Illinois' Community Water Supply Cross Connection Control Program

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Section 607.104 Cross Connections 
a) No physical connection shall be permitted between the potable portion of a supply and any other water supply not of equal or better bacteriological and chemical quality as determined by inspection and analysis by the Agency, except as provided for in subsection (d) of this Section. 
b) There shall be no arrangement or connection by which an unsafe substance may enter a supply. 
c) Control of all cross-connections to a supply is the responsibility of the owner or official custodian of the supply. If a privately owned water supply source meets the applicable criteria, it may be connected to a water supply upon approval by the owner or official custodian and by the Agency. Where such connections are permitted, it is the responsibility of the public water supply officials to assure submission from such privately owned water supply source or sources samples and operating reports as required by 35 Ill. Adm. Code 611 as applicable to the cross-connected source. 
d) The Agency may adopt specific conditions for control of unsafe cross-connections, which shall be complied with by the supplies of this State, as applicable. These conditions shall be adopted and/or changed by the Agency as prescribed in 35 Ill. Adm. Code 602.115. 
e) Each community water supply exempted pursuant to 35 Ill. Adm. Code 603.104 or Section 17(b) of the Act shall provide an active program approved by the Agency to continually educate and inform water supply consumers regarding prevention of the entry of contaminants into the distribution system.

This has been found to the one of the many breakdowns of the municipality's program, - educating the public is the first requirement to effectively administrate a safe effective program. 
So how does a water purveyor do this? 
The explanation of continually requires more than a brochure to be available to the public. 
It requires the use of media, new letters, a website, and annual report. 
CCRA believes that this is an integral part of responsible CCC protection, helping in the compliance and involvement of the community to participate in a safe and effective program. 
By educating the public on how to keep their costs down and effectively remove any over charge that has so often been associated with these programs, the public will have a better understanding on how CCC program works and this will eliminate many of the misconceptions and increase compliancy. 
Higher compliancy rate decreases accidental contamination to the water distribution system. 
The CCRA user friendly website is geared to help the consumer to have a better understanding and offers the opportunity of continual education program for CCRA costumers with the many links that are posted.

SUBPART H: CROSSCONNECTIONS 
This was established from research throughout the seventies and eighty and was acted into the federal law in nineteen ninety five in the safe water act of 1995. Every state EPA participates in this type of program and has established these requirements in the state codes and bylaws. The requirements are not flexible and all of them need to be part of a water purveyor CCC program, half measures will avail an incomplete program. This will render the water purveyor and municipality to exposure of possible expensive repairs and personal injury to the community it has been entrusted to serve. CCRA programs do not deviate from this agenda. To participate as a program provider in a water purveyor CCC program without these requirements is selling the water purveyor short, rendering them to all kinds of exposure and is irresponsible. 

Section 653.801 Cross Connection Control Program
An active cross connection control program shall be adopted and shall include the following: 
a) A cross connection control survey of the distribution system shall be conducted at least every two years by the official custodian or an authorized delegate.

• The purpose of this survey is to compile and update an inventory of devices; the survey must consist of a pencil and paper collection of information, conducted by telephone, mail or personal visit to the manager or owner of a specific property.

• This survey is not intended to include an actual visual inspection of piping or plumbing systems.

This is another breakdown for most CCC programs. When first these law in acted in the eighties some municipalities performed these surveys and many did not. Only a handful have been regularly survey their water users, many have been content with just gather test results. CCRA has available to water purveyor an effective and affordable way to survey water costumers. Our CCRA staff of Inspectors feels that this is necessary to provide the water the best custom plan that will reduce costs to the water purveyor and its community. This is a step forward towards conducting a safe effective CCC program and is the very important requirement need to have a complete program in place. 

b) An ordinance, tariff, or required condition for service whichever is applicable, which includes a plumbing code at least as stringent as the Illinois Plumbing Code, 77 Ill. Adm. Code 890, shall be adopted and enforced. 

Many ordinances in place today do not take advantage of the tariff available to them and can fall short meeting the requirements of the states plumbing codes. They need to be review and possibility be updated these ordinances that enforce a sound CCC program. CCRA will help to review these ordinances and make sure that these municipalities' codes are helping the water purveyors to regulate their programs. Additionally CCRA has on staff accountants that can help the water purveyor with making sound fiscal decisions that is why it is cost effective to use a CCRA program and save the tax payers money. With the help of CCRA, a water purveyor can increase departmental revenue through CCRA program. This is few of the many responsible ways that CCRA can help a water department improve their CCC program and elevate infrastructure issues that have and will continue to surface. 

c) Cross connection control programs shall include a record system which will maintain data on inspections, re-inspections, repairs, alterations and tests. 

An effective CCC program has a complete record of inspections, repairs and tests of any backflow device in service today. These records should be on file and maintained for accessibility. Every device should have a record of its maintenance, certification, repairs, and who has work on it. When a valve start malfunction it will fail the differential test it is important have accurate record on its repairs, "what was done", re-inspection "if is functional after the repair and who was the qualified individual that work on the device". An effective CCC program should have the ability to track the valve to insure that they do not continual to have operational issues. It is important for the water purveyor to have these frailer and repair document review and recorded. Many times the inspector will repair on the spot and sent results as if the valve has never had a problem and leaving the water purveyor with a possible device that could fail at any time during the year before the next annual inspections. With the consumer having to pay for these repairs it is financially prudent to have all the repairs recorded to help possible over charging and unnecessary repairs. Remember that the water distribution system and their customers both are the reason these laws were written and are enforced. CCRA programs isolate these devices to make sure that their mechanically sound and will review the repairs to make sure there are needed. 

d) Only cross connection control devices which are approved by the Research Foundation for Cross Connection Control of the University of Southern California, American Water Works Association, American Society of Sanitary Engineering, or American National Standards Institute of certified by the National Sanitation Foundation to be in compliance with applicable industry specifications shall be used. 

e) Installation of approved devices shall be made only as specified by the Research Foundation for Cross Connection Control of the University of Southern California, American Water Works Association, American Society of Sanitary Engineering, or American National Standards Institute. Maintenance as recommended by the manufacturer of the device shall be performed. 
Manufacturer's maintenance manual shall be available onsite. 

It is the responsibility of the owner of the device to have these maintenance manuals availabe at all times but in nine out ten cases these maintenance manuals are not available. 
CCRA has the informational links on their website to download free maintenance manualsfor the owner to meet these requirements. 

Section 653.802 Specific Conditions and Installation Procedures 
a) Complete removal of the cross connection or installation of an approved cross connection control device is required for control of backflow and backsiphonage. 
b) Cross connection control devices shall be installed in accordance with the manufacturer's instructions. 
c) Cross connection control devices shall be inspected at least annually by a person approved by the Agency as a cross connection control device inspector (CCCDI). The inspection of mechanical devices shall include physical testing in accordance with the manufacturer's instructions. 

This is the major problem for water purveyor; "who is testing these valves and are they qualified?" If the inspector does not meet these requirements and is NOT qualified, and then risk for the water purveyor is elevated. 
Keeping track of the testing inspector that may perform test, repair devices and survey inspections requires a special program and special diligence. The majority of water purveyors DO NOT TRACK THE INSPECTOR to see if they have met the qualifications needed to perform the requirements described in the states codes. 
CCRA programs do just that and more. CCRA understands what is required and our program and IT team has accessibility to the states CCCDI data files in Edwardsville. This is an extremely effective part of CCRA programs and very important. CCRA will make sure that every inspector is qualified, insured, and testing with mechanically sound equipment. 

d) Requirements for Cross Connection Control Device Inspector Approval

• 1) Each applicant for cross connection control device inspector (CCCDI) approval must meet the following qualifications:

  1. Must meet the qualifications to inspect plumbing and plumbing systems as described in the Illinois Plumbing License Law (Ill. Rev. Stat. 1983, chap. 111, par. 1103(1)), and provide proof of qualifications in writing on the application form provided by the Agency.

  2. Must complete and submit an application for CCCDI Approval at least thirty days prior to the examination date. Examinations shall be held not less frequently than annually. The application must be made on forms provided by the Agency, available at the headquarters and all regional office locations. Applicants shall be notified in writing of their status of eligibility. Notice of eligibility shall include an examination schedule and location.

  3. Must submit the examination eligibility notice to the examination proctor before being admitted to actual testing.

  4. Must successfully complete both written and performance examinations demonstrating understanding of the principles of backflow and backsiphonage, and the hazard presented to a potable water system; identifying locations which require installation of cross connection control devices; identifying, locating, inspecting, testing, maintaining and repairing cross connection control methods and devices inline, as located throughout each system which connects to a community public water supply Must successfully complete the written examination with a score of 75% minimum.

  5. Must successfully complete a performance based examination by demonstrating competency in testing device procedures on all types of devices at the examination center.

  6. Review of the written examination will be available at the test site on the day of examination.

  7. An applicant who does not agree with the Agency review of his application qualifications may write to the Agency to request that the application be presented to the Water Supply Advisory Board. The Advisory Board shall review the application and shall review the application and shall make a recommendation to the Agency for reconsideration or confirmation of the Agency evaluation.

• 2) CCCDI's must meet the renewal requirements of Ill. Rev. Stat. 1983, ch. 111, par. 1113(l), and must renew the CCCDI Approval each year, between May 1 and May 30. An application for CCCDI renewal will be sent by the Agency, and must be completed and returned by May 30 of the renewal year.

Many times this goes unchecked in municipalities CCC programs. CCRA programs tacks this through their re-registration process.

• 3) A CCCDI Approval or admission to examination for CCCDI Approval shall be suspended, revoked or not issued by the Agency for any one or more of the following causes:

  1. Practice of any fraud or deceit in obtaining or attempting to obtain a CCCDI Approval, including misrepresentation of approval;

  2. Any repeated, flagrant or willful negligence or misconduct in the inspection, testing or maintenance of cross connection control devices;

  3. Falsification of reports required by these rules;

  4. Willful violation of the Environmental Protection Act or any rules there under.

• 4) Suspension/Revocation Procedures

  1. The Agency may initiate the suspension/revocation procedure.

  2. Any person may initiate the procedure for suspension/revocation of any CCCDI by filing a sworn written complaint with the Agency. If the Agency determines that the complaint is duplicitous or frivolous, it shall notify the person filing the complaint but shall take no further action.

  3. The decision to institute suspension or revocation shall be based upon the seriousness of the violation and its potential deleterious impact upon public health and safety. Examples of cause for suspension include but are not limited to: failure to comply with proper reporting procedures as described in Section 653.802(e)(2), (3) and (4) below; incomplete or improper testing procedures; examples of cause for revocation include but are not limited to: falsification of records; negligence, incompetency or mis-operation which results in or could result in a potential or actual health hazard; fraudulent representation of credentials; attempt to obtain CCCDI approval using fraudulent methods; repeated violations meriting suspension. When the suspension/revocation procedure is warranted, the Agency shall notify the CCCDI by certified mail that suspension/revocation is being sought. Such notice shall specify the cause upon which suspension/revocation is sought and include the procedures for requesting a hearing before the Agency. Request for hearing must be made in writing 14 days following receipt of the Agency's certified notification. If no hearing is requested, the Agency will affect the suspension/revocation on the 15th day.

  4. Should a hearing be requested, the Director shall appoint one or more Agency employees to chair the proceedings. The hearing shall be conducted in accordance with hearing requirements of Sections 1025 through 1065 of the Illinois Administrative Procedure Act (Ill. Rev. Stat. 1991, ch. 127, pars. 101025 through 101065).

  5. The Director shall make a decision within 30 days after receiving the hearing transcript. The Director shall give written notice of that decision and reasons for the decision to the CCCDI by certified mail.

  6. Within 30 days of receipt of a notice of suspension/revocation from the Agency, the CCCDI may appeal the suspension/revocation to the Pollution Control Board. The suspension/revocation of the CCCDI's Approval shall be stayed pending a final decision on the appeal by the Pollution Control Board.

  e) Testing and Records

  1. Each device shall be tested at least annually or more frequently if recommended by the manufacturer.

  2. Records submitted to the community public water supply shall be available for inspection by Agency personnel in accordance with Ill. Rev. Stat. 1983, ch. 111 2, par. 1004(e).

  3. Each device shall have a tag attached listing the date of most recent test, name of CCCDI, and type and date of repairs.

  4. A maintenance log shall be maintained and include:

     1. date of each test;

     2. name and approval number of person performing the test;

     3. test results;

     4. repairs or servicing required;

     5. repairs and date completed; and

     6. servicing performed and date completed

  Keeping these records requires two departmental staff members; an efficient record keeper and a qualified person that is familiar will cross checking the paperwork for accuracy. CCRA has reviewed several of the filed paper work of water purveyors, over 50% to 90% of test reports were incomplete, wrong, or need additional attention. Most of these files have been filed as complete. This is NOT a direct result of incompetence; rather it is a result of over worked staff members and having inexperienced staff member do not have the experience to know what to look for and inconsistency of water purveyor having their own documentation, staff members reviewing hand written forms that lack the right information that the testing inspector provide. Having an experience CCCDI staff member is costly and can also render a program ineffective because the tax payer will not be able to afford it. CCRA recommends that water department has a licensed CCCDI staff member on staff to handle code issues in-house operations and other duties, but without the right programs his job will be overwhelming. CCRA programs are protected by CCRA software that review for informational accuracy and when there is an irregularity, software flags for review by a CCCD inspector and it will be address with water purveyor for correction. 
  
  This has been one of the misconceptions and opens the door to fraud. For years the inspectors have been leaving the inspections report hanging in envelopes around the valve thinking that this could serve as the valve tag and the maintenance log. It has been used to fill out forged test reports and sent in to create the illusion that these devices have been tested, when in fact they have not and many of the old test reports over the year are illegible. CCRA keeps a maintenance log of all information and provides owner with a valve tag that will have the CCCDI name, date, approved or failed, and certification number, all other information will be protected and can only be accessed by a qualified person through the CCRA or Water Purveyors data base. 
  
  f) Cross-connection control devices located in the treatment plant, well house or booster station of a community public water supply facility shall be inspected at least annually by either an approved crossconnection control device inspector or by a certified water supply operator trained for testing, installation, repair and maintenance of crossconnection control devices.

  1. Records must be kept as required by Section 653.802(e) above and must be signed by an approved CCCDI or a certified water supply operator who has successfully completed a crossconnection control device inspection training program conducted by the Environmental Resources Training Center (Ill. Rev. Stat. 1983, ch. 144, par. 691 et seq.).

  2. Certified water supply personnel who successfully complete Environmental Resources Training Center sponsored crossconnection control device inspection training will receive an authorization number which authorizes them to test only those devices located in the treatment plant, well house or booster station of the community public water supply facility.

  3. (Source: Amended at 9 Ill. Reg. 17367, effective October 23, 1985)

  
  Section 653.803 Cross Connection Control Devices
  
  a) A fixed proper air gap shall be used whenever technically possible. 
  b) Atmospheric Vacuum Breakers may be installed subject to the following conditions:

  1. An atmospheric vacuum breaker shall not be installed where back pressure may occur.

  2. An atmospheric vacuum breaker shall be installed at the highest point in the waterline and after the last control valve before the point of discharge and a minimum of six inches above the flood level rim of the receptacle.

  3. An atmospheric vacuum breaker shall not be used for installations where the substance in the container receiving water is lethal or toxic. Examples of acceptable installations include:

     1. surface wash piping for a gravity filter;

     2. solution tanks of gravimetric dry chemical feeders;

     3. outlets with hose attachments; and

     4. receptacles with a low level inlet where the substance contained is nontoxic such as food or beverages.

  c) Reduced Pressure Principle Backflow Preventers may be installed subject to the following conditions:

  1. Installation

     1. Units shall be accessible for maintenance and testing.

     2. Minimum clearances recommended by the manufacturer shall be used.

     3. Units shall be protected against flooding and freezing.

     4. Relief ports shall not be plugged. A drain which will remain free flowing under all conditions shall be provided.

     5. A collection system with an air gap under the relief port drain shall be installed with ceiling level units.

     6. No reduction shall be made in the size of the relief port drain.

  2. Bypasses - A second backflow preventer shall be installed parallel to the first if there is only one service line and the water service cannot be interrupted. Bypass lines without reduced pressure principle backflow preventers shall not be installed.

  3. Reduced pressure principle backflow preventers shall be used for installations where a fixed proper air gap is not possible. Examples of such installations include:

     1. the water line used to provide make up water for chemical feeders in a water treatment plant;

     2. receptacles with a low level inlet where the contents are nontoxic such as food or beverages; and

     3. receptacles or vessels which can subject the water supply line to back pressure.

  4. Water service lines which connect a community water supply to industrial or commercial establishments shall include either a reduced pressure principle backflow preventer or a fixed proper air gap with repumping if those establishments constitute a hazard to the water supply due to the nature of chemicals or other material handled within the facility. (Source: Amended at 9 Ill. Reg. 17367, effective October 23, 1985)