The southern United States is unique: culturally, geographically, environmentally, and, of course, in their cross-connection control requirements. The EPA delegates “primacy” to states regarding cross-connection control for public water sytems. That means each state has the right to implement codes, requirements, and regulations as they see fit. While every state prohibits unprotected cross-connections, each state has its own quirks within their requirements based on the unique risks facing their public water systems.
Watch the on-demand webinar, “Cross-Connection Control & Compliance: Securing the South’s Water,” to learn more about how to develop, implement, and maintain an effective program in Alabama, Georgia, North Carolina, South Carolina, and Tennessee.
The Regulatory Landscape of the South
Backflow from backpressure and backsiphonage are inherent in every piping system, and the south is no different. How do Alabama, Georgia, North Carolina, South Carolina, and Tennessee address these risks? Some regulatory highlights from the southern states in question include:
Alabama Administrative Code, Chapter 335-7-9 requires:
- A written cross-connection control policy that includes provisions for regular inspections
- Maintenance of inspection records for a minimum of five years
- Discontinuation of service to non-compliant service connections
Georgia Administrative Code, R. 391-3-5-.13 requires:
- Development of a cross-connection control program upon request by the Environmental Protection Division
- Annual testing of backflow prevention assemblies
- Maintenance of hazard assessment and backflow preventer test records for a minimum of three years
North Carolina Administrative Code, Chapter 15A, Section 18C .0406(b) requires:
- Annual testing of backflow prevention assemblies (low-hazard categorized irrigation systems may be tested on three-year frequency)
- Description of specific ongoing plans, actions, or schedules to inventory existing backflow prevention devices and to identify and address all uncontrolled cross-connection hazards
- Maintenance of records including:
- Location, type, installation date, size, and associated degree of hazard of backflow preventers
- Backflow preventer assembly test results (for a minimum of four years)
South Carolina Administrative Code, R.61-58.7(F) requires:
- A viable cross-connection control program
- Annual testing of backflow prevention assemblies
- Maintenance of records including the locations of existing backflow prevention assemblies, type and size of each assembly, and test results
Tennessee Administrative Code, R. 0400-45-01-.17 & 68-221-711 requires:
- A written and approved cross-connection control plan
- Annual testing and documentation of backflow prevention assemblies
- Compliance with the TDEC Cross-Connection Control Manual, including cross-connection control surveys
The Common Denominator
Across states, commonalities do exist—most notably, in the form of sanitary surveys. Increasingly, across southern states, sanitary surveys include questions regarding cross-connection control efforts. Many utilities “kick the can down the road” and simply wait for enforcement to occur. But in the meantime, your community and its drinking water are at risk. Plus, the consequences of enforcement, which can include fines or exclusion from grant opportunities, often result in significant challenges for a public water system.
When sanitary surveys roll around, be prepared to go beyond backflow preventer test records to explain how your utility manages the risk of cross-connections, including surveys, public awareness, and any other related activities.
Building a Compliant Cross-Connection Control Program
Many of these states require a cross-connection control program, but they don’t necessarily prescribe the elements of an effective program. The key areas of a successful (and compliant) program are:
- A method of detecting and correcting unprotected cross-connections
- A schedule for testing backflow prevention assemblies
- A process for notification of water customers
- Public education and awareness efforts
Your utility is made up of two types of connections: residential and non-residential. An effective cross-connection control program addresses each of these in turn. Non-residential connections often pose a higher risk to the distribution system, but your utility likely has a higher volume of residential connections. Balancing these competing priorities is a critical part of program design. For each service connection, you must:
- Conduct and/or document a survey, including the service connection’s containment status
- Document any unprotected cross-connections and all forms of backflow prevention
- Establish the compliance or non-compliance status of the site and notify the building owner
- Verify backflow preventer test records and completion of any corrective actions
Ultimately, your program should be engaged in finding and correcting cross-connections. If your program doesn’t find violations, you may not be looking as thoroughly as you need to be.
Ready to learn more about how HydroCorp can support your water utility’s cross-connection control efforts?
