Cross Connection 

Industry/Water Operator Overview fo Cross Connection Control

Cross-Connection Control Coordinator

This document gives the reader an overview of the basic Arkansas Department of Health (ADH) requirements for beginning and maintaining a cross-connection control (CCC) and backflow prevention program. It is written primarily for public water system managers and their staff; e.g., water operators, CCC coordinators, plumbing inspectors, and, of course, any other interested parties.

Q: Why is a Cross-Connection Control Program (CCCP) Required?   

Answer: The implementation of a CCCP is primarily required in order to protect the water distribution pipelines of the state's public water systems from contamination or pollution by virtue of the presence of cross-connections, within the plumbing systems, combined with the action of backflow occurrences Ultimately, the implementation of a CCCP is to protect the public health.

Q: What is the Regulatory Basis for a CCCP?    

Answer: The regulatory basis for the implementation of a CCCP by a public water system is the Rules and Regulations Pertaining to Public Water Systems (RRPPWS). This document is signed by the Governor of the State of Arkansas and the Secretary of the Arkansas State Board of Health.

Q: When was this Requirement for Backflow Prevention Established?   

Answer: Act 96 of the Acts of the General Assembly of the State of Arkansas enacted in 1913 empowered the Governor to appoint a State Board of Health. The Board was authorized to adopt laws regulating transaction of its business and power was conferred (on the Board) to make all reasonable rules, etc. Subsequent to the creation of the State Board of Health the RRPPWS soon were adopted. They have been amended at various times over the years.    

There has always been a general requirement for backflow prevention in the RRPPWS. However, in 1991, they were amended to include some specific requirements. Specific requirements included are:        

  • all public water systems shall institute a routine cross-connection control program to locate and eliminate cross-connections.
  • the program shall include routine inspections of commercial and industrial establishments and routine maintenance of a listing of the location of cross-connection control devices.
  • by January 1, 1996, each program shall include the mandatory testing of backflow prevention devices by certified testers, on a frequency approved by the Arkansas Department of Health (note: this frequency has been established to be within ten days of installation and annually thereafter.)

Q: Who is Affected by the Cross-Connection Control Program?    

Answer: Arkansas' CCCP is two-fold, internal isolation of the plumbing systems by virtue of the Arkansas State Plumbing Code (ASPC) and meter containment at certain commercial and industrial establishments per the ADH's Division of Engineering's    

CCCP. The ASPC addresses all plumbing systems whether they be residential, commercial or industrial. The CCCP addresses only commercial and industrial establishments.    

All public water systems must implement the CCCP. This includes both community water systems and non-community water systems (transient and non-transient.)     

Q: What is Meant by "Containment" and "Isolation" Within the Context of CCC?

Answer: A "containment configuration" refers to the placing of a backflow preventer just downstream of the water meter thereby containing any contamination that may occur within a plumbing system to that system and preventing the contamination from spreading to the water distribution piping. The containment configuration protects only the water distribution system, not the users within the plumbing system. The ADH requires a minimum of a containment type program.     An "isolation configuration" refers to placing a backflow preventer, where required, at the use points within a plumbing system. A water utility may go the extra step and permit an isolation configuration where they feel it is necessary. Sometimes, an isolation configuration is preferable to the containment type. Isolation protects the users within a plumbing system as well as the water distribution lines.

Q: What are the Advantages and Disadvantages of a Containment Type Configuration?

Answer: Advantages:

  • the water utility only has to keep records and track the testing of the one backflow preventer.
  • no further inspections of the facility are required.

Disadvantages:

  • the users within the plumbing system are not protected by the backflow preventer.
  • creates a water pressure drop over the entire plumbing system.

may create a situation where two backflow preventers are in series with a devastating drop in water pressure across the two units.

Q: What are the Advantages and Disadvantages of an Isolation Type Configuration?

Answer: Advantages:

  • the backflow preventer probably will be smaller in size and therefore less costly        
  • eliminates the possibility of having two backflow preventers in series possibly creating an extreme pressure drop.
  • protects the water users within the plumbing system as well as the distribution system.     -

Disadvantages:

  • the water utility staff must keep up with and track the testing of all of the RPs and DCs within the plumbing system.
    • an annual inspection by the water utility is required to assure that additional cross-connections have not been created.
    • atmospheric vacuum breakers are not acceptable to the ADH for meter protection, therefore where atmospheric vacuum breakers are used in the plumbing system they will have to be replaced with RPs or DCs.                 

Q: Is an Air Gap Separation Acceptable in Lieu of a Backflow Preventer?        

Answer: Yes.

Q: What are the Hazard Levels and What Type Backflow Preventer is Required for Each Level?

Answer:

  • High hazard

    (the substance which could backflow is a hazard to health): a reduced pressure principle backflow prevention assembly (RP) is required for this hazard level.
  • Medium hazard

    (the substance which could backflow is not a hazard to health but would be objectionable): a double check valve assembly (DC) is required (at a minimum) for this hazard level.
  • Low hazard

    (no high or medium hazards present and there is no possibility of backpressure): no backflow prevention assemblies required. Backflow devices such as hose bib vacuum breakers, dual checks, etc. may be required by the ASPC.

NOTE: an air gap separation is always acceptable in lieu of a Backflow Preventer. Will the ADH be checking on a Water Utility's Progress for Implementation of the CCCP?    

Yes. During the sanitary surveys of water treatment facilities the ADH analyst will inquire about CCCP progress and will want to inspect the CCCP records.

Q: Is a City Ordinance Required in Order to Implement a CCCP?   

Answer: Yes. The first step for implementing a CCCP is for the city council to pass a city ordinance. As an option a city water commission may adopt a written policy. For a water association, instead of a city ordinance, a resolution or other legal instrument will suffice. The water utility staff needs this legal backing in implementing their program.

Q: What Options Does a Water Utility have Where a Customer Will not Comply with the Requirement to Install a Backflow Preventer or have a Unit Tested?   

Answer: This largely depends upon how the city ordinance is written but termination of water service, after repeated warnings, may be required. Of course, any time water service to an establishment is discontinued common sense must be utilized. Water service to a dental clinic should not be shut-off while a dentist is working on a patient! Be advised that equipment could be damaged if water service is terminated. Discontinuing water service to a hospital or nursing home is not recommended. Cutting off the water to a poultry farm in hot weather could have disastrous results. In such cases legal action may be required.

In all cases of non-compliance, such as refusal to install a backflow preventer or failure to have the assembly tested, every effort should be made to get the customer to comply before terminating water service. The owner should be given ample time for installation of the unit. Repeated warnings and a final notice, with date and time of water shut-off noted, should be issued before pulling the meter. The State Plumbing Inspector or the ADH Cross-Connection Control Coordinator in the Division of Engineering may be able to assist in non-compliance situations.         

Be advised that even without a city ordinance or other legal document the Rules and Regulations Pertaining to Public Water Systems allows for discontinuing water service where a direct cross-connection is found.     

Q: Have Standards been Developed for Implementing  a CCCP?   

Answer: Yes. The ADH's Minimum Standards for a Cross-Connection Control Program and Policy for Cross-Connection Control on Fire Protection Systems. Both standards are available free-of-charge from the ADH. They may also be downloaded.