Massachusetts Department of Environmental ProtectionDrinking Water Program
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Guideline UpdatesAnita Wolovick
MassDEP, Environmental Analyst2011 Spring Training
Cross Connection Control Program
Why Are TheseUpdates Necessary?
Guidelines clarify interpretations of the Massachusetts Drinking Water Regulations (310 CMR 22.00)
Establish protocols for addressing site-specific problems encountered in the field
Set the regulatory framework necessary to maintain or improve public health and welfare
Massachusetts Department of Environmental ProtectionDrinking Water Program 2
9.10.2 Adoption of Local ControlsSuccessful promotion of a cross-connection
control and backflow prevention program will be dependent upon legal authority to conduct such a program
MassDEP recommends that a municipality adopt an ordinance, by-law, or have a policy statement on cross-connections that will establish a program for inspection and strategies for the elimination of cross connections within the community
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9.10.3 Chemical DispensersA PWS may allow the installation of chemical
dispensers provided:approved by the Board of State Examiners of
Plumbers and Gas Fittersinstallation of a backflow prevention device is
installed based on the degree of hazardTo view the entire Plumbing Board’s policy:http://www.mass.gov
Board of State Examiners of Plumbers and Gas Fitters
Board Policies (PL) Regarding Chemical Cleaning Dispensers4
Floor Drain Trap Primer Valve
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Floor Drain Trap Primer ValveApproved by Massachusetts Board of Examiners of Plumbers and Gas Fitters to be installed on domestic water lines
Must be installed with a minimum 12 inches elevation above the finished floor
MassDEP not requiring additional backflow protection at this point in time
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9.10.4 Containment PolicyLocally mandated & more stringent
than MassDEP regulationsDiffers from MassDEP high hazard
facilities containment requirement as stated in 310 CMR 22.22(8)(a)(3)
Must be included in PWS Program Plan
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9.10.5 Cross-Connection Control Program PlanCommunity PWS ≥ 3,300 must include: staff
profile, a strategy for testing, surveying, compliance and enforcement, fees structure, all forms required by the state, and a registration and tracking system
Community PWS <3,300 must complete Cross-connection Control Program Plan for Small Community Public Water Systems
Non-community PWS must complete the Cross-connection Program Plan Questionnaire for Non-community Public Water Systems
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9.10.5 Cross-Connection Control Program Plan
With 2012 ASR MassDEP will be requiring re-submission of updated program planssystems that can not produce current program plan
systems that have Plan older than 5 years
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9.10.6 Cross-Connection Tester and Surveyor Certification
Eligible to apply for a MassDEP certification if:Inspecting and testing backflow prevention
devices: pass a MassDEP approved written and practical examination
Surveying: pass a MassDEP approved written examination
Certification from a MassDEP approved teaching institution does not constitute a MassDEP Certification
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9.10.7 Emergency ReportingContamination of water in the distribution
system from a backflow or cross connection incident must be reported to MassDEP within 24 hours
After action report must be filed within 30 days of the incident as required
DEP 24-hour emergency number: 888-304-1133Drinking Water Program Emergency Contacts
http://www.mass.gov/dep/about/organization/contdwp.htm
Emergency Requirement regulations: http://www.mass.gov/dep/service/regulations/310cmr22.pdf
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9.10.8 Use of Fire Hydrants for Unauthorized Non-Firefighting Activities
Establish system for controlling hook-up to a fire hydrant by un-authorized persons
Locally mandated regulation, ordinance or bylaw
Permit with associated feeDamage deposit
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9.10.8 Use of Fire Hydrants for Unauthorized Non-Firefighting ActivitiesProvide:
hydrant meter and a wrench upon payment of deposit
backflow/meter assembly (BMA) unit or a meter assembly (MA) with an approved air gap
Establish fine for using a fire hydrant without the appropriate permit and deposit
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9.10.9 Fire Protection – Substantially Modified System
Any change or modification to an existing fire protection system installed prior March 21, 1997 for which the cost of the backflow prevention device including installation is equal to or more than five percent of the cost of the fire protection system modification; or
Total cost of the fire protection system modification excluding the cost associated with the installation of a backflow prevention device equals or exceeds $100,000.00
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New, existing or substantially modified fire protection system, including residential fire protection systems must be evaluated to determine if a cross connection exists.
If existing fire protection systems must be modified to meet new occupancies, storage changes, increase in building size, or differing building uses.
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9.10.9 Fire Protection – Substantially Modified System
Continued:
9.10.10 Testing of Inaccessible Non-Residential Backflow Preventers
Entry and testing not required if:hazard(s) has been removed device has been removed - physical separation between
the potable and non-potable piping
PWS must gain access if existing fire protection system continues to be operational and is equipped with a backflow prevention device
Even if building is not occupied owners must have suitable arrangements made so that inspections of backflow prevention devices and cross connection surveys can be made during regular business hours.
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9.10.11 Lawn IrrigationInstallation of a backflow prevention
device on lawn irrigation systems can prevent contamination from fertilizers, chemicals and pesticides.
MassDEP recommends PWS have a written residential lawn irrigation system cross connection control policy that:
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9.10.11 Lawn IrrigationIdentifies type of backflow prevention
device required on low hazard residential lawn irrigation systems
Establishes schedule for testing of testable backflow assemblies
Addresses high hazard residential lawn irrigation systemschemical additionsconnected to an unapproved water source
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9.10.12 Preparing for a Cross Connection Control Program Audit
Conducted to ensure PWS is adhering to their approved program plan and provide maximum public health protection.
Minimum reviewed:
MassDEP approved CCCP plan and letter of approvalList of staff and their cross-connection certifications
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9.10.12 Preparing for a Cross Connection Control Program Audit
Samples of all the official correspondenceBackflow prevention device test resultsCross-connection survey reports
Other documents, such as:Residential educational/informational
materialLocal ordinances/bylaws related to the
CCCP
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9.10.13 Record KeepingPWS must maintain a list of ALL cross
connections that are being protected by a reduced pressure backflow preventer or a double check valve assembly
PWS must be able to provide to MassDEP within two hours the list of cross connections as described above
List must be available in an electronic format.
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9.10.14 Residential Fire Sprinkler SystemsResidential Sprinkler Systems position statement jointly developed by MassDEP, Massachusetts Fire Chiefs Association, MWWA, and NEWWA
First Choice Option - Flow through Connections:
Sprinkler system supplies a household item, such as a toilet
Piping must be for potable waterNo backflow preventer will be necessary
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9.10.14 Residential Fire Sprinkler SystemsSecond Choice Option - Closed System:
Separate piping systemRequires a minimum of a residential
dual check backflow preventer, as long as NO chemicals or anti-freeze is used.
Reduced pressure backflow prevention device (RPBP) required if chemical or anti-freeze is added
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Cross Connection Control Program
Additional InformationMassDEP DWP website:
http://www.mass.gov/dep/water/index.htm
DWP Guidelineshttp://www.mass.gov/dep/water/laws/policies.htm#dwguid
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MassDEP CCCP ContactsWERO - James Gibbs 413.755.2299 [email protected]
CERO - Lynda Laine 508.849.4027 Lynda [email protected]
NERO - Nicholas Zessoules [email protected]
SERO - Giliane Tardieu 508.946.2789 [email protected]
BOSTON -
Anita Wolovick 617-292-5920 [email protected]
BOSTON -
Otavio Paula-Santos [email protected]
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