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HomeMy WebLinkAboutItem #3 Cross ConnectionCHUBBUCK IOAH0 Memo To: Mayor and City Council From: Bridger Morrison, Public Works Director Date: June 2, 2023 Re: Cross Connection Control Program Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us As you will likely recall, City staff gave a brief presentation to City Council on August 3, 2022, that covered an introduction to cross connections and backflow prevention in our water system with specific emphasis on cross connections created when both the city's pressurized irrigation systems and potable water system supply a homeowner's sprinkler system. State law (58.01.08.543) requires water purveyors to administer a Cross Connection Control Program to prevent cross connections and backflow to our potable water supply system. The city has had a cross connection control program defined in city ordinance Chapter 13.12 for many years. However, the city has not done a good job at enforcing the program. When attempts were made in the past to be more proactive with the program, it was met with much resistance. This lack of enforcement and follow-through poses a significant risk to our residents. Since our discussion last August, the Water Department has spent significant time taking inventory of a large portion of the cross connections that exist within the city. That investigation has shown that the concern over potentially problematic cross connections is widespread and significant. In an effort to better address these concerns and be more compliant with state and federal regulations, city staff have developed three different options to begin the first steps in implementing our cross connection program. These options are outlined below. Option 1 Recognizing there is a significant impact to homeowners, the first option is for the city to contract with a certified backflow testing company to inspect and perform tests on all existing backflow devices. The city would receive test reports back and then send follow-up information and corrective action notices to homeowners. The city would bear the expense of the initial testing and allow homeowners ample time to modify their systems to bring them into compliance. The approximate cost for the contracted services would be $75,000. This would be a one-time cost to the city which we would hope to accomplish this year. Going forward homeowners will be responsible for annual testing costs per city ordinance 13.12.060, "Inspections, tests, and maintenance shall be conducted at the property owner's expense." If property owners fail to comply with city regulations in the allotted time given, water service will be terminated until corrective actions are taken, 13.12.070. We anticipate that the additional work required to manage the testing, track the progress, and correspond with the residents could be accomplished with existing staff. Option 2 Acknowledging that ultimately it is the homeowner's responsibility per city ordinance, the second option would be to notify residents of the testing requirement and request they submit testing, or proof of no connection by a specified deadline. This would require significant tracking and follow-up by city staff for the testing process alone. This option would require the same corrective action notices and termination of services for failure to comply. Costs to homeowners could range from $50 — $100 for testing alone. Option 3 For this option, the city could hire additional personnel to implement and maintain the program. With this option, we would hire an employee and have them become a certified tester. They would then complete testing of all devices similar to Option 1. Personnel costs (annually) would be approximately $70,000 (1 FTE). Additionally, certification and licensing fees would need to be accounted for. We believe that by the time we were able to hire an employee and have them trained and certified, there would not be enough time left this season to complete all of the testing. The testing could be completed next year. Our biggest concern is whether or not the city wants to take on the liability associated with testing the devices ourselves. Option 4 Similar to Option 2, this option would place the cost of the testing on the homeowners. For this option, we would notify all homeowners of the requirements to have a proper device installed and tested. We would give them this summer to hire a tester and provide the results to us. We would then follow up next spring with those homeowners that had not provided the test results. If no testing was completed after that follow up, we would hire a tester to complete the tests and charge that cost back to the homeowner. We will need to get legal input to confirm that our ordinance allows for this charge to be applied to the homeowner. The primary difference between this option and Option 2 is that for this option, the city would hire a tester at the homeowner's cost instead of resorting to shutting off the water supply. This option would likely take more time to fully implement compared to the other options because of the amount of time we would need to provide to homeowners to comply with the notices. With any of the options selected, if a backflow prevention device must be replaced, that cost could be significant at $400 - $500 plus installation and testing. The current expectation is that the homeowner would be responsible for that cost unless they chose to remove the cross connection altogether. Attached are example letters we intend to send to residents for Options 1 and 2. The letters include the initial notification letter as well as the follow-up letter which will define the corrective action that may be required. The notifications letters for Options 3 and 4 would be very similar to what is included here. These options are certainly not all encompassing. Staff would recommend contracting with a third -party company to aid in the introduction of the program. Implementing and enforcing the city's Cross - Connection Control Program will proactively protect the city's potable water supply and protect the health and safety of our residents. Staff are requesting general input and direction from City Council; no formal action is required at this time. lao"�t\ CHUBBUCK **DRAFT Resident notification letter, OPTION #1** Date Chubbuck Resident Address Chubbuck, Idaho 83202 Re: Cross Connection Control Dear Resident, Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us Our records indicate that based on the location of your home, you may have access to Fort Hall Irrigation water through the city's, or a private, pressurized secondary irrigation system. Because of this we are reaching out to determine which of the following you have: • You have a sprinkler system with both household water and irrigation water connected: If you have both household water and irrigation water connected to your system, per city code 13.12 you are required to have a backflow device installed to prevent irrigation water from flowing back into your home. The backflow of irrigation water into drinking water can cause serious health issues. All homes with this type of connection must have an approved backflow prevention device installed and tested annually. Test results must then be submitted to the city. To assist homeowners in ensuring they have the proper device installed and that it's tested, the city will be contracting with a certified backflow testing contractor to provide testing of backflow devices this summer (insert specific date when determined). Testing consists of contracted personnel entering your yard and inspecting and testing the backflow prevention device. They will then send the results of the testing to the city, and we will send a copy of the results to you. Again, testing must be done annually by the homeowner. If there are no previous test records on file, testing will be completed at your home. We will notify you in advance of the specific time frame of when testers will be arriving. Please notify us if you do not have a backflow prevention device to be tested, or if there will not be access to your device. We do not want to send someone to your home if there is nothing to test or testing cannot be completed. If you do not want the city's contractor to test your device, please notify the city with the date when your test results will be submitted to the city. Test results need to be submitted prior to July 15, 2023. • You do not have a sprinkler system or do not have household water connected to your sprinkler system: If you do not have a sprinkler system or do not have household water connected to your system,Ip ease notify us. The city will still need to inspect your system to document a cross -connection does not exist. lao"�t\ CHUBBUCK Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us • You are unsure of what type of connection you have: If you are unsure of why type of connections you may have, please contact us and we will have someone come out and inspect your system for you. If the certified tester finds that your backflow prevention device is not approved or fails to pass the required test, the tester is required to immediately shut off water to the device and install a tag showing it cannot be used. If this occurs, you will not be able to utilize your household water line to supply your sprinkler system. Per state law, you are not allowed to utilize that cross -connection until an approved device is installed, tested, and appropriate documentation is submitted to the city. The City's follow-up letter which will be sent after the testing is completed, will include the test results and describe the corrective actions, if required. Please contact the city's Water Department at 208-237-2430 extension 145 with any questions and to report the status of your connection. Thank you in advance for your cooperation and for helping us keep our residents safe and healthy. Sincerely, Cameron Lusk Water/Wastewater Operations Manager CHUBBUCK IOAH0 **DRAFT Test Results Letter, Option 1** Date Chubbuck Resident Address Chubbuck, Idaho 83202 Re: Backflow Device Test Results Dear Resident, Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us The city recently completed inspection and testing (if possible) on installed backflow prevention devices on sprinkler systems that were connected to both the city's potable water supply and a secondary irrigation system. Test results of your device are attached to this letter for your records. The testing indicates that: (select one option below and delete the others) You do not have a backflow prevention device installed. 2. You do not have an approved backflow prevention device installed. 3. You have an approved backflow prevention device installed but it failed to pass the required test. 4. You have an approved backflow prevention device installed and it passed the required test. *Based on each result scenario, instructions and timing for correction will be included. Based on the testing results of your backflow prevention device, the following actions must be completed: (select one option below (1 or 2) and delete the others) 1. If an approved backflow prevention device which passed the required test was not found, the tester placed a tag on the device and closed valves to isolate the device. This must remain isolated to protect your drinking water. You have two options moving forward: You can remove the device altogether. This will create an air gap between the potable water supply and the irrigation water as required by law. This must be done within 10 days of receiving this letter and you must notify the City Water Department so that it can be verified. If done properly, your sprinkler system should still function as intended with irrigation water, but you will not be able to utilize potable water to run your sprinkler system. We recommend you review this with your sprinkler system contractor. If you would like to keep the cross connection, the unapproved or faulty backflow prevention device must be removed or replaced within 10 days of receiving this letter. If the unapproved or faulty device is removed, you can install an approved device at your CHUBBUCK IOAH0 Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us convenience as long as the cross connection is not reinstated before a correct device is installed and tested. That device must be tested by a certified tester and the results submitted to the city. Prior to installing the backflow prevention device, you must obtain a sprinkler system permit from the City of Chubbuck. That permit can be obtained by contacting the City's permit office at (208) 417-7176 or online at https:HcitVofchubbuck.us/sprinkler-systems/. The fee will be waived if this work is completed right away. On the same web page, you can also find a list of approved backflow prevention devices and certified testers. If you choose to remove the unapproved or faulty backflow prevention device but hold off on installing a new device, you must contact the City Water Department so that it can be verified. The cost to remove, replace, and test the backflow prevention device is that of the homeowner. Moving forward, homeowners with a cross -connection must have the backflow prevention device tested annually and submit results to the city. The cost of the annual testing is the homeowner's responsibility. Failure to submit annual test results may result in the city having to shut off your potable water supply. 2. Have your device tested annually and submit the results to the city. Failure to do so may result in the city having to shut off your potable water supply. Thank you, Cameron Lusk Water/Wastewater Operations Manager CHUBBUCK II00H0 **DRAFT Resident notification letter, OPTION #2** Date Chubbuck Resident Address Chubbuck, Idaho 83202 Re: Cross Connection Control Dear Resident, Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us Our records indicate that based on the location of your home, you may have access to Fort Hall Irrigation water through the city's, or a private, pressurized secondary irrigation system. Because of this we are reaching out to notify you that if you have both household water and irrigation water connected to your system, the DEQ and city code, 13.12, require that you have a backflow prevention device installed to prevent irrigation water from flowing back into your home. The backflow of irrigation water into drinking water can cause serious health issues. All homes with this type of connection must have an approved backflow prevention device installed and tested annually. Test results must then be submitted to the city. We have enclosed a list of certified testers for your convenience. If your device has been previously tested and reported, a new test and report is due within one year of the previous test date. If you do not have a sprinkler system or do not have household water connected to your system,Ip ease notify us, the city will still need to inspect your system to verify and document a cross -connection does not exist. Please make sure your system is tested and the report is submitted to the city no later than October 1, 2023. If we do not receive your test results or verification that a cross connection doesn't exist by the specified date, we may stop service until the required information is received. If you have any questions or are unsure about what type of connection you have, please contact the Water Department at 208-237- 2430 extension 145. Thank you in advance for your cooperation and for helping us keep our residents safe and healthy. Sincerely, Cameron Lusk Water/Wastewater Operations Manager CHUBBUCK II00H0 **DRAFT Test Results Letter, Option 2** Date Chubbuck Resident Address Chubbuck, Idaho 83202 Re: Backflow Device Test Results Dear Resident, Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us Thank you for completing the required backflow prevention testing on your device or system. Test results are attached to this letter for your records. The testing indicates that: (select one option below and delete the others) 1. You do not have a backflow prevention device installed. 2. You do not have an approved backflow prevention device installed and it failed the required test. 3. You do not have an approved backflow prevention device installed, but it passed the required test. 4. You have an approved backflow prevention device installed but it failed to pass the required test. 5. You have an approved backflow prevention device installed and it passed the required test. *Based on each result scenario, instructions and timing for correction will be included. Based on the testing results of your backflow prevention device, the following actions must be completed: (select one option below and delete the others) If an approved backflow prevention device which passed the required test was not found, the cross connection must be isolated immediately. This must remain isolated to protect your drinking water. Once your device is isolated, you have two options moving forward: You can remove the device altogether. This will create an air gap between the potable water supply and the irrigation water as required by law. This must be done within 10 days of receiving this letter and you must notify the City Water Department so that it can be verified. If done properly, your sprinkler system should still function as intended with irrigation water, but you will not be able to utilize potable water to run your sprinkler system. We recommend you review this with your sprinkler system contractor. CHUBBUCK II00H0 Public Works Department 290 E. Linden, Chubbuck, ID 83202 208.237.2430 — Fax 208.237.2409 www.CityofChubbuck.us If you would like to keep the cross connection, the unapproved or faulty backflow prevention device must be removed or replaced within 10 days of receiving this letter. If the unapproved or faulty device is removed, you can install an approved device at your convenience as long as the cross connection is not reinstated before a correct device is installed and tested. That device must be tested by a certified tester and the results submitted to the city. Prior to installing the backflow prevention device, you must obtain a sprinkler system permit from the City of Chubbuck. That permit can be obtained by contacting the City's permit office at (208) 417-7176 or online at https://cityofchubbuck.us/sprinkler-systems/. The fee will be waived if this work is completed right away. On the same web page, you can also find a list of approved backflow prevention devices and certified testers. If you choose to remove the unapproved or faulty backflow prevention device but hold off on installing a new device, you must contact the City Water Department so that it can be verified. The cost to remove, replace, and test the backflow prevention device is that of the homeowner. Moving forward, homeowners with a cross -connection must have the backflow prevention device tested annually and submit results to the city. The cost of the annual testing is the homeowner's responsibility. Failure to submit annual test results may result in the city having to shut off your potable water supply. 2. Have your device tested annually and submit the results to the city. Failure to do so may result in the city having to shut off your potable water supply. Thank you, Cameron Lusk Water/Wastewater Operations Manager CROSS CONNECTION CONTROL PROGRAM WAMfq ron &I. CHUBBUCI( 1 0 A H 0 June 7, 2023 Study Session Presentation I. C' :. What is Cross Connection.? CROSS CONNECTION: Any physical arrangement whereby a public water supply is connected, directly or indirectly, with any other water supply system, sewer, drain, conduit, pool, storage reservoir, plumbing fixture, or other device which contains or may contain contaminated water, sewage, or other waste or liquids of unknown or unsafe quality which maybe capable of imparting contamination to the public water supply as a result of backflow. 0 Water purveyors must take reasonable and prudent measures to protect theirwater systems against contamination and pollution from cross - connections. � Idaho Department of Environmental Quality pf,PART :q4 .n Responsibilities of Community Wq tel System s Community water system purveyors are required to implement and enforce a cross -connection control program to prevent toxic or hazardous materials from entering the system. Programs t Inspection Program go V must include at least the following: 6 Requirement of suitable protection before providing service Requirement of adequate backflow prevention installed, and tested annually Requirement that failed testing is corrected within 10 business days Discontinuance of service where backflow prevention has not been provided Idaho Department of Environmental Quality .� :_.r .. v r f: rte''{��i tpf .7y$''rt•v'a ..y .LF .. _i:r�u '�-.. �"�:. l'i`1,y�- _ �., 1 r. '• J�' _r�.. �.^ 24 st,•�t �' ;� - _�P ` �- .� .... ,�;�.y }rn h' +iy r • 't - -h, ' � TSN.%!� - '1 �.' � L . _ Y • Y?'.. yA' .. TZ •� � � 1, .� _, - �� . i' n, ,.� ` r � _ � dT :,:;:...} �• w a' ,. p► 'tc. v,44 key' i 3 l'- J1!� l- rf•. La.. ,�4. _ l`r„"-. y_�,'rn . S .. .�f. �4 1 .. __, .. - IZD •°�•_ L i!. .r.L �i 'f r. w✓__ '�� `. .=SC iI •t.:' .. "'°t�A t �'.'.S'J r'� �r�'� '�'i'rar � V. .-L :�3•. Contract with athird-party vendor to provide testing/ reporting services Require homeowners to submit testing at their own cost and track internally Hire additional city staff to design,, implement and maintain the program Spend the next year educating and asking homeowners to complete testing themselves. Next year the city will complete testing and bill homeowners for the service. -JEFle AY A AW?w LANFATAL %A j Option Contracted Services • Reduces initial impact to homeowners • Testing and reporting handled outside • One-time cost of approximately $75k • Follow-up,, corrective notices and tracking done by city staff YN" -300 ,dew • i4 41W +� lip 4 0 Y 160 7 pn. PS1D 2 3 4 S 6 7 87.1 10 rr r� 2 3p 40 5060 12 kF7 70 13 $Q 14 90 is 1QO � r i L tia i`� OF Option # 2 - Homeowners Responsibility • Testing is submitted to the city by homeowner or company performing the testing • May be significant costs to homeowners • Tracking and follow-up done internally • Likely requires significant follow-up and pressure (shut -offs) to get initial test results w • lot i Option # ? - Increase • Program would be implemented ani city staff including annual testing • Increases liability • Ongoing personnel costs would be approximately $70k annually plus certification/licensing costs • Testing could be provided at no additional cost to homeowner if rates were increased to account for additional costs I* T Option # 4 -Education &Request Homeowners Test •Spend this year educating and requesting homeowners to complete testing on their own • Next year the city would complete the testing (internally or contracted) at the homeowners expense • Likely results in longer time frame until compliance • Would need legal input regarding ability to charge the customer -for ciy performed/contracted testing r a 4 C s M •f r+� r a 4 C s M IN Creating a new utility agreement to include information about backflow prevention Producing additional educational materials to distribute with utility agreement and on social media Planning to make changes to website to highlight the program and provide clear information Working with GIS to determine capabilities of tracking each homes cross connection status Questions or Com ments?