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General Information About Public Notification (PN)

  1. When and why was the public notification (PN) rule revised?
  2. How are the violations or situations classified?
  3. What specific situations fall into each tier classification?
  4. What are the PN delivery deadlines and which delivery methods can water suppliers use?
  5. What steps should PWSs take when issuing PN?
  6. What information is required in the PN Certification?
  7. How can PWSs prepare for PN before a violation or situation occurs?
  8. How can PWSs access NSF Standard 60 maximum use values for drinking water treatment chemicals?
  9. What must a water supplier do when NSF Standard 60 maximum use values are exceeded?
  10. Tier 1 PN Templates
  11. How should retail grocery and food service establishments respond to a Tier 1 PN boil water advisory?
  12. Tier 2 PN Templates
  13. Tier 3 PN Templates
  14. What are standard terms used in PN?
  15. Where are templates for Operation and Maintenance (O&M) or Emergency Response Plans (ERP)?
  16. Where can I find information about automatic telephone dialing services?
  17. Where can I find EPA contaminant fact sheets?
  18. Where can I find PN guidances, handbook and regulations?
  19. Where can I find 2010 PN revisions training resources?

1. When and why was the public notification (PN) rule revised?

The PN rule became effective on May 6, 2002 and was published in Chapter 109 in August 2002. PN requirements were revised to provide for different delivery deadlines of notices based on the persistence of the violations and the seriousness of any potential adverse health effects that may be involved. In 2009, DEP revised the PN Rule to improve the delivery of Tier 1 public notices and the planning requirements under the Operation and Maintenance (O&M) plan and Emergency Response Plan (ERP). The revisions were published in Chapter 109 on May 9, 2009. Click icon icon (PDF) to view a summary of the revisions. Note that the direct delivery requirements for Tier 1 public notices become effective May 10, 2010. All other revisions are effective May 9, 2009. top


2. How are the violations or situations classified?

The following list shows the tier classification and how they relate to health effects, either as a result of short-term exposure or long-term exposure.

Classifications of Violations and Situations

  • Tier 1 - With the adverse health effects as a result of short-term exposure.
  • Tier 2 - With the potential to cause chronic health effects as a result of long-term exposure.
  • Tier 3 - That cause no health effects. top

3. What specific situations fall into each tier classification?

Tier 1 Violations and Other Situations Requiring Notice Within 24 Hours

  1. Violation of the MCL for total coliforms when fecal coliforms or E. coli are present in the water distribution system or when the water supplier fails to test for fecal coliforms or E. coli when any check sample tests positive for coliforms.
  2. Violation of the MCL for nitrate, nitrite, or total nitrate and nitrite or when the water supplier fails to take a confirmation sample within 24 hours of the system's receipt of the first sample showing an exceedance of the nitrate or nitrite MCL.
  3. Exceedance of the nitrate MCL by noncommunity water systems when permitted by the Department in writing to operate under an Alternate Nitrate Level.
  4. Violations of the MRDL for chlorine dioxide when one or more of the samples taken in the distribution system the day following an exceedance of the MRDL at the entrance of the distribution system exceed the MRDL or when the water supplier does not take the required samples in the distribution system.
  5. Violation of the turbidity MCL of 5 NTU based on an average for 2 consecutive days by a public water system using an unfiltered surface water source.
  6. Violation of a treatment technique requirement for pathogenic bacteria, viruses and protozoan cysts, resulting from a single exceedance of the combined filter effluent maximum allowable turbidity limit.
  7. Violation of a treatment technique requirement for Cryptosporidium , resulting from a failure to provide the level of treatment appropriate for the system's bin classification.
  8. Detection of E. coli in source water samples.
  9. A breakdown in treatment for groundwater sources.
  10. Occurrence of a waterborne disease outbreak or other emergency that adversely affects the quality or quantity of the finished water.
  11. Other violations or situations with significant potential to have serious adverse effects on human health as a result of short-term exposure, as determined by the Department on a case-by-case basis.

Tier 2 Violations Requiring Notice Within 30 Days

  1. All violations of the primary MCL, MRDL, treatment technique requirements, and failure to take corrective action, except where Tier 1 notice is required or when the Department determines that a Tier 1 notice is required.
  2. Violations of the monitoring requirements and additional requirements for groundwater sources, when the Department determines that a Tier 2 rather than a Tier 3 public notice is required, taking into account potential health impacts and persistence of the violation.
  3. Failure to comply with the terms and conditions of any variance or exemption in place.
  4. Other violations or situations determined by the Department to require a Tier 2 public notice, taking into account potential chronic health impacts and persistence of the violation.

Tier 3 Violations and Other Situations Requiring Notice Within 1 Year

  1. Monitoring violations, except when a Tier 1 notice is required or where the Department determines that a Tier 2 notice is required.
  2. Reporting and record maintenance violations for systems recycling their waste streams.
  3. Operation under a variance or an exemption granted.
  4. Availability of unregulated contaminant monitoring results.

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4. What are the PN delivery deadlines and which delivery methods can water suppliers use?

Table describes the delivery deadlines and methods suppliers can use for each Tier type.

Requirements for Issuing Public Notice
Tier Deadline for Notice Delivery Methods to Use
NOTES:
  • DEP may approve other methods.
  • For Tier 1, systems must also initiate consultation with DEP within 24 hours and issue a "Problem Corrected" notice within 24 hours of correcting the problem.
  • DEP recommends consolidating all Tier 3 violations/situations occurring within a given year into an annual notice.
1 24 hours
  • Provide direct delivery of public notice to each service connection using one or more of the following methods: hand delivery, electronic mail, automatic telephone dialing systems, or another form of direct delivery approved in writing by DEP.
  • provide public notice to transient and nontransient service connections (if applicable) by using appropriate broadcast media (radio or television).
2 30 days
  • Mail or other direct delivery, and any other method as needed to reach others.
3 1 year
  • Mail or other direct delivery, and any other method as needed to reach others.

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5. WHAT STEPS SHOULD PWSs TAKE WHEN ISSUING PN?

  1. Determine what tier the violation or situation falls into.
  2. Report to DEP within one (1) hour (for Tier 1 violations/situations and Tier 2 violations involving an MCL, MRDL or TT violation).
  3. Consult with DEP within 24 hours (for Tier 1 violations/situations).
  4. Determine the appropriate method (s) of delivery.
  5. Develop the notice, modifying the templates as needed.
  6. Provide the notice as soon as possible, but within the required time frame.
  7. For Tier 1 PNs, provide a "Problem Corrected" notice within 24 hours.
  8. Send a copy of each notice issued (including repeat notices) to DEP within ten (10) days, along with a certification that all PN requirements have been met.

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6. What information is required in the PN Certification?

The PN Certification formpn fulfills the certification requirements for PN. It must be submitted to DEP within 10 days of the required PN delivery time frame.

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7. How can PWSs prepare for PN before a violation or situation occurs?

PWSs must integrate planning for PN into their ERP and O&M Plans. When a serious violation, waterborne disease outbreak, or other emergency occurs, PWSs will already have an established decision process and chain of command. Preparatory steps must include the following:

  • Identification of probable emergency situations and alternative solutions to respond.
  • PN program that includes:
  • Procedures for 24/7 communications and coordination with the local DEP office and emergency management agency.
  • Procedures for notifying additional recipients.
  • Access to an alternative source of drinking water (i.e., emergency interconnection, bulk hauling capability, bottled water).

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8. How can PWSs access NSF Standard 60 maximum use values for drinking water treatment chemicals?

In order to determine what constitutes a drinking water treatment chemical overfeed, water suppliers will need NSF Standard 60 maximum use values NSF for each drinking water treatment chemical they use. When using the NSF database, remember that maximum use values are specific to the chemical manufacturer.

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9. What must a water supplier do when NSF Standard 60 maximum use values are exceeded?

When a water supplier discovers that a treatment chemical has been overfed, they must notify DEP within one hour to report their appropriate responses and to determine whether PN should be issued.


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10. Tier 1 PN Templates

All Tier 1 PN Notices are in DEP's eLibrary. Click this icon icon to view all Tier 1 documents. Click the icon on right to view individual document in PDF and MS Word formats. Use Ctrl-click to open in new window.
eLibrary Title Document Name Document Number Description Click icon to view document. Use browser back button to return.
Tier 1 PN Abbreviated Message Abbreviated Message 3930-FM-BSDW0197 Template and instructions for completing a Tier 1 abbreviated message when using an automatic telephone dialing system, TV scrollers, bullhorn announcements or radio station news flashes.  Abbreviated Message 
Tier 1 PN Chlorine Dioxide Maximum Residual Disinfectant Level Exceedance Chlorine Dioxide 3930-FM-BSDW0185 Template and instructions for completing a Tier 1 notice for exceedance of the chlorine dioxide MRDL (Acute).  Chlorine Dioxide 
Tier 1 PN Combined Filter Effluent Maximum Turbidity Exceedance Turbidity 3930-FM-BSDW0183 Template and instructions for completing a Tier 1 notice for violation of a treatment technique resulting from a single exceedance of the combined filter effluent maximum allowable turbidity limit (Acute).  Turbidity 
Tier 1 PN Do Not Drink - EPA Health Advisory Level Exceeded "Do Not Drink" PN when an EPA Health Advisory Level has been Exceeded 3930-FM-BSDW0198 Template and instructions for completing a Tier 1 "Do Not Drink" PN when an EPA Health Advisory Level has been exceeded.  Do Not Drink 
Tier 1 PN Do Not Drink - No EPA Health Advisory Level "Do Not Drink" PN without EPA Health Advisory Levels 3930-FM-BSDW0200 Template and instructions for completing a Tier 1 "Do Not Drink" PN without EPA Health Advisory Levels.  Do Not Drink 
Tier 1 PN Do Not Use - EPA Health Advisory Level Exceeded "Do Not Use" PN when an EPA Health Advisory Level has been Exceeded 3930-FM-BSDW0199 Template and instructions for completing a Tier 1 "Do Not Use" PN when an EPA Health Advisory Level has been exceeded.  Do Not Use 
Tier 1 PN Do Not Use - No EPA Health Advisory Level "Do Not Use" PN without EPA Health Advisory Levels 3930-FM-BSDW0201 Template and instructions for completing a Tier 1 "Do Not Use" PN without EPA Health Advisory Levels.  Do Not Use 
Tier 1 PN E. Coli in a Groundwater Source Without 4-Log Treatment Presence of E. coli in a Groundwater Source when 4-log Treatment of Viruses is not Provided 3930-FM-BSDW0150 Template and instructions for completing a Tier 1 Notice for the Presence of E. coli in a Groundwater Source when 4-log Treatment of Viruses is not Provided.  Presence of E. coli 
Tier 1 PN Failure of a Nitrate Removal Process Failure of a key water treatment process involving nitrate removal 3930-FM-BSDW0495 Template and instructions for completing a Tier 1 notice for the failure of a key water treatment process involving nitrate removal.  Failure of a key water treatment process 
Tier 1 PN Failure of Filtration or Disinfection Process Failure of a key water treatment process involving filtration or disinfection 3930-FM-BSDW0494 Template and instructions for completing a Tier 1 notice for the failure of a key water treatment process involving filtration or disinfection.  Failure of a key water treatment process 
Tier 1 PN Failure to Meet Cryptosporidium Treatment Requirements Failure to provide the level of Cryptosporidium Treatment that is appropriate for the System's Bin Classification 3930-FM-BSDW0153 Template and instructions for completing a Tier 1 Notice for the failure to provide the level of Cryptosporidium Treatment that is appropriate for the System's Bin Classification.  Failure to provide the level of Cryptosporidium Treatment 
Tier 1 PN Failure to Meet Entry Point Disinfection Requirements Failure to Meet Disinfection Treatment Requirements for GW and SW systems 3930-FM-BSDW0151 Template and instructions for completing a Tier 1 Notice for the failure to meet disinfection treatment requirements for groundwater and surface water systems.  Failure to Meet Disinfection Treatment Requirements 
Tier 1 PN Fecal Coliform or E. Coli Maximum Contaminant Level Violation Fecal Coliform 3930-FM-BSDW0182 Template and instructions for completing a Tier 1 notice for violation of the MCL for total coliforms when fecal coliforms or E. coli are present (Acute).  Fecal Coliform 
Tier 1 PN Ground Water under the Direct Influence of Surface Water (GUDI) Sources GUDI sources 3930-FM-BSDW0496 Template and instructions for completing a Tier 1 notice for GUDI sources.  GUDI sources 
Tier 1 PN Loss of Positive Pressure Loss of Positive Water Pressure in Distribution System 3930-FM-BSDW0180 Template and instructions for completing a Tier 1 Notice when a Boil Water Advisory is required to be issued in response to a loss of positive pressure in the distribution system where there is evidence of contamination or a water supplier suspects a high risk of contamination.  Loss of Positive Water Pressure 
Tier 1 PN Nitrate, Nitrite or Total Nitrogen Maximum Concentration Level -MCL- Exceedance Nitrate 3930-FM-BSDW0186 Template and instructions for completing a Tier 1 notice for violation of the nitrate, nitrite, or total nitrate and nitrite MCL (Acute).  Nitrate 
Tier 1 PN Noncommunity Water System Exceedance of an Approved Alternate Nitrate Level - ANL NCWS with an Alternate Nitrate Level (ANL) for an exceedance of the nitrate MCL (Acute) 3930-FM-BSDW0187 Template and instructions for completing a Tier 1 notice for a Noncommunity water system with an Alternate Nitrate Level (ANL) for an exceedance of the nitrate MCL (Acute).  NCWS with an Alternate Nitrate Level 
Tier 1 PN Preparedness Checklist Preparedness Checklist 3930-FM-BSDW0181 Checklist of action items needed for Tier 1 event.  Preparedness Checklist 
Tier 1 PN Problem Corrected Problem Corrected Notice 3930-FM-BSDW0188 Template and instructions for completing a Tier 1 "Problem Corrected" notice.  Problem Corrected Notice 
Tier 1 PN Waterborne Disease Outbreak Waterborne Disease Outbreak (Acute) 3930-FM-BSDW0184 Template and instructions for completing a Tier 1 notice for occurrence of a waterborne disease outbreak (Acute).  Waterborne Disease Outbreak 

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11. How should retail grocery and food service establishments respond to a Tier 1 PN boil water advisory?

The PA Department of Agriculture uses this practical guidedoc_icon (PDF) for retail grocery and food service establishments to plan and respond to emergencies that create the potential for an imminent health hazard.


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12. Tier 2 PN Templates

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All Tier 2 PN Notices are in DEP's eLibrary. Click this icon icon to view all Tier 2 documents.Click the icon on right to view individual document in PDF and MS Word formats. Use Ctrl-click to open in new window.
eLibrary Title Document Name Document Number Description Click icon to view document. Use browser back button to return.
Tier 2 PN Chemical or Radiological Maximum Concentration Level -MCL- Exceedance Chemical or Radiological MCL Violation 3930-FM-BSDW0191 Template and instructions for completing a Tier 2 notice for violation of a chemical or radiological MCL. Chemical or Radiological MCL Violation
Tier 2 PN Combined Filter Effluent Monthly Turbidity Exceedance Turbidity (Monthly Violation) 3930-FM-BSDW0192 Template and instructions for completing a Tier 2 notice for a monthly exceedance of the turbidity limit. Turbidity
Tier 2 PN Failure to Calculate and Report a Mean Cryptospridium Level Filtered Systems Failure to Determine and Report Bin Classification 3930-FM-BSDW0156 Template and instructions for completing a Tier 2 notice for a filtered systems failure to determine and report its bin classification Filtered Systems Failure
Tier 2 PN Failure to Complete a Level 1 Assessment Failure To Complete A Level 1 Assessment 3930-FM-BSDW0541 Template and instructions for completing a Tier 2 notice for failing to Complete a Level 1 Assessment. Failure To Complete A Level 1 Assessment
Tier 2 PN Failure to Complete a Level 2 Assessment Triggered by Total Coliform Failure to Complete a Level 2 Assessment Triggered by Total Coliform 3930-FM-BSDW0551 Template and instructions for completing a Tier 2 notice for Failure to Complete a Level 2 Assessment Triggered by Total Coliform. Failure to Complete a Level 2 Assessment
Tier 2 PN Failure to Complete Significant Deficiency Corrective Actions Failure to Take Corrective Action Within Required Time Frame 3930-FM-BSDW0155 Template and instructions for completing a Tier 2 notice for a filtered systems failure to take corrective action within required time frame. Failure to Take Corrective Action
Tier 2 PN Failure to Complete Start-Up Procedure Prior to Serving Water Failure to Complete Start-Up Procedure Prior to Serving Water 3930-FM-BSDW0539 Template and instructions for failure to complete start-up procedure prior to serving water. Failure to Complete Start-Up Procedure
Tier 2 PN Failure to Conduct Cryptosporidium Monitoring Failure to Conduct Required Cryptosporidium Monitoring For Any Three Months Notice 3930-FM-BSDW0154 Template and instructions for completing a Tier 2 notice for a filtered systems failure to conduct required cryptosporidium monitoring for any three months notice. Failure to Conduct Required Cryptosporidium Monitoring
Tier 2 PN Failure to Install Required Corrosion Control Treatment Lead and Copper Rule Treatment Technique Violation 930-FM-BSDW0195 Template and instructions for completing a Tier 2 notice for violation of a treatment technique for the Lead and Copper Rule. Lead and Copper Rule Treatment
Tier 2 PN Failure to Maintain Cryptosporidium Treatment Requirements Failure To Maintain Cryptosporidium Treatment Requirements 3930-FM-BSDW0522 Template and instructions for completing a Tier 2 notice for failure to maintain cryptosporidium treatment requirements. Failure To Maintain Cryptosporidium Treatment Requirements
Tier 2 PN Failure to Perform Corrective Action Triggered by E. coli Samples Failure To Perform Corrective Action Triggered by E. coli Samples 930-FM-BSDW0543 Template and instructions for completing a Tier 2 notice for failure to perform corrective action triggered by e. coli samples. Failure To Perform Corrective Action Triggered by E. coli Samples
Tier 2 PN Failure to Perform Corrective Action -Triggered by Total Coliform Samples- Failure To Perform Corrective Action Triggered By Total Coliform Samples 3930-FM-BSDW0542 Template and instructions for completing a tier 2 notice for failure to perform corrective action triggered by total coliform samples. Failure To Perform Corrective Action Triggered By Total Coliform Samples
>Tier 2 PN Failure to Respond to a Disinfection Treatment Breakdown Failure to Respond to a disinfection treatment breakdown 3930-FM-BSDW0492 Template and instructions for completing a Tier 2 notice for failing to respond to a disinfection treatment breakdown. Failure to Respond to a disinfection treatment breakdown
Tier 2 PN Fluoride Maximum Contaminant Level -MCL- Exceedance Fluoride MCL Violation 3930-FM-BSDW0194 Template and instructions for completing a Tier 2 notice for violation of the fluoride MCL. Fluoride MCL Violation
Tier 2 PN Total Coliform Maximum Contaminant Level -MCL- Exceedance Total Coliform Maximum Contaminant Level Exceedance 3930-FM-BSDW0193 Template and instructions for completing a Tier 2 notice for Total Coliform Maximum Contaminant Level Exceedance.

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13. Tier 3 PN Templates

All Tier 3 PN Notices are in DEP's eLibrary. Click this icon icon to view all Tier 3 documents. Click the icon on right to view individual document in PDF and MS Word formats. Use Ctrl-click to open in new window.
eLibrary Title Document Name Document Number Description Click icon to view document. Use browser back button to return.
Tier 3 PN Failure to Submit RTCR Report Failure To Submit RTCR Report 3930-FM-BSDW0550 Template and instructions for completing a Tier 3 notice for failure to submit Revised Total Coliform Rule (RTCR) report. Failure To Submit RTCR Report
Tier 3 PN Failure to Maintain Records Record Keeping Violation 3930-FM-BSDW0202 Template and instructions for completing a Tier 3 notice for a record keeping violation. Record Keeping Violation
Tier 3 PN Failure to Monitor Monitoring Violation 3930-FM-BSDW0196 Template and instructions for completing a Tier 3 notice for a monitoring violation. Monitoring Violation

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14. Where can I find the required standard health effects language in PN?

This linkcontaminant specific health effects language provides contaminant specific health effects language required to be included in public notices.

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15. Where are templates for Operation and Maintenance (O&M) or Emergency Response Plans (ERP)?

Below are links to eLibrary pages.
eLibrary Title Document Name Document Number Description Click icon to view document. Use browser back button to return.
Emergency Response Plan for Public Water System Emergency Response Plan 3900-FM-BSDW0300 Template and instructions for completing a Emergency Response Plan. available in PDF and MS Word format
Operation and Maintenance Plan for Public Water Systems Operation And Maintenance Plan 3900-FM-BSDW0301 Template and instructions for completing Operation and Maintenance Plan.
Operation And Maintenance Plan

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16. AUTOMATIC TELEPHONE DIALING SERVICE PURCHASE CONSIDERATIONS

Effective May 10, 2010, water suppliers will be required to provide Tier 1 public notices to each service connection within 24 hours. Click icon Considerations when Purchasing Telephone Dialing Services (PDF) to review some considerations when purchasing telephone dialing system services.


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17. EPA CONTAMINANT FACT SHEETS

epaEPA Contaminant Fact Sheets -- U.S. Environmental Protection Agency.

Water suppliers will need to access contaminant information if they experience an extraordinarily high exceedance of an MCL or MRDL that would also exceed health advisory levels. If this occurs, the Tier 2 situation (exceed MCL or MRDL) would be elevated to a Tier 1 situation; consequently, water suppliers would need to include acute health effects language in their Tier 1 PN. The acute health effects language is found in the "policy" document under section 18 titled Policy for Issuing and Removing Water Supply Warnings Policy for Issuing and Removing Water Supply Warnings (PDF) (383-2129-005).


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18. PN GUIDANCES, HANDBOOK AND REGULATIONS

Policy for Determining When Loss of Positive Pressure Situations in the Distribution System Require One-Hour Reporting to the Department and Issuing Tier 1 Public Notification doc icon (PDF) (383-2129-004) -- DEP's technical guidance for evaluating and responding to possible contamination of water distribution systems during loss of positive pressure situations. This guidance includes the criteria for one hour reporting and Tier 1 Public Notification.

Policy for Issuing and Removing Water Supply Warnings Policy for Issuing and Removing Water Supply Warnings (PDF) (383-2129-005) -- DEP's technical guidance for issuing and removing water supply warnings. This guidance includes EPA's health advisory levels and acute health effects language. Water suppliers are required to insert acute health effects language into a Tier 1 PN when EPA health advisory levels are exceeded.

PN Handbook for Community Water Systems (PDF) -- DEP's comprehensive handbook that describes all public notice requirements including the PN revisions that were published in the PA Bulletin on 05/09/09.

2012 Edition of the Drinking Water Standards and Health Advisories epa -- U.S. Environmental Protection Agency.

PA DEP Public Notification Revisions Regulations Final Rulemaking 2010 PN Revisions Training Workbook (5/9/09) -- PN Revisions Final Rulemaking was published in the PA Bulletin on 05/09/09. The Chapter 109 rule revisions are effective May 9, 2009 except those published under 109.408(d) (New direct delivery requirements for Tier 1 public notices) which will become effective May 10, 2010.


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19. 2010 PN Revisions Training Resources

2010 PN Revisions Training Workbook 2010 PN Revisions Training Workbook(PDF) -- This workbook contains the course material from the 2010 PN Revisions course for water suppliers.

2010 PN Revisions Training Q&A 2010 PN Revisions Training Questions and Answers(Word) -- This document summarizes specific questions DEP received during the 19 PN Revisions training sessions that occurred in 2010.