The Many Steps of a Cross-Connection Survey

There are many parts to a successful cross-connection control program. The installation, testing, and maintenance of backflow prevention protection is one of the most critical parts. Another, perhaps more important part, is the cross-connection survey. When a building is in the design stage, the mechanical engineer should be looking at the future use of water within the proposed facility and specifying the needed protection and locations as the drawings are created. This is an important first step in the process. Once drawings and specifications are complete, they will be submitted to the Authority Having Jurisdiction (AHJ). This is another step in the process — another set of eyes looking for issues prior to construction. After the plans are reviewed and approved, the project moves forward with the construction of the facility. Hopefully, any potential issues will be discovered and corrected before ground is broken on the project.

As the facility is built, there will be a number of inspections along the way. This is where either the contractor or building officials can discover and correct any issues. Once completed and a final inspection is completed, an occupancy permit will be issued and the facility occupied. In a perfect world, this process would ensure that the protection needed would be the protection installed. The problem is we do not live in a perfect world and never will. Oversights and mistakes occur far more often than we like. The photo on the following page is an example of a mistake that failed to be corrected in each and every step we discussed previously.

The photo above shows an actual installation that exists today. A combined (both domestic water and fire protection) water service enters the facility. The service is then split with a six-inch line feeding a water-based fire protection system and a four-inch line feeding the domestic water supply in the facility. The domestic service contains a reduced pressure principle assembly, while the fire protection service is unprotected. There is an eight-inch double-check valve assembly installed in a meter vault supplying the facility service line and several on-site fire hydrants. If the water service lost pressure for any reason, the assembly in the meter vault would prevent the building water from returning to the public supply, but there is no protection on the fire system to prevent it from backflowing into the domestic water system. The alarm check on the fire system is not considered backflow protection. This installation is in a large elementary school. The plans were drawn up by a licensed firm, they went through the plan review process and were approved. The job was put out to bid, awarded to a licensed contractor, and installed in accordance with the approved plans. The installation was inspected and approved by multiple inspectors working for state and local agencies, and also the school district. The building was granted an occupancy permit and
was allowed to open.

All of this happened, even though the plans, the installation, and the inspection were flawed. The installation does not meet adopted codes and standards, and may present a significant hazard to the individuals who come in contact with the water distribution system within the facility. How can a problem like this occur with all the checks and balances we have in place? How did no one involved in the design, installation, or inspection see the problem that was staring them in the face? Who now will address and fix the issue, and who will pay for the correction? The answer, right now, is no one. Why did this occur, and why do similar issues happen far too often? It is a lack of understanding of how and why cross-connections occur and what the correct backflow protection requires. It is also a fitting example of why cross-connection surveys are needed for both new and existing facilities. The surveys should be an ongoing and, in truth, never-ending process.

What is required in a cross-connection survey?

The purpose of a survey is to make sure no unprotected cross-connections exist, and that any existing protection installed is the proper protection. To do this, the surveyor needs to know what the potable water is being used for and what other hazards may exist, including any other auxiliary water supplies or pressurized systems that exist on site. To gather this information, the surveyor needs to study and review the as-built drawings of the facility and have the owner or facility manager fill out a detailed, accurate questionnaire spelling out what equipment exists within the facility, water sources on site, how water is used in the facility, what chemicals may be used, if pumps or injectors are used in the operations, and what, if any, protection is currently installed. Both the questionnaire and the drawing review will give the surveyor a starting point to begin planning for the actual on-site survey.

A cross-connection survey program will look at facilities in several separate ways. A containment survey will look at the level of hazard of the facility itself to ensure the proper protection is installed at the building service connection where it is directly connected to the public water system. This protection will prevent water that has entered the facility from leaving it, creating a closed water system downstream from the containment device or assembly. A containment survey, in most cases, is a fairly straightforward and relatively simple process. Containment surveys should be done on a regular schedule to ensure the facility has not been repurposed, and as a result of that change, the degree of hazard has increased. This needs to be done at least every three to five years. It needs to be understood that this containment program provides no protection for the individuals living or working in the facility. It is only installed to ensure that any possible backflow event cannot affect the public distribution system. For a containment survey, we would use the following steps:

1. Identify the type of hazard inherent within the facility.
2. Inspect the potable water entrance(s) to the facility (larger facilities, such as level one hospitals, may have multiple service lines from separate sections of the public distribution system) or immediately downstream of the meter installation for the correct protection.
3. Record the location of any existing containment protection.
4. Notify in writing the owner or his designee of any required corrective action.
5. Schedule a follow-up inspection after corrections are completed.

Surveyors need to understand that every facility needs to be looked at as unique. They should not develop tunnel vision or make assumptions about the facility prior to conducting the survey. This is important in all types of facilities. including residential, commercial, industrial, or institutional. Many Authorities Having Jurisdictions (AHJ), including water purveyors, tend to look at residential services as something that does not require surveys or backflow protection. This is a mistake; a residential lawn irrigation system carries the same hazard level as a commercial irrigation system and presents the same danger to the public supply. Do not fall into this trap — the laws of physics are the same in every system regardless of the building usage.

The second type of survey is an isolation survey. The purpose of this survey is to ensure that all piping, fixtures, and appliances downstream of the service connection are identified and protected. It ensures the facility itself is protected from any possible backflow incident. Depending on the facility type and facility size, this type of survey could take as little as several hours or as long as several months. It may require the individuals conducting the survey to receive specific training, including confined space certification or training on the use of lifts, ladders, and other safety equipment. In some locations, it may require security clearances or vaccinations. In an isolation survey, we would need to take the following steps.

1. Survey the facility, looking at all potable water piping, outlets, and fixtures, as well as their drainage connections.
2. Record all areas requiring backflow protection.
3. Record the location of all cross-connections and their hazard levels.
4. Record the location of all existing backflow protection.
5. Notify, in writing, the owner or his designee of any required corrective action.
6. Schedule a follow-up inspection after corrections are completed.

An isolation survey is a complicated process. It needs to be done correctly and all information gained from the survey needs to be documented. Follow-up after the survey is also critical. The survey report must document all unprotected cross-connections. It will include the location, the type of hazard, and the type of backflow protection needed to provide the necessary protection. It will list all existing backflow protection, their locations, and if they are properly installed and suitable for the level of hazard and the type of backflow they may be subject to. Digital photos and videos should be part of this documentation. As with so many things in the cross-connection industry, clear and concise documentation is vital to any quality program. Isolation surveys should be conducted on a regular basis and more frequently in facilities where the level of hazard is greater. Small changes to a facility can create significant hazards to the water system that must be addressed. The surveyor must also consider future expansions and additional possible changes that may occur. We do not have a crystal ball that allows us to see the future, but we need to be very proactive in our thinking.

What knowledge or certification should an individual have to be a cross-connection surveyor?

They should know federal, state, and local laws and regulations related to water systems and water quality. The surveyor should understand plumbing and mechanical systems, water distribution systems, blue-print reading, plumbing and mechanical codes, and on-site safety issues. They should also have a firm grasp of hydraulics and the principles of backflow prevention, including how or why it occurs. The surveyor must be familiar with all the tools in the backflow prevention toolbox — backflow devices, assemblies, and methods used to protect the water supply. They need to understand thermal expansion, installation requirements, pressure loss related to backflow protection, and fire protection system types and hazards. A surveyor must also understand recycled water systems, auxiliary water sources, and the list goes on. A surveyor should also attend a training and certification program that will test their knowledge and experience. ASSE International has a certification program for surveyors that is based on the requirements found in ASSE 5120, Professional Qualifications for Cross-Connection Control Suveyors. The 5120 certification also requires certified individuals to take a recertification class and both written and practical examinations every three years.

We have a number of checks and balances in place to prevent unprotected cross-connection from being created in new construction or remodeling projects. The building designer or mechanical engineer should not create any with their design. In the plan review, any issue should be discovered, and the design modified to eliminate the unprotected cross-connection. The licensed contractor and the tradespeople working for them should be able to discover and correct any design flaw during installation. The inspection company and its on-site inspectors should be the last line of defense to ensure a faulty installation that includes unprotected cross connections is corrected before an occupancy permit is issued. We have systems in place to prevent these problems, but in far too many situations these systems fail us. What is the problem and why does it keep happening? Many people will point to the use of multi-craft inspectors instead of traditional plumbing inspectors looking at these systems. Others may think it is a lack of training for both installers and mechanical engineers on backflow protection and cross-connection control. I think there are several factors at play here, but the fact that the situation exists drives home the point that cross-connection surveys need to be completed in both new and existing facilities and on a regular schedule to ensure mistakes are corrected in a timely matter.

The photo below is a perfect example of the need for regular cross-connection surveys. This is a direct connection between the water and sanitary sewer in this building. It is a code violation in every model code used in the United States. Although backflow protection is installed on this direct cross-connection, it is a violation and must be removed.

This installation was done after the building was inspected as a result of an issue with blockages in the sanitary sewer system. While it may have solved the blockage problem, it created another more dangerous issue. The more complicated the systems, the greater the chance that changes will occur over time. As equipment is replaced or updated, small changes can have large negative effects on system protection. This work may be done in-house with maintenance personnel who may not understand the potential hazards. If no permit is issued, then no inspection will take place.

As with everything, education and training are needed for inspectors, installers, designers, and end users. Certified backflow testers need to understand that every time they test an assembly, they should be doing a mini survey of the installation and the surrounding area. They should be asking the following questions:

• What is the degree of hazard?
• What type of backflow may occur?
• What is the system type?
• What are the pressure requirements?
• Is the location correct?
• Is the assembly for containment or isolation protection?
• What are the installation requirements?

If they discover an issue and note it on the test report, that should alert the AHJ or water purveyor that an issue exists and hopefully generate action to bring the system into compliance. As someone who travels the country doing cross-connection training, it is very clear to me that surveys need to be done and need to be performed much more often in many areas.

The photos below show an assembly installed incorrectly in a number of ways. It is a reduced pressure principle assembly installed in a vertical up-flow orientation. This assembly is not approved in that orientation, but that is just the beginning of the problem. The assembly is installed on a combined fire and domestic service in a medical facility. The assembly is installed prior to the splitting of the systems, which means the only thing separating the fire and domestic water is a single check valve installed at the beginning of the fire protection piping. It also must be noted that
the fire system contains chemical additives.

When I saw this installation, I reported that this was a high-health hazard situation that needed to be addressed as soon as possible. I am happy to report that, as you can see from the photos below, the system piping was corrected — the service was separated and the proper backflow protection was added to both the domestic and fire systems. It took several years to get the systems corrected.

Surveys are a vital part of any cross-connection program. They need to be completed on a regular basis and they need to be done thoroughly with re-inspections and documentation. The individuals conducting the surveys should be experienced and certified. Building owners and managers should not wait for issues or problems to occur before their system is inspected. They should also not wait for, or expect, the water purveyor or AHJ to inspect their properties for them. The responsibility of protecting the individuals living or working in their facilities rests with them. Now is the time to be proactive and have a survey completed. Backflow prevention is something that may not be exciting and flashy, but it is something incredibly necessary to protect public health.

The IAPMO Backflow Prevention Institute provides survey services for any size or type of facility. If you are interested in more information please contact us at ww.iapmobpi.org/survey-services or by phone at (855) 536-2800.