Recently the State Water Resources Control Board (SWRCB) distributed a COVID-19 Guidance Memo (“Public Water System COVID-19 Considerations” dated March 24, 2020). This morning SWRCB distributed an updated version of that document (copy enclosed) adding two new sections on (1) maintaining cross connection control programs and (2) remote supervision of operations. (REVISED COVID-19 SWRCB Guidance Memo to PWSs 04022020) The new sections 7 and 8 are copied below.
In addition, yesterday Governor Newsom signed the enclosed Executive Order regarding restricting water service shut-offs during the pandemic. (CA Gov Exec Order_2020-04-02)
- Maintaining the Cross-Connection Control Program
Maintaining a cross connection control program is considered an essential function for the protection of the distribution system from contamination. The following activities should be maintained during the COVID-19 crisis:
- Any newly discovered cross connections must be corrected immediately to protect public health: locking out water meters while corrective actions are being taken would be appropriate if it is needed to prevent distribution system contamination.
- Backflow prevention device testing should continue as scheduled when possible. However, since testing is an annual requirement, PWS’s should consider providing flexibility to customers on device testing due dates, provided testing can be completed within the calendar year.
- Failed devices should be repaired or replaced immediately. PWS’s should consider providing assistance to customers to ensure testing and corrective actions can be completed in a timely manner, for example, device repair and replacement services when testers or contractors are not available, or customers are unable to coordinate.
- Recycled water use site cross connection tests should continue as scheduled when possible, but flexibility should be considered, provided they are completed within the calendar year.
- Backflow testers are essential workers, whether they are PWS employees, are contracted by the PWS, or are hired directly by customers.
- Most backflow devices should be in areas where maintaining safe social distance would not be a concern. For devices where a safe distance cannot be maintained (for example, interior devices) consider deferring those tests until later in the year and moving up other, safer test locations.
- If the PWS has customers that directly hire a backflow tester, typically from a provided list, and they cannot afford to pay for testing due to economic hardship, investigate having the PWS directly contract for the testing of those devices and recover payment through regular billing. The PWS should exhaust every avenue before shutting-off someone’s water during this emergency.
- Remote Supervision of Water System Operations
With the concerns over the COVID-19 and the associated precautions to be observed, inquiries have been posed about the ability of the chief operator to provide remote supervision to onsite shift operators. The question is whether this adequately satisfies regulatory requirements for lead and shift operators. Any proposals or needs for such arrangements may be considered only on a case by case basis upon consultation, coordination, and approval by your District Engineer/Local Primacy Agency.