CROSS CONNECTION CONTROL PROGRAM

CROSS CONNECTION CONTROL PROGRAM

GEORGETOWN CHARTER TOWNSHIP

I. INTRODUCTION AND PURPOSE

When safe drinking water has been produced and pumped into the public water distribution system, precautions must be taken to be certain that it is not tainted with unsafe water or contaminants from other sources. Almost every water-using premise may have actual or potential cross connection hazards. Contaminated backflow into the public water distribution system, due either to back siphon age, from processes, appliances, or from secondary water sources, can occur.

The purpose of this Cross Connection Program is to prevent safe drinking water in the public water distribution system from being tainted with unsafe water or contaminants from other sources.

II. DEFINITIONS

The following listed words and phrases are defined for the purpose of their use in this Program. These definitions shall apply in the interpretation and enforcement of this Program unless otherwise specifically stated.

“Backflow” means water of questionable quality, or which is contaminated with wastes or other contaminants, which enters a public water supply system due to a reversal of flow.

“Coordinator” means the person designated in writing from time to time by the chief executive of the Water Utility to have responsibility for administering all aspects of the Program. In the absence of such a designation, the chief executive of the Water Utility shall be the Coordinator.

“Cross Connection” means a connection or arrangement of piping or appurtenances through which a backflow could occur.

“High Hazard” means contamination or an impairment of the quality of the potable water which creates an actual hazard to the public health through poisoning or through the spread of disease by sewage, industrial fluids or waste.

“Low Hazard” means pollution or an impairment of the quality of the potable water to a degree which does not create a hazard to the public health but which does adversely and unreasonably affect the aesthetic qualities of such potable water for domestic use.

“MDEQ” means the Michigan Department of Environmental Quality or any similar successor agency of the Michigan state government that has responsibility for the regulation of public water systems.

“Ordinance” means the Georgetown Charter Township Cross Connection Ordinance. A copy of the Ordinance is attached as Appendix A.

“Person” means a firm, association, partnership, joint venture, corporation, limited liability company, trust, municipal, or public entity, or a consortium of any of them, as well as a natural person.

“Program” means this cross connection control program including all attachments, appendices, and charts.

“Safe Air Gap” means the minimum distance of a water inlet or opening above the maximum high water level or overflow rim in a tank, vessel, fixture, container, or appliance to which public water is furnished. This minimum distance shall be not less than two times the inside diameter of the water inlet pipe, but shall not be less than one (1”) inch in any event and need not in any event be more than twelve (12”) inches.

“Secondary water supply” means a water supply system maintained in addition to a municipal type public water supply, including but not limited to water systems from ground or surface water sources not meeting the requirements of Act No. 98 of the Public Acts of 1913, as amended, being sections 325.201 to 325.214 of the Compiled Laws of 1948, or water from a public water supply which in any way has been treated, processed, or exposed to any possible contaminant or stored in other than an approved storage facility.

“Submerged inlet” means a water pipe or extension thereto from a public water supply terminating in a tank, vessel, fixture, or appliance which may contain water of questionable quality, waste, or other contaminant and which is unprotected against backflow.

“Water Utility” means the Georgetown Charter Township Water Utilities Department.

III. AUTHORITY

This Program has been adopted by resolution of the township board of Georgetown Charter Township pursuant to Section 9 of the Ordinance and completely replaces any previous promulgated programs for Cross Connection enforcement. This Program may be amended by resolution of the township board of Georgetown Charter Township at any time.

IV. CROSS CONNECTION CONTROL COORDINATOR

The Coordinator shall be responsible for administering all aspects of the Program. The Coordinator shall have the appropriate training in Cross Connections through the MDEQ, American Water Works Association, or other recognized agencies and/or organizations. The Coordinator shall, as a minimum, be certified by the MDEQ in the S-4 Distribution Classification or be a Master and/or Journeyman Plumber licensed by the State of Michigan. Any Water Utility staff or personnel from an inspection agent retained by the Water Utility that assist the Coordinator with inspections shall also have the same training and certifications or licensure as are provided above with respect to the Coordinator.

V. INITIAL INSPECTIONS

The schedule for customer inspections for Cross Connections shall be in accordance with Chart 1. As soon as reasonably possible after the Program becomes effective, the Coordinator shall review the Water Utility non-residential water customer list and determine those non-residential water customers that have the potential to have a High Hazard Cross Connection. Initial inspections shall then commence. All initial inspections shall be documented by completing the initial form found in attached Appendix B.

Chart 1

Initial Customer Inspection Schedule

All Non-Residential Customers with a Potential High Hazard Cross Connection(s)	Within 1 year of review of non-residential customer list
All Other Non-Residential Customers	Within 3 years of review of non-residential customer list

VI. RE-INSPECTIONS

Re-inspections of all non-residential customers shall be periodically and systematically conducted for the presence of new Cross Connections and/or modifications to the water customer’s water piping system. The schedule for re-inspections shall be as shown on Chart 2. Whenever it is suspected or known that modifications have taken place with respect to a water customer’s water piping system or with respect to any equipment or process system that affects the water customer’s water piping system, a re-inspection shall be made at that time. All re-inspections shall be documented by completing the re-inspection form found in attached Appendix B.

Chart 2

Re-Inspection Schedule

Non-Residential Customers with High Hazard Cross Connection(s)	Annual
All Other Non-Residential Customers	Every three years

VII. METHODS OF PROTECTION

The methods that may be employed to protect against the hazards of a particular Cross Connection are shown on Chart 3. The Coordinator may also refer to the Cross Connection Rules Manual, Michigan Department of Environmental Quality, Drinking Water and Radiological Protection Division, or any other references obtained during training where Chart 3 does not provide an appropriate means to protect against the hazards of a particular Cross Connection. Prior to installation and use, the type of mechanical device to be used to protect against potential Backflow shall be approved in writing by the MDEQ. Any deviation from the recommended methods of protection provided in Chart 3 or the above-referenced Cross Connection Rules Manual shall not be permitted without prior written approval from the MDEQ and the Water Utility. A list of currently approved devices is included in attached Appendix C. A description of the application of specific devices is included in attached Appendix D.

CHART 3 – APPROVED METHODS OF PROTECTION

PROTECTIVE DEVICES

TYPE OF CROSS CONNECTION	APPROVED AIR-GAP SEPARATION	APPROVED RPPBP	APPROVED DOUBLE CHECK VALVE ASSEMBLY	APPROVED VACUUM BREAKER
SUBMERGED INLET HOSE OUTLET	XXXX	XXXX		XXXX
TOILETS, URINALS, CHEMISTRY LABS	XXXX	XXXX		XXXX
REFRIGERATION SYSTEMS	XXXX	XXXX
WATER SOFTENERS	XXXX	XXXX	XXXX	XXXX
TREATED WATER SYSTEMS	XXXX	XXXX
CHEMICALLY TREATED AND/OR HIGH PRESSURE BOILERS	XXXX	XXXX
MORTUARIES	XXXX	XXXX		XXXX
LAWN IRRIGATION SYSTEMS	XXXX	XXXX		XXXX
WWTP, SEWAGE LIFT STATIONS	XXXX	XXXX
LOW PRESSURE AND/OR NON CHEMICALLY TREATED BOILERS	XXXX	XXXX	XXXX
ALL PRIVATE WELLS	XXXX	XXXX
SURFACE WATER	XXXX	XXXX
RECIRCULATING TOWERS	XXXX	XXXX
WATER STORAGE FACILITY (not acceptable)	XXXX	XXXX
WATER STORAGE FACILITY (acceptable facility)	XXXX	XXXX	XXXX
ALL OTHER APPLICATIONS	XXXX	XXXX

* REDUCED PRESSURE PRINCIPLE BACKFLOW PREVENTER

VIII. ENFORCEMENT

The Coordinator shall use the following procedures for instituting enforcement actions. Every attempt should be made to treat each water customer in an equitable manner. If conditions warrant a significant deviation from the following procedures, the Coordinator shall obtain prior written concurrence from the Water Utility chief executive.

A. HIGH HAZARD ENFORCEMENT

1. Water customers who have a High Hazard Cross Connection that is in violation of the Ordinance or this Program shall be handled on a case-by-case basis, due to the critical nature of these types of Cross Connections. Enforcement can include immediate water service termination pursuant to the water service termination procedures specified in subsection A.2. below. The Coordinator, if he/she is not the Water Utility chief executive, shall consult with the Water Utility chief executive as soon as reasonably possible to determine the best course of action. However, the High Hazard Cross Connection that is in violation shall be modified as soon as reasonably possible and, in any event, within thirty (30) days from the date the violation is first identified.

2. If the Coordinator determines that the water customer’s High Hazard Cross Connection that is in violation of the Ordinance or this Program poses an actual threat to the public health, the Coordinator may cause the water customer’s service to be terminated immediately by closing the valve in the curb stop and removing the meter to provide a Safe Air Gap. If this action causes any portion of the water customer’s fire protection system to be disconnected from the water system, the Coordinator shall, as soon as reasonably possible, provide oral notice and written notice by facsimile or personal delivery to the fire department that water service has been terminated.

The Coordinator shall provide the water customer with written notice, which can be by facsimile, of the reason for the immediate termination of service. The water customer shall be provided an opportunity to meet with the Water Utility Chief Executive within fourteen (14) days from the termination of service to discuss the reason(s) for termination of service and possible reinstatement of service.

3. If the Coordinator determines that the water customer’s violation of the Ordinance or this Program does not constitute an actual threat to the public health, the procedures for water service termination set forth in subsection B.4. below shall be followed.

B. LOW HAZARD ENFORCEMENT

1. A water customer who has a Low Hazard Cross Connection that is in violation of the Ordinance or this Program or is otherwise in violation of the Ordinance or this Program shall be given 45 days written notice to comply with the Ordinance and this Program and return a signed and dated copy of the inspection for attached as Appendix B to the Water Utility office. The 45-day time period shall begin when the notice is mailed to the water customer by first class or certified U.S. mail or is personally delivered. An extension(s) may be granted by the Coordinator in writing for a specific time period if there is a reason(s) that prevent timely compliance that are beyond the reasonable control of the water customer.

2. If the water customer has questions, or should the water customer request it, an appropriate information packet will be sent to or personally delivered to the customer.

3. No further action is required to be taken provided a signed and dated copy of the inspection form is returned within the 30 day time period or any extensions thereof granted by the Coordinator. If this does not occur, the Coordinator may give the water customer additional oral and/or written notice of the violation and otherwise work with the water customer to eliminate the violation or, in the discretion of the Coordinator, proceed with the water service termination procedures specified in subsection B.4. below.

4. The following procedures shall be followed for water service termination whenever the Coordinator has determined that a violation of the Ordinance or this Program does not pose an actual threat to public health:

a. Step 1: A water shut-off pre-warning letter shall be prepared and mailed via first class or certified U.S. Mail.

b. Step 2: If there is no response within 30 days to Step 1, a water termination notice shall be prepared and mailed via U.S. Certified Mail.

c. Step 3: If there is no response within 10 days to Step 2, the Coordinator shall conduct a final inspection of the water customer’s premises to determine whether the violation still exists and water service termination is warranted. If the violation still exists and the water service termination is still warranted, the Coordinator shall cause the water customer’s water service to be terminated by closing the valve in the curb stop and removing the meter to provide a Safe Air Gap. If this action causes any portion of the water customer’s fire protection system to be disconnected from the water system, the Coordinator shall, as soon as reasonably possible, provide oral notice by facsimile or personal delivery to the fire department that water service has been terminated.

In addition to the provisions of this Section VIII, the Water Utility shall have all other rights and remedies provided by law including, without limitation, a municipal civil infraction enforcement action as is provided in Section 17 of the Ordinance.

IX. TESTING

A. HIGH HAZARD. All water customers with High Hazard Cross Connections shall have all testable devices on High Hazard Cross Connections tested at least once every twelve months.

B. LOW HAZARD. All water customers with Low Hazard Cross Connections shall have all testable devices on Low Hazard Cross Connections tested at least once every three years.

C. REPORTS. Upon completion of testing and repairs, if any, which may be required, a completed, signed, and dated test report shall be sent to the Water Utility office. If the water customer fails to submit a report or fails to have the testing completed, and all necessary repairs completed, water service termination procedures in accordance with Section VIII shall be instituted.

D. DEVICE TESTERS. A list of approved device testers are included in attached Appendix E. Only licensed plumbers who have been certified by the Michigan Plumbing and Mechanical Contractors Association can both test and repair testable devices.

X. RESIDENTIAL CUSTOMERS

A. EDUCATIONAL MATERIALS. The elimination of residential Cross Connections will be achieved primarily through the publication and distribution of educational materials. The Coordinator will either publish educational materials in a newspaper of local distribution or mail educational materials directly to all residential customers, or both in the discretion of the Coordinator, at a minimum frequency of at least once every three years.

B. SUSPECT RESIDENTIAL CUSTOMERS. During the installation or replacement of water meters, a Cross Connection inspection shall be completed. If any violations are discovered, they will be reported to the Coordinator, who shall take appropriate enforcement action following the procedures specified in Section VIII above, for Low Hazard Enforcement. If a testable device is installed, the Coordinator shall add this customer to the testable device list.

XI. RECORDS

A. CROSS CONNECTIONS LIST. The Coordinator shall be responsible for preparing and maintaining a list that contains all known Low and High Hazard Cross Connections.

B. TESTABLE DEVICES. The Coordinator shall be responsible for preparing and maintaining a list of all testable devices. The list will provide details on the location, type, manufacturer, testing dates, repair history and other pertinent data.

C. ENFORCEMENT ACTION. The Coordinator shall maintain a record of all enforcement actions taken, including any correspondence, field notes, inspection reports, phone logs, etc.

XII. MISCELLANEOUS

A. RULES APPLYING TO TEXT. The following rules of construction apply to the text of this Cross Connection Control Program:

1. The particular shall control the general;

2. The headings which title various articles and sections are for convenience only and are not to be considered in any construction or interpretation of the Program or as enlarging or restricting the terms and provisions of this Program in any respect;

3. The word “shall” is always mandatory and not discretionary. The word “may” is permissive;

4. Words used in the present tense shall include the future, words used in the singular number shall include the plural, and words used in the plural number shall include the singular, unless the context clearly indicates the contrary;

5. Any word or phrase not defined in this Program shall be considered to be defined in accordance with its common or standard definition.

B. ADMINISTRATIVE LIABILITY. Neither the Coordinator nor any other Water Utility officer, agent, or employee, or any officer of Georgetown Charter Township, shall render himself or herself personally liable for any damage that may accrue to any person as a result of any act, decision or other consequence or occurrence arising out of the discharge of his or her duties and responsibilities pursuant to this Program.

C. SEVERABILITY. This Program and the various parts, paragraphs, sections, subsections, sentences, phrases, and clauses thereof, are hereby declared to be severable. If any part, paragraph, section, subsection, sentence, phrase, or clause is adjudged unconstitutional or invalid, it is hereby provided that the remainder of this Program shall not be affected thereby.

D. SAVINGS CLAUSE. Any actions pending on the effective date of this Program and which arose under a previous program which is replaced by this Program shall be finally concluded and resolved exactly as if the previous program had not been repealed.

E. EFFECTIVE DATE. This program shall become effective on

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