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HomeMy WebLinkAboutStaff Report 175-10TO: FROM: DATE: REPORT TYPE: SUBJECT: HONORABLE CITY COUNCIL CITY MANAGER MARCH 22, 2010 INFORMATIONAL DEPARTMENT: UTILITIES CMR: 175:10 Update on City's Cross Connection Control Program Compliance Efforts and Potential Water Service Interruption for Non -Compliant Customers This is an informational report and no Council action is required. BACKGROUND On October 15, 2008, the California Department of Public Health (CDPH), Division of Drinking Water and Environmental Management, performed a sanitary survey of the City's water distribution system. CDPH found the City's water system facilities to be in satisfactory condition, and noted several actions for the City to complete over the next two years to ensure water system safety. One of CDPH's requirements was that the City must ensure that all customers needing Backflow Prevention Devices (BPDs) had them installed. The purpose of the City' s backflow prevention or Cross Connection Control Program is to preclude contaminated water from entering the City's distribution system and contaminating the water supply. This program is mainly focused on commercial or industrial customers who conduct processes on their premises, or have connections to the water system that have the potential of allowing harmful agents to enter the system. Some examples of activities that require BPDs are: dry cleaning, metal plating, hospitals, medical, dental services, golf courses and the city's landscaping strips. Customers who have pressurized water systems or alternate water sources such as wells are also subject to this program. These may include residential customers. Section 7584, Title 17, California Code of Regulations lists the following required elements of the City's Cross Connection Control Program. (a) The adoption of operating rules or ordinances to implement the cross -connection control program, (b) The conducting of surveys to identify water user premises where cross -connections are likely to occur, (c) The provisions of backflow protection by the water user at the user's connection or within the user's premises or both, (d) The provision of at least one person trained in cross -connection control to carry out the cross -connection control program, (e) The establishment of a procedure or system for testing backflow preventers, and (f) The maintenance of records of locations, tests, and repairs of backflow preventers. U,Al.n 1 of 2 CDPH has mandated that all water systems in the City be in compliance with all cross connection regulations, including Title 17 of the California Code of Regulations and Utility Rule and Regulation 21(D), by December 15, 2010. The City reports on its progress towards this goal by submitting quarterly Program progress reports. In order to ensure compliance with these regulations, the City has sent a series of letters to water customers to assess the customer's property, identify BPD sites, and inform customers when BPD testing or installation is required. Many, but not all, customers have complied with applicable regulations. This informational report provides a summary of actions taken to date and potential future actions the City may need to take to ensure the safety of the City's potable water distribution system. As we proceed with Program enforcement, customer complaints may escalate. This may be an unavoidable consequence. DISCUSSION In April 2009, the City sent out a "Level of Hazard" survey to residential, industrial and commercial water customers. The "Level of Hazard" survey assesses potential hazards to the water system from operations on the customer's property and identifies sites where BPDs are already installed. The City sent the survey to 2,453 water customers and received 1,132 responses. However, 879 customers did not respond, and 442 surveys were returned unopened. FOLLOW-UP TO RESPONDENTS In June 2009, the City sent a series of letters to customers who had responded to the April 2009 letter but reported that they had potentially untested BPDs on their premises. Staff also sent a second letter to customers who had completed the survey and indicated that they had BPDs on site. This second letter informed them of the need to submit annual test results to the City to document the proper operation of their BPD. Lastly, staff sent a third letter to customers who had completed the survey and identified hazards on their properties that could contaminate the water system, yet who reported no existing BPDs. This letter informed these customers that they had to install a BPD within 90 days to be in compliance with Utility Rule and Regulation 21(D)(2)(E). In February 2010, a reminder letter was sent to the 189 customers who still had not installed a BPD. This letter required the customers to install the required BPDs by April 30, 2010 or risk service interruption. In February 2010, the City also sent a second notification to water customers with existing BPDs that have not provided a current test certification, giving them 30 days to provide a test report. If customers do not respond by the deadline, the City will have a contractor complete the testing and charge the customer for the expense. FOLLOW-UP TO 442 RETURNED UNOPENED SURVEYS Staff re -sent the survey letter to the 442 customers whose survey packages were returned unopened. This letter advised customers of the requirement to complete the survey. FOLLOW-UP TO 879 CUSTOMERS WHO FAILED TO RESPOND In April 2010, the City will send out a final survey request to the remaining 879 commercial water customers who have failed to respond to previous mailings. This letter requires non - responders to complete the survey within one month of the date the letter is received. If they do !`t\AD • 11 • 1 n Page 2 of 3 not complete the final survey, the City will hire a contractor to visit the properties and perform the survey at the customer's expense. If a BPD is required, the City will notify customers of this requirement with an additional letter indicating that they have 90 days to install a BPD. If they fail to do so within the allowed timeframe, water service to non -compliant customers will be interrupted until the BPD is installed and verified. RESOURCE IMPACT Existing staffing will be diverted to interrupt services for non -compliant customers and to turn services back on once the customer(s) is(are) in compliance, and manage the contracts for the survey and the testing. POLICY IMPLICATIONS This report is consistent with the Council's policy and program direction provided to staff regarding cross connection control and Strategy No. 7, "Implement programs that improve the quality of the environment". ENVIRONMENTAL REVIEW The actions summarized in this report do not meet the definition of a "project" pursuant to California Public Resources Code section 21065, thus no California Environmental Quality Act (CEQA) review is required. ATTACHMENT None. PREPARED BY: APPROVED BY: CITY MANAGER APPROVAL: ROLAND EKSTRAND Senior Project Engineer JOHN REINERT Water Distribution Supervisor MELISSA SMART Program Assistant GREG SCOBY WGW Engineering Manager OMM MARSHALL sistant Director, Utilities Engineering VALE Director, 'Ctilities Departm JAMEKEENE City anager CMR: 175:10 Page 3 of 3