How many of us remember US EPA’s rollout of the “Guidance Manual for Conducting Sanitary Surveys of Public Water Systems…” in April of 1999? At the time, many utilities believed it was a useful handbook toward discovering issues with the treatment and distribution systems. But unfortunately, it was ignored by many systems, because there was no regulatory incentive. Primacy agencies gave it limited attention, as it was not related to a federally funded mandate. The agencies were occupied with organic, inorganic, radiological, turbidity, and disinfection compliance matters.

As the calendar pages were turned, events compelled the regulators and water suppliers to pull the Manual from the bottom of the stack and give it a closer look. For example, September 11^th made people think about how a determined terrorist might attack our society. The water supply was and still is a vulnerable utility to ‘intentional’ cross connections. Unfortunately, backflow events have and continue to occur within the distribution systems. Organizations have conducted surveys and compiled event data to the point where regulators had to pay attention to what EPA had on its mind in 1999.

It is important to understand the focus of this EPA Manual. It is not necessarily a ‘how-to’ book when establishing a backflow prevention program for utility customers. It does not provide specifics on how to conduct quasi plumbing inspections, to protect water system users and their property.

The first focus of this document is to protect the potable water treatment, storage and distribution infrastructure. Twenty years after its publication, professionals today unfortunately look at much of the content and consider it outmoded. An example would be Figure 3-10. The text emphasizes the need for “non-return valves” on a gas feed system at the water plant. No backflow preventer is shown, such as a reduced pressure principle assembly. The non-return valves may have been considered a pressure reducing valve, ball valve or solenoid valve?

In section 3.2.4.10 of the Manual, there is an explanation of backpressure and backsiphonage. Examples are provided, such as a chemical feed system that may create pressures above the potable supply. Today, professionals would likely agree about the need for a reduced pressure principle assembly. The Sanitary Survey Manual identifies the need to maintain elevated supply pressure.

To its credit, the Manual does suggest the need to inspect several water uses inside the treatment facility. For example: ensuring a separation between filtered water and backwash water. Or another example for a surface water system is the possibility of a split feed on a chlorination system that may allow raw water to enter the clearwell’s finished water. Again, today’s recommended practice would incorporate the use of an RP assembly, but the US EPA Manual does not provide this specific direction.

Once the strategy to a cross-connection control plan is stated, including the need to label piping systems and determine the normal direction of flow in the pipe, the Manual advises that an inspector should have a copy of the 1989 edition of the USEPA Cross-Connection Control Manual or state manual equivalent for guidance on control measures.

The title of the US EPA document is Guidance Manual for Conducting Sanitary Surveys of Public Water Systems. The Manual is a good collection of things to think about, but here’s where it falls short. There is a serious lack of direction on specific cross-connection control measures.

To the Manual’s credit, there are important program elements provided. When you download the 432-page document, go to page 216. (The page number will appear as page 22 of Appendix B.) This last section of this appendix asks essential questions of the water supplier’s program. These include: 1) Does the supplier have a cross-connection control program? 2) Of the program components, is there an ordinance or bylaw(s) supporting the program? 3) Is there a public information or awareness effort for cross connection control? 4) What are the provisions for records storage, and what assurances are made of annual backflow preventer field tests? 5) Does the water supplier have the authority to enforce the rule or ordinance, and what are the penalties? 6) Has the supplier made an assessment of the actual/potential health and non-health hazards their users may present to the supplier? And has the proper protective measure been installed?

From the author’s perspective, these are essential questions that must be addressed by all public water supplies. It is not clear why the heart of the backflow prevention issue is located 200 pages to the back of the Manual.

The author recently attended a conference of utility professionals from the eastern United States. Their employers are directly regulated by the US EPA. These operations personnel all agreed that during the sanitary survey ‘audit/review’ process, the regulatory guidance was ‘all over the board.’ The utility representatives noted significant differences between EPA regions and requirements within the regions that varied with individual regulators. When protecting the public health through the potable water supply, there must be regulatory consistency. It’s not good practice for one individual to require a threaded hose bibb vacuum breaker and another regulator may require a reduced pressure principle assembly for the same application or use.

There is a need to update both of the USEPA manuals – Cross-Connection Control and the Guidance for Sanitary Surveys (PDF). These are downloadable documents. I urge you to take the time to review them and join others in asking EPA to modernize the aged documents.