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

2. Why Are These Updates 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 Protection
Drinking Water Program

3. 9.10.2 Adoption of Local Controls
Successful 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

4. Chemical Dispensers
A PWS may allow the installation of chemical dispensers provided:
approved by the Board of State Examiners of Plumbers and Gas Fitters
installation of a backflow prevention device is installed based on the degree of hazard
To view the entire Plumbing Board’s policy:
Board of State Examiners of Plumbers and Gas Fitters
Board Policies (PL)
Regarding Chemical Cleaning Dispensers

5. Floor Drain Trap Primer Valve

6. Floor Drain Trap Primer Valve
Approved 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

7. Containment Policy
Locally mandated & more stringent than MassDEP regulations
Differs from MassDEP high hazard facilities containment requirement as stated in 310 CMR 22.22(8)(a)(3)
Must be included in PWS Program Plan

8. 9.10.5 Cross-Connection Control Program Plan
Community 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

9. 9.10.5 Cross-Connection Control Program Plan
With 2012 ASR MassDEP will be requiring re-submission of updated program plans
systems that can not produce current program plan
systems that have Plan older than 5 years

10. 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

11. Emergency Reporting
Contamination 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:
Drinking Water Program Emergency Contacts
Emergency Requirement regulations:

12. 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 fee
Damage deposit

13. 9.10.8 Use of Fire Hydrants for Unauthorized Non-Firefighting Activities
Provide:
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

14. 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

15. 9.10.9 Fire Protection – Substantially Modified System
Continued:
Fire Protection – Substantially Modified System
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.

16. 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.

17. Lawn Irrigation
Installation 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:

18. Lawn Irrigation
Identifies 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 systems
chemical additions
connected to an unapproved water source

19. 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 approval
List of staff and their cross-connection certifications

20. 9.10.12 Preparing for a Cross Connection Control Program Audit
Samples of all the official correspondence
Backflow prevention device test results
Cross-connection survey reports
Other documents, such as:
Residential educational/informational material
Local ordinances/bylaws related to the CCCP

21. Record Keeping
PWS 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.

22. 9.10.14 Residential Fire Sprinkler Systems
Residential 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 water
No backflow preventer will be necessary

23. 9.10.14 Residential Fire Sprinkler Systems
Second Choice Option - Closed System:
Separate piping system
Requires 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

24. Cross Connection Control Program
Additional Information
MassDEP DWP website:
DWP Guidelines

25. MassDEP CCCP Contacts WERO - James Gibbs 413.755.2299
CERO -
Lynda Laine
Lynda
NERO -
Nicholas Zessoules
SERO -
Giliane Tardieu
BOSTON -
Anita Wolovick
Otavio Paula-Santos