Report
to / Rapport au:
Planning
and Environment Committee
Comité de l'urbanisme et de
l'environnement
and Council / et au Conseil
Submitted
by/Soumis par: R.G. Hewitt,
Deputy City Manager / Directeur
municipal adjoint
|
Ref N°: ACS2008-PWS-WWS-0009 |
SUBJECT: Protection
of Municipal Drinking Water from Cross‑Connections
OBJET: protection de l’eau potable municipale
contre les jonctions fautives
That the Planning and Environment Committee recommend
Council direct staff to develop a Cross-Connection Control Program in
accordance with the parameters set out herein with a report back to Council on
the program and implementation details.
Que le Comité de l’urbanisme et de
l’environnement recommande au Conseil de demander au personnel ŕ élaborer un
programme de contrôle des jonctions fautives conformément aux paramčtres
énoncés dans les présentes et rédiger un rapport ŕ l’intention du Conseil au
sujet des détails du programme et de la mise en śuvre.
EXECUTIVE SUMMARY
The installation, operation, maintenance and
repair of private water systems pose a potential risk to the safety of the
municipal water supply due to the potential for back-flow of contaminated water
into the public system. Mandatory
installation of back-flow prevention devices on private service lines
represents an effective means to significantly mitigate that risk.
Staff has examined a variety of programs across Ontario and elsewhere, and reviewed industry guidelines including the Federation of Canadian Municipalities’ InfraGuide “Methodologies for Implementing A Cross-Connection Control Program”. The guide addresses cross-connections that may be present on both municipal and private property, and states that “…the municipality has a responsibility to implement a program to eliminate or minimize the potential for contamination to occur”.
Upon consideration of the various approaches
available and the suitability for Ottawa, staff recommends that:
§
Council provide policy support for the creation and
implementation of a Cross Connection and Control Program;
§
The program:
§
Is developed
and administered on a full cost recovery basis.
§
Focuses on
businesses, institutions and multi-residential buildings.
§
Excludes
low-density residential dwellings.
§
Be phased-in,
with the first 5-year period focused on perimeter/premise protection.
§
Public
consultations are carried-out with affected stakeholders and that staff return
to Council with an Implementation Plan.
This means that a business or institution with a single water service line would be required to install a backflow prevention device at the water meter. Businesses or institutions with more than one service line (e.g. campuses) would have to install a backflow prevention device on each service line at the perimeter of the property. This approach addresses the 2005 City Auditor General recommendations that the City implement a Cross-Connection Control program.
This report outlines the range of options
considered, the rationale for the recommended approach, and the next steps
required for implementation. Assuming
approval of this report, staff will bring forward recommended program details
and any necessary by-law amendments for approval in Q4, 2008.
RÉSUMÉ
L'installation, l'exploitation,
l'entretien et la réparation des réseaux privés de distribution d'eau
présentent un risque pour la salubrité de l'eau potable municipale en raison
des possibilités de refoulement d'eau contaminée vers le réseau public de
distribution. L'installation obligatoire de dispositifs antirefoulement sur les
conduites de branchement privées représente un moyen efficace de réduire
sensiblement ce risque.
Le personnel s'est penché sur divers programmes
qui ont cours en Ontario et ailleurs et a passé en revue les lignes directrices
de l'industrie, notamment l'InfraGuide intitulé « Méthodes de création
d’un programme de contrôle des raccordements croisés » de la Fédération
canadienne des municipalités.
Ce guide, qui porte sur les raccordements
croisés tant sur les terrains municipaux que sur des terrains privés, précise
que « c’est ŕ la municipalité qu’il incombe de mettre en śuvre un
programme visant ŕ éliminer ou ŕ minimiser toute possibilité de contamination. »
Aprčs avoir examiné les différentes
approches disponibles et leur applicabilité ŕ Ottawa, le personnel
recommande :
§
que le
Conseil donne un soutien de principe ŕ la création et ŕ la mise en śuvre d'un programme de contrôle des
raccordements croisés;
§
que ce
programme :
-
soit conçu et administré selon une formule de
recouvrement intégral des coűts;
-
porte principalement sur les immeubles commerciaux,
institutionnels et multirésidentiels;
-
exclue les immeubles résidentiels de faible densité;
-
soit mis en śuvre par étapes, la premičre étape de
cinq ans devant cibler l'isolement des périmčtres ou des locaux;
§
que des consultations publiques soient menées auprčs
des parties touchées, aprčs quoi le personnel présenterait un plan de mise en
śuvre au Conseil.
Cela signifie qu'une entreprise ou
une institution ayant une seule conduite de branchement serait tenue
d'installer un dispositif antirefoulement au niveau du compteur d'eau. Celles
qui ont plus d'une conduite de branchement (p. ex., le campus d'un
établissement d'enseignement) auraient ŕ en installer un sur chaque conduite ŕ
la limite de leur terrain. Cette mesure donnerait suite au rapport de 2005 du
vérificateur général, qui recommandait que la Ville mette en śuvre un programme
de contrôle des raccordements croisés.
Le présent rapport résume les diverses options envisagées, la
justification de l'approche recommandée et les prochaines étapes nécessaires
pour la mise en śuvre. Advenant l'approbation du rapport, le personnel
présenterait, au 4e trimestre de 2008, ses recommandations sur les
modalités du programme et les modifications réglementaires qui pourraient ętre
nécessaires.
BACKGROUND
In the
2005 Audit of Drinking Water Services, the City Auditor General made the
following recommendations regarding cross-connection control:
1. That the City “implement a Cross-Connection Control program in accordance with InfraGuide’s Best Management Practice of Methodologies for Implementing A Cross-Connection Control Program”.
2. That the City “develop a by-law that requires all private water systems with more than one connection to the City’s distribution system to have written maintenance procedures and requires prior notification to the City of any activities on the private water system that may impact water quality”.
A cross-connection is an actual or potential connection between a potable water system and any environment that would allow other substances to enter the water system, such as chemicals, water products, steam, water from other sources, and any matter that could change the quality, colour, taste or add odour to the water.[1] Backflow is the mechanism through which those other substances enter the potable water system as a result of a cross-connection.[2] Backflow can occur as a result of back siphonage (when negative pressure exists within the water system) or back pressure (when the building water pressure is greater than the water system pressure), as illustrated in Figure 1. The hazards consumers can be exposed to from cross-connections can create serious health risks, depending on the substance(s) that may backflow into the building or municipal water system.[3]
The Federation of Canadian Municipalities’ InfraGuide “Methodologies for Implementing A Cross-Connection Control Program” discusses the elements of a comprehensive program, and presents guidance for program development and implementation. The guide addresses cross-connections that may be present on both municipal and private property, and states that “…the municipality has a responsibility to implement a program to eliminate or minimize the potential for contamination to occur”.
The City’s Water By-law No. 2003-500 includes provisions for cross-connection control and backflow prevention, and allows the City to require the installation of a backflow prevention device. However, the definitions are limited and the requirements are not mandatory. This does not allow the City to adequately protect the central water supply from backflow and contamination from private systems. Refer to Attachment A for relevant excerpts from the Water By-law.
The Ontario Building Code, 2006 references CSA Standard B64.10.1-07 which addresses cross-connection control and backflow prevention in greater detail, but is only applied to new construction by the City’s Building Code Services Branch pursuant to the Building Code Act and Code. Some relevant aspects of the Building Code[4] include:
· Connections to potable water systems must be designed and installed to prevent backflow to the system;
· Premise isolation must be installed where a potentially severe health hazard could result from backflow into the central supply;
· Industrial processes connected to an internal plumbing system must be designed and installed so that the water supply system is protected against contamination; and
· Small residential buildings are exempt from the above unless they have access to an auxiliary water supply (e.g. well supply).
The Canadian Standards Association (CSA) has developed two standards intended as guides for the selection, installation, testing and maintenance of backflow prevention devices: CSA B64.10-07, “Selection and Installation of Backflow Preventers” (which is referenced in the Ontario Building Code); and CSA B64.10.1-07, “Maintenance and Field Testing of Backflow Preventers”. As with the Ontario Building Code, these guides are excellent as they pertain to new construction, but do not adequately address the challenges of retrofitting the existing building stock to ensure universal backflow prevention.
Numerous Ontario municipalities either have or are in the process of developing cross-connection control programs. Preliminary research has included an examination of the programs and by-laws for Guelph, Toronto, London, Kingston, Halton, Hamilton, Cambridge and Orillia (refer to Attachment C for further details). Staff has also examined the model by-laws proposed by the AWWA and the Ontario Plumbing Inspectors Association (OPIA). Findings have also been considered in the development of the recommendations presented in this report.
In summary, there is a strong regulatory and technical foundation upon which to develop a cross-connection program for the City. The key program design questions to be addressed at this stage are the following:
· Should the City focus on protecting the potable water supply, or seek to protect the quality of water within individual buildings and campuses as well;
· Should the program focus on high-risk businesses and institutions, or make backflow prevention universally applicable to all Industrial, Commercial, Institutional (IC&I) and Multi-residential properties as defined by the CSA Standards; and
· Should the program have an on-going compliance monitoring and reporting requirement.
The next section of this report explores these issues and makes recommendations regarding the parameters to be used in developing a cross-connection program and the requisite amendments to the City’s Water By-law.
DISCUSSION
Program Approach
The Canadian Standards Association recommends alternative approaches and specific backflow prevention devices depending on the type of application and risk level. Figure 2 illustrates the approaches used to manage different situations.
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1. Property/Premise Isolation: Installation of a backflow prevention device on an incoming water service allows for protection of the municipal water supply from potential contamination from private water systems, and uses a minimum number of backflow preventers. For properties with more than one connection to the municipal water supply, backflow prevention devices are required at the property line at each connection point. This approach does not, however, protect those working at a facility from cross-contamination within the property.
2. Internal Protection: Installation of backflow preventers either on individual water usages (e.g. chemical feed pumps) or zones of usage (e.g. laboratories). This approach protects private water systems from internal contamination, but may not provide adequate protection for the municipal potable water system if used without premise isolation due to the complexity of industrial and commercial plumbing systems.
3. Combined Premise, Zone and Individual Protection: Installation of premise backflow preventers with additional device installed within a property to ensure that both the public and private potable water systems are protected from contamination.
Based on research findings and internal consultation, it is recommended that the City phase implementation, with the first five years focused on a property/premise approach to cross-connection control and backflow prevention.
This approach represents a significant undertaking and will satisfy the City’s responsibility to protect the municipal water supply from cross-contamination. Municipal communal well systems (e.g. Carp) will be included in the program, ensuring the same degree of protection for rural residents.
Once the Property/Premise Isolation program has been fully implemented, the City will examine the need to implement a Combined Approach (i.e. premise and internal protection) to further reduce risks associated with potential exposure to contaminants through private water systems (i.e. to users of water within a building or campus).
Program Scope
The Canadian Standards Association defines three categories of hazards for potential backflow (Severe, Moderate, and Minor), and recommends alternative approaches and devices suitable for each hazard rating[5]. For example, the guide identifies the following activities as posing a potentially “Severe” hazard: automotive shops, car washes, dental clinics, hospitals, laboratories, a wide range of manufacturing and water and wastewater treatment plants. “Moderate” hazard premises include apartment buildings, hotels/motels, schools and swimming pools.
The City has approximately 200,000 water billing accounts. The vast majority, approximately 190,000, are low-density residential accounts that will be excluded from the cross-connection control program as they represent a very low potential risk to the municipal water supply.[6] The program will target Industrial, Commercial, Institutional (IC&I) and Multi-Residential water accounts (refer to Table 1) in accordance with the hazard ratings identified by CSA. This could represent over 9,000 accounts, depending upon the final scope of the program. It is not possible to accurately estimate the number of “Severe”, “Moderate” and “Minor” hazard buildings at this time.
Table 1 – Ottawa’s
Industrial, Commercial, Institutional and
Multi-residential
Water Accounts
Building / Facility Type |
Zoning Codes |
No. of Accounts |
Potential Hazard Ratings[7] |
Commercial |
C1, C2, C3 |
4,792 |
Severe, Moderate, Minor |
Schools and Universities |
I1, I2, I3 |
482 |
Severe, Moderate |
Hospitals, Rehab and Nursing homes |
I4 |
133 |
Severe, Moderate |
Other Institutions |
I5 |
509 |
Severe, Moderate, Minor |
Industrial and Manufacturing |
M1, M2 |
131 |
Severe, Moderate |
Government and Private Offices (may include
Labs) |
OF |
443 |
Severe, Moderate |
Residential-Commercial |
RC |
739 |
Moderate, Minor |
Utilities |
UT |
7 |
Severe, Moderate |
IC&I Sub-total |
|
7,236 |
|
|
|
|
|
Apartments <5 Floors (>4 units) |
R7 |
214 |
Moderate, Minor |
Apartments >4 Floors |
R8 |
1,829 |
Moderate |
Residential Sub-total |
|
2,043 |
|
|
|
|
|
TOTAL |
|
9,279 |
|
It is
recommended that Severe and Moderate hazard buildings/properties, as defined by
CSA, be subject to the City’s Cross-Connection Control program as these pose
the greatest risk to the public water supply, for which Council is
responsible. This scope is recommended
by the Federation of Canadian Municipalities (FCM) InfraGuide and has been
implemented by several municipalities in Ontario.
Program
Implementation and Maintenance
The Ontario Building Code references CSA Standard B64.10.1-07 that specifies maintenance and testing requirements for backflow prevention devices. However, once a building passes the final building inspection and receives approval, the Building Code does not provide authority for the City’s Building Code Services Branch to re-enter the building at a later date to ensure that backflow prevention devices are maintained and tested in accordance with the Standard. This is primarily due to the legislation assigning on-going responsibility for buildings to the building owners and limiting the interference of proprietary rights to the time of construction, renovation or demolition of a building. The City therefore has no assurance that testing and maintenance activities are conducted as recommended, and the Building Code does not provide authority to inspect existing buildings for backflow prevention requirements.
As
noted previously, several other Ontario municipalities have or are in the
process of developing cross-connection control programs. At the heart of these programs is a By-law
providing the authority to:
· Enter premises for the purpose of inspecting for cross-connections;
· Require the completion of plumbing system surveys by approved professionals at the owner’s expense;
· Order the correction of cross-connections with appropriate backflow prevention devices;
· Enact enforcement actions for non-compliance; and
· Develop a certified installer and tester registry.
Accordingly,
it is recommended that the Cross-Control program allow the City to close the
regulatory gap regarding the on-going inspection, testing and maintenance of
backflow prevention devices.
The
By-law can also be used to dictate Cross-Connection Control program
requirements such as:
· Land use subject to program requirements;
· Frequency of cross-connection control surveys;
· Minimum mandatory level of protection (often premise isolation only, but some municipalities also include source or zone isolation);
· Training and certification requirements for professionals engaged in testing and maintaining backflow prevention devices;
· Testing frequency;
· Maintenance requirements;
· Reporting requirements; and
· Program fees for cost recovery.
Next Steps
InfraGuide’s
Best Management Practice recommends a stepped approach for Cross-Connection
Control program development and implementation. To date, staff has completed Steps 1 to 3 (general investigation
of cross-connection, investigation of program components and preliminary
planning/brainstorming). Step 4
involves obtaining preliminary approval to proceed, which is the purpose of
this report.
The following key issues must be addressed in developing the Cross-Connection Control program and Water By-law amendments:
· Degree of Support—Some municipalities place the onus on building owners to perform the water system surveys, and to install, test and maintain backflow prevention devices, while others choose to perform inspections and surveys for a fee. The division of private versus municipal responsibilities will be undertaken in consultation with the IC&I community to determine the most appropriate program design for Ottawa.
· Administrative Responsibility—One or more of the following arms of the City could administer this program: Water Division, Building Code Services, By-law Services and Ottawa Public Health. These groups will work together over the next several months to develop the program and to identify the most appropriate group(s) to administer the program.
Next steps will include identifying program design options, consulting with the IC&I community and internal stakeholders regarding program options, drafting a detailed implementation plan including detailed cost estimates, and preparing draft amendments to the Water By-law. Staff will report back to Committee and Council in Q 4 2008 with a complete Cross-Connection Control program and proposed modifications to the Water By-law for approval.
Estimated Program
Costs
Typical Staff Requirements: Initial research into cross-connection control programs at other Ontario municipalities revealed that staff requirements are generally limited to one full or part-time Program Coordinator (often a plumbing inspector or other similarly qualified person), 1 to 2 full or part-time Clerks for data management and general administrative duties, and up to 5 part-time inspectors. These requirements will vary dependant on program details such as level of service, phase in periods and risk mitigation needs.
Cost Recovery: Nearly all Ontario municipalities with cross-connection control programs charge fees for different elements of the program, including:
· Backflow Prevention Device Permit Fees;
· Test Tag Fees;
· Testing and Inspection Report Form Fees;
· Testing and Inspection Report Submission Fees;
· Backflow Prevention Device Tester Registration Fees; and
· Backflow Prevention and Cross-Connection Survey Fees.
Staff will examine these and other possible cost recovery mechanisms and develop a plan to fund the program on a full cost recovery basis. These details will be included in the Implementation Plan report in Q 4 2008.
RURAL IMPLICATIONS
The implications for the rural community are limited to the rural communities serviced by the municipal potable water system and/or municipal communal well systems.
CONSULTATION
To date
consultation has been conducted with Water and Wastewater Services (Customer
Services Division), Building Code Services, Ottawa Public Health and Legal
Services. Once approval for development
of a program is received, staff will promote the initiative and meet with
stakeholders to discuss program options.
Staff will report back to Council on the results of the consultation as
part of an implementation plan report.
This report has no 2008 budget implications. Detailed program costs, resource requirements and cost recovery mechanisms will be outlined in the follow-up report to Committee and Council in Q 4 2008.
Attachment 1 – Excerpts from the Ottawa Water By-law
Attachment 2 –
Excerpts from the Ontario Building Code, Chapter 7
Attachment 3 – Comparison of Ontario Cross-Connection Control By-laws and Programs
1. That Public Works and Services work in cooperation with Building Code Services Branch and Ottawa Public Health Branch to develop a Cross Connection Control program.
2. That Public Works and Services report back on the consultation results with specifics on implementation; detailing program design, costs (including cost recovery options), phasing risk mitigation and necessary supporting changes to Water By-law (2003-500).
DEFINITIONS
1. In this by-law:
“cross-connection” means the direct or indirect linking of the City’s
drinking water system to another drinking water system without the required
backflow prevention measures required by the Ontario Plumbing Code.
BACKFLOW PREVENTION
31. The Deputy City Manager may require installation of an approved backflow prevention mechanism on a private watermain or private water service.
32. Refrigeration equipment shall be designed, installed and operated such that no objectionable gases or coolant can enter the water distribution system.
33. No cross-connections shall be permitted.
1.4.1.2.(1)(b)
Backflow means a flowing back or reversal of the normal direction of the flow.
Backflow preventer means a device or a method that prevents backflow in a water distribution system.
Back-siphonage means backflow caused by a negative pressure in the supply system.
Back-siphonage preventer means a device or a method that prevents back-siphonage in a water distribution system.
7.1.2. Application
7.1.2.1. Application
(1) Except as
provided in Sentence (2), this Part applies to the design and construction
of plumbing.
(2) This Part
does not apply to industrial process systems unless the industrial process
system is interconnected with the plumbing system, in which case the
interconnection shall be so designed and installed so that the plumbing
system is protected against contamination or malfunction that may be caused
by the industrial system.
7.2.10.10. Back-Siphonage
Preventers and Backflow Preventers
(1) Except as
provided in Sentence (2) back-siphonage preventers and backflow
preventers shall be certified to,
(a)
CAN/CSA-B64.0, “Definitions, General Requirements and Test Methods for Vacuum
Breakers and Backflow Preventers”,
(b)
CAN/CSA-B64.1.1, “Vacuum Breakers, Atmospheric Type (AVB)”,
(c)
CAN/CSA-B64.1.2, “Vacuum Breakers, Pressure Type (PVB)”,
(d)
CAN/CSA-B64.2, “Vacuum Breakers, Hose Connection Type (HCVB)”,
(e)
CAN/CSA-B64.2.1, “Vacuum Breakers, Hose Connection Type (HCVB) with Manual
Draining Feature,”
(f)
CAN/CSA-B64.2.2, “Vacuum Breakers, Hose Connection type (HCVB) with Automatic
Draining Feature,”
(g)
CAN/CSA-B64.3, “Backflow Preventers, Dual Check Valve with Atmospheric Port
Type (DCAP)”,
(h)
CAN/CSA-B64.4, “Backflow Preventers, Reduced Pressure Principle Type (RP)”,
(i)
CAN/CSA-B64.5, “Backflow Preventers, Double Check Valve Type (DCVA)”,
(j)
CAN/CSA-B64.6, “Backflow Preventers, Dual Check Valve Type (DuC)”,
(k)
CAN/CSA-B64.7, “Vacuum Breakers, Laboratory Faucet Type (LFVP)”,
(l)
CAN/CSA-B64.8, “Backflow Preventers, Dual Check with Intermediate Vent Type (DuCV)”,
or
(m)
CAN/CSA-B64.10, “Manual for the Selection and Installation of Backflow
Prevention Devices”.
(2) Back-siphonage
preventers for tank type water closets shall be certified to
CAN/CSA-B125, “Plumbing Fittings”.
7.2.11.4. Required
Check Valve
(1) Where a water
service pipe is supplied with water by more than one drinking water
system, a check valve shall be installed at each connection with a drinking
water system.
(2) Where a fire
service main is supplied with water by more than one source, a check
valve shall be installed at each connection with a source of water.
7.4.2. Connections
to Drainage Systems
7.4.2.1. Connections
to Sanitary Drainage Systems
(1) Every fixture
shall be directly connected to a sanitary drainage system, except that,
(a)
drinking fountains may be,
(i)
indirectly connected to a sanitary drainage system, or
(ii)
connected to a storm drainage system provided that where the system is
subject to backflow, a check valve is installed in the fountain waste
pipe,
7.6.1.16. Thermal
Expansion
(1) Protection
against thermal expansion shall be required when a check valve is
required by Article 7.6.1.10., a backflow preventer is required by
Article 7.6.2.2., or a pressure reducing valve is required by Article 7.6.3.3
7.6.2. Protection
from Contamination
7.6.2.1. Connection
of Systems
(1) Connections
to potable water systems shall be designed and installed so that
non-potable water or substances that may render the water non-potable
cannot enter the system.
(2) No connection
shall be made between a potable water system supplied with water
from a drinking water system and any other potable water
system without the consent of the water purveyor.
7.6.2.2. Back-Siphonage
(1) Every potable
water system that supplies a fixture or tank that is not subject
to pressures above atmospheric shall be protected against back-siphonage
by a backflow preventer.
(2) Where a potable
water supply is connected to a boiler, tank, cooling jacket, lawn sprinkler
system or other device where a non-potable fluid may be under pressure
that is above atmospheric or the water outlet may be submerged in the non-potable
fluid, the water supply shall be protected against backflow by a backflow
preventer.
(3) Where a
hose bibb is installed outside a building, inside a garage, or where
there is an identifiable risk of contamination, the potable water system
shall be protected against backflow by a backflow preventer.
7.6.2.4. Backflow
from Fire Protection Systems
(1) A backflow
preventer shall not be required in a residential full flow through fire
sprinkler system, in which the pipe and fittings are constructed of potable
water system materials.
(2) Except as
required in Sentence (4), potable water system connections to
fire sprinkler and standpipe systems shall be protected against backflow
caused by back-siphonage or back pressure in conformance with the
following Clauses:
(a)
Residential partial flow through fire sprinkler systems in which the
pipes and fittings are constructed of potable water system materials
shall be protected by a dual check valve backflow preventer conforming
to CAN/CSA-B64.6.1, “Backflow Preventers, Dual Check Valve Type for Fire
Systems (DuCF)”,
(b)
Class 1 fire sprinkler/standpipe systems shall be protected by a single check
valve backflow preventer conforming to CAN/CSA-B64.9, “Backflow Preventers,
Single Check Valve Type for Fire Systems (SCVAF)”, provided that the systems do
not use antifreeze or other additives of any kind and all pipes and fittings
are constructed of potable water system materials,
(c)
Class 1 fire sprinkler/standpipe systems not covered by Clause (b) as well
as Class 2 and Class 3 fire sprinkler/standpipe systems shall be
protected by a double check valve backflow preventer conforming to
CAN/CSA-B64.5.1, “Backflow Preventers, Double Check Valve Type for Fire Systems
(DCVAF)”, provided that the systems do not use antifreeze or other additives of
any kind,
(d)
Class 1, Class 2 or Class 3 fire sprinkler/standpipe systems, in
which antifreeze or other additives are used shall be protected by a reduced
pressure principle backflow preventer conforming to CAN/CSA-B64.4.1,
“Backflow Preventers, Reduced Pressure Principle Type for Fire Systems (RPF)”,
installed on the portion of the system that uses the additives and the balance
of the system shall be protected as required by Clause (b) or (c),
(e)
Class 4 and 5 fire sprinkler/standpipe systems shall be protected by
a reduced pressure principle backflow preventer conforming to
CAN/CSA-B64.4.1, “Backflow Preventers, Reduced Pressure Principle Type for Fire
Systems (RPF)”,
(f)
Class 6 fire sprinkler/standpipe systems shall be protected,
(i) by a
double check valve backflow preventer conforming to CAN/CSA-B64.5.1,
“Backflow Preventers, Double Check Valve Type for Fire Systems (DCVAF)”, or
(ii) where
a potentially severe health hazard may be caused by backflow, by a
reduced pressure principle backflow preventer conforming to CAN/CSA-
B64.4.1, “Backflow Preventers, Reduced Pressure Principle Type for Fire Systems
(RPF)”, and
(g)
backflow prevention devices on fire sprinkler and standpipe systems shall be
selected and installed in conformance with Table 7.6.2.4.
Table
7.6.2.4.
Backflow Prevention Devices on Fire Sprinkler and Standpipe Systems
Forming
Part of Sentences 7.6.2.4.(2)
|
|
|
|
|
|
Column
1 |
Column
2 |
Column
3 |
Column
4 |
Column
5 |
Column
6 |
CSA
Standard Number |
Type
of Device(1) |
System
Made with Potable Water System Materials |
System
Not Made with Potable Water System Materials |
||
|
|
Minor
Hazard(2) Residential Partial Flow-Through System |
Minor
Hazard(2) Class 1 System |
Moderate
Hazard(2) Class 1, 2, 3 and 6 Systems |
Severe
Hazard(2) – Any Class of System in which Antifreeze or Other
Additives Are Used |
B64.6.1 |
DuCF |
P |
NP |
NP |
NP |
B64.9 |
SCVAF |
P |
P |
NP |
NP |
B64.5.1 |
DCVAF |
P |
P |
P |
NP |
B64.4.1 |
RPF |
P |
P |
P |
P |
Notes to Table 7.6.2.4.:
P– Permitted
NP– Not
Permitted
(1)The product
is only permitted for use on fire sprinkler and standpipe systems.
(2)Minor
Hazard, Moderate Hazard and Severe Hazard have the same meaning as indicated in
CAN/CSA-B64.10 “Manual for the Selection and Installation of Backflow
Prevention Devices”.
(3) The backflow
preventer required by Sentence (2) shall be installed upstream of the fire
department pumper connection.
(4) Where a
reduced pressure principle backflow preventer is required on the water
service pipe at a service connection located on the same premises as the fire
service main in Class 3, 4, 5 and 6 fire sprinkler/standpipe
systems, a reduced pressure principle backflow preventer conforming
to CAN/CSA-B64.4.1, “Backflow Preventers, Reduced Pressure Principle Type for
Fire Systems (RPF)”, shall also be provided on the fire service connection.
(5) Except as
permitted in Sentences (1) and (8), backflow preventers shall be
selected, installed and tested in conformance with CAN/CSA-B64.10 “Manual for
the Selection and Installation of Backflow Prevention Devices”.
(6) Backflow prevention
devices shall be provided in conformance with Sentence 7.2.10.10.(1).
(7) Tank type
water closet valves shall be provided with a back-siphonage preventer in
conformance with Sentence 7.2.10.10.(2).
(8) Buildings of residential
occupancy within the scope of Part 9 are not required to be isolated unless
they have access to an auxiliary water supply.
(9) In
addition to the backflow preventer required by this Subsection, for buildings
or facilities where a potentially severe health hazard may be caused by backflow,
the potable water system shall be provided with premise isolation by the
installation of a reduced pressure principle backflow preventer.
Attachment 3 –
Experience in Other Ontario Municipalities
Numerous Ontario municipalities either have, or are in the process of developing, cross-connection control programs (see the attached table). Preliminary research has included an examination of the programs and by-laws in Guelph, Toronto, London, Kingston, Halton, Hamilton, Cambridge and Orillia. Staff has also examined the model by-laws proposed by the AWWA and the Ontario Plumbing Inspectors Association (OPIA).
In general, the more advanced municipal programs researched to date rely on the risk based approach defined by the Building Code and the CSA Standards. There is, however, some variation between municipalities with respect to their approach to backflow prevention - some have elected to utilize Combined Premise, Zone and Individual Protection, while others have chosen to apply the Containment Theory (premise isolation) with the potential to require source or zone isolation in limited instances. Each approach leads to different program and staffing requirements, and different program costs, with the Combined Protection approach generally leading to expanded requirements and costs to building owners.
In all
cases, plumbing system surveys, installation, testing, maintenance and
reporting costs are the responsibility of the building owner (and/or tenant in
some instances). Most municipalities
require building owners to retain the services of certified private contractors
to complete the work, but some will complete plumbing system surveys.
Most programs also employ some form of direct cost recovery, including:
· Backflow Prevention Device Permit Fees;
· Test Tag Fees;
· Testing and Inspection Report Form Fees;
· Testing and Inspection Report Submission Fees;
· Backflow Prevention Device Tester Registration Fees; and
· Backflow Prevention and Cross-Connection Survey Fees.
Staff requirements vary from municipality to municipality, depending upon a number of factors[8]:
· Type of customers (bedroom community versus large industrial commercial component);
· Number of service connections;
· Type of program (e.g., premises isolation versus internal isolation);
· Plumbing inspection involvement (new construction, renovations, etc.);
· Survey of existing buildings by municipal staff or contracted services;
· Data management activities; and
· Enforcement required.
For the
municipalities assessed to date, staff requirements are generally limited to
one (1) full or part-time Program Coordinator (often a plumbing inspector or
other similarly qualified person), one (1) to two (2) full or part-time Clerks
for data management and general administrative duties, and zero (0) to (5)
part-time inspectors.
Comparison of Ontario Cross-Connection Control By-laws and Programs
By-law / Program Components |
OPIA Model |
AWWA Model |
Guelph |
London |
Toronto |
Hamilton |
Halton |
Cambridge
|
Kingston |
Orilla |
||
1 |
Authority and Administrative Responsibility |
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(a) |
Authority (as per by-law) · Municipality / City · Water Division / Utility / PW · Building Division |
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x |
x |
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x |
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x |
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x |
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x |
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x |
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x |
x |
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(b) |
Administration of the program · Water Division / Utility / PW · Sewer Use · Building Division |
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x |
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x |
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x |
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x |
x |
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x |
x |
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2 |
Service Policy |
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(a) |
Type of isolation required ·
Premise
isolation ·
Fixture
isolation (i.e., source or zone isolation) o Mandatory o May be required |
|
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x |
x |
x |
x |
x |
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x |
x |
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x |
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x |
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x |
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x |
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x |
x |
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(b) |
Mandatory premise isolation required for · Severe hazard (e.g. hospitals, laboratories, car washes) · Moderate hazard · Minor hazard |
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x |
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x |
x |
x |
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x |
x |
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x |
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x |
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x |
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x |
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x |
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x |
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(c) |
Other mandatory isolation requirements · Private water systems (with main >100mm) · Irrigation systems · Construction water · Fire systems · Fire hydrant permits · New residential water accounts (as part of meter package) · All bulk metered townhouses (at each service) · Wherever the municipality deems there is a risk · Where there is an auxiliary water supply · Where there are two or more Services |
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x |
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x |
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x |
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x |
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x |
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x |
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x |
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x |
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x |
x |
x |
x |
x |
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x |
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x |
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x |
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3 |
Ownership of Premise Isolation Backflow Assemblies |
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Municipality Building Owner |
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X(1) |
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x |
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x |
x |
x |
x |
x |
x |
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x |
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4 |
Inspection for Cross-Connections |
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· At any time, with reasonable notice · By municipality · By an approved company at owner’s expense |
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x |
x |
x |
x |
x |
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x |
x |
x |
x |
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x |
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x |
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x |
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5 |
Survey of Plumbing System |
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(a) |
At owner’s expense |
X |
|
x |
|
x |
|
x |
x |
|
x |
|
(b) |
All existing IC&I and multi-residential buildings · All commercial accounts |
x |
|
x |
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x |
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x |
x |
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x |
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(c) |
Must be completed by an authorized person |
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X |
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x |
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x |
|
(d) |
Required · Every 5 years · Every 3 years · Upon change of ownership or rezoning of property |
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x |
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x |
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x |
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x |
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x |
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x |
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x |
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(e) |
Reporting using standard form · Within 2 months · Within 30 days · Within 14 days |
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x |
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x |
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x |
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x |
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x |
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x |
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x |
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6 |
Selection and Installation of Backflow Prevention Devices |
|
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(a) |
In accordance with Building Code and CSA Standard B64 |
|
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|
x |
x |
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x |
x |
x |
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(b) |
Devices specified in By-law, depending on application |
|
x |
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(c) |
Building Permit · Is required · May be required |
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x |
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x |
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x |
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(d) |
Removal is prohibited without immediate replacement |
x |
|
x |
x |
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x |
x |
x |
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(e) |
Must be easily accessible |
|
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x |
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x |
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(f) |
All work at owner’s expense |
|
|
x |
x |
x |
|
x |
x |
x |
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(g) |
Must be located on-site, indoors or in a chamber |
|
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x |
x |
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7 |
Testing of Backflow Prevention Assemblies |
|
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|
(a) |
Completed by “approved person” at owner’s expense |
x |
x |
x |
x |
x |
x |
x |
x |
x |
|
|
(b) |
Completed · Upon installation and annually · Within 72 hours of cleaning or repairs · When device is relocated |
|
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x |
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x |
x |
x |
x |
x |
x |
x |
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|||
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x |
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x |
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(c) |
Test report submitted to municipality within 14 days · Within 10 days |
x |
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x |
x |
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x |
x |
x |
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x |
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(d) |
Test tag displayed on or adjacent to device |
x |
|
x |
x |
x |
x |
x |
x |
x |
|
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(e) |
Test method in accordance with CSA Standard B64 |
|
|
x |
x |
x |
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x |
x |
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8 |
Maintenance of Backflow Prevention Assemblies |
|
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(a) |
Completed by “approved person” at owner’s expense |
x |
|
x |
x |
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(b) |
In accordance with Building Code and CSA Standard B64 |
x |
|
x |
x |
x |
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(c) |
Written confirmation of failed test within 24 hours |
|
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x |
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(d) |
Repairs or replacement within · 5 days · 4 days / 96 hours · 48 hours |
|
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x |
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x |
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x |
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x |
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x |
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x |
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(e) |
At Owner’s Expense |
|
|
x |
x |
x |
x |
x |
x |
x |
|
|
9 |
Enforcement Action
|
|
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|
|
|
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|
(a) |
Notice allowing 14 days to provide access to premises |
|
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x |
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|
x |
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(b) |
Notice allowing 4 (or 5) days to complete testing of a device |
|
|
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x |
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|
x |
|
(c) |
Orders to correct cross-connections |
x |
x |
x |
x |
x |
|
x |
x |
x |
x |
|
(d) |
Shut off water supply · With notice (if owner fails to provide access to premises) · With notice (if owner fails to comply with an order) · With notice (if owner fails to test or maintain a device) · Without notice (immediate threat) |
|
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|
x |
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x |
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x |
|||
x |
x |
x |
x |
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x |
x |
x |
x |
|||
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x |
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x |
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x |
|||
x |
|
x |
x |
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x |
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|
x |
|||
(e) |
Penalties of up to $100,000 per violation |
|
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|
x |
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|
(f) |
Penalties of up to $5,000 per day for contravention of by-law |
|
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|
x |
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10 |
Risk Assessment |
|
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|
In accordance with Building Code and CSA Standard B64 |
x |
|
x |
x |
x |
x |
x |
x |
x |
|
|
All commercial accounts |
|
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|
x |
||
Original records retained on file (e.g. Survey Report) |
|
|
x |
x |
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|
x |
||
11 |
Training |
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Cross-connection control program administration |
|
|
x |
x |
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|
x |
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|
|
Cross-connection surveys and inspection |
|
|
x |
x |
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|
x |
|
|
||
Backflow-prevention assembly field testing |
|
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Backflow-prevention assembly repair |
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12 |
Certification |
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Testers · Certificate of Achievement in cross-connection control endorsed by the OWWA · Calibration certificate for the test equipment |
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x |
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x |
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x |
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x |
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x |
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x |
|||
13 |
Quality Assurance |
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|
(a) |
Review of performance of backflow-prevention assembly testers · Spot checking (auditing) · Comparing field test data with manufacturer’s data · Checking for proper completion of field test forms · Verifying tester’s certification is current |
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x |
x |
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x |
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x |
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x |
|
x |
|||
(b) |
Review of field test results to determine · If results are unsatisfactory · That replacement or repair is needed · If repair, replacement, relocation or modification has been done with municipal knowledge · That the device is improperly installed or in an improper application |
|
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x |
x |
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x |
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x |
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x |
x |
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x |
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x |
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(c) |
Monitoring of test equipment to ensure accuracy · Requiring that field test equipment be certified by independent laboratory · Checking the field-test equipment |
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x |
x |
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x |
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x |
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14 |
Record Keeping and Data Management |
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|
(a) |
Original documents retained on file · Permanent · One (1) year |
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x |
|
x |
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x |
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(b) |
Inventory of all backflow-prevention assemblies |
|
|
x |
x |
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x |
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|
(c) |
Test reports, etc., entered into database |
|
|
x |
x |
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|
x |
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|
|
(d) |
Correspondence retained on file |
|
|
x |
x |
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|
x |
|
x |
|
(e) |
Software is used to manage all data, work orders, etc. |
|
|
x |
x |
|
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x |
|
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|
15 |
Public Relations and Education |
|
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|
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|
|
|
|
(a) |
Website,
brochures, etc. |
|
|
x |
|
x |
|
|
x |
|
x |
|
(b) |
Public consultation for by-law development |
|
|
|
|
x |
|
|
x |
|
|
|
16 |
Backflow Incident Response Plan |
|
|
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|
|
A documented plan detailing how water quality complaints that indicate possible backflow contamination are to be investigated |
|
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|
17 |
Budget and Sources of Funding |
|
|
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|
|
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|
|
|
|
(a) |
Staff · One (1) plumbing inspector to administer program · One (1) water department staff member to coordinate program · One (1) full-time clerk for day-to-day, data entry, etc. · One (1) part-time clerk for day-to-day, data entry, etc. · Additional plumbing inspectors for inspections and surveys |
|
|
|
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|
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|
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|
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|
|
|
x |
x |
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|||
|
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|
x |
|||
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|
x |
x |
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|||
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|
x |
|||
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x |
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|||
(b) |
Cost recovery · No fees · Backflow prevention device permit fee (each) · Complete backflow prevention tester kit · Test tag fee (each) · Testing and inspection report forms · Testing and inspection report fee · Backflow prevention device tester registration (per tester, annually) · Backflow prevention and cross-connection survey |
|
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|
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|
x |
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|
x |
|||
|
|
$60 |
$36 |
$68 |
|
$55 |
$54 |
|
|
|||
|
|
|
$25 |
|
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|
|||
|
|
|
$9 to $27.50 |
|
|
$25 |
$28 |
|
|
|||
|
|
|
$7 |
|
|
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|
|||
|
|
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|
|
|
$75 |
|
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|||
|
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|
|
$100 |
$60 |
|
|
|||
|
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|
$100 |
|
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|
Notes:
(1) City of Toronto may supply a backflow prevention device.
Acronyms:
OPIA: Ontario Plumbing Inspectors Association
AWWA: American Water Works Association
[1] American Water Works Association (AWWA), 2004. “Recommended Practice for Backflow Prevention and Cross-Connection Control”, Manual of Water Supply Practices, M14, Third Edition.
[2] AWWA, 2004.
[3] InfraGuide, Oct. 2005. Best Management Practice – “Methodologies for Implementing A Cross-Connection Control Program”.
[4] Ontario Building Code, Chapter 7 – Plumbing. Refer to Attachment B for key excerpts.
[5] Canadian Standards Association (CSA), July 2007. CSA B64.10-07 “Selection and Installation of Backflow Preventers”.
[6] There will be a few exceptions, however, where backflow prevention will be required due to direct connection of a residential service to a trunk watermain.
[7] The City’s water billing account categories do not directly correspond to the various activities identified in the CSA Guideline, therefore the “Potential Hazard Rating” may not be identical to that identified in the Guideline.
[8] InfraGuide, Oct. 2005.