HomeMy WebLinkAboutDDW-2025-009333
Zion Red Rock
Water System
Culinary Water Cross Connection
Control Plan
JUNE 16, 2025
FOR:
Zion Red Rock Retreat, LLC
5513 West 11000 North #222
Highland, UT 84003
BY:
ProValue Engineering, Inc.
20 South 850 West, Suite 1
Hurricane, UT 84737
PROJECT LOCATION
Contents
I. Policy Purpose ....................................................................................................................................... 1
II. AUTHORITY ........................................................................................................................................... 1
A. APPLICABLE FEDERAL LAWS ............................................................................................................. 1
B. STATE REGULATIONS/CODES ........................................................................................................... 1
C. LOCAL ORDINANCES ........................................................................................................................ 1
III. PROCEDURES AND NOTIFICAIONS ................................................................................................... 2
A. ANNUAL BACKFLOW ASSEMBLY TESTING POLICY ........................................................................... 2
B. CROSS CONNECTION CONTROL ONSITE SURVEY POLICY ................................................................ 3
C. BACKFLOW ASSEMBLY TESTING POLICY ON “FAILED” TEST REPOSRTS .......................................... 4
IV. SELECTION OF BACKFLOW PREVENTION METHODS AND ASSEMBLIES .......................................... 5
A. DEGREE OF HAZARD ......................................................................................................................... 5
B. METHODS OF PROTECTION ............................................................................................................. 5
V. RECORD KEEPING .................................................................................................................................. 7
VI. TRAINING ......................................................................................................................................... 7
VII. PUBLIC EDUCATION ......................................................................................................................... 7
APPENDIX A ................................................................................................................................................. 12
APPENDIX B ................................................................................................................................................. 14
APPENDIX C ................................................................................................................................................. 17
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I. Policy Purpose
This policy serves as a dynamic framework to enforce and implement Zion Red Rock Water System
Cross-Connection Control and Backflow Prevention. The Cross Connection Control Coordinator, within
the Zion Red Rock Water System, will diligently execute this policy to the best of their abilities.
Cross-connections pose a significant risk to the Zion Red Rock Water Distribution System and its users.
Preventing backflow through the elimination or protection of cross connections is a top priority for Zion
Red Rock Water System.
Zion Red Rock Water System Cross-Connection Control Program is designed to fully comply with Utah
Drinking Water Rule 309-105-12, Utah Plumbing Code, and the Clean Drinking Water Act.
II. AUTHORITY
Federal, state, and local laws, codes, and ordinances establish the Company’s responsibility for
the establishment and enforcement of an on-going cross-connection control program and for
the water user’s responsibility to install and maintain on-site plumbing systems in compliance
with applicable codes and regulations.
A. APPLICABLE FEDERAL LAWS
Federal Public Law 104-182 outlines public water departments’ “responsibility of public
water system[s] to protect quality of water to consumers.” This complies with the US
EPA Cross Connection Control Manual, which states the importance of the water
purveyor providing water that complies with all EPA standards at the source, and deliver
it to the customer without the quality being compromised as a result of its delivery to
the customer. The 1974 Safe Drinking Water Act, with the Amendments of 1996,
requires “water systems are responsible to protect the quality of water to the last free-
flowing tap or point of protection from any contamination”.
B. STATE REGULATIONS/CODES
Utah Code Section 19-4-112 (2d) states that there will exist “no cross connection
between potable and non-potable water systems.” In addition, cross connection control
procedures are given in the Utah Administrative Code R309-105-12, stating the
importance of implementing cross control prevention practices, and following standard
procedures that will protect against a compromise to the potable water supply.2
C. LOCAL ORDINANCES
Zion Red Rock Water System Code Chapter 10.07 Cross Connection Control and Backflow
Protection (see Appendix A) provides the local authority for enforcing potable water
protection by means of cross connections throughout the water system. It sets forth
requirements for water users, and promotes the reasonable elimination or control of
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cross connections to assure water system safety. This Program provides Zion Red Rock
Water Resources personnel with the authority to administer the program, enter facilities
to conduct hazard assessments, and enforce backflow prevention assembly testing
requirements.
III. PROCEDURES AND NOTIFICAIONS
A. ANNUAL BACKFLOW ASSEMBLY TESTING POLICY
Zion Red Rock Water System will endeavor to issue timely notifications to all registered
contacts regarding required annual testing of backflow assemblies. However, failure to
receive these notifications does not exempt property owners or responsible parties
from the obligation to ensure that all backflow assemblies are tested annually as
mandated by local laws.
General Testing Requirements: Backflow prevention assemblies must be tested within
10 business days of installation, relocation, or repair, and annually thereafter, by a
Certified Backflow Technician. Backflow prevention assembly testing at more frequent
intervals may be required, as determined by Zion Red Rock Water System. Submitted
test reports must follow the format approved by Zion Red Rock Water System.
Notification Process
Initial Notification: Notification letters or emails will be sent at the beginning of the
month when testing is due. For instance, an assembly tested in July 2023 will be notified
on July 1, 2024, with testing and reporting due by the end of that month.
Second Notification: If testing or reporting is not completed, a second notice will be sent
on or around the 1st of the following month.
Third Notification: If compliance is still not met, a third notice will be issued on or
around the 15th of the following month. For instance, an assembly due for testing in
July 2024 will receive the third notification on or around August 15, 2024.
Fines and Penalties
There are no fines set up because this water system is owned by one company.
Water Shutoff Notice
A 10-day water shutoff notice will be issued at the beginning of the fourth month of
noncompliance. For example, if testing is due in July 2024, the shutoff notice will be sent
in early October 2024. Water service will not be restored until full compliance is
achieved.
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EXAMPLE: Backflow assembly was last tested in July 2023 and is due for annual testing
July 2024.
July 1 - First Notification
August 1 - Second Notification (out of compliance)
August 15 - Third Notification and first Non-Compliance Fine issued
September 1 - Second Non-Compliance Fine issued
September 15 - Third Non-Compliance Fine issued
October 1 - Shutoff Notice issued
October 15 - Water services are terminated
Non-Compliance notices continue until compliance is achieved.
B. CROSS CONNECTION CONTROL ONSITE SURVEY POLICY
Cross Connection Control Onsite Surveys, also known as hazard assessments, are critical
for identifying and mitigating risks to the public drinking water system. Zion Red Rock
Water System officers and employees must have access to all premises receiving water
during reasonable hours to conduct these assessments. The presence of the owner or
representative is required during the survey, and thorough documentation will be
maintained.
Failure to grant access for hazard assessments, address unprotected cross-connections,
or comply with backflow prevention requirements may result in water service
termination or the imposition of maximum backflow protection measures.
Notification Process
Initial Notification: A post hazard assessment letter will be mailed or emailed as quickly
as possible following the onsite assessment. Typically this will be issued with a 30-day
notice to bring the water user to compliance.
Second Notification: If compliance is not achieved, a second notice will be issued 30
days following the initial notification.
Third Notification: If compliance is not achieved, a third notice will be issued 45 days
following the initial notification.
Fines and Penalties
A fine of $100 per assembly or cross-connection violation will be issued on or around 45
days following the initial notification if testing or reporting remains incomplete.
A second fine of $100 per assembly or cross-connection violation will be issued on or
around 60 days following the initial notification if testing or reporting remains
incomplete.
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Continued non-compliance will result in additional fines issued biweekly until
assembly(s) or cross-connection violations are brought into compliance. Fines may be
issued at a more frequent interval as determined by Zion Red Rock Water Resources.
Water Shutoff Notice
A 10-day water shutoff notice will be issued 75 days after the hazard assessment, if the
facility/residence remains out of compliance. Water service will not be restored until full
compliance is achieved.
C. BACKFLOW ASSEMBLY TESTING POLICY ON “FAILED” TEST REPORTS
Backflow assembly test reports with a status of “Passed” must be furnished to Zion Red
Rock Water Resources within (30) calendar days of testing. Backflow assembly test
reports with a status of “Failed” must be furnished within five (5) business days of
testing.
If the assembly fails installation requirements described or has a testing status of
“Failed,” the user must arrange repairs with the manufacturer’s specified parts, in
accordance with the manufacturer’s suggested procedure, or have the assembly
replaced with the same type of backflow assembly. Following repairs or replacement,
the assembly must be tested again within ten (10) business days to verify that it is
meeting performance standards and has the status of “Passed.” Submitted test reports
must follow the format approved by Zion Red Rock Water System.
Notification Process
Initial Notification: A failed backflow assembly test report letter will be mailed or
emailed as quickly as possible following the receipt of a failed backflow assembly test.
This letter will include the requirement that the backflow assembly is to be replaced or
repaired, and then retested with a status of “Passed” within 10 business days after the
initial failed test. All letters or emails will be sent to Company employees and managers.
Second Notification: If compliance is not met, a second notice will be issued 15 days
following the initial notification.
Fines and Penalties
There are no fines set up because this water system is owned by one company.
Water Shutoff Notice
A 10-day water shutoff notice will be issued 60 days after the first notification of the
failed backflow assembly test report if the facility/residence remains out of compliance.
Water service will not be restored until full compliance is achieved.
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IV. SELECTION OF BACKFLOW PREVENTION METHODS AND ASSEMBLIES
When selecting backflow prevention methods and assemblies, it’s essential that water users, or
their designated professionals, thoroughly evaluate the degree of hazard associated with each
cross connection. This assessment should take into account the potential for backpressure or
backsiphonage.
Water users must ensure that the applicable plumbing code and water system codes are
referenced to determine the correct backflow prevention method or assembly for each situation.
This process is critical to maintaining compliance and protecting the integrity of the water supply.
A. DEGREE OF HAZARD
Degree of Hazard - the degree of threat to public health through a cross connection.
The two possible degrees are:
Health Hazard – a hazard arising from a Contaminant; and
Non-Health Hazard - a hazard arising from a Pollutant.
Below are the definitions for Contaminants and Pollutants:
• Contaminant - any substance introduced into the public drinking water system
which creates a threat to the public health such as poisoning, pathogenic
organisms, or any other public health concern.
• Pollutant - any substance introduced into the public drinking water system that
does not create a threat to the public health, but that does adversely and
unreasonably affect the aesthetic quality of the water.
Potential high-hazard locations, such as those with fire protection systems, irrigation
systems, carbonated beverage machines, chemical detergent dispensers, or industrial
water processes, should be documented to ensure they receive "high priority" during
cross-connection control onsite surveys. Additionally, locations with a history of
noncompliance should be documented and given the same "high priority" status.
B. METHODS OF PROTECTION
The table below from the 2021 International Plumbing Code, which is currently adopted
by the State of Utah with amendments, outlines the degree of hazard, types of backflow,
and approved methods of protection for backflow prevention devices and assemblies.
This table should be referenced in most situations, except where Sections 608.2 through
608.17.10 of the ICP or any current amendments adopted by the State of Utah specify
otherwise.
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DEVICE DEGREE OF HAZARD APPLICATION APPLICABLE STANDARDS
Double check backflow prevention assembly and double
check fire protection backflow prevention assembly Low Hazard Backpressure or backsiphonage Sizes 3/8"-16"ASSE 1015, AWWA C510,
CSA B64.5, CSA B64.5.1
Double check detector fire protection backflow prevenion
assemblies Low Hazard Backpressure or backsiphonage Sizes 2"-16"ASSE 1048
Pressure vacuum breaker assembly High or low hazard Backiphonage only Sizes 1/2"-2"ASSE 1020; CSA B64.1.2
Reduced pressure principle backflow prevention assembly
and reduced pressure principle fire protection backflow
assembly
High or low hazard Backpressure or backsiphonage Sizes 3/8"-16"ASSE 1013; AWWA C511;
CSA B64.4; CSA B64.4.1
Reduced pressure detector fire protection backflow
prevention assemblies High or low hazard Backsiphonage or backpressure (automatic sprinkler
systems)ASSE 1047
Spill-Resistant vacuum breaker assembly High or low hazard Backsiphonage only Sizes 1/4"-2"ASSE 1056; CSA B64.1.3
Antisiphon-type fill valves for gravity water closet flush tanks High hazard Backsiphonage only
ASSE 1002/ASME A112.
1002/CSA B125.12; CSA
B125.3
Backflow preventer for carbonated beverage machines Low Hazard Backpressure or backsiphonage Sizes 1/4"-3/8"ASSE 1022
Backflow preventer with intermediate atmospheric vents Low Hazard Backpressure or backsiphonage Sizes 1/4"-3/4"ASSE 1012; CSA B64.3
Backflow preventer with intermediate atmospheric vent and
pressure reducing valve.Low Hazard Backpressure or backsiphonage Sizes 1/4"-3/4"ASSE 1081
Dual-check-valve-type backflow preventer Low Hazard Backpressure or backsiphonage Sizes 1/4"-1"ASSE 1024; CSA B64.6
Hose connection backflow preventer High or low hazard Low head backpressure, rated working pressure,
backpressure or backsiphonage Sizes 1/2"-1"
ASME A112.21.3; ASSE
1052; CSA B64.2.1.1
Hose connection vacuum breaker High or low hazard Low head backpressure and backsiphonage Sizes
1/2", 3/4", 1"
ASME A112.21.3; ASSE
1011; CSA B64.2; CSA
B64.2.1
Laboratory faucet backflow preventer High or low hazard Low head backpressure and backsiphonage ASSE 1035; CSA B64.7
Pipe-applied atmospheric-type vacuum breaker High or low hazard Backsiphonage only Sizes 1/4"-4"ASSE 1001; CSA B64.1.1
Vacuum breaker wall hydrants, frost-resistant, automatic-
draining-type High or low hazard Low head backpressure or backsiphonage Sizes 3/4"-
1"
ASME A112.21.3; ASSE
1019; CSA B64.2.2
Air gap High or low hazard Backsiphonage or backpressure ASME A112.1.2
Air Gap fittings for use with plumbing fixtures, appliances, and
appurtenances high or low hazard Backsiphonage or backpressure ASME A112.1.3
Barometric loop high or low hazard Backsiphonage only (See Section 608.14.4)
Backflow prevention assemblies:
Backflow preventer plumbing devices:
Other means or methods:
TABLE x APPLICATION OF BACKFLOW PREVENTERS
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V. RECORD KEEPING
Physical or electronic documentation of all activities should be kept to ensure thorough
application of the cross connection control program including, but not limited to:
1. Inspection and testing results
2. Records of cross connection control surveys or inspections
3. Inventories and locations of assemblies and high hazard air gaps should be entered
into the Zion Red Rock Water System Map.
4. Test histories and inspection records of inventoried sites
5. Any backflow incidents, and any corrective actions taken
6. All compliance and enforcement actions
VI. TRAINING
At least one certified member of the Water system shall be designated as the Cross Connection
Control Coordinator and trained and certified as a backflow tester. The Cross Connection
Control Coordinator should be familiar with cross connection hazards, be familiar with locations
where potential hazards exist within the Water system, and be familiar with the approved
methods for preventing the occurrence of a backflow.
VII. PUBLIC EDUCATION
The Water system recognizes that it is beneficial to have water users educated on what cross
connections are, how they can be prevented, what types of protection are available, and the
concerns associated with thermal expansion*. Some educational strategies are:
▪ Hold public meetings and send notices to customers to educate the community about
the need for the program and how it may affect them.
▪ Inform water customers with newsletters, brochures, press releases, and the use of web
sites.
▪ Encourage the installers of the backflow assembly devices to educate their customers of
the hazards associated with cross connections.
▪ Make educational materials available to the public at public facilities and on the Water
system Website.
▪ During site and building inspections explain cross connection control to the owner or
resident of the inspected facility or building.
▪ Provide notices to owners of a scheduled cross connection control onsite survey dates
and any required corrective action.
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*An event that occurs when expanding water, such as in a water heater, has nowhere to go
because the backflow device creates a “closed system,” and may result in rupture or, in worst
cases, explosion of the water container.
VIII. ENFORCEMENT RESPONSE PLAN
If in the judgment of the Water system an approved backflow prevention assembly is required
at the customer’s water service connection or within the customer’s private water system for
the safety of the water system or, if violations of the Water system’s Cross-Connection Control
program exist, the designated agent of the Water system shall:
1. Give notice in writing to workers to immediately install or repair such approved backflow
prevention assembly(s) at specific locations(s) on their premises. Upon receiving such notice,
the customer shall immediately install or repair such approved assembly(s) at the customer’s
own expense.
2. Discontinue service of water to any premises if an unapproved cross connection is found or if
a Water system-approved backflow prevention assembly is not installed, tested, and
maintained, or if it is found that a backflow prevention assembly has been removed, bypassed,
or if any unprotected cross connection exists on the premises. Non-compliance fines will also
be issued if compliance is not achieved.
3. Failure, refusal, or inability on the part of the customer to install, have tested, or maintain
said assembly(s) shall constitute grounds for discontinuing water service to the premises until
such requirements have been satisfactorily met.
4. Once discontinued, the Water system shall not restore water service until such conditions or
defects are corrected in conformance with the state and water system statutes relating to
plumbing, safe drinking water supplies and the regulations adopted pursuant thereto.
IX. BACKFLOW INCIDENT RESPONSE PLAN
1. Purpose
The purpose of this Backflow Incident Response Plan is to establish a clear, organized, and
efficient procedure for responding to incidents involving backflow into the public water supply.
This plan aims to minimize potential health risks, ensure the safety of the water supply, and
comply with all relevant local, state, and federal regulations.
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2. Scope
This plan applies to all backflow incidents within the jurisdiction of Zion Red Rock Water
System. It includes actions to be taken by Water system personnel and any other relevant
stakeholders to mitigate and manage backflow events.
3. Incident Identification
3.1 Monitoring
• Continuous monitoring of water pressure and quality is conducted by the Water
system’s Water to detect any anomalies that may indicate a backflow event.
• Public complaints or reports of unusual water quality (e.g., discoloration, taste, or odor)
are also potential indicators of a backflow incident and should be investigated
immediately.
3.2 Initial Response
• Upon detection or notification of a suspected backflow incident, the first responder
(typically a Water Certified employee) will immediately notify the Incident Response
Team (IRT).
4. Incident Response Team (IRT)
4.1 Composition
The IRT will typically consist of the following personnel:
• Water Certified Employee
• Cross Connection Control Coordinator
• Public Information Officer
• Legal Counsel (if required)
• Emergency Services Public Information Officer (if required)
4.2 Roles and Responsibilities
• Water Superintendent: Oversees the response, coordinates actions, and ensures
compliance with regulations.
• Cross Connection Control Coordinator: Leads the technical assessment and determines
the source and extent of the contamination.
• Water System Information Officer: Manages communication with the public, media, and
other stakeholders.
• Legal Counsel: Advises on legal obligations and potential liabilities. Emergency Services
Public Information Officer: Coordinates with emergency services if the incident
escalates.
5. Immediate Actions
5.1 Isolation of Affected Area
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• Shut off water supply to the affected area to prevent further contamination.
• Isolate the suspected source of contamination by closing valves and employing backflow
prevention devices
5.2 Water Quality Testing
• Conduct immediate water quality tests to identify contaminants and determine the
severity of the incident.
• Samples should be taken from multiple points within the affected area to ensure
accuracy.
5.3 Notification of Affected Parties
• Notify affected residents and businesses of the backflow incident, advising them to
avoid using tap water for drinking, cooking, or bathing until further notice.
• Issue a boil water advisory or alternative safety instructions based on the nature of the
contamination.
5.4 Documentation
• Document all actions taken during the response, including timelines, communications,
and test results.
6. Remediation and Recovery
6.1 Source Identification and Elimination
• Identify the source of the backflow and take corrective actions to eliminate it, such as
repairing or replacing faulty backflow prevention devices.
6.2 System Flushing and Disinfection
• Flush and disinfect the water system in the affected area to remove any contaminants.
• Continue water quality testing to ensure the system is safe before restoring service.
6.3 Post-Incident Inspection
• Conduct a thorough inspection of the backflow prevention devices and other related
infrastructure to prevent future incidents.
7. Public Communication
7.1 Ongoing Updates
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• Provide regular updates to the public on the status of the incident, actions being taken,
and when normal water service is expected to resume.
• Use multiple communication channels, including the water system website, social
media, press releases, and direct notifications.
7.2 Final Notification
• Once the incident is fully resolved and water service is safe to use, issue a final
notification lifting any advisories and thanking the public for their cooperation.
8. Incident Review and Reporting
8.1 After-Action Review
• Conduct an after-action review to evaluate the response, identify lessons learned, and
implement improvements to the response plan.
8.2 Reporting
• Prepare a detailed incident report documenting the cause, response actions, outcomes,
and any recommendations for future prevention.
• Submit the report to relevant authorities, including state regulators, as required.
9. Training and Preparedness
9.1 Regular Training
• Conduct regular training exercises for the IRT and other relevant personnel to ensure
preparedness for backflow incidents.
9.2 Public Awareness
• Promote public awareness about the importance of backflow prevention and how
residents can help protect the water supply.
10. Policy Review and Updates
10.1 Annual Review
• The Backflow Incident Response Plan shall be reviewed annually and updated as
necessary to reflect changes in regulations, technology, or best practices.
This plan provides a comprehensive framework for managing backflow incidents, ensuring a
rapid and effective response to protect public health and safety.
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APPENDIX A
SITE MAP
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APPENDIX B
APPROVED BACKFLOW PREVENTION DEVICES
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Zion Red Rock Water System utilizes the University of Southern California Foundation for Cross
Connection Control and Hydraulic Research (FCCCHR) List of Approved Backflow Assemblies' as the
standard for selecting backflow assemblies. The most current list is available at the following link:
https://fccchr.usc.edu/list.html
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Examples of backflow prevention assemblies and devices
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APPENDIX C
REFERENCES
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Associated Organizations
Rural Water Association of Utah
Intermountain Section of the American Water Works Association
Rural Community Assistance Corporation Chapter of the American Backflow Prevention
Association Division of Drinking Water
University of Southern California Foundation for Cross Connection Control and Hydraulic
Research (FCCCHR)