“Enforcement of Cross Connection Control Measures and Not Speaking Backflow”
Ignorance by City Management on viable Cross Connection Control measures, along with the Arrogance of eliminating and/or basically Ignoring the detailed procedures established in all standards, codes and guidelines for viable backflow prevention programs, in my opinion, is negligent and fundamentally wrong. Where is common sense and moral responsibility in protecting the public water supply? Management (Cities) should be providing support for the Cross Connection Control Program instead of looking for reasons not to enforce it, in some instances.
Think the public would be demanding all backflow prevention assemblies be tested and maintained if they were made aware of the documented incidents that have occurred due to the lack of Plumbing Code Enforcement?
With reference to the aforementioned, the following letter was sent to a large metropolitan city’s governing body, concerning the plumbing inspection department’s decision to stop monitoring the testing and maintenance of internal backflow prevention assemblies. The names of the city and assistant director involved have been intentionally removed from this article. The letter did get a positive response from the city and might be considered in similar situations.
To: Mayor -- City Council Members -- City Manager
Date: October 7, 2010
Re: SECOND NOTICE – Backflow Prevention Re-Instatement
This is the second urgent request for a provision to be adopted by City Council that directs the City’s Development Services Department to re-instate the internal backflow prevention assembly testing and monitoring of high hazard backflow prevention assemblies. As of Oct. 1, 2010, the City’s Plumbing Inspection Department stopped sending out Test Due Notices on High Hazard Backflow Prevention Assemblies. Please refer to City Ordinance XXXXX Code Amendments – which indicates record keeping and processing. Additionally, no records will be maintained on the backflow prevention assemblies as established in the following national guidelines: American Society of Sanitary Engineering, American Water Works Association, Foundation of Cross Connection Control and Hydraulic Research and the Environmental Protection Agency.
This is a very IMPORTANT Health and Safety issue – To emphasize this, review State rules for water purveyors. The “Texas Commission on Environmental Quality (TCEQ)” requires water departments to establish a viable cross connection control program that includes monitoring high hazard, containment backflow prevention assemblies, i.e., backflow preventers installed at water meter to protect city’s potable water main. The Plumbing Codes apply to all internal assemblies.
Without annual test due notices being sent to facilities having high hazard cross connections – the backflow preventers “will not be tested”! As an example, in addition to those events listed below, we have had facilities falsify test and maintenance report forms, i.e., the backflow prevention assembly was never tested. Facility managers and owners do not speak backflow and recognize the importance!
There are some in management comparing the testing and maintenance of backflow preventers to a facility’s responsibility to test and maintain emergency generators. We do not view this as comparable. If a backflow prevention assembly fails, has been removed or by-passed, your potable water will be contaminated. Many of these Backflow Preventers are located on cross connections having very toxic substances. Apples and Oranges!
Not to gross out Council – However, just a few of the many other events than those previously supplied in first letter to Council, involving unprotected cross connections and the lack of sending out annual test due notices and maintaining records:
Mortuary East Side: Water Purveyor loses water pressure – body being embalmed which involves water pressure- backflow preventer not working – water turned back on – Blood reported from Drinking Fountain
Asphalt Manufacturing Plant –1604 & IH 10 – Diesel Fuel Pumped through out 150-acre site – 4” piping – Water Purveyor’s containment backflow preventer prevented the diesel fuel from getting into water main – Three (3) water wells on site – no backflow protection.
Hide rendering plant on W. Malone – Large vats used to remove hair from hides – not a backflow preventer installed any where in plant – all BFPA’s been removed – all vats cross connected – been in business 20 years (24 –7). How many times was pressure lost?? Wonder what the water tasted like in area?
In Paul Anderson Building – Downtown – 50 gal barrel of algaecide and slimicide pumped back into the building’s internal water system – cooling tower make-up water - dark green chemical – Backflow preventer had been removed.
Soda Dispensing Machines – Have a water connection that if backflow protection is not installed or working as designed, allows CO2 (~200 psi) to be back-pressured into the restaurants/facilities potable water system –PH is such that when it comes in contact with copper – dissolves copper resulting what the Local Health Dept. has labeled “Copper Poisoning - Toxic” when consumed through sodas or water.
Is this what the city wants to go back to??? The Internal Backflow Prevention Program is very important and it has worked great, as established through national/state guidelines and regulations. As stated in previous correspondence, the documented cross connection events have steadily decreased due to an excellent internal cross connection control program enforced by the local Plumbing Inspection Department.
PLEASE – Do not allow the Development Services Department to stop sending out annual test due notices and monitoring these high hazard backflow prevention assemblies. With what appears to be ignorance of viable cross connection control measures, along with the arrogance of eliminating the detailed procedures that are recognized in all standards, codes and guidelines for viable backflow prevention programs, in my opinion, would be negligent and fundamentally wrong. Where is common sense and moral responsibility here??? The city should be providing support for the program instead of looking for reasons to abandon the program. Think the public would be demanding these high hazard backflow prevention assemblies be tested?
FUNDING: The city “was collecting” a filing fee on the test and maintenance report forms and like other cities, this could be increased to assist in funding the program. The City is charging a $5.00 fee, whereas many other cities are charging $15.00. Additionally, many cities charge an annual backflow tester registration fee of $100.00 and in some cases a tester gauge registration fee. This is more than enough to fund a program that is established for the “health and safety” of the public. There even are companies that will handle all notifications and tracking for approx. $7.00 per assembly.
We have seen cities charge $10.00 per assembly, utilizing the additional $3.00 to assist in funding the Plumbing Inspection Department.
It is respectfully requested the testing notification and monitoring process be re-established by the City as adopted by the Council.
This will not go away and if necessary will be taken to a national level.
Blind Notes:
As of Jan. 2009 – The State will now allow an inter-connection with another water source, e.g., well, pond, river, etc., through a backflow prevention assembly.
Backflow Protection is not required on water wells located within High Hazard Type Facilities.
The Texas State Regulations require water purveyors to install containment backflow protection, i.e., BFPA at the water meter, to any facility having actual or potential high hazard internal cross connections that are not being tested and maintained in accordance with State Regulations. The State requires testing on high hazard backflow prevention assemblies only upon installation and annually thereafter. Records must be retained on all aspects of program. The test and maintenance report forms must be on file for 3 years. This involves annual facility notification, approved forms, gauge accuracy checks, etc., etc.
Attachments: IPC 2209 CODE AMENDMENTS
State Regulations
-----------------------------------------------------------------
Note: A meeting between the City’s Development Services Department and the local water purveyor was called for on Oct. 20, 2010. The internal testing program was re-instated by the City’s Plumbing Inspection Department until June 2011, at which time, the local Water Purveyor agreed to include the annual monitoring of the internal backflow prevention assembly testing program with the containment program. The Real Positive Here: We believe, as a result of this situation, City Officials and Management now “speak a little more backflow” and understand the necessity to monitor backflow prevention assemblies.
Bottom Line: We have documented results of not enforcing an internal CCC Program vs. enforcing a viable program over the last 40 years. The majority of the cross connection related contamination events documented have been the result of non-enforcement of an internal backflow prevention program.
Health and Safety decisions made by managers that may not be knowledgeable on the subject matter can place the public at risk. This can be career ending for those making these decisions, as we have personally witnessed and can go to the Director and V.P level.
EDUCATION! EDUCATION! EDUCATION!