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Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring Training Cross Connection Control Program

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Page 1: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

Massachusetts Department of Environmental ProtectionDrinking Water Program

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Guideline UpdatesAnita Wolovick

MassDEP, Environmental Analyst2011 Spring Training

Cross Connection Control Program

Page 2: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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

Page 3: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 4: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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

Page 5: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

Floor Drain Trap Primer Valve

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Page 6: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 7: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 8: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 9: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 10: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 11: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 12: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 13: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 14: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 15: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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:

Page 16: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 17: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 18: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 19: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 20: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 21: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 22: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 23: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 24: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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Page 25: Massachusetts Department of Environmental Protection Drinking Water Program 1 Guideline Updates Anita Wolovick MassDEP, Environmental Analyst 2011 Spring

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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