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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 PN guidances, handbook and regulations?
  18. 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 PN (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 E. coli MCL when one of the following occurs:
    • The system has an E. coli-positive check sample following a total coliform-positive routine sample.
    • The system has a total coliform-positive check sample following an E. coli-positive routine sample.
    • The system fails to take all required check samples following an E. coli-positive routine sample.
    • The system fails to test for E. coli when any check sample tests
  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 maximum allowable turbidity limit
    • A failure to meet the minimum log inactivation for more than 4 hours.
    • A failure to maintain the minimum entry point residual disinfection concentration for more than 4 hours and either of the following:
      • A failure to calculate the log inactivation every 4 hours until the residual disinfectant concentration at the entry point is at or above the minimum value.
      • A failure to meet the minimum log inactivation for more than 4 hours.
  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 and has a significant potential to have serious adverse effects on human health as a result of short-term exposure.
  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 relating to monitoring requirements, lead and copper, 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 when 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.
  5. Failure to report an E. coli MCL violation or an E. coli-positive routine or check sample.
  6. Failure to submit a completed assessment form.
  7. Failure to submit certification of completion of a Department-approved start-up procedure by a seasonal system.

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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
TierDeadline for NoticeDelivery 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.
124 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).
230 days
  • Mail or other direct delivery, and any other method as needed to reach others.
31 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 of the problem being corrected/resolved.
  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 Template 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 TitleDocument NumberDescription Click icon to view document. Use browser back button to return.
Tier 1 PN Abbreviated Message3930-FM-BSDW0197Template 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 Exceedance3930-FM-BSDW0185Template 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 Exceedance3930-FM-BSDW0183Template 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 Exceeded3930-FM-BSDW0198Template 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 Level3930-FM-BSDW0200Template 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 Exceeded3930-FM-BSDW0199Template 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 Level3930-FM-BSDW0201Template 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 Treatment3930-FM-BSDW0150Template 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 Process3930-FM-BSDW0495Template 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 Process3930-FM-BSDW0494Template 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 Requirements3930-FM-BSDW0153Template 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 <em>Cryptosporidium</em> Treatment 
Tier 1 PN Failure to Meet Disinfection Requirements at the Entry Point to the Distribution System (for Groundwater Systems)3930-FM-BSDW0151ATemplate and instructions for completing a Tier 1 Notice for the failure to meet disinfection treatment requirements for groundwater systems.  Failure to Meet Disinfection Treatment Requirements 
Tier 1 PN Failure to Meet Disinfection Requirements at the Entry Point to the Distribution System (for Surface Water Systems) 3930-FM- BSDW0151BTemplate and instructions for completing a tier 1 Notice for the failure to meet disinfection treatment requirements for surface water systems  Failure to Meet Disinfection Treatment Requirements 
Tier 1 PN E. coli Maximum Contaminant Level Violation3930-FM-BSDW0182Template and instructions for completing a Tier 1 notice for violation of the E. coli MCL.  Fecal Coliform 
Tier 1 PN Ground Water under the Direct Influence of Surface Water (GUDI) Sources3930-FM-BSDW0496Template and instructions for completing a Tier 1 notice for GUDI sources.  GUDI sources 
Tier 1 PN Loss of Positive Pressure3930-FM-BSDW0180Template 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- Exceedance3930-FM-BSDW0186Template 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 3930-FM-BSDW0187Template and instructions for completing a Tier 1 notice for a Noncommunity water system with an ANL for an exceedance of the nitrate MCL (Acute).  NCWS with an Alternate Nitrate Level 
Tier 1 PN Preparedness Checklist3930-FM-BSDW0181Checklist of action items needed for Tier 1 event.  Preparedness Checklist 
Tier 1 PN Problem Corrected3930-FM-BSDW0188Template and instructions for completing a Tier 1 "Problem Corrected" notice.  Problem Corrected Notice 
Tier 1 PN Waterborne Disease Outbreak3930-FM-BSDW0184Template and instructions for completing a Tier 1 notice for occurrence of a waterborne disease outbreak (Acute).  Waterborne Disease Outbreak 
Tier 1 PN HAB Exceedance Vulnerable Population Warning (VPW) for Children Under 6 -Do Not Drink- Exceeding an EPA Health Advisory for a Cyanotoxin3930-FM-BSDW0203Template and instructions for completing a Tier 1 notice for occurrence of an exceedance of a health advisory level related to a harmful algal bloom for vulnerable populations.  Waterborne Disease Outbreak 
Tier 1 PN HAB Exceedance for Entire Population -Do Not Drink – Exceeding an EPA Health Advisory for a Cyanotoxin3930-FM-BSDW0204Template and instructions for completing a Tier 1 notice for occurrence of an exceedance of a health advisory level related to a harmful algal bloom for the entire population.  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 guideGuide (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 Tier 2 documents 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 TitleDocument NumberDescription Click icon to view document. Use browser back button to return.
Tier 2 PN Chemical or Radiological Maximum Concentration Level -MCL- Exceedance3930-FM-BSDW0191Template 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 Exceedance3930-FM-BSDW0192Template 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 Level3930-FM-BSDW0156Template 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 Assessment3930-FM-BSDW0541Template 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 Coliform3930-FM-BSDW0551Template 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 Actions3930-FM-BSDW0155Template 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 Water3930-FM-BSDW0539Template 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 Monitoring3930-FM-BSDW0154Template 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 <em>Cryptosporidium</em> Monitoring
Tier 2 PN Failure to Install Required Corrosion Control Treatment930-FM-BSDW0195Template 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 Perform Corrective Action - Triggered by E. coli Samples3930-FM-BSDW0543Template 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 <em>E. coli</em> Samples
Tier 2 PN Failure to Perform Corrective Action -Triggered by Total Coliform Samples3930-FM-BSDW0542Template 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 Breakdown3930-FM-BSDW0492Template 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- Exceedance3930-FM-BSDW0194Template and instructions for completing a Tier 2 notice for violation of the fluoride MCL. Fluoride MCL Violation
Tier 2 PN Failure to Meet the Distribution Disinfectant Residual Treatment Technique3930-FM-BSDW0189Template and Instructions for completing a Tier 2 notice for failing to meet the distribution disinfectant residual treatment technique Template and instructions
Tier 2 PN Exceeding an EPA Lifetime Health Advisory Level for Perfluorooctane Sulfonate (PFOS) / Perfluorooctanoic Acid (PFOA)3930-FM-BSDW0006Template and Instructions for completing a Tier 2 notice for Exceeding Lifetime Health Advisory for PFOS/PFOA Template and instructions
Tier 2 PN Exceeding an EPA Lifetime Health Advisory Level for an Unregulated Contaminant3930-FM-BSDW0555Template and Instructions for completing a Tier 2 notice for an Unregulated Contaminant EPA Lifetime Health Advisory Level Exceedance Template and instructions
Tier 2 PN Failure to Complete a Level 2 Assessment (Triggered by E. Coli Samples)3930-FM-BSDW0556Template and Instructions for completing a Tier 2 notice for Failure to Complete a Level 2 Assessment (Triggered by E. Coli) Template and instructions
Tier 2 PN Failure to Respond to an Imminent Health Threat3930-FM-BSDW0557Template and Instructions for completing a Tier 2 notice for Failure to Respond to an Imminent Health Threat Template and instructions
Tier 2 PN Failure to Meet Disinfection Requirements at the Entry Point While Calculating and Providing 1.0-Log Giardia Inactivation3930-FM-BSDW0577Template and Instructions for completing a Tier 2 notice for Failure to Meet Disinfection Requirements at the Entry Point While Calculating and Providing 1.0-Log Giardia Inactivation Template and instructions

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13. Tier 3 PN Templates

All Tier 3 PN Notices are in DEP's eLibrary. Click this icon Tier 3 PN Notices 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 TitleDocument NumberDescription Click icon to view document. Use browser back button to return.
Tier 3 PN Failure to Submit RTCR Report3930-FM-BSDW0550Template 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 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 Monitor3930-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 TitleDocument NumberDescription Click icon to view document. Use browser back button to return.
Emergency Response Plan for Public Water System3900-FM-BSDW0300 Template and instructions for completing an Emergency Response Plan. available in PDF and MS Word format
Operation and Maintenance Plan for Public Water Systems 3900-FM-BSDW0301 Template and instructions for completing an 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. 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 Determining Loss of Positive Pressure Situations (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 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.

2018 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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18. 2010 PN Revisions Training Resources

2010 PN Revisions Training Workbook PN 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.