TO:
Honorable Mayor and Members of the City Council
THROUGH:
Talyn Mirzakhanian, City Manager
FROM:
Erick Lee, Public Works Director
Jeff Page, Utilities Manager
Sandy Nimat, Environmental Compliance Supervisor
SUBJECT:Title
Consideration of Adopting a Cross-Connection Control Plan for Compliance with the State's New Regulations in the Cross-Connection Control Policy Handbook (Budgeted) (Public Works Director Lee).
(Estimated Time: 1 Hr.)
ADOPT
Body
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RECOMMENDATION:
Staff recommends that the City Council adopt the City of Manhattan Beach Cross-Connection Control Plan (CCC Plan), prepared in accordance with the Cross-Connection Control Policy Handbook (CCCPH), and authorize submittal to the State Water Resources Control Board’s Division of Drinking Water (DDW) for final approval, as required by state drinking water regulations.
FISCAL IMPLICATIONS:
The internal fiscal implications associated with the recommended action are estimated to total $50,000 for Fiscal Year 2025-2026. These costs relate to consultant fees required for ongoing training and program support. Sufficient funding for these activities is available in the Public Works Department’s budget for the Fiscal Year 2025-2026 within the Water Fund.
The external costs to individual water customers will vary significantly and are dependent on the specific conditions and hazard classifications identified during required cross-connection control hazard assessments. Properties determined to be unprotected or insufficiently protected will be required to install, test, and maintain appropriate backflow prevention assemblies. The costs associated with these compliance actions, including equipment, labor, permitting, and ongoing testing, will be the responsibility of the affected property owners.
BACKGROUND:
Cross-connections pose a significant risk to drinking water quality, potentially allowing contaminants to backflow into the public water supply. To eliminate or mitigate these risks, the State Water Resources Control Board (SWRCB) adopted an updated Cross-Connection Control Policy Handbook (CCCPH), replacing the prior Title 17 framework. The new standards took effect on July 1, 2024.
Under this mandate, all public water systems must prepare and submit a detailed Cross-Connection Control Plan by July 1, 2025 to the Division of Drinking Water (DDW), the regulatory branch of the SWRCB responsible for enforcing drinking water safety requirements. Final implementation of the CCC Plan is contingent upon DDW review and approval.
To enable compliance, the City Council adopted Ordinance No. 24-0004 (Attached) on November 19, 2024, which amended the Manhattan Beach Municipal Code to grant the City legal authority to implement, inspect, and enforce the CCC Plan.
DISCUSSION:
The CCC Plan is a detailed regulatory and operational document that fulfills all ten required program elements under the CCCPH and aligns with DDW expectations for cross-connection protection. A summary of the Plan’s contents is below.
1. Operating Rules and Legal Authority
• The Plan is underpinned by City of Manhattan Beach Ordinance 24-0004, providing enforceable authority to require and monitor backflow protection.
• The ordinance establishes an implied service contract between the City and all Water Users, mandating CCC compliance as a condition of service.
• The authority to terminate service for non-compliance is essential for meeting DDW enforcement expectations.
2. CCC Program Administration
• The City has designated a certified Cross-Connection Control Program Coordinator (CCCPC) with authority to track, manage, and report program metrics.
• A certified Cross-Connection Control Specialist (CCCS) is available within one hour for emergency consultation, a DDW requirement for systems with more than 3,000 service connections.
• Administrative and technical oversight will be shared between staff and qualified contractors.
3. Hazard Assessments
• The CCC Plan mandates hazard surveys of all new and existing water connections.
• Initial assessments are scheduled based on priority risk tiers, with re-evaluations occurring every 5 to10 years.
• Site Supervisors must be designated at complex properties and trained in backflow risks and reporting responsibilities.
4. Backflow Prevention Requirements
• The City’s approach is based on premises containment using approved assemblies - e.g., Reduced Pressure Principle Assembly (RP), Double-Check Backflow Prevention Assembly (DC), and Air Gap (AG).
• Requirements align with CCCPH and DDW guidance, including enhanced standards for fire lines, recycled water connections, and multi-use commercial properties.
• All installations must be inspected and recorded prior to activation.
5. Certified Personnel
• Only certified Backflow Prevention Assembly Testers (BPATs) and CCCSs may perform testing and inspections.
• The City maintains a pre-qualification and disciplinary framework consistent with DDW oversight expectations.
• BPATs must report deficiencies, modifications, and observed hazards immediately.
6. Assembly Testing and Compliance
• All devices must be tested at installation, annually, and following repair or suspected contamination.
• Testing results are submitted via SwiftComply, with failed test repairs due within 14 days.
• Failure to test or repair within designated timeframes may result in water service disconnection, as permitted by the ordinance.
7. Recordkeeping
• The City will maintain all required records outlined in CCCPH Section 3.5.1, including:
o Hazard assessments.
o Assembly inventories and test histories.
o Backflow incident documentation.
o Outreach records (at least three years).
• These records must be made available to DDW upon request and retained in accessible formats (paper, digital, and GIS-compatible systems).
8. Backflow Incident Response
• The CCC Plan includes a structured incident response protocol:
o Identification and isolation of contaminated areas.
o Notification of affected users.
o Emergency coordination with DDW and Los Angeles County Public Health.
o Public notification when required under Title 22 (e.g., Tier 1 notices).
o Root cause analysis and mitigation documentation.
• Incidents must be reported to DDW within 24 hours of confirmation.
9. Public Outreach and Education
• In compliance with CCCPH and DDW expectations, the City is launching an expansive education program targeting both residential and commercial audiences:
o Water bill inserts, brochures, and compliance flyers.
o Online educational hub on the City’s website with tutorials, FAQs, and schedules.
o Presence at community events (e.g., Water Harvest, Hometown Fair) to engage residents.
o Social media campaigns to boost awareness and share deadlines.
o Direct outreach to high-risk business sectors, such as medical, food service, and industrial users.
• Educational efforts will be tracked and reported as part of DDW compliance monitoring.
10. Local Coordination
• Staff will coordinate with:
o Los Angeles County Department of Public Health.
o Building and Safety Division (for plumbing permits).
o Fire Department (for fire suppression system assessments).
o DDW (as oversight authority for all reporting and approvals).
Once approved by the City Council, the CCC Plan will be submitted to DDW for formal approval prior to implementation in the Manhattan Beach community.
PUBLIC OUTREACH:
Staff conducted targeted business outreach by hosting meetings with the Downtown Business & Professional Association on September 4, 2024, and the Chamber of Commerce and the North Manhattan Beach Business Improvement District on October 30, 2024. Staff also organized interactive booths and informational sessions at the Hometown Fair and Water Harvest Festival on October 5 and 6, 2024; these events will be utilized for future communication as well
In addition, staff has developed and distributed FAQs, brochures, and flyers related to cross-connection control and established a dedicated webpage with resources and contact details (<https://www.manhattanbeach.gov/departments/public-works/utilities-division/cross-connection-control-ordinance>). Targeted social media campaigns will be launched once program implementation starts.
ENVIRONMENTAL REVIEW:
The City has reviewed the proposed activity for compliance with the California Environmental Quality Act (CEQA) and has determined that the activity is not a “Project” as defined under Section 15378 of the State CEQA Guidelines; therefore, pursuant to Section 15060(c)(3) of the State CEQA Guidelines the activity is not subject to CEQA. Thus, no environmental review is necessary.
LEGAL REVIEW:
The City Attorney has reviewed this report and determined that no additional legal analysis is necessary.
ATTACHMENTS:
1. Cross-Connection Control Program Plan
2. Ordinance No. 24-0004 (November 6, 2024)
3. PowerPoint Presentation