TL 20250624 VSFB CCCPM for Submittal to DDWv2.pdf
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This is a Vandenberg Space Force Base (VSFB) Cross-Connection Control Manual supplement establishing policy and procedures for managing cross-connection control and backflow prevention (CCCBP) programs to protect the base's drinking water system. The manual applies to all units, DoD organizations, federal and state agencies, lessees, commercial customers, and residents connected to VSFB's drinking water system, which comprises 1,161 service connections (1,021 residential, 128 commercial, and 12 industrial) operated by American Water O&M, LLC.
The supplement implements requirements from the California State Water Resources Control Board's Cross-Connection Control Policy Handbook (CCCPH), adopted December 19, 2023, and mandates compliance with California Health and Safety Code sections 116407 and 116555.5. Key responsibilities are assigned to the 30th Civil Engineer Squadron (30 CES), with the Water Fuels Systems Maintenance unit serving as primary program manager. The manual establishes hazard assessment procedures conducted at 25 percent of facilities annually through 2030, mandates backflow prevention assembly (BPA) testing at installation, after repairs, and minimally annually, requires certified BPA testers per SWRCB-recognized organizations, and specifies inspection and testing schedules with field test kits certified annually. Cross-connection abatement timelines range from immediate for backpressure hazards to 120 days for low-hazard backsiphonage situations exceeding four inches in pipe size. The base maintains a Cross-Connection Management System (CCMS) database tracking BPA profiles, test histories, and compliance status. All contractors and independent agencies must designate user supervisors, maintain three-year test records, provide test results within 30 days, report high-hazard deficiencies within seven days and low-hazard deficiencies within 30 days, and immediately report suspected backflow incidents to American Water and the 30 CES Damage Control Center.
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BY ORDER OF THE COMMANDER
30TH CIVIL ENGINEER SQUADRON
VANDENBERG SPACE FORCE BASE
SUPPLEMENT 32-1067
23 JUN 2025
Civil Engineering
VANDENBERG SFB CROSS-
CONNECTION CONTROL MANUAL
COMPLIANCE WITH THIS PUBLICATION IS MANDATORY
ACCESSIBILITY: Publications and forms are available by request (michael.kalata.1@spaceforce.mil)
RELEASABILITY: There are no releasability restrictions on this publication.
OPR: 30 CES/CEIE
(Mr. Mike Kalata)
Supersedes: N/A
Certified by: 30 CES/CC
Pages: 21
This supplement applies to all units assigned or attached to Vandenberg Space Force Base (hereinafter referred to as Vandenberg SFB, Vandenberg, VSFB, or the Base), to include any Department of Defense (DoD) associate/tenant organizations, federal and state agencies, lessees, commercial customers, and residents (hereinafter referred to as Independent Agencies, or IAs)1 whose facilities or equipment is connected to the VSFB drinking water system. It supplements the Cross-Connection and Backflow Prevention portions of Department of the Air Force Manual (DAFMAN) 32-1067, Civil Engineering Water and Fuel Systems. This supplement establishes policy and provides further instruction and guidance in the local management of the Vandenberg SFB Cross-Connection Control and Backflow Prevention (CCCBP) Program pursuant to state regulations contained within the California Health and Safety Code (CHSC), sections 116407 and 116555.5 and established in the State Water Resources Control Board (SWRCB) approved Cross-Connection Control Policy Handbook (CCCPH) and conditions stipulated in the Vandenberg SFB water permit issued by the SWRCB Division of Drinking Water. Other applicable standards are referenced in the California Plumbing Code (CPC) and the Uniform Plumbing Code (UPC). Also, as defined in the CCCPH, Article 3, Section 3.3.3, Vandenberg SFB reserves the right to implement additional requirements beyond Department of the Air Force (DAF)
1 Independent Agencies are organizations or entities that are not under the direct supervision or control of the Vandenberg Cross Connection Control Program Manager.
VANDENBERG SFB
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 2 or state regulations regarding the CCCBP Program to further protect public health and to safeguard the Vandenberg SFB public water supply and system. This supplement applies to all drinking water systems located on VSFB property and its geographically separated units (GSUs).
Chapter 1 OVERVIEW 4
1.1. Purpose
1.2. Applicability
1.3. Program History
Chapter 2 ROLES AND REPONSIBILITIES 5
2.1. 30th Civil Engineer Squadron
2.2. American Water
2.3. Bioenvironmental Engineering
2.4. Balfour Beatty Communities
2.5. Contractors and Independent Agencies That Test Their Own BPAs
Chapter 3 GUIDANCE AND PROCEDURES 9
3.1. Achieving and Maintaining Compliance with this Supplement
3.2. Hazard Assessments
3.3. Legal Authority
3.4. Process and Time Frames for Inspections and Field Testing
3.5. Non-Testable Backflow Preventer Installation and Maintenance
3.6. BPA Field Tester Requirements
3.7. Backflow Incidents
3.8. Cross-Connection Management System
3.9. User Supervisor
3.10. Corrective Actions
3.11. Public Outreach
3.12. Coordination with Local Entities
Attachment 1— GLOSSARY OF REFERENCES AND SUPPORTING INFORMATION
Attachment 2—CCC SPECIALIST CERTIFICATE
Attachment 3—CROSS-CONNECTION SURVEY FORM
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 3
Attachment 4—AIR GAP AND BACKFLOW PREVENTER INSTALLATION GUIDANCE
Attachment 5—DAFMAN 32-1067
Attachment 6—LIST OF BPAs APPROVED BY FCCCHR
Attachment 7—BLANK BPA TEST FORM
Attachment 8—BACKFLOW INCIDENT FORM
Attachment 9—PUBLIC OUTREACH BROCHURE
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 4
Chapter 1
OVERVIEW
1.1. Purpose.
1.1.1. The primary goal of this supplement is to implement the Vandenberg SFB Cross- Connection Control and Backflow Prevention (CCCBP) Program and to ensure the potability and safety of the Base’s drinking water supply system. This supplement is also intended to meet compliance requirements pursuant to the SWRCB Cross-Connection Control Policy Handbook
(CCCPH).
1.1.2. The CCCPH was adopted by the SWRCB on December 19, 2023, and has been established to enforce standards applicable to California public water systems (PWS’s) to protect public health by ensuring that public drinking water distribution systems will not be subject to the backflow of liquids, gases, or other substances, in accordance with the CHSC, Section 11655(a)(2). The CCCPH applies to all California PWS’s as described in California Health and Safety Code (CHSC), Section 116275(h).
1.1.3. Vandenberg SFB owns and operates a PWS with 1,161 reported service connections and its operation is regulated by CCCPH requirements and its prescribed standards. As prescribed by the CCCPH, Vandenberg SFB is required to prepare and submit by 1 July 2025 a cross-connection control (CCC) plan stating how it will meet the requirements of the CCCPH. The CCCPH also requires that the CCC Plan be developed in consultation with a certified CCC specialist if the PWS has 1,000 or more service connections. Since the Vandenberg SFB water system has more than 1,000 service connections, it is required to develop the CCC Plan in consultation with a certified CCC specialist.
The certification of the CCC specialist involved in the preparation of this plan is included in Attachment 2. This supplement constitutes Vandenberg SFB’s CCC Plan. Table 1.1 provides a summary of Vandenberg SFB’s drinking water system.
Table 1.1. Drinking Water System Summary.
Item Description
Water system name: American Water O&M, LLC - VSFB Physical location 339 11th Street
Vandenberg SFB, CA 93437 Public water system number: CA4210700 Number of residential service connections:
1,021
Number of commercial service connections:
Number of industrial service connections:
1.2. Applicability.
1.2.1. This supplement applies to Vandenberg SFB and its GSUs that fall under the operation and maintenance responsibility of Vandenberg SFB. This supplement also applies to any Department of Defense (DoD) associate/tenant organizations, federal and state agencies, lessees, commercial customers, and residents whose facilities or equipment is connected to the VSFB drinking water system
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 5
1.2.2. To the extent this supplement or referenced playbooks conflict with applicable regulations and statutes, the regulations and statutes take precedence.
1.3. Program History.
1.3.1. In 1999, in accordance with (IAW) Air Force Instruction (AFI) 32-1066, Cross- Connection Control and Backflow Prevention, the 30th Civil Engineer Squadron (30 CES) initiated a comprehensive cross-connection (CC) survey of the entire Vandenberg SFB drinking water treatment and distribution system to satisfy the DAF requirement that the water system be surveyed every 5 years. The CC survey inspected and catalogued approximately 1,000 facilities and backflow assemblies on Vandenberg SFB and classified each system and assembly according to the hazard risk it posed to the water system. Based on the CC survey results, 30 CES corrected all identified deficiencies and developed an inspection and testing schedule to inspect and test all known assemblies as required by DAF and state regulations. A base-level Wing Instruction was also issued to ensure program continuity and uniformity of the testing and recordkeeping requirements for all facility and water system components. This included water system components operated and maintained by tenant and commercial agencies and contractors.
1.3.2. In 2007 30 CES conducted another comprehensive CC survey of the PWS. The contract included the development of a stand-alone computer and software system to track and schedule future CC surveys and the inspection, testing, repair, and establishment of the operational status of backflow prevention assemblies (BPAs) assigned to Vandenberg SFB. In addition, as a cost savings initiative, Vandenberg reduced the CC survey schedule to approximately 20 percent of the system annually with the goal of surveying the entire system by the end of each 5-year period. This change in survey schedule was adopted by the DAF as an alternative to the requirement to survey the system every 5 years. Rolling CC surveys continued to be conducted through 2015, when funding was curtailed due to budgetary constraints and funding reallocation. Backflow testing, inspections and reporting continued throughout that period and was in effect at the time this supplement was prepared IAW with DAF and state requirements.
Chapter 2
ROLES AND REPONSIBILITIES
2.1. 30th Civil Engineer Squadron.
2.1.1. The Base Civil Engineer will ensure the overall implementation and success of the Vandenberg SFB CCCBP Program.
2.1.2. Installation Management Flight (30 CES/CEI) will:
2.1.2.1. Ensure all applicable DAF, federal, state, and local regulations concerning the CCCBP are implemented and executed.
2.1.2.2. Assist the CES Operations Flight by providing guidance on applicable requirements, such as DAF, federal, state, and county regulations.
2.1.2.3. Assist the CES Operations Flight, as needed, to coordinate activities and communication with contractor organizations operating on Vandenberg.
2.1.2.4. Assist the CES Operations Flight to operate and maintain the Cross-Connection Management System (CCMS) database.
2.1.2.5. Serve as a point of contact (POC) for all official communications with American Water and the SWRCB as it relates to the CCCBP program.
2.1.2.6. Establish and publish technical policy and guidance through this supplement to base organizations.
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 6
2.1.3. The Operations Flight (CEO) Commander will:
2.1.3.1. Ensure all applicable DAF, federal, state, and local laws and regulations concerning the CCCBP are implemented and executed.
2.1.3.2. Ensure a base-wide CC survey is conducted every 5 years IAW DAFMAN 32-1067, para 4.3.5.8, or a continuous 20 percent rolling survey is conducted over a consecutive five-year period.
2.1.3.3. Ensure an adequate number of personnel are allocated for the CCCBP Program.
2.1.3.4. Ensure adequate funding is allocated for required training, certification, and recertification of CCCBP Program survey personnel.
2.1.4. Infrastructure Element (30 CES/CEOI) will:
2.1.4.1. Ensure the successful implementation of the Vandenberg SFB CCCBP Program.
2.1.4.2. Ensure a base-wide CC survey is conducted by Water Fuels Systems Maintenance (WFSM) (30 CES/CEOIU) every 5 years IAW DAFMAN 32-1067, para 4.3.5.8., or a continuous 20 percent rolling survey is conducted over a consecutive five-year period.
2.1.4.3. Ensure that an adequate number of personnel are properly trained and certified for backflow testing, cross-connection surveying, and program management.
2.1.5. Water Fuels Systems Maintenance Foreman (30 CES/CEOIU) will:
2.1.5.1. Ensure the successful implementation and management of the Vandenberg SFB CCCBP Program.
2.1.5.2. Ensure all applicable DAF, federal, state, and local laws and regulations concerning CCCBP are implemented and executed.
2.1.5.3. Ensure the records for BPAs are maintained and kept current.
2.1.5.4. Ensure a base-wide CC survey is conducted every 5 years IAW DAFMAN 32-1067, para 4.3.5.8., or a continuous 20 percent rolling survey is conducted over a consecutive five-year period.
2.1.5.5. Appoint a manager for the Vandenberg SFB CCCBP Program.
2.1.5.6. Serve as the Alternate Vandenberg SFB CCCBP Program Manager.
2.1.6. The Vandenberg CCCBP Program Manager will:
2.1.6.1. Implement and manage the Vandenberg SFB CCCBP Program.
2.1.6.2. Ensure all applicable DAF, federal, state, and local laws and regulations concerning CCCBP are implemented and executed.
2.1.6.3. Conduct the base-wide CC survey every 5 years IAW DAFMAN 32-1067, para 4.3.5.8, or conduct a continuous 20 percent rolling survey over a consecutive five-year period if the CC survey is not contracted.
2.1.6.4. Ensure all backflow prevention assemblies (BPAs) are maintained, operated, tested, and repaired in accordance with all applicable DAF, federal, state, and local regulations.
2.1.6.5. Manage the training program to ensure BPA testing and CC survey personnel are properly trained and certified and that their training and certifications are kept current.
2.1.6.6. Maintain a current list of personnel that are trained and certified in CCC specialist program management and backflow testing, to include a copy of their current certifications. This list also pertains to contracted personnel who perform backflow testing and CC surveys on Vandenberg or its GSUs.
2.1.6.7. Proactively manage the CCMS database and ensure the records within the system are
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 7 current and accurate (to include contractor and independent agency BPAs).
2.1.6.8. Implement an efficient, accurate, and timely method to identify and include newly installed BPAs in the CCMS database.
2.1.6.9. Maintain current hard-copy records of CC information for each BPA, with line and isometric drawings (to include contractor and independent agency BPAs).
2.1.6.10. Maintain current hard-copy records of BPA inventory for all BPAs (to include contractor and independent agency BPAs).
2.1.6.11. Maintain current hard-copy records of all field test results for a minimum of 3 years for each installed BPA (to include contractor and independent agency assemblies).
2.1.6.12. Perform, at a minimum, a semiannual review of the BPA Program to ensure its currency and compliance with all applicable DAF, federal, state, and local regulations.
2.1.6.13. Provide technical guidance and advisement to Vandenberg SFB contractor and independent agency personnel in the management of the BPA Program.
2.2. American Water.
2.2.1. The American Water General Manager will:
2.2.2. Act as the primary POC with the SWRCB in regard to the CCC Program at Vandenberg.
2.2.3. Notify the SWRCB of any suspected or confirmed backflow incidents.
2.2.4. Coordinate with 30 CES to investigate backflow incidents affecting the Vandenberg SFB potable water system.
2.2.5. Coordinate with 30 CES to suspend water service to facilities or equipment that are identified as having a CC risk to the drinking water system if the CC is not properly addressed or mitigated in a timely manner
2.2.6. Coordinate with 30 CES to suspend service to facilities with confirmed backflow incidents.
2.3. Bioenvironmental Engineering.
2.3.1. Will, as feasible, assist in reviewing and approving hazard assessment designations.
2.4. Balfour Beatty Communities.
2.4.1. Will regularly inspect and abate CC hazards within Military Family Housing that pose a risk to the Vandenberg SFB drinking water system.
2.5. Contractors and Independent Agencies That Test Their Own BPAs.
2.5.1. Appoint a single individual as the user supervisor for their organization to act as the focal point for the management of their own respective backflow prevention program.
2.5.2. Ensure all applicable DAF, federal, state, and local laws and regulations concerning CCCBP are implemented and executed within their facilities.
2.5.3. Ensure all BPAs under their responsibility are maintained, operated, tested, and repaired in accordance with all applicable DAF, federal, state, and local regulations.
2.5.4. Provide reasonable facility or site access to Vandenberg SFB personnel or their contracted representatives to conduct CC surveys and backflow prevention program inspections.
2.5.5. Provide the CCCBP Program Manager or appropriate Contracting Office Representative (COR) with a current list of trained and certified CCC specialist program managers and backflow testers, to include a copy of their training documentation and/or current certification.
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 8
2.5.6. Maintain a current inventory list and applicable test schedule of all BPAs under their responsibility. The inventory list will, at a minimum, contain information detailing assembly location, facility number, size, and manufacturer information (model and serial number).
2.5.7. Maintain, at a minimum, a 3-year historical record of all BPA Field Test Forms for the backflow assemblies under their responsibility.
2.5.8. Provide a hard-copy test result to the CCCBP Program Manager or your COR of all BPA field test forms for each assembly within 30 days of its test, repair, or retest.
2.5.9. Ensure the BPA Field Test Forms for all BPAs under their responsibility are properly annotated in accordance with this local instruction.
2.5.10. Notify the CCCBP Program Manager:
2.5.11.1. if a BPA cannot be repaired within 30 days after a malfunction, test, or retest failure.
2.5.11.2. if a high hazard CC cannot be corrected within 7 days of its discovery.
2.5.11.3. if a low hazard CC cannot be corrected within 30 days of its discovery.
2.5.11. Immediately report observed or suspected backflow incidents to American Water and 30 CES Damage Control Center (DCC) within 24 hours of the occurrence.
2.5.12. Notify American Water and 30 CES/CEOIU of any plumbing modifications or repairs that may affect the proper operation of a BPA. Notification shall be made NLT one week prior to start of work. If the work is due to an urgent or emergency repair requirement, notification to 30 CES/CEOIU will be made as soon as practically possible but NLT three days after work has begun.
2.5.13. Request review and approval from American Water and 30 CES/CEOIU prior to the installation or replacement of a BPA.
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 9
Chapter 3
GUIDANCE AND PROCEDURES
3.1. Achieving and Maintaining Compliance with this Supplement
3.1.1. This supplement is designed to help Vandenberg SFB implement its CCC Program and achieve and maintain compliance with the CCCPH. It reflects the elements that Vandenberg has in place to protect its potable water supply while addressing state compliance requirements established under the recently approved CCCPH.
3.1.2. Implementing this supplement combined with established DAF directives will constitute the Vandenberg SFB’s CCC Program. This supplement describes the necessary elements and procedures required to help Vandenberg achieve and maintain compliance with the CCCPH. Its execution will support the Air Force’s priority of providing safe drinking water to the public.
3.2. Hazard Assessments
3.2.1. The following sections describe the process, personnel, and time frames for completing initial and ongoing hazard assessments pursuant to CCCPH Section 3.2.1. Hazard assessments are intended to assist in developing an understanding of the level of hazard posed by each facility connected to the potable water distribution system. Initial hazard assessments are conducted to establish a baseline for all commercial (i.e., commercial, industrial, and agricultural) and residential facilities, whereas ongoing hazard assessments are conducted to revisit facilities that undergo modifications, such as changes in operations or processes and remodeling. Another purpose for ongoing hazard assessment is the presence of new CCs observed during the process of conducting day-to-day field operations by the 30 CES/CEOIU staff.
3.2.2. Initial Hazard Assessments. Initial hazard assessments have been completed at Vandenberg SFB and accepted by the DDW. Vandenberg SFB has a history of conducting hazard assessments to protect its potable water system. The 30 CES approach to conducting hazard assessments consists of conducting CC surveys at all its facilities (i.e., Base-owned facilities;
contractor-occupied facilities, and residential areas). During the CC surveys, 30 CES/CEOIU staff visit and survey the plumbing system within each facility connected to the Base’s potable water system. The information collected during the CC survey is used to determine the hazard level for each point of use, abate unprotected CCs, upgrade or replace deficient BPAs, validate existing BPAs, and inventory newly identified BPAs. The last set of hazard assessments for the entire Base was documented from 2011 through 2015. These surveys constituted Vandenberg’s initial hazard assessment. Copies of these hazard assessments are kept at the CCCBP Program Managers office and are available for review upon request.
3.2.3. Hazard Assessment Approach. This supplement’s approach to performing hazard assessments consists of conducting a CC survey of all the facilities connected to the Base’s potable water system, determining the hazard level for each facility, and determining backflow prevention methods to control CCs.
3.2.3.1. Cross-Connection Survey. The CC survey effort consists of using exercises geared toward determining the level of hazard presented by each facility within the Base and GSUs. The key measures include reviewing available as-built records and conducting site visits to each facility.
Attachment 3 provides the CC Survey Form that contains the basic elements that would be collected in the field. This section describes the key elements of the CC survey.
3.2.3.1.1. Geographic Information System (GIS) Maps and Tracking Application. An atlas-type booklet depicting Vandenberg’s distribution system will be assembled as a tool to navigate and track areas and facilities targeted each year for hazard assessment. The Base also will employ a GIS application similar to ArcGIS Field Maps to document observed uncontrolled CCs and installed
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 10 backflow preventers. The application will enable the Base to instantly track hazard assessment progress by using a color-coding feature that assigns distinct colors to surveyed facilities and to facilities that have not been surveyed. The application will also enable the CC survey team to document the location of observed CCs and existing backflow preventers, as well as to download and validate compiled data back in the office. Key data collected in the application are represented in the CC Survey Form included in Attachment 3.
3.2.3.1.2. As-Built Records Review. To complement field efforts, available as-built records kept at the Base’s vault will be reviewed on an as-needed basis to identify plumbing configurations. The records will be reviewed for specific systems, including, but not limited to, swimming pools, irrigation systems, fire sprinkler systems, boilers, chillers, cooling towers, and auxiliary sources (e.g., domestic wells).
3.2.3.1.3. Site Visit. At the time this supplement was prepared, the Base had identified water uses for all the CCs having backflow prevention assemblies (BPAs) that are inventoried in the Base’s CCMS based on prior CC surveys. Site visits will be conducted to confirm that existing BPAs are adequately protective of their associated CCs and to identify any BPAs and CCs for which records have not been previously identified. Site visits to non-residential facilities (e.g., office buildings, shops, clinics, dormitories, and contractor-occupied facilities) will be conducted to verify existing BPA information, document installed BPAs not currently inventoried in the Base’s CCMS, and identify any unprotected CCs needing backflow protection. Existing BPAs will be inspected for information including point of use, manufacturer’s plate data verification, and proper installation per CPC and manufacturer’s recommendations. Air gaps (AGs) will be recorded and inspected to determine proper operation, and that the installation complies with the CPC. Residential premises (single-family homes) will be grouped by community based on construction patterns, such as year constructed and similar construction configuration. As-built drawings will be reviewed to identify community groupings and structure configurations. On-site visits will be conducted as needed to verify community groupings, verify existing BPA information, document installed BPAs that may not be currently inventoried in the Base’s CCMS, and identify any unprotected CCs needing backflow protection. On-site visits will focus on community areas and landscapes with irrigation systems requiring BPAs.
3.2.4. Hazard Determination. The information collected from the record review process and CC survey site visits will be compiled, validated, and used to determine the level of hazard for each facility. The degree of hazard associated with a CC is either a pollution (or non-health) or contamination (or health) hazard and is related to the conditions within a system supplied with potable water. A non-health hazard is ranked as a low hazard. A health hazard is ranked as a high hazard. The hazard assessment also will determine whether existing BPAs provide adequate protection based on the degree of hazard determined for the associated CC. The following sections describe the criteria used to determine hazard levels.
3.2.4.1. Cross-Connections. A CC is an actual or potential connection between potable water piping and a non-potable water source (e.g., sink, toilet, irrigation system, fire sprinkler system, pool, chiller, or boiler). Potable water can become impaired by pollutants or contaminants through backflow. The UPC describes pollution as an impairment of the quality of the potable water to a degree that does not create a hazard to the public health, but which does adversely and unreasonably affect the aesthetic qualities of the potable water for domestic use. The UPC also describes contamination as an impairment of the quality of the potable water that creates an actual hazard to the public health through poisoning or through the spread of disease by substances such as sewage, industrial fluids, or waste (IAPMO 2024). Backflow is the undesired flow of pollutants or contaminants into the potable water system. Backflow can occur through either backsiphonage or backpressure. Backsiphonage is created when the supply water pressure is lowered to a sub-atmospheric condition. For example, backsiphonage can occur when a main water line installed below the street surface breaks, causing a pressure loss downstream of the break and drawing water with
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 11 non-potable substances from a higher elevation into the potable water system. Backpressure occurs when the downstream pressure is higher than the supply pressure. One instance in which backpressure can occur is when circulating pumps installed in the drinking water supply network introduce a reverse of flow at a pressure higher than the supply pressure. Plumbing fixtures (e.g., lavatories, toilets, urinals, sinks, tubs, showers, and hose bibbs) installed in accordance with the plumbing code typically use AGs or vacuum breakers to protect potable water. Other plumbing systems, such as irrigation systems, fire sprinkler systems, boilers, and chillers, are required to use BPAs or other types of backflow prevention devices. Each facility poses either a pollution (or non-health) or contamination (or health) hazard depending on a range of factors, including the type of operations, plumbing configurations, and materials used for the facility. Hazard level for each facility will be primarily based on the CC with the highest hazard level associated with the facility. Each CC within a facility represents a pollution or contamination hazard. Non-health hazards also are referred to as low hazards.
Health hazards are also referred to as high hazards. The type of substances associated with each CC are the driving factor in determining whether a CC has a high or low hazard level. Substances that impair the aesthetics of potable water will be assessed as posing a low hazard risk. Substances deemed capable of inflicting health damage to humans will be assessed as posing a high hazard risk. Table
3.1 provides a summary of typical CCs found in facilities.
Table 3.1. Typical Cross-Connections Found in Facilities.
Cross-Connection Pollutants or Contaminants Hazard Level
Typical Backflow Prevention Method
Fire sprinkler system Stagnant water and pipe residues Low DC Fire sprinkler system Injected chemicals High RP Irrigation systems Fertilizers, herbicides, pesticides, and pet waste High AVB, PVB, RP
Boilers and chillers Corrosion inhibitors High RP RV dump stations Sewage High AG, RP Laboratory faucets Chemicals High AVB Mop and service sink Wash water and cleaning agents High AVB Dishwasher and food processors
Wash water, food waste, and cleaning agents
High AVB
Pool Used chlorinated water High AG, RP Notes: AVB – atmospheric vacuum breaker; DC – double check valve assembly; PVB – pressure vacuum breaker backsiphonage prevention assembly; RP – reduced pressure principle backflow prevention assembly; RV – recreational vehicle.
3.2.4.1.1. Degree of Plumbing System Complexity. Due to its complexity, an intricate plumbing system may introduce CCs when plumbing modifications are required. For this reason, facilities with complex plumbing systems will be deemed as having a high hazard level. A complex plumbing system typically has multiple CCs associated with points of use, such as, but not limited to, irrigation systems, fire sprinkler systems, boilers, chillers, pumps, and manufacturing processes. Facilities with complex systems will typically be identified during the CC survey.
3.2.4.1.2. Auxiliary Water Supplies. Auxiliary water supplies such as domestic wells supply water that has not been treated to meet primary and secondary water quality standards. These systems are typically fitted with pumps to pump ground water to the surface. The pumps introduce pressure to
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 12 move water from a lower to a higher elevation. When interconnected with the potable water system, they introduce a backpressure against the supply pressure of the potable water system. For this reason, facilities with auxiliary water supplies will be deemed as having a high hazard level. Auxiliary systems will be identified either during the process of reviewing construction records or while on an on-site survey.
3.2.4.1.3. Facilities with Likelihood of Introducing Backflow. Facilities with distribution system conditions that may increase the likelihood of a backflow event, such as hydraulic gradient differences impacted by main breaks and high-water demand situations, and/or multiple service connections, will be assessed as having a high hazard level. This type of facility will most likely be identified during the CC survey.
3.2.4.1.4. User Premise Accessibility. Premises with accessibility constraints represent an unknown with possible high-hazard CCs. For this reason, facilities with accessibility constraints will be assessed as having a high hazard level.
3.2.4.1.5. History of Previous Backflow Incidents. Facilities with a history of previous backflow incidents on the user premises will be deemed as having a high hazard potential and will be assigned a high hazard level.
3.2.5. Cross-Connection Control
3.2.5.1. Guidance in the Manual for Cross-Connection Control, 10th Edition will be used to determine whether installed BPAs are adequate to protect the potable water system, the type of CCC method for uncontrolled CCs identified during survey efforts, and appropriate CCC for new plumbing systems (USC FCCCHR 2009). Table 3.2 summarizes acceptable backflow protection for different conditions.
Table 3.2. Backflow Protection Requirements.
Hazard Backflow Type Acceptable Backflow Prevention Method
High Backpressure RP, AG High Backsiphonage PVB, SVB, RP, AG
High Backsiphonage (less than 12 hours of continuous use)
AVB, SVB, PVB, RP, AG
Low Backpressure RP, DC, AG Low Backsiphonage PVB, SVB, DC, RP, AG Low Backsiphonage (less than 12 hours of continuous use)
AVB, PVB, SVB, RP, DC, AG
Notes: AG – air gap; AVB – atmospheric vacuum breaker; DC – double check valve assembly; PVB – pressure vacuum breaker backsiphonage prevention assembly; RP – reduced pressure principle backflow prevention assembly;
SVB – spill-resistant pressure vacuum breaker backsiphonage prevention assembly.
3.2.5.2. Air Gap. The simplest backflow prevention control is the AG. An approved AG is the unobstructed vertical distance through free atmosphere between the lowest point of a water supply outlet and the flood level rim of the fixture or assembly into which the outlet discharges. These vertical, physical separations must be at least twice the diameter of the water supply outlet, but never less than one inch. An example of an AG is presented in a common bathroom lavatory where the faucet outlet is separated from the lavatory rim by an AG.
3.2.5.3. Atmospheric Vacuum Breaker (AVB). The AVB consists of an air inlet seat with a float that seals against the seat during normal flow conditions. This device will guard against backsiphonage but not backpressure conditions in low and high hazards.
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 13
3.2.5.4. Double Check Valve Backflow Prevention Assembly (DC). The DC has two internal, spring-loaded check valves that open when the water is flowing in the correct direction and close when flow stops or reverses. The DC is effective against backflow caused by backpressure and backsiphonage in low hazards.
3.2.5.5. Pressure Vacuum Breaker Backsiphonage Prevention Assembly (PVB). The PVB consists of an independently operating, internally loaded check valve and an independently operating, loaded air inlet valve located on the discharge side of the check valve, with properly located resilient-seated test cocks and tightly closing resilient-seated shutoff valves attached at each end of the assembly. The PVB is effective against backflow caused by backsiphonage low and high hazards and should not be used if backpressure could develop in the downstream piping.
3.2.5.6. Reduced Pressure Principle Backflow Prevention Assembly (RP). The RP offers the most protection against backflow and backsiphonage conditions. The RP contains two check valves like the DC but also contains a pressure-differential relief valve located between the two check valves.
3.2.5.7. Spill Resistant Vacuum Breaker (SVB). The SVB is essentially the same as a PVB except it is designed to minimize spills from the air inlet port.
3.2.5.8. Cross-Connection Abatement. CCs created by water users must be abated with the installation of an approved backflow prevention measure and in accordance with this supplement. The water user will be responsible for bearing the cost of implementing backflow prevention measures associated with user-generated CCs. The type of backflow prevention must be commensurate with the degree of hazard that exists on the water user’s premises. BPAs must be installed as close as practical to the meter box and public right-of-way. Guidance in the Manual for Cross-Connection Control, 10th Edition and provided as reference in Attachment 4 will be used for proper installation of AGs and backflow preventer (USC FCCCHR 2009).
3.2.6. Ongoing Hazard Assessments. Vandenberg SFB is required to conduct CC surveys of all its facilities connected to the potable water system every five years per DAFMAN 32-1067. To this end, Vandenberg plans to conduct hazard assessments of all the facilities within its boundary within a four-year period from calendar years 2026 through 2030 at a rate of 25 percent of its facilities per year. After this round of hazard assessments Vandenberg will restart conducting hazard assessments at a rate of 20 percent of all facilities connected to the drinking water system per year. The approach described for conducting initial hazard assessments will be used to conduct ongoing hazard assessments. Hazard assessments will be conducted per the schedule in Table 3.3.
Table 3.3. Ongoing Hazard Assessment Plan.
Year Calendar Year
Target
1 2026 25 percent of all facilities at VSFB and all facilities at GSUs
2 2027 25 percent of all facilities at VSFB and housing parks 3 2028 25 percent of all facilities at VSFB 4 2029 25 percent of all facilities at VSFB
3.3. Legal Authority
3.3.1. This section describes the legal authority pursuant to CCCPH Section 3.1.3 to implement corrective actions in the event a water user fails to comply in a timely manner with the provisions of
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 14 the Base’s CCCBP Program.
3.3.2. The Base has the legal authority to pursue corrective action in the event a water user fails to comply in a timely manner with the Base’s provisions regarding the installation, inspection, field testing, or maintenance of BPAs required pursuant to Chapter 3 of the CCCPH. The Base’s legal authority is codified in DAFMAN 32-1067, a copy of which is provided as Attachment 5.
3.3.3. This supplement and DAFMAN 32-1067 constitute the Base’s legal authority to enforce implement of corrective actions required for noncompliant CCs and backflow prevention installation deficiencies. In regard to corrective actions DAFMAN 32-1067 Section 5.4.4, states “Installations will correct cross-connections and illicit discharges identified through inspections by elimination, operational modifications, repairs, or construction.”
3.3.4. Vandenberg SFB is responsible for installing, inspecting, testing, and maintaining backflow preventers associated with facilities operated by Vandenberg SFB organizations.
Vandenberg SFB is also responsible for abating cross-connections within AF occupied facilities.
3.3.5. Tenant and commercial agencies and contractors are responsible for installing, testing, and maintaining backflow preventers associated within their facilities. They are also responsible for abating cross-connections within their facilities.
3.4. Process and Time Frames for Inspections and Field Testing
3.4.1. This section describes the process and time frames for ensuring each BPA is inspected and field tested, and AGs are inspected at a frequency no less than required by Chapter 3 of the CCCPH.
3.4.2. Vandenberg (30 CES) will install, test, and maintain backflow assemblies in facilities that fall under the maintenance responsibility of 30 CES. In other circumstances (i.e. a leased facility), the responsibility to install, test, and maintain BPAs may fall to the Independent Agency assigned as the responsible party for the occupancy, management, or maintenance of that facility.
3.4.3. BPAs must be kept in good working order. To ensure that BPAs perform accordingly, they must be tested at the time of installation, after undergoing repairs, before being put in service after a period of inactivity, and minimally on an annual basis. An inventory of backflow preventers installed on Vandenberg and its GSUs is kept at the CCCBP Program Manager’s office and is available for review upon request.
3.4.4. BPA Inspection and Testing Requirements
3.4.4.1. Inspection. BPAs must be inspected at the time of installation to ensure that their installation meets the UPC standards and/or manufacturer-prescribed installation requirements. Water users must provide manufacturer specifications sheets for BPAs proposed for installation. Proposed BPAs must be selected to adequately provide protection against the CC for which they are installed.
BPA installations must be inspected and approved by the CCCBP Program Manager (30 CES/CEOIU). BPAs installed within Vandenberg property and its GSUs must be on the list of BPAs approved by the Foundation for Cross-Connection Control and Hydraulic Research (FCCCHR), which can be obtained from the FCCCHR website at https://fccchr.usc.edu/list.html. A copy of the list of approved BPAs published at the time this CCC Plan was prepared is provided as Attachment 6.
3.4.4.2. Testing. The Base requires each BPA to be tested at the time of installation, following a repair, at time of reinstatement following a period of inactive status (i.e., the water supply to the BPA is suspended by closing shutoff valves), relocation, and at least annually. All required field testing must be performed by certified BPA testers. Field testing of BPAs must be performed in accordance with procedures prescribed in the FCCCHR Manual of Cross-Connection Control, Tenth Edition. The Base has a BPA testing plan that requires each backflow preventer to be field tested at least once during any given year. Customers with BPAs are divided into 12 groups, each of which is scheduled
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 15 for testing in a specific month of the year.
3.4.4.2.1. BPAs with Passing Results. When a BPA is field tested with a passing result, the subsequent test for that BPA is due the following year on its assigned scheduled month. All BPAs with a passing test result will be deemed compliant for testing purposes.
3.4.4.2.2. BPAs with Failed Results. Any BPA that fails a field test is required to be repaired or replaced and retested with a passing result within 30 days of notification of the failure to the Base.
The Base may allow extensions on a discretionary basis based on the Base’s understanding of planning and coordination required for elements such as procurement of parts and water line shutdowns. Water users must communicate to 30 CES/CEOIU the need for additional time and provide valid reasoning for the request. The 30 CES/CEOIU reserves the right to grant the request for any reason.
3.4.4.2.3. BPAs Placed in Inactive Status. Water users are required to notify 30 CES/CEOIU when a BPA becomes inactive due to circumstances such as shutting off the water supply to the BPA or the building’s service connection. 30 CES/CEOIU will keep BPAs in inactive status until the water user requests the reinstatement of the BPA or if 30 CES/CEOIU observes that the BPA has become active (e.g., supplying water to a point of use such as an irrigation system). The BPA must pass a field test prior to being reinstated. Failure to conduct the field test will result in 30 CES/CEOIU’s decision to deny service.
3.4.4.2.4. Backflow Incidents and Unprotected Cross-Connections. The Base requires BPA testers to report to American Water as soon as possible within 24 hours any suspected or actual backflow incidents or unprotected CCs. Upon learning of the backflow incident or unprotected CC, American Water and 30 CES/CEOIU will conduct an investigation to collect evidence, determine whether an actual backflow incident occurred or a CC exists, and identify the steps necessary to mitigate backflow incident or CC. Backflow incident investigation and reporting procedures are described in detail in this supplement.
3.4.5. Air Gap Inspection Requirements. The simplest backflow prevention control is the AG.
An approved AG is the unobstructed vertical distance through free atmosphere between the lowest point of a water supply outlet and the flood level rim of the fixture or assembly into which the outlet discharges. These vertical, physical separations must be at least twice the diameter of the water supply outlet, but never less than one inch. An example of an AG can be found in a common bathroom lavatory where the faucet outlet is physically separated from the lavatory rim. AGs must be inspected at the time of installation, following a repair, at time of reinstatement following a period of inactive status, and annually. The inspection must be completed by a certified BPA tester. AGs that do not meet installation requirements prescribed in Table 603.3.1, Minimum AGs for Water Distribution, of the UPC will be deemed noncompliant and will require immediate repair.
3.5. Non-Testable Backflow Preventer Installation and Maintenance.
3.5.1. This section describes the process and time frame for ensuring each non-testable backflow preventer that is under the Base’s ownership or administration is installed and maintained according to the UPC and/or manufacturer-recommended installation standards.
3.5.2. Approval. Non-testable backflow preventing devices under the Base’s ownership or administration must be approved before their installation. The Base’s CCCBP Program Manager will review specifications sheets and approve or deny installation of non-testable backflow prevention devices. All non-testable backflow prevention devices must meet standards from at least one of the following organizations:
3.5.2.1. American Water Works Association
3.5.2.2. American Society of Sanitary Engineering
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 16
3.5.2.3. International Association of Plumbing and Mechanical Officials
3.5.2.4. Underwriters Laboratories
3.5.3. Installation. Non-testable backflow preventers must be installed per the UPC standards.
3.5.4. Maintenance. Maintenance and repair of non-testable backflow preventers must be completed in accordance with manufacturer’s recommendations. Non-testable backflow preventers will be inspected at the time of installation, following a repair, at the time of reinstatement following a period of inactive status with valves shutoff, relocation, and annually. All required field inspections must be performed by certified BPA testers.
3.6. BPA Field Tester Requirements
3.6.1. This section describes the process for ensuring BPAs testers are no less qualified than required by Chapter 3 of the CCCPH, including, but not limited to, confirmation of the individual’s certification as a BPA tester, field test kit accuracy verification, and BPA field test result reports.
3.6.2. Certification. BPAs are to be tested by certified BPA testers who have been certified in accordance with the compliance requirements outlined in Table 3.4.
Table 3.4. BPA Tester Certification Compliance Dates.
Tier Starting
Compliance Date Requirement
1 1 July 2025 • BPA testers must be certified by a certifying organization recognized by the SWRCB as a certifying organization for BPA testers pursuant to Article 4, Subsection (c) of the CCCPH.
2 1 July 2028 • BPA testers must be certified by an American National Standard Institute-accredited certifying organization accredited in accordance with Article 4, Subsection (b) of the CCCPH and
ISO/IEC 17024.
• BPA testers with certifications obtained from organizations in accordance with Article 4, Subsection (c) of the CCCPH will be invalid.
3.6.3. Prohibitions. BPA testers will not be allowed to test BPAs within Vandenberg and its GSUs under the following circumstances:
3.6.3.1. If the BPA tester is found to be deficient in accurately determining the operating condition of BPAs.
3.6.3.2. If it is determined that a BPA tester has falsified or materially altered testing or survey records. In addition, these individuals will be reported to their certifying agency immediately.
3.6.4. BPA Tester Verification. Contracted backflow preventer tester technicians or companies seeking to test BPAs within Vandenberg and its GSUs must provide valid copies of current BPA tester and test kit calibration certificates to the CCCBP Program Manager (30 CES/CEOIU). Authorization to test BPAs within the Base will be granted once BPA tester certificates have been confirmed with the certifying organizations.
3.6.5. Field Test Kit Accuracy Verification. Field test kit accuracy must be verified via a certificate issued by a laboratory using equipment that has been calibrated using measurement standards traceable to the National Institute of Standards and Technology standards. Test kits must be
CROSS-CONNECTION CONTROL MANUAL 32-1067- 23 June 2025 17 certified annually. Test records generated with test kits with expired verification certificates will be considered invalid.
3.6.6. BPA Field Test Result Reports. Upon completion of field testing, BPA testers must provide copies of test results for each BPA tested within 30 days of the test date. The Base’s CCMS generates test forms that include each BPA’s information. Attachment 7 provides a copy of the CCMS-generated blank test form used by the Base to record field test results.
3.7. Backflow Incidents
3.7.1. This section describes the procedures and time frames of activities for responding to backflow incidents, including notification of customers, and reporting backflow incidents pursuant to CCCPH Section 3.5.2.
3.7.2. Notification. Within 24 hours of a determination that a backflow incident is suspected to have occurred or has occurred, American Water, in coordination with 30 CES, will notify the SWRCB of the incidents. If required by the SWRCB, American Water will issue a Tier 1 public notification pursuant to the California Code of Regulations (CCR), Title 22, Section 64463.1.
3.7.3. Investigation. The Base will investigate all reported backflow incidents and unprotected CCs immediately after being reported. The Base will use the backflow incident form included in Attachment 8 to document and report the investigation.
3.7.4. Response and Follow-up.
3.7.4.1. Backflow. In coordination with American Water, 30 CES, and any impacted water service customers, Vandenberg will isolate the source of the backflow by closing the supply valves to the source. If a backflow incident originates within a facility and cannot be isolated within that facility so that it extends beyond the facility’s limits (i.e., the water meter) Vandenberg may suspend water service to that facility or facility complex by closing the service connection valve. Service to the affected facility will not be restored until the backflow incident is mitigated, which may require physically separating the water supply piping to the facility or by installing an approved BPA. Water service will only be restored when the BPA has passed required testing. Close coordination and communication between American Water, 30 CES, and the water service customer will be key to a timely and successful resolution so that service can be restored as quickly as possible.
3.7.4.2. Unprotected Cross-Connections. Unprotected CCs will be protected with either an AG or a backflow preventer (testable or non-testable).
3.8. Cross-Connection Management System.
3.8.1. The Base manages its BPA records with the use of the CCMS. The CCMS is a database designed to store, track, and manage BPA information pursuant to Section 3.5.1 of the CCCPH. The following describes the CCMS primary features.
3.8.2. BPA Profile. This feature is used to create and store BPA information, such as manufacturer, serial number, size, point of use,…
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