Katherine McGlaughlinResponse and Capacity Development TeamTexas Commission on Environmental Quality

Customer Service Inspections The “Missing-Link” in many Cross-

Connection Control Programs

Outline

• Texas Backflow Regulations– Overview

• Customer Service Inspection (CSI) requirements– Related requirements

Texas regulations

• Statute and Regulations:– Texas Health and Safety Code requires

‘protection of public water supplies’ from connection to water that is not ‘of safe and sanitary quality’

– The Texas Commission on Environmental Quality (TCEQ) implements the regulations from Texas Administrative Code

What is a CSI?

– A direct inspection of private premises plumbing (water-distribution) on the customers side of the meter to ensure that the potable water is not vulnerable to contamination.

Purpose of CSI

• The purpose of a CSI is to determine if water service can be safely provided to a site without the risk of contamination. This determination is based on an inspection to identify and prevent:– Direct and indirect cross-connections,– Potential contamination hazards, and– Illegal lead materials.

Local Rules for CSIs

• Water systems and municipalities should have CSIs covered in local ordinances/tariffs/customer service agreements– [§290.46(i)].– These rules should grant the licensed

CSI authority to enter a customers premises to check for hazards.

When is a CSI Required?

• New construction• Material improvement, correction, or addition to

the private water distribution system, such as:– Significant changes to existing plumbing– A customer request for a larger meter– Drilling a private well, etc.

• When the water supplier believes there is a cross-connection, or other potential contamination hazard.

When is a CSI Not Required

• No material change to the plumbing• Construction connections• Temporary connections• Transfer of service/change in

occupancy• Mobile homes and manufactured homes

Scope of CSI

• Examples of Potential Contamination Hazards [§290.38(66)]– Bypass arrangements, Jumper connections,– Water-cooling towers, carbonated-beverage

dispensers, landscape irrigation systems– Removable sections or spools, and– Swivel or changeover assemblies

• Assessment of Hazards [§290.47(f)]

Scope of CSI

• Internal programs:– A CSI is used to determine whether an

internal program is adequate.

• An adequate internal cross-connection control program shall include an annual inspection and testing by a certified backflow prevention assembly tester on all backflow prevention assemblies used for health hazard protection. [§290.44(h)(1)(B)(i)]

Internal Protection vs. Premises–Isolation…Can you Choose?

• The use of a backflow prevention assembly at the service connection shall be considered as additional backflow protection and shall not negate the use of backflow protection on internal hazards as outlined and enforced by local plumbing codes. [§290.44(h)(5)]

What a CSI is Not

• A CSI is NOT a plumbing inspection– Plumbing inspections ensure compliance

with adopted codes and ordinances related to plumbing

– A CSI can be conducted in conjunction with a plumbing inspection, by a properly licensed individual

What if a CSI finds a hazard?

• If the CSI identifies a hazard, it must be removed or the connection must be equipped with an appropriate backflow prevention assembly– Texas rules include requirements for

testing, maintenance, and reporting [§290.44(h)(1), (4)]

Rule language requiring hazard protection

• As potential contamination hazards are discovered, they shall be promptly eliminated to prevent possible contamination of the water supplied by the public water system. The existence of a health hazard, as identified in §290.47(f) of this title, shall be considered sufficient grounds for immediate termination of water service. Service can be restored only when the health hazard no longer exists, or until the health hazard has been isolated from the public water system in accordance with §290.44(h) of this title. [§290.46(j)(2)]

Who can conduct a CSI?

• TCEQ issues CSI licenses• Texas State Board of Plumbing

(TSBPE) licensees include:○ Licensed Plumbing Inspector○ Licensed Plumber with a Water Supply

Protection Specialist (WSPS) Endorsement

CSI and the Cross-Connection Control Program

• CSI documentation [§290.46(j)]○ TCEQ Form 20699: Customer Service

Inspection Certificate○ Available on the TCEQ website

CSI Record Keeping Requirements

• CSI Certificates must be kept a minimum of 10 years [§290.43(f)(3)(E)(iv)]– Strong recordkeeping practices support water

systems by providing historical data – TCEQ recommends keeping CSI Certificates

indefinitely

• Alternate versions of Form 20699 must be approved by the commission

CSIs at RV Parks

• Graywater Tanks vs. Blackwater Tanks– TCEQ recommends water systems

perform periodic CSIs of RV parks within their service area○ Periodic means at a frequency determined by the

water system that best protects their potable supply from any new cross-connections or compromised BPAs

– Have appropriate protection based on hazard identification

CSIs at Mobile Homes

• Are CSIs required on mobile homes inmobile home parks?

○ No, unless it is suspected that there is a cross-connection or potential contamination source.

○ Due to plumbing standards under the Manufactured Housing Construction and Safety Standards enforced by Department of Housing and Urban Development

CSIs at RV Parks & Mobile Homes

• Water systems can be protected from contamination from RV and Mobile home parks with either premises isolation or internal protection.

In Summary

• What is the importance of a Customer Service Inspection in relation to a Cross-Connection Control Program?

• What is the importance of a Cross-Connection Control Program in providing safe, potable water?

Take-home message

• CSIs identify risks and hazards that could cause drinking water contamination, and force accountability/action

• CSIs are the keystone of a successful cross-connection control program

• In Texas, they are not just a good idea, they are the rule

CCCP

Code Enforcement

Fire Marshall

Irrigators

CSIBPATs

PlumbingInspector

PWSCCCP Administrator

PWS Staff

Cross-Connection Control Program: CSIs are the keystone of a CCCP

Questions?