Connection Control Program (CCCP)? RTCR assessment (etc.) lessons learnedAssistance available from TCEQ:SurveysDirected Assistance Module (DAM) 12 2

The importance of backflow protection is well understood Drinking water is at risk of contamination from non-potable liquid.Where a cross-connection exists:Back-siphonage: Low pressure in system ‘sucks in’ contaminants.Back-pressure: High pressure in connections ‘pushes in’ contaminants. 3

1854The ‘Broad Street Pump’ cholera outbreak occurredin 1854 in Londonas a result of cross-connection. 4

5 Well A: Well B: “Drain” C: Sewer Flooring Vault Vault Well Water Line Level of Broad St. Pump Vault 2 Front Kitchen Back Kitchen ‹#› Vault 1

Regulations: HistoricalPre-1986 regulations included general provisions that were strengthened over the years, starting ca. 1948. For example:Interconnections were only allowed with water of ‘safe sanitary quality.’Plumbing fixtures capable of backflow or siphonage were prohibited.Check valves were mentioned, internal programs were implied.6

1986: Texas adopted statutes to address risk of backflow/cross-connection Statute: Broad, general requirements adopted by the legislature directly.Regulations: TCEQ’s regulations adopted in Texas Administrative Code (TAC) describing detailed requirements to implement Texas statutes and Federal codes. 7

Statute: THSC 341.033 (f) Texas Health and Safety Code (THSC) Sec. 341.033. Protection of Public Water Supplies (b) An owner, agent, manager, operator, or other person in charge of a water supply system that furnishes water for public or private use may not knowingly furnish contaminated drinking water to a person or allow the appliances of the water supply system to become unsanitary… (e) The distribution system of a public drinking water supply and that of any other water supply may not be physically connected unless the other water is of a safe and sanitary quality and the commission approves the connection. (f) A public drinking water supply may not be connected to a sprinkling, condensing, cooling, plumbing, or other system unless the connection is designed to ensure against a backflow or siphonage of sewage or contaminated water into the drinking water supply. (g) On discovery of a connection in violation of Subsection (e) or (f), the local health authority shall give written notice to the owner or agent maintaining the condition. The owner or agent shall make the necessary corrections to eliminate the condition. 8 …ensure against a backflow or siphonage of sewage or contaminated water into the drinking water supply…

Regulations: 30 TAC Chapter 2901986:To implement the 1986 statutes, more detailed requirements were adopted in30 TAC §290.44 and §290.46.Taken together, implementation of these regulations constitutes a “Cross-Connection Control Program.” 9

2016: EPA adopts the RTCRDuring the early 2000s, EPA discussed adoption of broad rules for distribution systems.This discussion resulted in the Revised Total Coliform Rule (RTCR).Concerns regarding distribution management for avoidance of contaminant intrusion into potable water were included in Level 1 and Level 2 Assessments. 10

RTCR AssessmentsAssessments are performed when the presence of coliform is more abundant than triggers defined in the RTCR.More in the accompanying presentation.An assessment looks at all potential pathogen pathways, including cross connections. 11

2019: Lessons learnedRTCR assessments (etc.) show that not all PWSs have a robust, compliant Cross-Connection Control Programs.RTCR defines a ‘sanitary defect’ as a ‘potential pathway for pathogens’ to enter the drinking water. TCEQ may identify failure to implement a CCCP as a ‘sanitary defect’ in an assessment. 12

Elements of a successful CCCPAuthorityService agreement and/or ordinance Compliance programsInspections, testing, customer service inspections (CSIs), recordkeeping, etc.CommunicationInternal and externalBackflow-incident response plan. 13

Lessons learnedAuthority may be lacking.Response may be inadequate. Hazards may be un-identified.Communication may be a challenge. 14 !

Authority 15

Authority to implement the CCCP §290.46( i ) Plumbing Ordinance: Public water systems must adopt an adequate plumbing ordinance, regulations, or service agreement with provisions for proper enforcement to insure that neither cross-connections nor other unacceptable plumbing practices are permitted. 16

Code Vs. OrdinanceThe CCCP combines the responsibility of the PWS and the plumbing authoritiesIt is a mechanism which a PWS uses to ensure that these responsibilities are met. 17 PWS Plumbing Authorities Cross Connection Control Program Local ordinance, Service agreement National code UPC or IPC

Code Vs. Ordinance Plumbing Code (IPC, UPC) Plumbing Ordinance* Written by National or International organization Written by PWS, for example, City. Applies ONLY IF adopted by a local entity. Applies directly to the PWS. For example, City Limit, ETJ, CCN INCLUDES detailed requirements for premise plumbing. Refers to detailed premise plumbing requirements in Code. Does NOT provide authority to PWS to perform inspections. Adopts authority of PWS to enter premises to perform inspections. Does NOT provide authority to PWS to enforce requirements.Establishes authority of PWS to enforce requirements.18* Or Service Agreement.

Large Vs. SmallLarge and small systems comply differently:In Texas, a municipality over 5,000 people must adopt one of two plumbing CODEs into their local ordinance , usually by reference. (IPC or UPC)At a small system, the PWS can have a local ordinance—or it can use a Service Agreement. It does not need to include a CODE. 19

How can I figure out the right language?TCEQ provides example language for a Service Agreement or ordinance.Key elements of authority include:Requirements for backflow devices, installation, testing, and reporting Right of entry for hazard evaluationRight to discontinue water service for hazard OR noncomplianceLead ban 20

Authority: Reference materialTCEQ Web site: www.tceq.texas.gov/drinkingwater/cross-connectionTCEQ Regulatory Guidance (RG):RG 478: “Establishing and Managing an Effective Cross-Connection Control Program” Available at:www.tceq.texas.gov/assets/public/permitting/… watersupply/groups/ccc/rg-478.pdf 21

Response Plan 22 !

A backflow event is a kind of emergencyIt does not happen often, But when it happens, it can be devastating.23 !

A backflow response plan is like any ERPIncludes direction on:Roles and responsibilities Identifies communication pathwaysIdentifying contaminantsIsolating potential hazards (maps with valves)Flushing proceduresDon’t flush before identifying/isolating hazard 24 !

Lessons learned from backflow incident responseDon’t ‘flush first and ask questions later.’Flushing before identifying the risk may cause the contaminant to be spread further through the distribution system. An ounce of planning saves a pound of painMake sure that those required to implement the response have needed information before the event: Maps, labs, TCEQ #s, etc. 25 !

Lessons learned from backflow incident responseIdentify the range of potential hazards present and become familiar with labs who can analyze for themPotential contaminants include chemical or biological constituents that may not be routinely analyzed for PWSs can’t have labs to analyze every chemical and microbe, but can have relationships with existing labs. 26 !

Backflow response: Reference materialTCEQ Regulatory Guidance (RG): RG 477: “A PWS Guide to Preparing a Backflow-Incident Emergency-Response Plan” RG 476: “A PWS Guide to Responding to a Backflow Incident” TCEQ Web site:www.tceq.texas.gov/drinkingwater/cross-connection 27 !

Hazards 28

The more you know…Identifying hazards initially and periodically can eliminate surprises.Initial evaluation of potential hazards at newly constructed homes or businesses Review after the building is occupiedPeriodic evaluation of potential new hazardsChecking with call center for complaintsDouble checking previously identified hazard locations 29

Customer Service Inspections (CSIs)CSIs are designed to identify hazardsContaminants and pollutantsHazards can come and go. Hazard identification should be performed not just initially, but also periodically.New businesses may use a different set of chemicals, for example. 30

Potential hazards31 A strong CSI program will identify ranges of potential contaminants Refineries will have certain chemicals, plating operations a different set. Identifying a hazard from observing its effect in water is difficult. Eg : “Foamy” “Acidic taste” “Slippery” Knowing the potential scope will help make response to an event more efficient.

Hazards: Reference materialTCEQ Regulatory Guidance (RG): RG 206: “Customer Service Inspections—A Guide for PWSs” Under review, currently in draft formRG 476: “A PWS Guide to Responding to a Backflow Incident”Information about types of identification of hazardsTCEQ Web site: www.tceq.texas.gov/drinkingwater/cross-connection 32

Communication 33

The 3 CsImplementing the 3 Cs leads to success:Communication,C oordination,Cooperation. 34

The 3 CsAlthough no explicit regulations states that PWSs ‘must do the 3Cs,’ inadequate communication has been observed to cause issues. 35

CCCP Communication, Coordination, and Cooperation 36 Code Enforcement Fire Marshall Irrigators CSI BPATs Plumbing Inspector PWS CCCP Administrator PWS Staff

37 Code Enforcement Fire Marshall Irrigators CSI BPATs Plumbing Inspector PWS CCCP Administrator PWS Staff We found a possible problem! I wonder what’s on TV? Poor communication causes risks

How to improve communication…Identify stakeholdersOrganizational units with some responsibility or authority over a piece of the CCCPIdentify highest level of authority exposed to risk A backflow event can make a entity ‘look bad’ which can lead to job changesHave an initial informational meeting to share—for example, training event. 38

How to improve communication…Maintain communicationKeep stakeholders informed routinelyDon’t wait till an event occurs Implement positive activitiesPublic educationParticipation in ‘Water Week’ 39

Assistance 40 Take-home message

TCEQ provides targeted compliance assistance“We’re from the government, and we’re here to help!” The shared mission of TCEQ drinking water programs and public water systemsis to help ensure that Texans have safeand adequate drinking water. 41

CCCP Survey2 to 4 hour meeting with:TCEQ Cross-Connection Control expert, andSystem representatives.Specific focus on PWS program Strengths, weaknesses, opportunities, etc.Go thru T&M forms, CSI forms, list of BPATs, local hazards, etc.Develop action items for improving program. 42

Directed Assistance Module (DAM)Free, one-day, on-site general trainingCovers all aspects of cross-connection and backflow prevention. Includes brief presentation and in-depth Student Manual for future referenceGiven by FMT Assistance providersTargeted to students’ and system’s needsCovers all aspects of the CCCP in general 43

Call or email to get assistanceCall the TCEQ Water Supply Division at 512-239-4691 and ask to talk to the FMT assistance program or a cross-connection control expert, orEmail FMT@tceq.texas.govOperators are standing by! 44

Thanks!45