Attachment_6_-_Previous_Cross-Connection_Survey_Memo_Report_FOR_REFERENCE.pdf

NCDOT HSP

Date: 4 November 2011

To: Earl Alexander – 5 CES/CEOIU Mark Turner – HQ ACC/A7OI

From: URS Group, Inc.

Perry Gayle, PhD, PE, LEED AP – Project Manager Shannon Clunn, PE – Deputy Project Manager Heidi Gilmore, PE – Site Visit Coordinator Bryan Burnitt, EI – Field Team Leader

Subject: Final Cross-Connection Control Survey Memorandum Report, Minot AFB Contract FA4890-05-D-0003 – Task Order 5012

1.0 Introduction

The purpose of this memorandum report is to provide Headquarters Air Combat Command (HQ ACC) and 5 CES/CEOIU a summary of findings from the Cross-Connection Control Survey performed by URS

Group, Inc. (URS) at Minot Air Force Base (AFB) under Contract FA4890-05-D-0003 – Task Order

5012, Air Combat Command Cross-Connection Control Survey. The field work was performed from 23

August – 3 September 2010.

This project was based upon the requirements contained within Air Force Instruction (AFI) 32-1066, Backflow Prevention Program, which requires Air Force installations to survey all facilities and water-using equipment and systems every five years. The goal of this project was to identify cross-connections, inventory existing backflow prevention assemblies (BFPAs), and recommend corrective actions to address unprotected cross-connections and to bring existing BFPAs into compliance with applicable Air

Force requirements. Testing of BFPAs was not included in this scope of work.

This memorandum report provides the cross-connection control survey regulatory background, survey methodology, inventory results, and recommended corrective actions.

2.0 Regulatory Background

AFI 32-1066 is the primary governing document for backflow prevention program implementation at Air

Force bases. It provides information related to backflow prevention and cross-connection control, BFPA inspection frequency and maintenance requirements, and BFPA testing certification procedures. It also adopts the Uniform Plumbing Code (UPC) and the UPC Illustrated Training Manual for most requirements related to BFPA inspection, testing, installation, repair, and replacement. According to

Unified Facilities Criteria (UFC) 3-420-01, Plumbing Systems, Air Force bases must also comply with the

URS Group, Inc.

1600 Perimeter Park Drive

Morrisville, North Carolina 27560 Telephone: 919.461.1100

Fax: 919.461.1415

Final Cross-Connection Control Survey Memorandum Report, Minot AFB URS Group, Inc.

4 November 2011

International Plumbing Code (IPC) for general plumbing system design (Naval Facilities Engineering

Command, 2009). When there are conflicts between AFI 32-1066, UPC, and IPC backflow requirements, the documents take precedence in the order listed.

According to AFI 32-1066, state drinking water regulations typically apply to Air Force bases if the regulations specifically apply to “public water systems,” as defined in the Safe Drinking Water Act.

However, because many state plumbing and building codes do not rely on the “public water system” designation, they typically do not apply to Air Force bases. Local regulations may apply to Air Force bases that purchase their water from a municipality or other water provider. When state and local regulations apply to an Air Force base, the base is required to comply with the more stringent requirements of the state/local regulations and AFI 32-1066. For determination of whether state and local regulations apply, base Civil Engineering and Bioenvironmental Engineering personnel should refer to the base Legal Office or Judge Advocate. Table 2-1 presents a comparison of AFI 32-1066 and North

Dakota (North Dakota Administrative Code [NDAC] Article 33-17, Chapter 01, Section 19) backflow prevention program requirements with respect to management and administration, operation and maintenance (O&M), recordkeeping, and specific requirements.

Minot AFB purchases water from the City of Minot Water Treatment Plant, and according to Mr. Dan

Jonasson, the Assistant Public Works Director for the City of Minot, an interconnection point must have an American Flow Series 2100 check valve1. The line supplying Minot AFB is protected by a check valve meeting these specifications. In other municipalities, it is customary and appropriate for interconnection points to be protected by a reduced-pressure principle assembly (RP). However, given the distance from the base’s interconnection to the next service connection outside the base, the occurrence of a backflow event from Minot AFB that would impact other water users outside of the base is highly unlikely, and the check valve should provide sufficient protection on that line. The Northwest Area Water Supply (NAWS)

Project is being considered as a secondary water source for the base. Interconnection to the NAWS system may require more robust backflow protection than the current connection with the City of Minot.

1 Personal communication, telephone conversation, 17 August 2010.

Table 2-1. Regulatory Comparison Table, Minot AFB

Cross-Connection Control Program AFI 32-1066 Requirements

North Dakota Regulations, NDAC Article 33-17, Chapter 01, Section 19

Requirements Category Component

Administrative Requirements

Approved/Required Guidance Documents

UPC, UPC Illustrated Training Manual, UFC 3-420-01 (requires compliance with IPC), AWWA M14, USC FCCCHR Manual, AFI 48-144

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Administrative Requirements

Backflow Preventer Approval

All BFPAs: Approved by IAPMO, USC-FCCCHR, or

ASSE

Fire Suppression System BFPAS: Approved and listed for fire protection use by Underwriters Laboratories, Inc.® or Factory Mutual Research Corporation.

Approved by the authority having jurisdiction.

Administrative Requirements

Cross-Connection Control Program

A program to identify, isolate, record, and correct cross-connections and other potential sources of distribution system contamination will be conducted in accordance with AFI 32-1066, Plumbing Systems. CE will maintain the inventory of cross connections and backflow prevention devices. At least every five years, the BEE reviews the inventory and assigns health hazard classifications for cross connections using guidance established in the latest edition of the UPC.

In addition, during construction design reviews, the BEE will recommend appropriate backflow prevention devices where equipment plumbed to potable water supplies is being installed (Per AFI 48-144).

Not specified.

Administrative Requirements

Review Plans

Review plans for new and modified water systems and facilities to identify potential cross-connections and verify that appropriate devices are specified and located.

Not specified.

Backflow Preventer Inspection

Frequency Develop schedule to inspect cross-connection areas annually.

Suitable protective devices must be installed, tested, and maintained to ensure proper operation on a continuing basis.

Backflow Preventer Installation Requirements

Accessibility

Device must be located within 1' to 5' above the floor or grade, at least 1' from the back wall, have at least 1' clearance above, and at least 2' clearance on the test cock side. A permanent platform must be provided for installations higher than 5'.

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Table 2-1. Regulatory Comparison Table, Minot AFB (Continued)

Cross-Connection Control Program AFI 32-1066 Requirements

North Dakota Regulations, NDAC Article 33-17, Chapter 01, Section 19

Requirements Category Component

Backflow Preventer Installation Requirements

Critical Water Systems

If the water use served by a BFPA is deemed critical by the BCE, install approved backflow preventers in parallel to allow maintenance/repair of the backflow preventers without system shutdown.

Not specified.

Backflow Preventer Installation Requirements

Fire Suppression System

- Design

Because pressure loss through a backflow preventer can degrade the effectiveness of a fire suppression system, design and submittal acceptance must ensure that the rated working flow rate of the backflow prevention device selected or installed meets the flow requirements of the system.

When there is a valid requirement to upgrade, install, or change a backflow device on a fire protection system, increased pressure losses and resulting lower flow rates must be considered. A registered PE must approve the design.

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Backflow Preventer Installation Requirements

Freeze Protection

Backflow assemblies and devices shall be properly insulated and protected from freezing.

Outdoor enclosures must comply with ASSE 1060 (per

IPC).

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Backflow Preventer Installation Requirements

Location Safety

1. Locate devices outside of areas containing toxic, poisonous, or corrosive fumes.

2. RPs and other venting devices shall not be installed immediately above electrical panel and chemical storage areas.

3. Relief ports, collector assemblies, and drainage piping connected to venting devices shall not be located in or drained to locations that potentially create flooding hazards.

Not specified.

Backflow Preventer Installation Requirements

Protective Enclosures

Install enclosures to secure exterior backflow devices serving critical or high-risk facilities. Enclosures should be designed to prevent tampering and introduction of contaminants to the water system.

Backflow devices serving only non-potable uses are excluded.

Not specified.

Table 2-1. Regulatory Comparison Table, Minot AFB (Continued)

Cross-Connection Control Program AFI 32-1066 Requirements

North Dakota Regulations, NDAC Article 33-17, Chapter 01, Section 19

Requirements Category Component

Backflow Preventer Installation Requirements

Relief Valve Drainage Drainage piping shall be twice the pipe diameter of the piping to the backflow device.

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Backflow Preventer Installation Requirements

Vertical Installation If a backflow device must be mounted in the vertical position, ensure that the device is rated and approved for vertical installation.

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Backflow Survey

Frequency

Conduct survey every 5 years or conduct an annual survey of 20 percent of the facilities and devices.

Conduct a survey of new buildings upon completion and prior to acceptance.

Not specified.

Backflow Survey

Implementation of Recommendations

Implement corrective actions identified during backflow survey. Immediate actions shall be taken to eliminate high cross-connection hazards.

Not specified.

Backflow Survey

Recordkeeping Requirements

Document survey results on AF Form 848, a CMMS, or state submittal forms. State forms or CMMS records must record information that is equivalent to the information on AF Form 848. Maintain inspection records and the status of installation and upgrade actions in a central location.

Not specified.

Backflow Survey

Survey Personnel Qualifications

Certification issued by the state or satisfactory completion of an approved training program.

Not specified.

Backflow Survey

Survey Tasks

Surveys shall include a detailed inventory of assemblies, identification of cross-connections, a description of water usage, classification of hazard, and selection of proper protection.

Not specified.

Backflow Preventer Inspection

Inspection Tasks

Inspect identified cross-connection locations to ensure that proper air gaps are maintained, BFPAs are in good condition and readily accessible, newly installed devices were installed correctly, devices have been properly insulated and protected against freezing weather conditions.

Table 2-1. Regulatory Comparison Table, Minot AFB (Continued)

Cross-Connection Control Program AFI 32-1066 Requirements

North Dakota Regulations, NDAC Article 33-17, Chapter 01, Section 19

Requirements Category Component

Backflow Preventer Inventory

Data Management BFPA information should be entered and managed via ACES-PM or other approved CMMS.

Not specified.

Backflow Preventer Inventory

Recordkeeping Maintain and update inventory records of all BFPA locations (AF Form 848) and copies of individual records (AF Form 845) for each assembly.

Not specified.

Backflow Preventer Testing

BFPA Tester Certification

Certification issued by the state or MAJCOM.

MAJCOM certifications expire after three years.

Not specified.

Backflow Preventer Testing

Frequency Testing should be conducted after installation, cleaning, repair, or relocation, and at least annually.

Suitable protective devices must be installed, tested, and maintained to ensure proper operation on a continuing basis.

Backflow Preventer Testing

Recordkeeping Record test data on AF Form 843 and AF Form 845, sate mandated forms, ACES-PM, or another approved

CMMS.

Not specified.

Backflow Preventer Testing

Testing Procedure Test in accordance with USC-FCCCHR Manual, manufacturer's instructions, or procedures recognized by the tester's certifying agency.

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Hazard Classification

Assign Hazard Classification

In conjunction with 5-year survey, new construction, or as needed. Use UPC and AFI 32-1066 to determine appropriate hazard level.

Not specified.

Roles and Responsibilities

Backflow Program Manager

Authorizes and assigns trained and certified BCE personnel or contractors to properly inspect, install, test, maintain, and repair backflow prevention devices, and to document actions on those devices. Identifies training needs and ensures that training is provided to assigned BCE personnel.

Not specified.

Roles and Responsibilities

Backflow Program Manager

Reviews all plans and drawings of new and modified water systems and facilities to identify potential cross-connections, and verifies that appropriate devices are specified and located. Requests BCE assistance as needed to address cross-connection and backflow issues.

Table 2-1. Regulatory Comparison Table, Minot AFB (Continued)

Cross-Connection Control Program AFI 32-1066 Requirements

North Dakota Regulations, NDAC Article 33-17, Chapter 01, Section 19

Requirements Category Component

Roles and Responsibilities

Backflow Program Manager

Manages a proactive backflow prevention program to prevent contamination of the potable water system.

Identifies, investigates, and documents all cross-connections. Responsible for following up corrective actions identified in the backflow prevention device and cross-connection survey and assisting technicians in addressing corrective actions.

Not specified.

Roles and Responsibilities

Base Bioenvironmental Engineer

Assigns, or ensures that qualified BE personnel are responsibly assigning, the correct hazard classification to each cross-connection using the UPC criteria and this AFI. Assists the BPM by recommending appropriate protection for each cross-connection to ensure that potable water quality is maintained.

Not specified.

Roles and Responsibilities

Base Bioenvironmental Engineer

Reviews plans of new and modified water and plumbing systems to identify and guard against cross-connections and other potential sources of contamination or pollution (AFI 48-101, Aerospace Medicine Operations). Provides BPM documentation of plan review findings, comments, and recommendations as needed.

Not specified.

Specific Hazards Building Containment In accordance with UPC, IPC, AWWA M14, and USC FCCCHR Manual.

Not specified.

Specific Hazards Fire Suppression Systems - Existing

1. Systems using only water are exempted from requirements for new systems if they met the existing requirements at the time they were installed.

2. Systems that use antifreeze, foam, or other hazardous chemicals shall be retrofitted with an RP.

3. When replacing or upgrading backflow protection on existing systems, or making significant modifications to the fire suppression system, install a DC on dry/wet fire suppression system that use only water.

Table 2-1. Regulatory Comparison Table, Minot AFB (Continued)

Cross-Connection Control Program AFI 32-1066 Requirements

North Dakota Regulations, NDAC Article 33-17, Chapter 01, Section 19

Requirements Category Component

Specific Hazards Fire Suppression Systems - New

In accordance with Chapter 6 of AWWA M14 in lieu of UPC.

1. Dry/wet fire systems that use only water (with or without a fire department connection) must have a DC.

2. Fire systems with antifreeze, foam, or other hazardous chemicals must have an RP.

Not specified.

Specific Hazards Hose Bibs In commercial, industrial, and recreational areas, install HBVBs (ASSE 1011-2004).

North Dakota Plumbing Installation Standards (references the

2009 UPC).

Specific Hazards Irrigation

Sprinkler and irrigation systems that include chemical injection or that include pumps, connections for pumping equipment, or auxiliary air tanks, or are otherwise capable of creating back-pressure must be protected with an RP (Per UPC).

Not specified.

Acronyms and Abbreviations:

ACES-PM – Automated Civil Engineering System-Project Management AF – Air Force ASSE – American Society of Sanitary Engineers AWWA – American Water Works Association BCE – Base Civil Engineer BEE – Bioenvironmental Engineering BPM – Backflow Program Manager CMMS – Computerized Maintenance Management System DC – Double check valve assembly HBVB – Hose bib vacuum breaker IAPMO – International Association of Plumbing and Mechanical Officials MAJCOM – Major Command PE – Professional Engineer USC FCCCHR – University of Southern California Foundation for Cross-Connection Control and Hydraulic Research

3.0 Cross-Connection Control Survey Methodology

The following sections present the survey field visit and data collection protocol, the data management approach, and the hazard and containment rationales used to determine hazard level.

3.1 Data Collection and Field Visits

The survey information presented in this report was collected by URS from 23 August – 3 September

2010 at Minot AFB. Prior to arriving on base, URS prepared a preliminary listing of facilities to be surveyed using the BFPA inventory (populated XC2® database), geographic information system (GIS) data, and Real Property information provided by the base. This preliminary listing of facilities was used as a starting point for identifying facilities likely to have a potable water connection and for scheduling daily survey activities. Additional information gathered on site was used to further refine and prioritize daily survey activities.

The facilities included on the survey list, when accessible, were surveyed by a URS field team to identify existing BFPAs (as listed in the BFPA inventory) and unprotected cross-connections within the scope of this project. Facility surveys included exposed water piping and point-of-use devices in accessible areas within the facility, as well as the area within a 100-foot radius surrounding the outside of the facility.

The following non-testable devices were not included in the scope of work for this survey:

Hose bib vacuum breakers (HBVBs) (low hazard) Laboratory sink vacuum breakers Atmospheric vacuum breakers (AVBs) Dual check valve devices (DuCs) Vented dual check valve devices (VDuCs) Other non-testable devices integral to food service, medical, and other commercial and industrial equipment

Additionally, the individual evaluation of the following equipment was not included in the scope of work for this survey:

Laboratory and mop sinks Toilets Urinals Low hazard food service and commercial equipment Low hazard equipment with built-in backflow protection Equipment drain lines Domestic laundry equipment

The non-testable devices and excluded equipment listed above are addressed with global recommendations in Section 4.0 of this report.

Field work was conducted by five one-person teams. Each survey team member participated in cross-connection control and backflow prevention training prior to conducting the survey. Each team used customized field survey forms for documentation of relevant data during the survey process. Copies of the blank field survey forms used are included as Attachment A. Identified BFPAs and cross-connections were tagged and photographed, when accessible, and were assigned a unique control number. When appropriate, URS used the control number previously assigned by the base. For cross-connections without a control number, URS created a new unique control number, which consisted of the building number followed by a hyphen and a consecutive numeral or letter (numerals were used for BFPAs; letters were used for unprotected cross-connections). For example, the first BFPA and unprotected cross-connection located at Building 100 would be labeled 100-1 and 100-A, respectively. Figures 3-1 and 3-2 provide examples of the tag types and numbering schemes.

Figure 3-1. BFPA Tag Figure 3-2. Unprotected Cross-Connection Tag

3.2 Data Management

After completion of the survey field work, the survey forms underwent an initial quality assurance/quality control (QA/QC) process. URS then entered inventory and survey results, as well as digital photographs, into the XC2® database, an off-the-shelf backflow management software program selected by HQ

ACC/A7OI. All surveyed testable BFPAs were entered into the database, along with unprotected cross-connections that require installation of a testable BFPA or a non-testable carbonated beverage dispenser vented dual check (CBD-VDuC) backflow preventer (BP). The data files necessary to populate the Minot

AFB XC2® database will be provided to both the base and HQ ACC with the final report.

3.3 Hazard and Containment Rationales

During the survey, URS characterized each cross-connection as either a high hazard or low hazard to determine appropriate protection using the definitions provided in AFI 32-1066. Low hazard is also defined as "pollution" and includes an impairment of the quality of the potable water to a degree that does not create a significant hazard to the public health, but that does adversely and unreasonably affect the aesthetic quality of potable water for potable use. High hazard is also defined as "contamination" and includes an impairment of the quality of the potable water that creates an actual hazard to public health through poisoning or through the spread of disease by sewage, industrial fluids, chemicals, or wastewaters. URS has developed a hazard ranking rationale to assist in assigning hazard rankings. A copy of this rationale is presented in Attachment B. This rationale was developed using AFI 32-1066 and a combination of available industry publications, including the UPC; the IPC; the American Water Works

Association (AWWA) Manual of Water Supply Practices – M14, Recommended Practice for Backflow

Prevention and Cross-Connection Control; and the Manual of Cross-Connection Control developed by the

University of Southern California Foundation for Cross-Connection Control and Hydraulic Research

(USC FCCCHR).

In addition, URS developed a containment rationale to assist in providing facility containment (i.e., backflow protection at the potable water service connection to a facility). The AWWA recommends that, in addition to the installation of BFPAs at each individual source of contamination (point-of-use or isolation), containment BFPAs be installed on the water service connection to high hazard facilities to isolate the entire premises from the potable water distribution system (AWWA, 2004). Facility containment recommendations made by URS during this project are based upon the containment rationale presented in Attachment B.

4.0 Inventory Results and Recommendations

The following sections provide the inventory results of the cross-connection control survey and the recommended corrective actions.

4.1 Inventory Results

A summary of the cross-connection control survey results is provided in Table 4-1. A total of 200 buildings with water service at Minot AFB were surveyed, resulting in the identification of 425 total protected and unprotected hazards. A total of 284 unprotected cross-connections were identified, of which

162 were considered to be high hazard. Attachment C provides a list of the buildings surveyed and their status (Table C-1) and a complete list of the cross-connections and BFPAs identified during the survey

(Table C-2).

Table 4-1. Summary of Cross-Connection Control Survey Results, Minot AFB

Survey Parameters Total Buildings evaluated 225

Buildings with water 200 Buildings without water 25

Unprotected cross-connections 284 High hazard cross-connections 162 Low hazard cross-connections 122

Installed testable BFPAs 141

Sub-total of hazards insufficiently protected with installed BFPAs 22 Hazards insufficiently protected with installed BFPAs 4 Installed BFPAs that are failing 18

BFPAs recommended for repair, relocation, or removal 72 BFPAs applied and installed appropriately, and cross-connections not requiring protection

Total number of cross-connections 425

Note: Subtotals in italics are not included in the totals in boldface.

4.2 Recommendations

The recommendations for installing, repairing, and replacing backflow preventers based on this survey were divided into seven distinct priority categories to assist the base in execution, either in phases or as funding becomes available. These priority categories are summarized in Table 4-2. The recommendations within five of the priority categories (Priorities 1, 2, 3, 4, and 5) are organized according to system type

(e.g., fire systems, heating and cooling, irrigation). The rationale URS developed for this survey suggests that all facilities (including administrative buildings) require a minimum of a double check valve assembly (DC) on the building water supply for containment protection. However, AFI 32-1066 does not require containment devices on administrative-type buildings, and it is unlikely that funding will be allotted for those recommendations. Therefore, low hazard containment recommendations have been put in a separate priority grouping.

A summary of recommendations and their budgetary cost estimates sorted by priority categories are provided in Table 4-3. These cost estimates are not detailed construction cost estimates, but rather are rough order of magnitude (ROM) cost estimates for installing, repairing, or replacing a hazard-appropriate BP on a cross-connection of a particular diameter. Detailed information on cost estimate development is included in Attachment D for reference. Additionally, detailed recommendations and cost estimates are listed by Priority Category in Attachment D (Table D-1). The table includes the following information:

Facility Number (Facility Num.)

Facility Name

Cross-connection Owner (CC Owner)

Cross-connection Number (CC ID)

Cross-connection Location (CC Location)

Hazard / Cross-connection

Degree of Hazard

Pipe Size (in)

Isolation or Containment

Existing Backflow Preventer Type (BP Type)

Existing Backflow Preventer Size in inches (BP Size (in))

Height (ft)

Priority Category

System Type

Deficiency

Recommendation

Cost of Unit

Cost of Labor

Additional Materials

Additional Labor

Freeze Protection

Total Cost (including overhead and profit)

Table 4-2 includes two additional priority categories (Priorities 6 and 7). Priority 6 addresses cross-connections outside of the scope of this survey and can be addressed by base-level personnel. Therefore, a cost estimate has not been developed for these recommendations. Priority 6 recommendations include the removal of cross-connections, installation and regular replacement of non-testable backflow prevention devices, installation of sufficient air gaps on equipment drainage lines, minor plumbing modifications, or the use of administrative controls to remove cross-connections (e.g., labeling hose bibs downstream of a

BFPA as “non-potable”). Priority 7 includes fire suppression systems with fire department connections

(FDCs) that are currently protected by a DC. The rationale URS developed for this survey considers these systems high hazard and requires an RP. However, AFI 32-1066 only requires a DC on these systems, and it is unlikely that funding will be allotted for upgrading the backflow prevention to an RP for this grouping. Therefore, no cost estimate has been developed for Priority 7. Table 4-4 lists the fire suppression systems with FDCs where a DC is installed.

It should be noted that the addition of a BFPA may cause a restriction in flow and reduction of water pressure at the point of installation, and this should be considered during installation of the BFPA. Proper hydraulic analysis must be conducted to ensure that installation of the recommended level of backflow protection does not compromise the ability of the water supply system to provide required flow and pressure for fire suppression systems in an emergency.

Table 4-2. Summary of Recommendation Priority Categories, Minot AFB

Priority Category Description Priority 1:

Install BFPAs, CBD- VDuCs, and Air Gaps on Unprotected Systems

This recommendation includes installation of BFPAs and air gaps on unprotected high and low hazard systems and CBD-VDuCs on unprotected carbonated beverage dispenser systems. There is no existing protection on these systems. This priority does not include unprotected fire suppression systems without chemicals.

Priority 2:

Replace BFPAs and CBD-VDuCs on Insufficiently Protected Systems

This recommendation includes replacement of existing backflow preventers that are providing insufficient protection. There is existing protection on these systems; however, it is not the appropriate level of protection.

Priority 3:

Repair/Relocate BFPAs on Protected Systems

This recommendation includes repair/relocation of existing BFPAs. The existing BFPA provides adequate protection; however, it has been improperly installed or modified in a manner that is inappropriate based on regulatory and industry guidance for installation of BFPAs (e.g., installed too high or otherwise difficult to access for testing and operations and maintenance).

Priority 4: Install BFPAs on Fire Suppression Systems without Chemicals

This recommendation includes installation of BFPAs on unprotected fire suppression systems without chemicals (including systems with FDCs).

Priority 5: Install Containment BFPAs on Unprotected Low Hazard Facilities

This recommendation includes installation of BFPAs on the main supply lines for unprotected low hazard facilities. The building containment rationale recommends installing a DC on these supply lines; however, such protection is not required by AFI 32-1066 unless applicable state and local regulations require it. Funding for this priority is unlikely unless state and/or local regulations support it. For Minot AFB, this protection is not required per NDAC Article 33-17, Chapter 01, Section 19.

Priority 6:

Global Recommendations

These recommendations are related to removal or prevention of cross-connections that can be completed by base personnel and that were not included in the scope of work for this survey.

Replace non-testable backflow prevention devices at least every three years, due to the possibility of failure associated with the prolonged use of these devices. This includes HBVBs; AVBs on industrial sinks, mop sinks, and other equipment; VDuCs on low hazard equipment; integral DuCs; and other non-testable devices integral to food service, medical, and other commercial and industrial equipment.

Provide sufficient air gaps for ice machine and other equipment drain lines. Air gaps should be twice the diameter of the drain line but no less than 1 inch.

Remove hose bibs from locations where they have the potential to interfere with the supply of water to an emergency eyewash or shower.

Table 4-2. Summary of Recommended Priority Categories, Minot AFB (Continued)

Priority Category Description Priority 6:

Global Recommendations (Continued)

Protect the fill lines to all pressure washers, industrial floor scrubbers (zamboni-type), and other portable equipment hard-piped to the potable water system with adequate air gaps or RPs, and implement standard operating procedures. Personnel should be trained to use designated protected fill points when appropriate.

Provide portable RPs for all construction, lawn care, and other contractors that need to connect to a fire hydrant for water supply.

Ensure that the RPs are installed and supported properly and provided with adequate freeze protection when in use. These RPs should also be tested on an annual basis.

Replace yard hydrants with “sanitary” yard hydrants and ensure that each sanitary yard hydrant is equipped with a HBVB at the hose connection. Sanitary yard hydrants drain into a sealed tank below the frost line to prevent freezing, rather than draining directly into the soil like conventional yard hydrants. Draining into a tank prevents cross-contamination of the drained water with the soil.

Ensure that the following equipment is properly protected with an integral backflow preventer or appropriate non-testable device:

o Laboratory and mop sinks (built-in AVB, laboratory faucet vacuum breaker) o Toilets (air gap, flush valve vacuum breaker, anti-siphon ball cock hose connection) o Urinals (flush valve vacuum breaker) o Low hazard food service and commercial equipment (built-in backflow protection varies with equipment – ensure that it meets manufacturer’s specifications) o Equipment drain lines (air gap) o Domestic laundry equipment (air gap)

Replace each single-walled heat exchanger with a double-walled heat exchanger with leak detection and interstitial monitoring capability (located in the space between the two walls). In the interim, an RP should be installed on the potable water supply line to the unit. For such systems, an RP has been recommended, as appropriate, in Priority 1.

Ensure that hand-held eyewash equipment connected to flexible hose maintains an adequate air gap, and install a VDuC as secondary protection in the case that the air gap is compromised by the operator.

Ensure eyewash stations are equipped with independent water connections to ensure adequate pressure and eliminate potential sources of contamination.

Properly label potable and non-potable water piping.

Label as non-potable all hose bibs on the downstream side of a backflow preventer.

Table 4-2. Summary of Recommended Priority Categories, Minot AFB (Continued)

Priority Category Description Priority 6:

Global Recommendations (Continued)

Install VDuCs on all hose bibs where spray nozzles may be used.

Hose bib vacuum breakers are not rated for continuous pressure, such as would be exerted by a downstream spray nozzle.

All hoses attached to sink faucets should be removed when not in use.

It is recommended that all RP units be installed horizontally;

however, according to AFI 32-1066, approved units include those certified by the American Society of Sanitary Engineers (ASSE).

Therefore, if an RP unit installed vertically is approved by ASSE for vertical installation, no recommendation was made for it in this survey. However, when the unit is replaced in the future, it is recommended that the base consider reconfiguring for horizontal installation.

Ensure the policy of providing make-up water to boilers and chillers from a tank truck is not circumvented. Specifically, make-up water to boilers and chillers must not be provided by direct connection to the potable water system through a hose bib using a hose of any kind. AVBs on hose bibs do not provide sufficient protection for the high hazard cross-connection formed using a hose to supply make-up water to a boiler or chiller.

Ensure that BFPAs on all systems except fire suppression systems have an upstream wye strainer installed to reduce debris entering and interfering with the operation of the BFPA.

Priority 7: Fire Suppression Systems with FDCs Protected by DCs

This priority category includes fire suppression systems with FDCs that are currently protected by DCs. URS recommends installing RPs on these systems because the FDC provides the opportunity for water of unknown, and potentially hazardous, quality to be introduced to the system under pressure; however, AFI 32-1066 only requires a DC.

Table 4-3. Summary of Recommendations and Cost Estimates, Minot AFB

Recommendations by Priority Category Number of Units Total Cost

Priority 1: Install BFPAs, CBD-VDuCs, and Air Gaps on Unprotected Systems 116 $498,355

Carbonated Beverage Dispensers 4 $2,342 Containment on High Hazard Facilities 65 $385,617

Heating and Cooling systems 4 $10,060 Industrial Water Usages 15 $36,213

Irrigation 1 $8,009 Kitchen Equipment 18 $34,931 Medical Equipment 1 $530

Miscellaneous 8 $20,653 Priority 2: Replace BFPAs and CBD-VDuCs on Insufficiently Protected Systems 22 $104,259

Containment 5 $34,762 Heating and Cooling systems 14 $33,628

Industrial Water Usages 1 $1,316 Irrigation 1 $17,728

Fire Suppression System with Contaminant 1 $16,825 Priority 3: Repair/Relocate BFPAs on Protected Systems 72 $292,769

Containment 4 $2,137 Heating and Cooling systems 27 $59,100

Industrial Water Usages 5 $24,459 Irrigation 5 $25,930

Kitchen Equipment 1 $403 Medical Equipment 2 $2,044

Fire Suppression System with Contaminant 3 $103,014 Fire Suppression Systems with FDC 16 $66,393

Miscellaneous 9 $9,289 Priority 4: Install BFPAs on Fire Suppression Systems without Chemicals 49 $975,097

Fire Suppression Systems with FDC 49 $975,097 Fire Suppression Systems without FDC 0 0

Priority 5: Install Containment BFPAs on Unprotected Low Hazard Facilities 119 $394,214

Total 378 $2,264,694

Table 4-4. Priority 7 Fire Suppression Systems with FDCs Protected by DCs, Minot AFB

Control Number

Facility Number Facility Name Hazard Type

140-1 140 Bowling Center Fire Suppression System W/ FDC 156-1 156 Education Center/ Library Fire Suppression System W/ FDC 156-2 156 Education Center/ Library Fire Suppression System W/ FDC 166-1 166 Child Development Center Fire Suppression System W/ FDC 185-1 185 Dormitory - Honor Guard Fire Suppression System W/ FDC 186-2 186 Shoppette Fire Suppression System W/ FDC 221-2 221 Dormitory Fire Suppression System W/ FDC 246-2 246 Commissary Fire Suppression System W/ FDC

248-3 248 Base Exchange Fire Suppression System W/ FDC and Pumps

270-1 270 Burger King Fire Suppression System W/ FDC 286-1 286 David Jones Youth Center Fire Suppression System W/ FDC 286-2 286 David Jones Youth Center Fire Suppression System W/ FDC 292-2 292 J. R Rockers Fire Suppression System W/ FDC

455-1 455 Gymnasium/ Indoor Pool Fire Suppression System W/ FDC and Pumps

537-1 537 Hardened Intersite Cable System Facility Fire Suppression System W/ FDC 543-3 543 Vehicle and Equipment Section Fire Suppression System W/ FDC 544-1 544 Dispatch Center Fire Suppression System W/ FDC 545-1 545 Vehicle Barn Fire Suppression System W/ FDC 547-1 547 Simonson Center/ Security Forces Fire Suppression System W/ FDC 686-2 686 Propulsion System Rocket Engine Storage Fire Suppression System W/ FDC 758-1 758 Dock 9 Fire Suppression System W/ FDC 837-3 837 Dock 5/ Wash Rack Fire Suppression System W/ FDC 848-1 848 Operations Facility Fire Suppression System W/ FDC 862-1 862 Dock 2/ Corrosion Control Fire Suppression System W/ FDC 870-1 870 Communications Fire Suppression System W/ FDC 896-1 896 Fire Department Fire Suppression System W/ FDC 980-1 980 Conventional Munitions Maintenance Fire Suppression System W/ FDC

1133-1 1133 Missile Assembly Shop Fire Suppression System W/ FDC 1142-1 1142 Pylon Loader Adapters Maintenance Fire Suppression System W/ FDC

References

AWWA, 2004. Recommended Practice for Backflow Prevention and Cross-Connection Control. Manual of Water Supply Practices – M14, 3rd ed. Denver, CO: AWWA.

HotBox, 2010. Contractor’s Net Price List 2010. Effective 1 July 2010. Jacksonville, FL: HotBox.

Available at http://www.hot-box.com/catalog/HotBox_Catalog.pdf (accessed November 2010).

International Association of Plumbing and Mechanical Officials (IAPMO), 2006. Uniform Plumbing

Code. Ontario, CA: IAPMO.

IAPMO, 2009. Uniform Plumbing Code. Ontario, CA, USA: IAPMO.

International Code Council (ICC), 2006. International Plumbing Code. Country Club Hills, IL: ICC.

ICC, 2009. International Plumbing Code. Country Club Hills, IL: ICC.

LMI Marketing, LLC. Heat Trace Cables. http://www.heattracecables.com/Heat_Trace_Cable_ pipe_tank.asp (accessed November 2010).

Naval Facilities Engineering Command, 2009. UFC 3-420-01, Plumbing Systems, with Changes 1-8

(original publication 25 October 2004). Washington, DC: Department of Defense. Available at http://www.wbdg.org/ccb/DOD/ UFC/ufc_3_420_01.pdf

North Dakota Department of Health, 2005. NDAC, Article 33-17 (NDCC 61-28.1-03), Public Water

Supply Systems. Revised April 1, 2005. Bismarck, ND: North Dakota Century Code.

North Dakota Department of Health, 2010. NDAC, Article 62-03.1 (NDCC 43-18-09), Plumbing

Installation Standards, Amended effective April 1, 2010. Bismarck, ND: North Dakota Century

Code.

R.S. Means Company, Inc., 2010. R. S. Means Site Work and Landscape Cost Data. Kingston, MA: R.S

Means.

Secretary of the Air Force, 2007. AFI 32-1066, Backflow Prevention Program. Washington, D.C.: Air

Force Departmental Publishing Office. (17 October 2007).

Sloan Valve Company, 2010. Product Listing. Available at http://www.sloanvalve.com (accessed

November 2010).

T&S Brass and Bronze Works, Inc., 2010. Product Listing. Available at http://www.tsbrass.com

(accessed November 2010).

USC FCCCHR, 1993. Manual of Cross-Connection Control. 9th edition. Los Angeles, CA: USC

FCCCHR.

Watts, 2010. Watts 2010 Price List – Water Safety, Flow Control, and Backflow Prevention Products.

Effective 1 March 2010. Available at http://media.wattswater.com/PL-WR.pdf (accessed

November 2010).

Acronyms and Abbreviations

A7OI Civil Engineering Operations Division, Infrastructure Support Branch ACC Air Combat Command ACES-PM Automated Civil Engineering System-Project Management AFB Air Force Base AF Air Force AFFF Aqueous film-forming foam AFI Air Force Instruction AIRGAP_REQ Air gap required ASSE American Society of Sanitary Engineers AVB Atmospheric vacuum breaker AWWA American Water Works Association BCE Base Civil Engineer BEE Bioenvironmental Engineering BFPA Backflow prevention assembly BFPA_REQ Backflow prevention assembly required Bldg Building BP Backflow preventer BPD Backflow prevention device BPM Backflow Program Manager C Contaminant CBD Carbonated beverage dispenser CBD – VDuC Carbonated beverage dispenser vented dual check valve backflow preventer CC Cross-connection CES Civil Engineer Squadron CEOIU Civil Engineer Operations – Infrastructure – Utilities CMMS Computerized maintenance management system CSA Canadian Standards Association DC Double check valve assembly DCDA Double check detector assembly DC_REQ Double check valve assembly required DuC Dual check valve device DUALC_V_REQ Dual check valve with atmospheric vent (for carbonated beverage dispensers) required FDC Fire department connection FSS Fire suppression system

ft. Feet FY Fiscal year GIS Geographic information system H High hazard HBVB Hose bib vacuum breaker HQ Headquarters HQ ACC Headquarter Air Combat Command HVAC Heating, ventilation, and air conditioning HW Hot water rated IAPMO International Association of Plumbing and Mechanical Officials ICC International Code Council ID Identification

in. Inches IPC International Plumbing Code

L Low hazard LEED AP Leadership in Energy and Environmental Design Accredited Professional MAJCOM Major Command Mech Mechanical MSA Munitions Storage Area N/A Not applicable NAWS Northwest Area Water Supply NDAC North Dakota Administrative Code NDCC North Dakota Century Code NDT Non-destructive testing NRS Non-rising stem O&M Operations and maintenance O&P Overhead and profit OSY Outside screw and yoke P Pollutant PE Professional Engineer POL Petroleum, oils, and lubricants PVB Pressure vacuum breaker QA/QC Quality assurance/quality control ROM Rough order of magnitude RP Reduced-pressure principle assembly RPDA Reduced-pressure detector assembly RP_REQ Reduced-pressure principle assembly required SOV Shut-off valve SVB Spill resistant vacuum breaker TC Test cock UFC Unified Facilities Criteria UPC Uniform Plumbing Code URS URS Group, Inc.

USC FCCCHR University of Southern California Foundation for Cross-Connection Control and

Hydraulic Research VDuC Vented dual check valve device WSA Weapon Storage Area

Attachments

Attachment A Blank Cross-Connection Control Survey Forms Attachment B Hazard Ranking Rationale and Containment Rational Attachment C Cross-Connection Control Inventory Results Attachment D Cross-Connection Control Recommendations and Cost Estimates

Statement of Limitations This report was prepared in accordance with the customary thoroughness and competence of environmental science and engineering consulting professionals and in accordance with the standard for professional services for a national consulting firm at the time these services were provided. The analysis, conclusions, and recommendations expressed in this report were developed based upon a limited scope of services and the information made available to URS at the time this work was conducted.

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Attachment A

Blank Cross-Connection Control Survey Forms

Final Cross-Connection Control Survey Memorandum Report, Minot AFB Attachment A

A-1

Figure A-1. Cross-Connection Control Survey Form: Facility

A-2

Figure A-2. Cross-Connection Control Survey Form: Hazard (front)

A-3

Figure A-3. Cross-Connection Control Survey Form: Hazard (back)

Attachment B

Hazard Ranking Rationale and Containment Rationale

Final Cross-Connection Control Survey Memorandum Report, Minot AFB Attachment B

B-1

Table B-1. Backflow Prevention Hazard Ranking Rationale

Cross-Connection Type P/C1 L/H2

Recommended Type of

Backflow Preventer Rationale Source3 Comments

Arc welders, water cooled, closed loop system

C H RP (ASSE 1013) Recirculating water cooler systems contain chemicals such as antifreeze, coolants, and/or corrosion inhibitors, which are contaminants and elevate the hazard to high.

Pump pressure elevates the challenge on the BFPA by creating backpressure.

AWWA M14,

Chapter 5 (pg 67)

No comments.

CBD C H RP (ASSE 1013)

CBD-VDuC

(ASSE 1022)

Air Gap

Potential leaching of metals from pipes due to carbonation elevate the hazard to high.

Pump pressure elevates the challenge on the BFPA by creating backpressure.

UPC, Section 603.4.12

IPC, Section 608.16.1

No comments.

Boilers and heaters feed/make-up water lines (with or without chemicals)

C H RP (ASSE 1013) Toxic metals potentially leached from the heating system piping through continued recirculation are a contaminant and elevate the hazard to high.

Chemicals such as corrosion inhibitors are also potential contaminants.

Recirculation pump pressure elevates the challenge on the BFPA by creating backpressure.

UPC, Sections

603.3.6 and 603.4.10

No comments.

Booster pump: Priming funnels for booster pump systems

C H Cover and signage Cover and place sign that says “Potable water system priming funnel. Do not add chemicals”.

N/A This recommendation represents an attempt to prevent potentially hazardous chemicals from being introduced into potable water systems. Booster pump priming funnels often resemble chemical addition funnels for boilers or chillers and should be clearly labeled and covered to prevent a hazardous mix up.

Chemical feed system for building heating/cooling systems

C H RP (ASSE 1013) Chemicals added to cooling/heating systems, corrosion inhibitors, biocides

AWWA M14,

Chapter 5 (pg 67)

No comments.

Closed-looped water cooling for diesel engines or other equipment

C H RP (ASSE 1013) Chemicals such as antifreeze and corrosion inhibitors are contaminants and elevate the hazard to high.

Pump pressure elevates the challenge on the BFPA by creating backpressure.

AWWA M14,

Chapter 5 (pg 67)

No comments.

Table B-1. Backflow Prevention Hazard Ranking Rationale (Continued)

B-2

Cross-Connection Type P/C1 L/H2

Recommended Type of

Backflow Preventer Rationale Source3 Comments

Cooling system:

Cooling towers and chillers

C H Air Gap

RP (ASSE 1013)

Chemicals such as corrosion inhibitors and biocides are contaminants and elevate the hazard to high.

AWWA M14,

Chapter 5 (pgs 63-64, 67)

The BFPA or air gap should be placed on the supply line to the water reservoir.

Additional piping to/from the equipment not requiring BFPAs are the supply return and overflow lines.

Cooling system:

Evaporative coolers (“swamp coolers”)

C H RP (ASSE 1013) Integral air gaps are often defeated due to drainage port clogged with scale and miscellaneous debris.

High hazard similar to that of non-potable water storage tanks.

Backsiphonage potential; continuous pressure potential; backpressure potential depending on placement of RP and if unit is located on facility roof.

AWWA M14,

Chapter 5 (pgs 63-64, 67)

No comments.

Decontamination room water supplies

C H RP (ASSE 1013) Contamination AWWA M14, Chapter 5 (pgs 63-64)

No comments.

Dishwasher, commercial

C H RP (ASSE 1013)

PVB/SVB (ASSE

1020/1056)

Detergents and automatic injection systems elevate the hazard to high.

Generally backsiphonage potential only.

AWWA M14,

Chapter 5 (pgs 65-66

USC FCCCHR

Manual, 5.2.12

No comments.

Fire sprinkler system4:

with chemicals with or without FDC single or multistoried

C H RPDA (ASSE

1047)

RP (ASSE 1013)

Chemicals such as antifreeze, corrosion inhibitors, and AFFF are contaminants and elevate the hazard to high. This includes systems that may be exposed via an FDC to chemicals in fire trucks.

AFI 32-1066,

Section C, 6.6.1

UPC, Section 603.4.16.3

No comments.

Fire sprinkler system4:

with or without chemicals single or multistoried with FDC single or multistoried

P/C H RPDA (ASSE

1047)

RP (ASSE 1013)

Fire trucks may introduce chemicals or non-potable water sources into the system via the

FDC.

UPC, Section 603.4.16.2

IPC, Section 608.16.4

AFI 32-1066 states that water-only systems with or without an FDC only require a DC.

However, both the IPC and the UPC require an RP on systems with FDCs. URS recommends RPs on all fire suppression systems with FDCs.

B-3

Type P/C1 L/H2

Recommended Type of

Backflow Preventer Rationale Source3 Comments

Fire sprinkler system4:

without chemicals without FDC single or multistoried

P L DCDA (ASSE

1015)

DC (ASSE 1015)

Water could contain bacteriological contamination, but chlorine residual in distribution system would minimize impact to the public.

AFI 32-1066,

Section…