20221223_Veolia to Staff Attachment - Response to No. 140.pdf

VEO-W-22-02 IPUC DR 140 Page 1 of 2
VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02
THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
Preparer/Sponsoring Witness: Cooper
REQUEST NO. 140:
Please provide a copy of the most recent Company Cross Connection Control Program as
required by the Idaho Department of Environmental Quality.
a. Please provide copies of the Company’s annual and long-term Cross Connection Control
Program work plans.
b. Please explain how the Company is notified when an existing residential customer installs a
cross connection assembly or device. Is the notification process the same regardless of
whether or not the customer is located within a municipality?
c. Does a Certificate of Occupancy require the Company to inspect and sign off on cross
connections?
d. Please explain how the Company is notified when an existing customer, of any type, has an
existing cross connection assembly or device tested. How does the Company confirm that the
person performing the testing has adequate certification and/or expertise?
e. Please provide examples of notices sent to customers regarding backflow assembly testing,
including “Notice to Test Your Irrigation/Fire Backflow Assembly.”
RESPONSE NO. 140:
The most recent copy of the Company Cross Connection Control Program is attached
(Attachment 1).
a. The Company’s plan is based on assessing risk by 1) degree of hazard, 2) new acquisition, 3)
commercial customers. This ranking process informs the Company’s daily and annual work
plans.

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b. The licensed tester, contracted by the customer, is required to send Veolia a copy of the
premise backflow test report. This process is the same for all Veolia customers, regardless of
whether they live in a Municipality.
c. The Certificate of Occupancy in all jurisdictions where Veolia Water Idaho operates does not
require the Company to sign off on cross connections.
d. The Company is notified by the licensed backflow tester, and the tester’s name, address and
license number appear on the test report, and on the certification tag placed on the backflow
assembly.
e. Veolia sends annual mailers to all customers about testing backflow assemblies, and also runs
commercials on local media. A copy of the mailer from 2022 is attached (Attachment 2).

Cross-Connection Control Program
June 2019
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Cross-Connection Control Program
Contents POLICY 3
ADMINISTRATION 3
SAFETY 4 Confined Spaces 4
Hazardous Materials 4 Traffic 4 PUBLIC EDUCATION 4 REGULATION 5
ADMINISTRATIVE AUTHORITY AND STANDARDS 5 SITE INSPECTION AUTHORITY 5 DETERMINATION 6
NEW AND REMODEL CONSTRUCTION REVIEW 6 NOTICE OF SURVEY EXISTING SERVICE CONNECTIONS 6 COMMERCIAL AND PUBLIC AUTHORITY CONNECTIONS 6
IRRIGATION AND RESIDENTIAL CONNECTIONS 6 WATER USAGE PERMIT - FIRE HYDRANTS 6 INSTALLATION 8
NEW SERVICE INSPECTIONS 8 RESIDENTIAL BUILDINGS 8 COMMERCIAL BUILDINGS 8
FIRE SERVICE 8 IRRIGATION SERVICE 9 TESTING 10
PROVISIONS 10 NOTICE TO TEST 10 TEST REQUIREMENTS 10
ELECTRONIC BACKFLOW ASSEMBLY TEST REPORT DELIVERY 11 ASSEMBLY TAGGING 11 TERMINATION OF WATER SERVICE 12
IMMEDIATE TERMINATION OF SERVICE 12 FAILURE TO COMPLY WITH NOTICE OF DETERMINATION 12 FAILURE TO COMPLY WITH NOTICE TO TEST 12
INITIAL NOTICE OF INTENT TO TERMINATE SERVICE 12 FINAL NOTICE OF INTENT TO TERMINATE SERVICE 13 REESTABLISHING SERVICE AFTER A CROSS CONNECTION RELATED TERMINATION 13 APPENDIX A– NOTICE OF DETERMINATION 14
APPENDIX B– DOOR TAG (DETERMINATION) 15
APPENDIX C – RESIDENTIAL PROPERTY 16
APPENDIX D– COMMERCIAL PROPERTY 17
APPENDIX E– NOTICE TO TEST (PAGE 1) 18
APPENDIX E– NOTICE TO TEST (PAGE 2) 19
APPENDIX F – APPROVED TEST FORM 20
APPENDIX G– INITIAL NOTICE OF TERMINATION 21

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Cross-Connection Control Program
POLICY
The purpose of this program is to protect the public served by SUEZ’s water system from contamination due to actual or potential cross connections with non-potable water sources.
SUEZ’s (water purveyor) responsibility begins at the source and includes wells, storage, treatment and the water distribution system and ends at the point of delivery to the customer (meter or fire service). SUEZ does not provide check-valve assemblies as part of normal meter settings or fire service connections.
In accordance with its Cross-Connection Control Program, as required and recognized by the State Department of Environmental Quality, the Company (SUEZ Water Idaho Inc.) shall require an appropriate backflow prevention device be installed on any customer's service connection whenever an actual or potential health hazard is deemed to exist. All required devices shall conform to the State of Idaho’s approved list of backflow prevention devices or be approved by the Company prior to installation.
In the event a backflow prevention device is required, it shall be installed, maintained and tested at the customer's expense. Failure to properly install, maintain or test the required device may result in termination of service to the customer in accordance with the IPUC's Customer Relations Rules and Regulations.
When the premises served by the Company is also served in any manner from alternate supply of water, public or private, the customer must install the appropriate backflow prevention device or maintain a physical separation between the two systems at all times. The type of device or separation and the installation of the device or separation shall be determined by the Company in accordance with its Cross-Connection Control Program as recognized by the State.1
The Company reserves the right to require a meter and appropriate backflow prevention device to be
furnished and installed by the customer on any fire service connection. The meter and required backflow prevention device shall be inspected and approved by the company prior to providing
service.2
Administration
SUEZ’s Transmission and Distribution Department Manager is the Program Administrator for the Cross-Connection Control Program and provides supervision of SUEZ’s Cross-Connection Control Specialist(s). The Program Administrator is responsible for development and implementation of the program. Periodic reviews of the program will be conducted to evaluate procedures, change in codes and regulations to ensure program effectiveness.
SUEZ’s Cross-Connection Control Specialist(s) will, at a minimum, maintain a current Idaho Drinking Water Distribution Operator Class II license and complete an Idaho Bureau of Occupational Licenses (IBOL) Backflow Assembly Tester certification course and successfully pass the Idaho Backflow Tester exam. They will be required to keep their Idaho Backflow Testers license current and complete a Backflow Tester refresher course every two years.
Within the scope of this program, SUEZ’s Cross-Connection Control Specialist(s) will be responsible for:
● Determination of need for backflow protection, approved assembly selection, and specific location for premise isolation
1 SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations Governing the Rendering of Water Service
and Water Main Extensions, Idaho Public Utilities Commission, Sheet 13, Items 14-16
2 SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations Governing the Rendering of Water Service
and Water Main Extensions, Idaho Public Utilities Commission, Sheet 19, Item 45
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● Review of assembly installation and upgrade ● Test notification and acceptance ● Termination of water service for failure to comply with this program ● Program record keeping ● Cross connection database integrity and upkeep
Safety
The Cross-Connection Control Specialist must follow all Company safety policies and procedures during investigations and audits. Includes wearing required PPE (i.e. hard hat, safety toed boots and safety glasses). Additional PPE may include hearing protection, safety vest and gloves, or other personal protective equipment as required by the jobsite.
Confined Spaces
During any investigation or audit, the Cross-Connection Control Specialist will not enter any confined space unless authorized with a permit, wearing appropriate safety equipment, and there is a Company-trained personnel are present.
Hazardous Materials
Hazardous and toxic materials may be present during investigations and audits. These hazards may
be near backflow assemblies, as this is often the reason why a backflow assembly is required. Proper precautions should be used when working in these areas.
Traffic
Backflow assemblies may be located in or near streets and parking areas. Precaution should be taken when working in these areas. Appropriate traffic-related PPE will be worn by the Cross-Connection Control Specialist.
Public Education
Educating the public is an important element of SUEZ’s Cross-Connection Control Program. The program explains SUEZ’s responsibility to protect the drinking water supply from contamination or
pollution and the customers’ responsibility to prevent contaminants from entering public drinking water through their plumbing system by installing, maintaining and testing their approved backflow
assemblies annually.
Public education efforts may include:
● Utility bill inserts and bill messages to customers ● TV campaigns ● Website promotion ● Radio announcements ● Outreach to the local testing community ● Distribution of printed materials at local community centers, libraries, and irrigation/plumbing
equipment suppliers

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REGULATION
SUEZ’s regulatory authority for enforcement of its Cross-Connection Control Program falls under the Idaho Rules for Public Drinking Water (IDAPA) 58.01.08 administered by the Idaho Department of Environmental Quality, Uniform Plumbing Codes and the Idaho Public Utilities Commission (IPUC) Rules and Regulations.
The customer’s domestic plumbing and irrigation systems must be installed and maintained in accordance with the Uniform Plumbing Codes which are adopted by Idaho. Fire services are installed and maintained according to the International Fire Code.
ADMINISTRATIVE AUTHORITY AND STANDARDS
● IDAPA 58.01.08 - Idaho Rules for Public Drinking Water (Sec. 543, 552) ● IDAPA 31.21.01 - Idaho Public Utilities Commission Utility Customer Relations Rules (Sec. 303) ● IPUC - SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations Governing the Rendering of Water Service and Water Main Extensions ● Idaho Statutes ● 54-2409 - Drinking Water and Wastewater Professionals Licensing Act ● 18-2402 - Theft ● 18-7022 - Trespass and Malicious Injuries to Property ● Uniform Plumbing Codes (UPC) ● International Fire Code (IFC) ● AWWA Recommended Practice for Backflow Prevention and Cross Connection Control (M14) ● University of Southern California (USC), Foundation for Cross Connection Control and
Hydraulic Research (USC FCCCHR) SITE INSPECTION AUTHORITY
● IPUC - SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations Governing the Rendering of Water Service and Water Main Extensions ● SHEET NO. 19, MISCELLANEOUS, 46.
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DETERMINATION
Determination of the need for backflow protection will be made at the discretion of SUEZ’s Cross-Connection Control Specialist(s) in accordance with referenced industry standards. Determinations will be conducted for new and remodeled construction, surveys of existing service connections and for commercial and public authority connections.
If it is determined by SUEZ that an approved backflow assembly is required, a Notice of Determination (Appendix A) will be provided to the customer outlining the requirements for installation and premise isolation. This notice will detail the approved assembly type, premise isolation location, and ongoing test requirements for protection. Failure to comply with any notice to install or upgrade may result in termination of water service (see: Failure to Comply with Notice of Determination).
New and Remodel Construction Review
A Cross-Connection Control Specialist will make initial determination of the need for backflow prevention. Customers will be provided a Notice of Determination (Installation or Upgrade) via mail or
email by the Cross-Connection Control Specialist.
Notice of Survey Existing Service Connections
A Cross-Connection Control Specialist(s) will conduct ongoing determination surveys on existing service connections and associated facilities. These surveys will be prioritized according to the highest degree of health hazard. Each survey may include a review of the customer’s facility operations, domestic plumbing system, fire system and irrigation system.
Commercial and Public Authority Connections
The Cross-Connection Control Specialist(s) will notify commercial and public authority customers of pending surveys by phone or in person. This survey will be conducted at the site of the connection and may include inspection of interior facilities. This inspection may be scheduled with any person familiar with the plumbing system, heating and cooling system, processes, fire system and irrigation system.
Results of the survey will be documented in a Notice of Determination and be sent to the customer. This notice will detail cross connection hazards, locations for premise installation, and the type(s) of approved assembly to be required. Failure to comply with any notice may result in termination of water service, and notification to fire and building code officials.
Irrigation and Residential Connections
Walk-by hazard determinations surveys may be conducted on residential customers with lawn irrigation systems or irrigation connections, for the purpose of protecting public health. No prior notice will be given for meter book surveys.
If a hazardous condition is suspected, a follow up door hanger (see Appendix G – Door Tag [Determination]) may be left at properties when clear field determination is not possible. A Notice of Determination will be sent to any customer whose irrigation plumbing poses a hazardous condition to public health. Failure to comply with any notice may result in termination of water service and notification to building code officials.
Water Usage Permit - Fire Hydrants
SUEZ has an agreement with the Boise City Fire Department authorizing the Company to issue and control fire hydrant use permits for fire hydrants owned by Boise City or SUEZ.
Direct connections to fire hydrants will not be permitted. All water taken from a fire hydrant must be placed in an approved container (tanker truck). The container must be fitted with an approved Air Gap
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or approved reduced pressure backflow assembly with a current test. All containers will be inspected and labeled before a permit will be issued.
Boise City Police and Ada County Sheriff can issue citations for theft and trespass if failure to obtain a
fire hydrant use permit is determined3 (or also for any use on fire hydrants other than those designated
in SUEZ permit instructions).
3 Idaho Statutes, Theft 18-2402, (8) – (10), Trespass and Malicious Injuries to Property 18-7022
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INSTALLATION
Following a Notice of Determination, approved backflow assemblies are to be installed for premise isolation as the primary means of protection. Failure to comply with a Notice of Determination may result in termination of water service or a delay in a service being turned on until the issue is fixed.
A list of state approved backflow assemblies can be obtained from the State Cross Connection Coordinator with the Idaho State Department of Environmental Quality (DEQ, 1410 N. Hilton, Boise, Idaho http://www.deq.idaho.gov/water-quality/drinking-water.aspx).
SUEZ will not accept any backflow assembly type that has not been previously accepted and approved by the State DEQ Cross Connection Coordinator.
All backflow assemblies will be installed in accordance with the local plumbing codes in effect at the time of the installation.
New Service Inspections
When turn-on orders are received for new or previously inactive service connections, an initial
assembly inspection will be performed by the Cross-Connection Control Specialist or trained Company staff. This inspection will verify installation of an approved backflow assembly and confirm the initial
assembly testing has been scheduled or completed.
Water service may remain off until corrections are made because:
● The required assembly is not present ● The installed assembly is not the required type ● The assembly has been installed incorrectly ● The assembly has not been tested and passed
Additional notification will be set to the plumbing inspector to stop issuance of an occupancy permit.
Residential Buildings
Residential properties served only by the Company (i.e. without other public or private water service) will not typically be required to have premise isolation. However, residential properties of this type may still pose a hazard to the public drinking water system via a cross connection to a residential lawn sprinkling system. The Company will require appropriate protection in the form an approved premise or sub-premise isolation backflow assembly in these settings.
Minimum requirements for a lawn sprinkler system will be an atmospheric vacuum breaker (AVB) backflow devise. Further determination to a higher standard will be made at the company’s discretion. (See Appendix C)
Commercial Buildings
For the purpose of this program, any building larger than a duplex, or built to produce income, is defined as a commercial building and is required to have a premise isolation assembly installed on all service lines.
The minimum requirement will be a Double Check Valve Assembly (DCVA). A Reduced Pressure Backflow Assembly (RPBA) may be required depending on the degree of assessed hazard. The assembly will be installed on the customers’ service line as close as possible to the meter. No connections will be allowed between the backflow assembly and the meter except an irrigation connection with a proper backflow assembly installed. (See Appendix D)
Fire Service
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Fire services are comprised of two categories: fire sprinkler systems (single or dual feed) and fire hydrant systems.
All fire sprinkler systems require backflow protection. The minimum requirement will be a Double
Check Valve Assembly (DCVA). Buildings with dual feed fire lines which are connected together, the minimum requirement will be a Double Check Valve Assemble installed on each line. A Reduced Pressure Backflow Assembly (RPBA) may be required depending on the degree of assessed hazard. NFPA 13D style Residential flow-through fire systems do not (by themselves) require backflow protection. (See Appendix C & D)
Fire hydrant systems will not typically be required to have backflow protection. The Company reserves
the right to require protection as hazards and circumstances warrant.
Irrigation Service
All irrigation services require an isolation backflow assembly.
Irrigation services fed from SUEZ can use any state approved backflow assembly properly installed and tested based on the degree of hazard.
Any irrigation system with a chemical feed will be required to have an approved Reduced Pressure Backflow Assembly properly installed and tested.
Irrigation services that use SUEZ and have access to an alternate source such as pressurized irrigation, a private well, ditch pump, or any other type of non-potable source will require a Reduced Pressure Backflow Assembly properly installed and tested. (See Appendix C)

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TESTING
Provisions
There are several situations when a backflow assembly must be tested by a state licensed tester.
Testing scenarios include: upon initial installation, after repair or relocation of a backflow assembly, and annually thereafter on all assemblies.
Testing shall be done in accordance with approved University of Southern California (USC), Foundation for Cross Connection (USC FCCCHR) Control and Hydraulic Research testing
procedures, American Water Works Association (AWWA), or American Society of Civil Engineers (ASCE) methods. Backflow testers must have a current license issued by the State of Idaho Bureau of
Occupational Licenses (IBOL). All testers must have their test kits calibrated annually. A list of state licensed backflow testers can be obtained from the State of Idaho Bureau of Occupational Licenses’
website (http://ibol.idaho.gov).
The scheduling and cost of testing is the customer’s responsibility. The customer, or the customer’s
contracted backflow tester, is required to send the original, legible copy of the backflow assembly test report to SUEZ no more than 15 days after the test has been conducted.
Failure to provide for ongoing maintenance and annual testing of an approved backflow assembly may result in termination of service to the customer in accordance with the Idaho Public Utilities
Commission’s (IPUC) Customer Relations Rules and Regulations.
Assemblies that cannot pass annual tests or those found to be defective shall be repaired, replaced, or
isolated within ten (10) business days. If the failed assembly cannot be repaired, replaced, or isolated within ten (10) business days, water service to the failed assembly shall be discontinued. (IDAPA
58.01.08.552.06.e)
Notice to Test
For assemblies that operate year-round, SUEZ may send annual test notification to affected customers describing the hazard, assembly details, and testing history of their premise isolation assembly.
Notification schedules will be based on testing and assembly records maintained by the Cross Connection Program Administrator.
For assemblies that operate year-round, the final due date for annual testing will be 1 year from the last record of successful testing. The Notice to Test may be sent out no later than 30 days prior to the previous test anniversary date.
For all seasonally operated backflow assemblies and irrigation services, annual notice for testing may
be sent out in early April (regardless of anniversary test date). The due date for testing will be 30 days from the start of the irrigation district watering season.
Test Requirements
Testing shall be done in accordance with approved USC, AWWA, or ASCE methods. Test reports that fail to meet the minimum record keeping requirements will not be accepted. Incomplete test reports may be returned to the customer for completion by their tester.
At a minimum, any valid test report must include:

Test Date, Pass/Fail Result
Premise Name,Street Address, Zip Code, Premise
Protection Type, Assembly Location Description
Customer Name,Mailing Address, Zip Code, Phone Email (if available)
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Tester Information IBOL license #, Tester Name, Test Date, Signature
Assembly Information Serial Number, Size (inch diam.), Make, Model, Type

The tester should provide each customer with a copy of the completed assembly test report for their records.
Completed test reports must be received by SUEZ within 15 days of the assembly test date. It is the customer’s responsibility to ensure test results have been communicated to SUEZ.
Test results must be submitted using the SUEZ Backflow Assembly Test Report Form (See Appendix F) or a pre-approved alternative.
Two test report delivery formats will be accepted:
● Hard copy reports delivered to SUEZ by mail or drop-off ● Legible digital reports in .PDF or .TIFF format emailed to [e-mail].
Testers who choose the email option are encouraged to send an initial sample report to ensure delivery and acceptance. Electronic Backflow Assembly Test Report Delivery
An electronic submittal option for test reports is available to testers who seek pre-approval from the
Company, and have the ability to provide results in a standard file format. Please contact SUEZ for more information on the e-delivery test report option.
Backflow Tester will be suspended from testing in the SUEZ service area if they are found to falsify reports, commit fraudulent acts, misrepresent repairs, or continually submit late reports. Testers may
petition the company for reinstatement the following calendar year.
Assembly Tagging
Testers must physically tag each tested assembly. Tags will be weather resistant and securely affixed to each assembly (laminated business cards and zip-tie fasteners are acceptable). As shown in the example, tags must include: test date, tester name, license number, and testing company name.

Example 1: Tag Format and Example of Properly Tagged Assembly

Test Date:
MM/DD/YYYY

Company: Testing Co.
Tester: Tester Name
License#: 123456789
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TERMINATION OF WATER SERVICE
The Cross-Connection Control Program is essential to reducing the risks of backflow contamination or pollution to the public drinking water supply. This Program seeks to eliminate the potential for cross connection between the public water system and other non-potable water sources. It is SUEZ’s intention to provide customers every opportunity to comply with state cross connection control requirements and this program.
Immediate Termination of Service
Water service may be terminated immediately upon discovery of any actual or potential cross connections with the public water system. IPUC Utility Customer Relations Rules provide SUEZ the
right to deny or terminate service without prior notice to any customer or applicant and without the customer’s or applicant’s permission when conditions immediately dangerous or hazardous to life,
physical safety, or property exists, or if necessary to prevent a violation of federal, state or local safety or health codes. (Ref: IDAPA 31.21.01, Rule 303)
Failure to Comply with Notice of Determination
Water service will be withheld (or terminated) for failure to comply with a Notice of Determination requiring installation of an approved backflow assembly. A backflow determination review will be part of any new service establishment process, and may also result from site inspections of existing service locations.
Failure to comply with any notice of determination will result denial of water service to new customers,
or immediate termination for existing connections. (Ref: IPUC SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations, Sheet No. 13-15, and IDAPA 31.21.01, Rule 303)
Failure to Comply with Notice to Test
A Notice to Test may be sent to all registered backflow assembly owners each year as a reminder of annual testing requirements. These notices clearly indicate a testing due date based on irrigation season or the anniversary date of prior testing.
Any assembly owner who fails to provide timely evidence of annual testing by a state licensed Backflow Assembly Tester will receive an Initial Notice of Termination.
Initial Notice of Intent to Terminate Service
Any backflow assembly owner who does not comply with annual state testing requirements will be sent an Initial Notice of Termination (See Appendix G) 10 days prior to a proposed date of termination.
This Initial Notice of Termination will include:
● The reason(s), citing Idaho Public Utilities Commission (IPUC) and Idaho Department of
Environmental Quality (DEQ) rules, why service will be terminated. ● The proposed date of termination. ● Actions to be taken to avoid termination, including details on the approved assembly type, premise isolation location, and ongoing test requirements for protection. ● Complaint filing and service re-establishment instructions.
Customers can avoid termination by providing SUEZ with evidence of annual testing, or by demonstrating to SUEZ’s Cross-Connection Control Specialist(s) that permanent physical separation
exists between potable water service and related cross connection hazards. (Ref: IPUC SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations, Sheet No. 14)

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Final Notice of Intent to Terminate Service
SUEZ will diligently attempt to contact any backflow assembly owner who is out of compliance with state testing requirements. Either in person or by telephone, contact will be attempted to advise owners and customers of the proposed action. SUEZ staff will also make clear steps that can be taken to avoid termination.
At least twenty-four (24) hours before the proposed date of termination, SUEZ will provide a final notice of intent to terminate water service. This notice will include:
● The reason(s), citing IPUC and DEQ rules, why service will be terminated. ● The proposed date of termination. ● Actions to be taken to avoid termination. ● Complaint filing and service re-establishment instructions.
Customers can avoid termination by providing evidence of annual testing, or by demonstrating to SUEZ’s Cross-Connection Control Specialist(s) that permanent physical separation exists between
potable water service and related cross connection hazards. (Ref: IPUC SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations, Sheet No. 14)
Reestablishing Service After a Cross Connection Related
Termination
Following a cross connection related service termination, customers may contact SUEZ to schedule a site inspection for service reestablishment. Prior to reconnection, it will be the responsibility of the customer to demonstrate to SUEZ’s satisfaction that the root cause for termination has been addressed. At a minimum, this will require completion of backflow test by a state licensed backflow assembly tester. In locations where an approved assembly was not in place, it will require installation and inspection of an approved backflow assembly per determination instructions from SUEZ Water
Idaho’s Cross-Connection Control Specialist(s). Assembly owners will be responsible for the full cost of assembly installation and testing.
Alternatively, if a customer can demonstrate to SUEZ’s satisfaction that the cross connection hazard has been eliminated, water service may be reestablished without the need for premise protection. SUEZ’s Cross-Connection Control Specialist must witness or inspect the permanent physical separation from any related cross connection hazards. Further determination of the need for backflow
protection will be made at the discretion of SUEZ’s Cross-Connection Control Specialist (s).
(Ref: IPUC SUEZ Water Idaho Inc. Rate Schedules and Rules and Regulations, Sheet No. 14)
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APPENDIX A – NOTICE OF DETERMINATION
Client Name
Company Name Street Address
Address line two
City, State zip code

Month ##, 2017
SUEZ CROSS-CONNECTION CONTROL PROGRAM NOTICE OF DETERMINATION Dear TBD, It has been determined by SUEZ that an approved backflow assembly is required at your service location. This Notice of Determination is meant to inform you of state requirements to install, maintain, and annually test your required backflow assembly (IDAPA 58.01.08.552.06).
Determination requirements for your premise:
Premise Service Location: (Address - Service Line)
Determination: (Install or Upgrade)
Required Assembly Type: (ie. Reverse Pressure Backflow Assembly)
Location for Installation: To be installed immediately after point of
connection, but prior to any sub-premise point of
service… Ongoing Test Requirements: Annual inspected and testing by state lic. tester Failure to comply with this notice may result in denial or termination of water service to your property.
Yours sincerely,
SUEZ NAME AUTHORIZED COMPANY REPRESENTATIVE CROSS-CONNECTION CONTROL PROGRAM PO BOX190420 BOISE, ID, 83719 TEL [phone]
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APPENDIX B – DOOR TAG (DETERMINATION)

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APPENDIX C – RESIDENTIAL PROPERTY

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APPENDIX D – COMMERCIAL PROPERTY

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APPENDIX E – NOTICE TO TEST (PAGE 1)

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APPENDIX E – NOTICE TO TEST (PAGE 2)

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APPENDIX F – APPROVED TEST FORM
Premise Details
Premise Name Premise Address
Required Protection  Premise  Irrigation  Fire  Other _______________________
Assembly Location

Assembly Details
Assembly of Record New or Replaced
Serial Number
Size
Make and Model
Assembly Type
Initial Test:  Pass  Fail Repair:  Yes  No
Leaked  Closed Tight 
Leaked  Closed Tight 
Open at _____ lbs.

Open Under 2# (or did not open)
Open at _____ PSI Open Under 2# (or
Final Test
PSI Across_________ Closed Tight  PSI Across_________ Closed Tight  Open at_____ lbs. Reduced Pressure Back On 
*In completing and submitting this test report, the Tester certifies that the assembly has been tested and maintained in accordance with applicable state regulations and SUEZ’s rules and regulations. Assembly Owner Contact Details Final Tester Sign-Off Name _____________________________________ Test Date ___ /___ /____ Mailing Address ___________________________ License # ____________
CITY_____________ STATE _________, ZIP ________ NAME _______________ PHONE (___)________________ EMAIL____________ SIGNATURE OF TESTER
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APPENDIX G– INITIAL NOTICE OF TERMINATION
Client Name
Company Name Street Address
Address line two
City, State zip code

Month ##, 2013 SUEZ CROSS-CONNECTION CONTROL PROGRAM NOTICE OF INTENT TO TERMINATE SERVICE Dear TBD, IPUC Utility Customer Relations Rules provide SUEZ with authority to deny or terminate service without prior notice to any customer when conditions immediately dangerous or hazardous to life, physical safety, or property exists, or if necessary to prevent a violation of federal, state or local safety or health codes. (Ref: IDAPA 31.21.01, Rule 303) You have failed to provide evidence of installation and testing for a required cross connection
control assembly on your water service line. This inaction is deemed a threat to public health. As a
result, water service to the following address will be turned off after 8:00 am on the date listed
below.

Service Address: (Address and Service Line)
Shut Off Date: TBD Notice Date: TBD Action you can take to avoid termination: • Contact SUEZ Water Idaho with proof of assembly installation and testing by a state licensed backflow tester.
• Contact Suez Water Idaho Verify physical disconnection from the source of your cross connection hazard.
If you remain unsatisfied with the company, you may file a complaint with the Idaho Public Utilities Commission, PO Box 83720, Boise, ID 83720-0369. [phone].
SUEZ
CROSS-CONNECTION CONTROL PROGRAM
PO BOX190420
BOISE, ID, 83719
TEL [phone] DEFINITIONS
Air Gap (AG) A method of preventing backflow by using the unobstructed vertical distance between the lowest opening of any pipe or faucet supplying potable water and the flood level rim of any
receiving vessel such as a tank, vat or fixture. An “approved” air gap separation must be at least twice the effective opening (the inside diameter) of the supply line piping, but never less
than one-inch. Air gap separation requirements are increased, if the discharge end of the pipe could be affected by a sidewall or other obstructions. Approval or Approved
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Acceptable to the administrative authority (Company, Local Jurisdiction, or State) as meeting a standard or requirement.
Approved Backflow Prevention Assembly
A backflow preventer assembly as a unit with properly located and approved shutoff valves and test cocks so the assembly can be approved by a recognized testing agency as meeting material, construction and operating requirements that are acceptable to the administrative authority. Also referred to as “assembly”.
Atmospheric Vacuum Breaker (AVB) A backflow prevention device consisting of an air inlet valve, a check valve seat and an air
inlet vent. When water is shut off to the AVB, the air inlet valve drops and allows air to enter the device. AVBs are designed to only protect against back siphonage conditions in both low health and high health hazard conditions. Auxiliary Water Supply
Any water supply, on or available to the premises, in addition to the approved potable water supplied by the purveyor.
Backflow The undesirable reversal of flow of water, other liquids, mixtures, gases or substances from the intended direction of flow in potable water distribution piping caused by backsiphonage or backpressure conditions.
Backflow Assembly Tester (BAT) A person who has shown competence to test and maintain backflow prevention assemblies and who is certified in accordance with the applicable state agency or other administrative authority. Also referred to as “Certified or Licensed BAT”.
Backflow Preventer A device, assembly or means used to prevent backflow from entering the potable water
system.
Backflow Prevention Assembly (BPA) See “Approved Backflow Prevention Assembly”
Backflow Prevention Device A backflow preventer generally not designed for in-line testing or repair such as an atmospheric vacuum breaker, single check or dual check. Also referred to as “Backflow
Prevention Assembly”
Backpressure A source of pressure which exceeds the operating pressure of the potable water supply and could cause water or other substances to flow opposite of their intended direction. This type of backflow could be caused by pumps, thermal expansion, elevation or other sources of pressure.
Backsiphonage The negative pressure (below atmospheric pressure) or reduced pressure within the distributing pipes of a potable water supply that creates a partial vacuum causing water or other substances to flow opposite of their intended direction. This type of backflow could be caused by a loss of pressure in a water supply main or fire hydrant demand.
Check Valve (CV)
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Cross-Connection Control Program
A general term used for a variety of valves designed to allow flow in only one direction.
Confined Space Three characteristics must be present to identify this safety hazard: limited or restricted
means of entry or exit, large enough to enter and perform work and are not designed for continuous occupancy. Confined spaces may include underground vaults, tanks, storage
bins, manholes, pits, silos, underground utility vaults and pipelines.
Cross Connection Any actual or potential connection between a potable water supply and any pipe, vessel, tank, plumbing fixture, equipment or device through which it is possible for used, polluted or
contaminated water or any other substance to enter into the potable water system.
Cross-Connection Control Program (CCCP) The administrative and technical procedures the water purveyor implements and maintains to protect the public water system from contamination and pollution due to cross connections.
Customer Any person served by a public water system. Also referred to as “consumer” or “water user”.
Degree of Hazard The type of potential risk or hazard such as pollution or contamination that is determined by
an evaluation of the conditions within a consumer’s water system.
Determination Determining the probability of an actual connection between the potable water supply and a non-potable substance, the existence of a backflow condition, the failure of existing backflow
protection and the likelihood that the non-potable substance will have an adverse effect on the distribution system or the water consumer. Device See “Backflow Prevention Device”
Distribution System
All the piping components of a water system that convey water from the transmission mains linked to source, storage and treatment facilities to the point of delivery to a consumer.
Double Check Detector Assembly (DCDA) An approved assembly consisting of two approved double check valve assemblies, set in parallel, equipped with a meter on the bypass line for the purpose of detecting small amounts of water leakage or unauthorized use. DCDAs are designed to protect against both
backsiphonage and backpressure in low health hazard conditions. Double Check Detector Assembly–Type II (DCDA-II) An approved assembly consisting of an approved double check valve assembly with a bypass installed around the second check valve that is equipped with a meter and an approved check valve. The bypass line is for detecting small amounts of water leakage or
unauthorized use. DCDA-IIs are designed to protect against both backsiphonage and backpressure in low health hazard conditions. Double Check Valve Assembly (DCVA) An approved assembly consisting of two independently-operating check valves, loaded to the closed position by springs or weights that are installed between two tightly-closing resilient-seated shutoff valves with four properly located test cocks for testing. DCVAs are designed to
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protect against both backsiphonage and backpressure that are subject to low health hazard conditions. Dual Check Valve A device consisting of two spring-loaded independently-operating check valves. Some types
may not be testable or repairable in-line. Dual checks are illegal in the State of Idaho.
Emergency An unforeseen event that causes damage or disrupts normal operations in a public water system and requires immediate action to protect public health and safety. Fire Sprinkler Systems The protective sprinkler heads and piping systems designed to deploy under certain circumstances to extinguish or control fires. Systems can contain water, air, nitrogen or other chemicals such as antifreeze.
Flow-Through Fire Protection System
A fire system constructed with approved potable water piping, fixtures and materials and designed so the potable water regularly moves through the fire system piping to avoid stagnation. These combination fire systems are only connected to the public water supply and they do not have fire department pumper connections. Also referred to as “combined” or
“multi-purpose” fire sprinkler systems.
Health Hazard
Any physical, chemical, biological or radiological substance that may enter the drinking water supply and impair the quality of the potable water and may result in injury, poisoning or the spread of disease. Also referred to as “high health hazard”, “contamination hazard” or “severe health hazard”.
Low Health Hazard Those contaminants which, at the levels found in the water, could cause adverse aesthetic
problems to the drinking water supply such as taste, odor and color of the water but do not present a danger to public health. Also referred to as “low hazard”, “non-health hazard” and
“pollution hazard”.
Non-potable Fluid Any water, liquid, gas or other substance which is not intended for human consumption.
Non-potable Piping System
A piping system made of materials that are not approved for potable use and which can affect the aesthetics or degrade the quality of the water.
Non-potable Water Distribution System A system that carries water for non-potable use.
Plumbing The materials and fixtures used in the installation, removal, maintenance and alteration of
piping, fixtures, appliances and appurtenances in connection with sanitary or storm drainage facilities, waste venting systems and water supply systems that are within or adjacent to any building or structure.
Plumbing Code The standards developed by a committee or organization designed to provide consumers with safe and sanitary plumbing systems. The intent of the code is to create a reference
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Cross-Connection Control Program
manual that can be adopted by state or local jurisdictions for uniformity and safety in plumbing practices.
Point of Delivery
The connection where the public water system connects to a consumer’s water system.
Point of Hazard The point where a direct, indirect or potential cross-connection can be determined. Hazard points include fixtures and any systems connected to potable water piping including boilers, fire protection services or systems where the possibility of chemical contact or stagnation exists.
Pollution An impairment of the quality of the public potable water supply which does not create a hazard to the public health, but which does adversely affect the aesthetic qualities of such potable water for domestic use. Also referred to as “low hazard” or “non-health hazard”. See also “Contaminant”.
Potable Water
Water which is safe for human consumption, free from harmful or objectionable materials that could cause injury, disease or harmful physiological effects.
Premise Any property where water service is provided, including all buildings, improvements, moveable and permanent structures.
Premise Isolation
The practice of protecting the public potable water supply by installing an approved backflow prevention assembly or an approved air gap at or near the point where the water supply enters the premises, and before any other branch connections, to isolate the consumer’s water system from the water supplier’s distribution system. While this approach protects the public water supply, it does not negate further need for sub-premise isolation on the customer’s plumbing system. Also referred to as “containment”.
Pressure Vacuum Breaker Assembly (PVBA) An approved assembly consisting of a spring-loaded check valve loaded to the closed position, an independently-operating air inlet valve loaded to the open position and installed as a unit between two tightly-closing resilient-seated shutoff valves with two test cocks properly located for testing. PVBs are designed to protect only against backsiphonage in both low health and high health hazard conditions. Public Health Hazard A condition, device or practice that may allow the introduction of waterborne disease organisms or harmful chemical, physical or radioactive substances into a public water system and which creates an unreasonable risk to health. Public Water System A system to provide the public with piped water for consumption. Federal, state or local laws, statutes, codes or rules define public water systems and how they are classified.
Reduced-pressure Principle Backflow Assembly (RPBA) An approved assembly consisting of two independently-operating check valves, spring loaded to the closed position, separated by a properly located and independently-operating spring loaded differential pressure relief valve loaded to the open position and installed as a
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unit between two tightly-closing resilient-seated shut-off valves with four test cocks properly located for testing. RPBAs are designed to protect against backsiphonage and backpressure in both low health and high health hazard conditions. Reduced-Pressure Principle Detector Assembly (RPDA) An approved assembly consisting of two approved reduced-pressure backflow assemblies, set in parallel, equipped with a meter on the bypass line for the purpose of detecting small amounts of water leakage or unauthorized use. This type of assembly is most commonly used on fire line water services in place of an approved reduced pressure backflow
assembly, if approved by the local water purveyor. RPDAs are designed to protect against backsiphonage and backpressure in both low health and high health hazard conditions. Reduced-pressure Principle Detector Assembly–Type II (RPDA-II) An approved assembly consisting of an approved reduced-pressure backflow assembly with a bypass installed around the second check valve that is equipped with a meter and an
approved check valve for the purpose of detecting small amounts of water leakage or unauthorized use. RPDA-IIs are designed to protect against backsiphonage and
backpressure in both low health and high health hazard conditions.
Service Connection The piping connection where water is conveyed from the water purveyor’s distribution main to a consumer’s premises. For a community water system, the portion of the service connection
which conveys water from the distribution main to the consumer’s property line or to the service meter is under the jurisdiction of the water purveyor.
Single Check Valve A device consisting of a single check that is intended to allow water to flow in the normal direction. Some types may not be testable or repairable in-line.
Spill-resistant Pressure Vacuum Breaker Assembly (SVBA)A backflow assembly
containing an independently-operating, internally-loaded check valve and independently-operating loaded air inlet valve located on the discharge side of the check valve. It is equipped with a properly located resilient-seated test cock, a properly located vent valve and tightly-closing resilient-seated shutoff valves attached at each end of the assembly. SVBs are designed to protect against backsiphonage in both low health and high health hazard condition
Stand-alone Fire Suppression System A piping system connected to the public water supply that extends into a consumer’s premises and is only intended to serve as a water supply for an emergency fire protection system. Also called “dedicated fire suppression system”.
Stand-alone Irrigation System A piping system connected to the public water supply that extends into a consumer’s
premises and is only intended to serve as a water supply for an irrigation system. Also called “dedicated irrigation system”.
System Hazard The actual or potential threat to the components of a piping system or to the quality of the water in public and private plumbing systems.
Test Equipment The electronic or mechanical equipment recognized by the administrative authority that is designed to field test the operational performance of a backflow prevention assembly. Also referred to as “Differential Pressure Gauge”, “Test Kit”.
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Thermal Expansion The pressure increase due to a rise in water temperature.
Thermal Expansion Tank
A container equipped with an air bladder which is used to safely control the expansion of water when a closed loop plumbing system is created. Installation of the tank may be required by administrative authorities or plumbing code regulations. Toxicity The degree to which a substance is toxic or poisonous and affects the quality of the water
supply. University of Southern California (USC), Foundation for Cross Connection Control and Hydraulic Research (USC FCCCHR) An agency that conducts laboratory and field tests to evaluate and grant “Certificates of Approval” to manufacturers of backflow prevention assemblies that meet USC-approved
standards.
Vacuum
Any pressure less than that exerted by the atmosphere.
Vault An enclosure, above or below ground, designed to protect a backflow prevention assembly and approved by the administrative authority.
Waterborne Diseases Any disease caused by pathogenic microorganisms which are directly transmitted when contaminated water is consumed.
Water Purveyor Any agency, subdivision of the state, corporation, firm, company, mutual or cooperative association, institution, partnership, person or other entity that owns or operates a public
potable water system. It also means the authorized agents of the entities listed above. Also referred to as “Water Supplier”.
Water Source Any lake, river, stream, spring, canal, groundwater supply, impoundment or other source from which water is obtained for a water system.
Water Supply System
The system of water service and distribution piping, including all necessary connecting pipes, fittings, valves, fixtures and appurtenances, that are designed for the provision of potable water.

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Protect your family,stay informed andconserve water.
√ Keep your water safe to drink with backflow prevention.
√ Keep your bills low with water conservation tips.
√ Keep informed and up to date with us.
Tips inside on how to use water wisely:
VEO-W-22-02
IPUC DR 140 Attachment 2
Page 1 of 8
To view your annual water quality report, launch this QR code or visit https://mywater.veolia.us/ water-in-my-area/water- quality-reports.
Dear Customer:
Earlier this year, Veolia completed its merger with SUEZ. You’ve likely also noticed that, despite the name change, you haven’t seen any changes to the service — or the people who provide it — that you have grown accustomed to over generations.
Our highest priority will continue to be delivering quality drinking water to all our customers smoothly, efficiently and safely. You can help. To help us maintain our extraordinary water quality in the Treasure Valley, we are asking for a quick check to see whether your home needs backflow protection. At the same time, we want to help you. We are going to be stepping up our efforts to offer our community choices for water conservation – that can add up to big savings for you.
Backflow assemblies are mechanical devices that prevent contaminants from entering the public drinking water supply. Homes and businesses are required by Idaho state law to have properly installed backflow protection with annual testing. Please review this guide to learn what this means for you.
When you choose to conserve water, the benefits add up rapidly. Watching your water bills consistently drop is incredibly satisfying. So is the boost you give to Treasure Valley agriculture and the stability conservation brings to our community. You’ll find a number of convenient options for conservation in this guide.
I invite you to review this guide and learn more about backflow devices, cross connection and how we serve the Treasure Valley. Feel free to contact our customer service team with questions or to check your account details at 362-7304. As always, thank you for trusting us to deliver an essential service to you and your family.
Marshall Thompson, Vice President and General Manager, Idaho Operations VEO-W-22-02
IPUC DR 140 Attachment 2
Page 2 of 8
Backflow Education
What is backflow?
Backflow is the reversal of the flow of water in the plumbing system. It can occur when the
pressure in the water main or a home’s plumbing system changes.
What is a backflow prevention assembly, and do I need one?
A backflow prevention assembly is a mechanical device that prevents non-potable water
from entering the drinking water system. If you have a sprinkler system installed at your
home, you are required by the Uniform Plumbing Code to have an approved backflow
assembly installed and annually inspected. It’s a good idea to test your backflow assembly
every spring when you turn your irrigation system on.
What if I have separate pressurized irrigation service?
If there is no physical connection between the pressurized irrigation system and the public
water supply, there is no need to have a backflow assembly. If there is any connection
between the two water supply systems, you must have a backflow assembly installed and
tested annually.
How do I get my backflow assembly tested?
A complete list of water professionals licensed as Backflow Assembly Testers by the State
of Idaho can be found at https://apps.dopl.idaho.gov/DOPLPublic/LPRBrowser.aspx.
• Under Profession, select “Water & Wastewater Professionals”
• Under license type, select “BAT-Backflow Assembly Tester”
Visit this state website to find a
professional to test your backflow
assembly. Protect your neighbors and
prevent water supply contamination!
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IPUC DR 140 Attachment 2
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Backflow Education
How am I at risk if there is a backflow incident?

Below are common backflow assemblies used by our customers.

If there is backflow at your home, you could
contaminate your drinking water with non-
treated water from an irrigation canal or
water pooled around a sprinkler head that has
fertilizer on it. Also, if you use your hose
to fill a wading pool or hot tub, a reversal of the
water flow could siphon pool or spa chemicals
back through the garden hose and into your
house’s plumbing.
Garden hoses that are used to apply chemical
fertilizers or pesticides are also susceptible to
drawing contaminants into your home. If your
home was built after 1985, it should be
equipped with backflow-preventing hose bibs.

If your home is older, you need to check to make
sure you have the proper protection for
outside faucets.
Don’t forget to protect your family – Test your backflow assembly!
If you have a sprinkler system connected to
the public water supply or own a commercial
property, you are required by Idaho state law to
have an approved backflow assembly installed
and tested annually.
Backflow assemblies are mechanical devices
that safeguard public health by preventing
contaminants from entering the public
water supply.
Reduced Pressure Backflow Assembly Double Check Valve Assembly
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IPUC DR 140 Attachment 2
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Backflow Education
Below are common backflow assemblies used by our customers.

If there is a backflow incident at just one home
in a neighborhood, there is the potential for
contaminants to spread into the public water
supply, threatening your neighbors.
A properly operating backflow
assembly can help
prevent this.
Don’t forget to protect your family – Test your backflow assembly!
If you are unsure, please contact us to schedule
a determination survey. Our Backflow Inspectors
can provide you with details about approved
devices, premise isolation location and
information for ongoing test requirements.
Call 208-362-7304 to schedule an appointment.
Pressure Vacuum Breaker Assembly
Remember,
failure to provide
for ongoing
maintenance and
annual testing 
of an approved
backflow
assembly
may result in
termination
of service in
accordance
with the Idaho
Public Utilities
Commission
(IPUC) Customer
Relations Rules
and Regulations.Do I need a backflow assembly?
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IPUC DR 140 Attachment 2
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Water Conservation
Conserving water helps keep your water bill down. In the summer months, many customers use more water to irrigate lawns and gardens, wash cars and fill swimming pools. By using water wisely, you can maintain a healthy landscape and keep more money in your pocket too.
You can make a difference! Here are just a few ideas to help conserve water inside and outside your home.
• Water during the coolest time of the day when more water is
absorbed into the lawn and less evaporates into the air.
• Inspect your sprinkler heads frequently keeping them free of
grass and other debris to ensure they work properly.
• Water deeply and less frequently. Apply enough water for the
moisture to soak into the root zone. Remember, overwatering
is just as damaging as under watering.
• Use a broom to clean garages, sidewalks and driveways instead
of hosing everything down.
• Soak pots and pans instead of letting the water run while you
scrape them clean
• When using the washing machine or dishwasher, make sure it is
fully loaded. Also, use the light wash setting on your dishwasher.
• Put food coloring in the toilet tank. If colored water appears in
the bowl without flushing, there’s a leak that needs repairing.
• Shortening shower time by two minutes can save up to 150 gallons
per month. A short shower uses less water than taking a bath.
Close the faucet
while brushing
your teeth,
shaving, or
washing your
face. This one tip
can lead you to
save up to
3,000 gallons
per year.
Close the faucet
while brushing your
teeth, shaving, or
washing your face.
This one tip can
lead you to save
up to 3,000 gallons
per year.
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IPUC DR 140 Attachment 2
Page 6 of 8
Water Conservation
Wash dark clothes in
cold water to save on
water and energy while
helping your clothes
retain their color.
Wash fruits and
vegetables in a
pot filled with
water instead
of under an
open faucet.
Reuse the water
for houseplants.
Set your lawn mower
higher. Taller grass
shades the roots and
retains moisture.
Monitor your water bill!
• Sign up for an online account at mywater.veolia.us to review your water usage and receive notifications.
• Take our Conservation Quiz to find where you can save water every month: mywater.veolia.us/basic conservation-survey
Visit University of Idaho’s Extension for gardening and landscaping tips: https://www.uidaho.edu/extension/landscapesConsider planting low-water
plants in your yard or garden.
How to reach us You can reach our Customer Service:
Monday – Friday, 8:00 am - 4:30 pm
208-362-7304
(After-hours, holidays and emergencies
208-362-1300)
[e-mail] or at mywater.veolia.us
Facebook: Veolia Water Idaho
Twitter: @VeoliaWaterID
Check: mywater.veolia.us/idaho/water-in-my-area for more information about how we serve you.
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IPUC DR 140 Attachment 2
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IPUC DR 140 Attachment 2
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