Program Records and Testing Frequency Dispute at a Multi-Building Campus
A university campus has 14 backflow prevention assemblies: 6 reduced-pressure principle assemblies, 5 double check valve assemblies, and 3 pressure vacuum breakers. The campus maintenance department keeps a spreadsheet listing assembly location, make, model, size, and the date of the last test. A review finds that 4 assemblies have not been tested in 18 months, 2 test reports are missing the tester's certification number, and 1 RPBA was replaced with a different model without updating the spreadsheet. The utility has issued a notice requiring annual testing and has threatened to terminate service. The maintenance supervisor argues that the campus is a single customer and that the utility cannot require testing more often than the state code, which the supervisor believes requires testing every three years.
1. Evaluate the supervisor's argument about testing frequency and identify the recordkeeping deficiencies.
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The supervisor's argument is flawed on two points. First, the state code's minimum testing frequency does not prevent the utility from requiring more frequent testing as a condition of service, and many utilities require annual testing for RPBA and double check assemblies. The utility's notice is a condition of service, and the campus must comply or risk termination. Second, the campus is a single customer, but each assembly is a separate device with its own test history, and the utility can require testing of each assembly. The recordkeeping deficiencies are significant: 4 assemblies are overdue, 2 reports lack the tester's certification number, and 1 assembly was replaced without updating the record. The spreadsheet lacks the test results, the tester's name and certification, and the repair history. The program needs a complete inventory with unique identifiers, a testing schedule, and a file for each assembly containing the test report, the tester's certification, and any repair records. The replacement assembly must be recorded with its make, model, size, and serial number, and the utility should be notified of the change.
2. Recommend a records and program management approach that would prevent these deficiencies and support compliance.
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The campus should establish a written cross-connection control program with a designated program administrator, a complete inventory of all assemblies and devices, and a testing schedule based on the utility's requirements and the state code. Each assembly should have a unique identifier and a file containing the installation date, make, model, size, serial number, location, and hazard level. The file should include every test report with the tester's name, certification number, gauge calibration information, and test results, as well as repair and replacement records. The program should use a calendar or database to schedule tests before the due date and to track overdue assemblies. The administrator should review test reports for completeness and follow up on failures. When an assembly is replaced, the inventory and the utility records should be updated immediately. The program should also include periodic surveys to identify new cross-connections, training for maintenance staff, and a procedure for responding to utility notices. Records should be retained for the period required by the state code and the utility, and the program should be audited annually to verify compliance.