Every public water system in Tennessee is required to run a cross-connection control program. Not to own a few test kits — to run a documented, ongoing program that the state has approved. That distinction is where most systems fall short, and it is usually discovered during a sanitary survey rather than beforehand.
What Tennessee requires
We help water systems develop cross-connection control programs around applicable DEC/EPA requirements, including hazard identification, program documentation, and coordination with the responsible regulatory agency.
Three practical consequences follow:
- You need an adopted ordinance or policy, not an informal practice. For a municipal system that usually means a council or board vote.
- Testable assemblies need annual testing. Reduced pressure assemblies (RPBA), double check valve assemblies (DCVA) and pressure vacuum breakers (PVB) all fall in scope.
- Testing must be done by certified personnel. Tennessee requires a certificate of competency in backflow assembly testing issued by the Department of Environment and Conservation.
Assemblies installed to protect a public water system should also appear on the current listing of Approved Backflow Prevention Assemblies maintained to University of Southern California standards. An assembly that is not on that list can be correctly installed and correctly tested and still be a finding.
The part that gets systems written up
In our experience the failure is rarely the hardware. It is the record.
A system knows where its assemblies are, tests most of them, and can produce a folder of test reports. What it cannot produce is a current inventory tied to service addresses, evidence that every high-hazard connection has been surveyed, documentation that failed assemblies were repaired and retested, or proof that customers were notified. The program exists in practice and not on paper — and only the paper is auditable.
What a working program contains
- A hazard survey identifying every connection that warrants protection, with degree of hazard assessed and recorded.
- An assembly inventory — location, type, size, make, serial number, installation date, service address.
- An annual testing cycle with scheduling, notification, and follow-up on non-responders.
- Repair and retest tracking so failures are closed out rather than logged.
- Recordkeeping that can be handed to an inspector without assembling it first.
How we help
S&L Environmental works with municipal and industrial water systems on cross-connection control. That covers building a program from nothing, repairing one that has drifted, coordinating annual testing cycles, and preparing the documentation DEC/EPA expects to see.
Because our work is operator-led, we tend to build programs around how a system is actually staffed. A procedure that assumes two spare people on a Tuesday will not survive its first winter.
Service area
West Tennessee, Northern Mississippi, and Eastern Arkansas.
Related: NPDES permit compliance and contract plant operations.