EPA 430/9-74-010
CONSTRUCTION GRANTS PROGRAM
        REQUIREMENTS
 PROTECTION OF SHELLFISH
                   WATERS
                      JULY 1974
       U.S. ENVIRONMENTAL PROTECTION AGENCY
           Office of Water Program  Operations
             Municipal Construction Division
                Washington, D.C.  20460
                                              MCD-06

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            U.S. ENVIRONMENTAL PROTECTION AGENCY
             OFFICE OF WATER PROGRAM OPERATIONS
               PROTECTION OF SHELLFISH WATERS
     The Federal Water Pollution Control Act Amendments of
1972 establish an extensive program to upgrade the quality
of our Nation's waters.  The program of Federal grants for
construction of municipal wastewater treatment plants will
have significant benefits in reducing pollution and improv-
ing water quality.  The effluents from many municipal plants
could impact on shellfish waters, with serious potential for
public health and local shell-fishing industries.  As these
plants are upgraded through the EPA construction grants pro-
gram, it is essential that project designs include provisions
for protection of shellfish waters.

     Presented is a compilation of information to provide a
high degree of reliability in the protection of shellfish
waters.   Most of the requirements are based on existing in-
formation from publications of the Environmental Protection
Agency and the Food and Drug Administration.

     EPA Regional Administrators will work closely with the
Food and Drug Administration to reasonably determine if com-
pleted project designs provide a level of protection which
meets the objectives of these requirements.  In some cases
the need for construction of additional reliability features
may be identified and appropriately accomplished in a project
subsequent to the one being reviewed.  By July 1975 it is
anticipated that designs will be in accordance with the re-
quirements and routine project review by the Food and Drug
Administration would not be necessary.

     These requirements will be revised from time to time as
additional information becomes available.  All users are
encouraged to submit suggested revisions and information to
the Director, Municipal Construction Divison (WH-547), Office
of Water Program Operations, Environmental Protection Agency,
Washington, D.C. 20460.
                                 James L. Agee
                             Assistant Administrator
                        for Water and Hazardous Materials

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            U.S. ENVIRONMENTAL PROTECTION AGENCY
             OFFICE OF WATER PROGRAM OPERATIONS
               PROTECTION OF SHELLFISH WATERS
Purpose;

     The purpose of these requirements is to ensure that
maximum protection is provided for shellfish waters receiving
effluent discharged from municipal wastewater treatment works
proposed for an EPA construction grant.

App1i c abi1i ty:

     These requirements apply to projects which could affect
shellfish waters.

Relationship to National Shellfish Sanitation Program;

     The National Shellfish Sanitation Program  (NSSP) is a
voluntary cooperative program conducted by the Food and Drug
Administration (FDA) of the U.S. Department of Health, Educa-
tion, and Welfare and 23 coastal States and the shellfish
industry.  NSSP requirements are contained in the National
Shellfish Sanitation Program Manual of Operations, Part I,
Sanitation of Shellfish Growing Areas  (1965). Provided are
requirements for design of publicly owned treatment works
to meet the objectives of the Manual of Operations.

Definitions:

     The following definitions apply to the terms used herein:

     Shellfish:  Molluscan shellfish species of oysters, clams,
and mussels.  As used in this bulletin, the term does not
include other species, such as crabs, lobsters, shrimp, or
scallops.

     Shellfish Waters;  Any waters which are classified by
the State as either shellfish growing waters or potential
shellfish growing waters.

     Shellfish Growing Waters;  Waters classified by the State
as acceptable for commercial or recreational harvesting of
shellfish.   In the manual of operations these are classified as
either Approved or Conditionally Approved growing areas.

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     Potential Shellfish Growing Waters;  Waters classified
by the State as not presently acceptable for commercial or
recreational harvesting of shellfish, but which the State
plans to make acceptable in the future by improving certain
conditions.  In the NSSP Manual of Operations these would be
presently classified as either Restricted or Prohibited
growing areas.  To be in this category, the waters must have
been formally classified by the State as potentially meeting
the approved shellfish growing water quality requirements for
the production of shellfish.

Background;

     These requirements are necessary because of the public
health hazards resulting from the harvesting of edible mol-
luscan shellfish from waters subject to discharge of pollutants.
Shellfish are known to concentrate pollutants from the aquatic
environment.  The quality of the shellfish is directly related
to the quality of the overlying waters.  In the past there have
been numerous typhoid fever and infectious hepatitis outbreaks
associated with the consumption of sewage contaminated shell-
fish.  Since shellfish are frequently eaten uncooked or partially
cooked, their habitat must be protected to preclude contamination
and the resultant health hazard.

Action to be taken by the grant applicant;

     1.  Determine if the proposed project could affect shellfish
waters.  Some projects clearly could never affect shellfish
waters, and these requirements do not apply to such projects.
Assistance in making this determination is available from the
State water pollution control agency and the EPA Regional
Administrator.

     2.  Assess the impact of the proposed project on the shell-
fish waters.  This is accomplished during the facility planning
phase  (see Section 35.917, 40 CFR 35).  Coordination with envi-
ronmental protection authorities, shellfish regulatory agencies
(Appendices 1 and 2), and local interests must be initiated
early in the project planning.  The assessment of total impact,
and screening of alternatives for cost-effectiveness analysis
(40 CFR 35, Appendix A) will include, but is not limited to,
the determination of the following:

          a.  Location of the effluent discharge in relation
              to the shellfish waters.

          b.  Volumes of wastewater.

          c.  Effluent quality expected under normal and adverse
              conditions.  Includes bacterial quality, substances

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           that could be toxic (such as heavy metals or pesticides),
           or other materials which could adversely affect public
           health.

       d.  Estimates of the effect on the shellfish waters of combined
           sewer overflows or other uncontrolled discharges from the
           treatment works. Provide information on rainfall frequency,
           duration, and intensity,  or  other conditions,  which cause
           overflows,  bypasses,  or significant reductions in treatment
           efficiency,  and the locations in the project system where
           these conditions will occur.

       e.  A summary of NPDES municipal permit information on
           wastewaters introduced into the municipal system by
           industrial users.

       f.  The reliability of the processes and equipment included in
           the project, including  an estimate of the frequency of
           adverse  conditons affecting the shellfish waters and
           measures included in the project to increase reliability
           of wastewater treatment works performance  or provide
           containment of potentially adverse discharges.

       g.  An evaluation of dilution, dispersion, mixing, thermal
           effects,  and seasonal variations affecting the shellfish
           waters as a result of the proposed project.

       h.  Relate  the present shellfish water conditions to those
           conditions expected during  and after construction of the
           project.  Information on the existing shellfish water
           conditions is available from environmental protection
           authorities, shellfish regulatory agencies,  and public
           health departments.

    3.  Estimate the size of a closed safety zone around the outfall
site.  The closed safety zone is a designated portion of the shellfish
waters adjacent to a source of contamination (such as  an outfall) in
which harvesting of shellfish would be  prohibited. The closed
safety zone is required by the NSSP Manual of Operations between
conditionally approved  growing areas and the source of pollution,
and is subject to review and approval by environmental protection
authorities and shellfish regulatory agencies.  There is a two-fold
objective in designating the closed safety zone.  Both objectives are
related to the time required for pollutants to travel from the source
of pollution,  through the closed safety  zone, to the shellfish  growing
areas.  One objective is to ensure public health is protected by

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preventing pathogen contamination of shellfish waters from normally
operating treatment works.  Mixing, dilution, and natural pathogen
die off occur as the pathogens tranverse the closed safety zone and
the pathogen concentrations are decreased accordingly.  The objective
is achieved by defining the closed safety zone so that the pathogen
concentrations beyond the zone are at acceptable levels under normal
operating conditions.  The second  objective  is to provide the time
necessary for notification to cease harvesting in the shellfish growing
waters following a malfunction in the wastewater treatment works.
Define a closed safety zone to provide the required safety factor
for both objectives. The factors to be considered  in determining
the boundaries for a closed safety  zone are:

       a.  For normally operating wastewater treatment works:

           (1)  The maximum concentration  of contaminants (usually
               coliform bacteria)  expected in the effluent before an
               emergency response plan is  activated.

           (2)  Time and distance from the discharge point for the
               effluent containing  the maximum expected concentration
               of contaminants to  be reduced to permissable levels,
               considering dilution expected under adverse conditions
               in the receiving waters (e. g., high stream flows  and
               spring tides which  result in minimum time of flow
               to the boundary and reduced salinity).

       b.  For a malfunction in wastewater  treatment  works:

           (1)  The total time it would take for the wastewater treat-
               ment works operator to detect a malfunction, notify the
               shellfish regulatory agency,  and for the agency to
               stop shellfish harvesting.  Due consideration should be
               given to adverse conditions such as time of occurrence
                (weekend, holiday, or at night), the areas to be covered,
               and the methods of communication. In some cases
               instrumentation and alarms beyond the level established
               in this publication  can  be provided  to reduce the time re-
                quired to notify  the shellfish regulatory agency of a
               malfunction.

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          (2)   The reliability of wastewater treatment works.
               See paragraph 4a of this publication.

          (3)   The travel time for flow from the points of
               discharge to the Conditionally Approved
               growing areas.  Adverse conditions which
               will reduce travel time, such as river
               stages or tides, will be considered.  Al-
               lowance must also be made for the expected
               degree of mixing.

          (4)   The safety factor to be provided.  Normally
               the travel time through the closed safety
               zone should be twice the time required for
               the notification process to become effec-
               tive.  Where this is not feasible, provide
               increased reliability or storage.

     c.   Each of the above factors has some variability.
         Analyze these factors and determine the optimum
         combination to ensure protection of public health,
         preserve valuable shellfish growing waters, and
         provide for cost-effective wastewater treatment
         works.

4.   Base the wastewater treatment works design on the fol-
    lowing requirements:

     a.   "Design, Criteria for Mechanical, Electric, and
         Fluid System and Component Reliability", EPA-430-
         99-74-001, MCD-05.  Shellfish waters will be
         Reliability Class I.  When conditions warrant
         (e.g. proximity of shellfish beds, unusual chlo-
         rine demand variations, excessive wet weather
         flows) a degree of reliability higher than de-
         scribed in MCD-05 may be needed.  This could
         include increased disinfection contact time,
         larger holding basins, or equipment redundancy.

     b.   Discharges in close proximity to shellfish har-
         vesting areas should be avoided.  Where such
         dischargers are unavoidable, the applicant should
         contact environmental protection authorities and
         shellfish regulatory agencies for guidance.

     c.   Where the effluent discharge will be to waters de-
         signated by the State as potential shellfish growing

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    waters,  the criteria will either be incorporated in  the de-
    sign or  provision will be made  to incorporate them by future
    modifications to the waste water treatment works.  The
    course of action to be followed will be based on the
    timing of planned actions to upgrade the shellfish waters.

d.  Disinfection System.  Effluent disinfection performance
    requirements are contained in the municipal NPDES
    permit.   The permit is based on the EPA secondary
    treatment information (40 CFR 133),  but more stringent
    requirements may be imposed for other conditions, such
    as water quality related  to shellfish waters. Shellfish safety
    is closely related to reduction of pathogenic micro-organisms.
    Thus, the disinfection system must be designed to achieve
    high effectiveness and reliability. The following requirements
    apply where chlorine is used as the disinfectant.  Other
    disinfectants  are acceptable provided a level of performance
    and reliability comparable to chlorination is attained.

    (1)  The sanitation requirements for approved shellfish
        growing areas are given in the following quotation from
        the  NSPP Manual of Operation:

        "Growing areas may be designated as approved when:
        (a)  the sanitary survey indicates that pathogenic micro-
        organisms,  radionuclides, and/or harmful industrial
        wastes do not reach the area in dangerous concentration,
        and (b)  this is verified by laboratory findings whenever
        the  sanitary survey  indicates the need.  Shellfish may
        be taken  from such areas for direct marketing.

        "Satisfactory compliance.  -- This item will be satis-
        fied when the three following criteria are met:

        (a)  The area is not  so contaminated with fecal  material
            that  consumption of the shellfish might be hazardous,
            and

        (b)  the area is not so contaminated with radionuclides
            or industrial  wastes that consumption of the shell-
            fish  might be hazardous (see section c item 7 in the
            Manual of Operation,  regarding toxins in shellfish
            growing areas), and

         (c)  the  coliform  median MPN of the water does not
             exceed 70 per  100 mil., and not more than 10
             percent of the samples ordinarily exceed an

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   MPN of 230 per 100 ml. for a 5-tube decimal dilution
   test (or 330 per 100 ml., where the 3-tube decimal
   dilution test is used) in those portions  of the area most
   probably exposed to fecal contamination during the most
   unfavorable hydrographic and pollution conditions.
   (Note: This concentration might be exceeded if less
   than 8 million cubic feet of a coliform-free dilution
   water are available for each population equivalent
   (coliform) of  sewage reaching the area).   The fore-
   going limits need not be applied if it can  be shown
   by detailed study that the coliforms are not of direct
   fecal origin and do not indicate a public health hazard.
   This MPN value is based on a typical ratio of coliforms
   to pathogens and would not be applicable  to any situation
   in which an abnormally large number of pathogens might
   be present.  Consideration must also be  given to the
   possible presence of industrial or agricultural wastes
   in which there is an atypical coliform  to  pathogen ratio. "

(2) Maintain an adequate chlorine residual in the chlorine
    contact chamber to ensure that the bacteriological
    requirements are not exceeded in the  effluent or shellfish
    waters.  Because of insufficient data  available to relate
    effluent bacteriological quality and chlorine residual
    and variatons in types and strengths of wastewater,  no
    specific chlorine residual is recommended.

(3) Provide sufficient chlorinator capacity to continuously
    maintain adequate disinfection with the largest unit
    out of service.  Disinfection must be  continuous during
    container and/or chlorinator changeover.

(4) Chlorine Contact Tank

    (a)  Premixing - Rapidly and thoroughly mix the chlorine
        with the wastewater before entering the chlorine
         contact chamber.

    (b) Contact chamber - Design the  chlorine  contact
         chamber for a contact time of at  least 30 minutes
        at the peak hourly flow rate.  Additional contact
         chamber capacity or flow equalization may  be
        necessary where there are unusually high peak
        flow rates.

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                    Design the chlorine contact chambers in
                    accordance with paragraph 212.1.9 of "Design
                    Criteria for Mechanical, Electric, and Fluid
                    System and Component Reliability", MCD-05.
                    Chambers should be designed to produce, as
                    nearly as possible, a plug flow condition
                    (plug flow occurs when each increment of
                    flow is in the chamber for a time equal to
                    theoretical detention time).  The design
                    will include adequate measures to minimize
                    short circuiting, stratification, and stag-
                    nation zones.  Velocity variations within
                    the chamber will be minimized.

               (c)  Outfalls - conduits conveying effluent will
                    not normally be considered as part of the
                    required chlorine contact chamber.  One ex-
                    ception could be where the chlorine residual
                    is continuously monitored at the end of the
                    portion of conduit used for contact chamber.

          (5)  The chlorine residual in the effluent after de-
               tention in the chlorine contact chamber  (or
               other conduit) will be continously monitored and
               recorded.

          (6)  Provide an alarm for low chlorine residual in the
               effluent.  Additionally, depending on the size
               of the plant, proximity to the shellfish beds,
               and other safety factors, alarms may be required
               as indicated in Paragraph 243 of MCD-05, "Design
               Criteria for Mechanical, Electric, and Fluid
               System and Component Reliability".  Examples of
               such alarms are:

               (a)  Disinfectant container depletion.

               (b)  Low chlorine water pressure.

               (c)  Automatic changeover.

          (7)  Design alarm circuits to indicate circuit mal-
               functions .

     5.  Include the following in the operation and mainte-
nance manual for a facility which could affect shellfish water:

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       a.  Definition of the types of incidents or malfunctions to be
           reported to the shellfish regulatory agency and the maximum
           acceptable time for accomplishing this report.

       b.  An emergency response plan, including procedures to be used
           to make reports to the shellfish regulatory agency.

       c.  Recommended frequency of laboratory check tests to verify
           performance of analyzers such as chlorine residual
           indicator and recorder.

       d.  Recommended frequency and types of laboratory tests re-
           quired for monitoring coliform bacteria.

References;

    1.  "National Shellfish  Sanitation Program Manual of Operations,
       Part I,  Sanitation of Shellfish Growing Areas", 1965 Revision,
       U.S. Department of Health, Education and Welfare,  Public
       Health Service.

    2.  EPA-430-99-74-001, Design Criteria for Mechanical, Electric,
       and Fluid System and Component Reliability,  1973.,  Office of
       Water Program Operations, EPA.

Technical Assistance:

    Criteria and technical  assistance for specific problems  may be
obtained from local or State environmental protection authorities or
agencies concerned with the protection of shellfish wates.  Additionally,
assistance if available from the following offices:

    1.  Environmental Protection Agency Regional Offices

    2.  Shellfish Regulatory Agencies:  (Appendix A)

    3.  Food and Drug Administration: (Appendix B)

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                    APPENDIX A
           SHELLFISH REGULATORY AGENCIES

    STATE OFFICIALS RESPONSIBLE FOR GROWING AREA
CLASSIFICATION AND EVALUATION OF THE EFFECT POLLUTION
      SOURCES HAVE ON SHELLFISH GROWING WATERS
ALABAMA

Director
Environmental Health Administration
Alabama State Department of Public Health
State Office Building
Montgomery, Alabama  36130
(205) 832-3176

Director
Water Improvement Commission
Department of Public Health
State Office Building
Montgomery, Alabama  36130
(205) 277-3630

CALIFORNIA

Chief
Water Sanitation Section
California State Department of Health
2151 Berkeley Way
Berkeley, California  94704
(415) 843-7900, Ext. 413

CONNECTICUT

Director
Environmental Health Services Division
Connecticut Department of Health
79 Elm Street
Hartford, Connecticut  06115
(203) 566-2195

DELAWARE

Chief
Bureau of Environmental Health
Department of Health & Social Services
Jesse S. Cooper Memorial Building
Dover, Delaware 19901
(302) 678-4731
                         A-l

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Director
Division of Environmental Control
Department of Natural Resources
Legislative Avenue & William Penn Street
Dover, Delaware  19901
(302) 678-4761

FLORIDA

Director
Department of Health & Rehabilitative Services
Box 210
Jacksonville, Florida  32201
(904) 354-3961

Executive Director
Department of Environmental Regulation
Bureau of Sanitary Engineering
Montgomery Building
2562 Executive Center Circle, East
Tallahassee, Florida  32301
(904)  488-4807

GEORGIA

Director
Georgia Game & Fish Division
Department of Natural Resources
Trinity Washington Building
270 Washington Street
Atlanta, Georgia  30334
(404) 656-3523

Director
Department of Natural Resources
Environmental Protection Division
Trinity Washington Building
270 Washington Street
Atlanta, Georgia  30334
(404) 656-4713

LOUISIANA

Head
Department of Health Services & Environmental Quality
Bureau of Environmental Services
Division of Engineering - Water Quality Section
Box 60630
New Orleans, Louisiana  70160
(504) 568-5115
                         A-2

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MAINE

Resources Scientist
Maine Department of Marine Resources
State House
Augusta, Maine  04333
(207) 289-2291

Director
Fisheries Research Station
Department of Marine Resources
West Boothbay Harbor, Maine  04575
(207) 633-5572

MARYLAND

Chief
Division of General Sanitation
Department of Health & Mental Hygiene
201 W. Preston St.
Baltimore, Maryland 21201
(301) 383-4244

Chief
Environmental Health Administration
Department of Health and Mental Hygiene
201 W. Preston St.
Baltimore, Maryland 21201
(301) 383-3126

MASSACHUSETTS

Director
Department of Environmental Quality Engineering
Division of Water Supply
600 Washington Street - Room 320
Boston, Massachusetts  02111
(617) 727-2692

MISSISSIPPI

Director
Bureau of Environmental Health
Mississsippi State Board of Health
Box 1700
Jackson, Mississippi  39205
(601) 354-6616
                         A-3

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Executive Director
Mississippi Air & Water Pollution Control Commission
Box 827
Jackson, Mississippi  39205
(601) 354-2550

Mississippi Marine Conservation Commission
1201 East Bayview St.
Biloxi, Mississippi  39530
(601) 432-8769

NEW HAMPSHIRE

Director
Bureau of Consumer Protection - Public Health
New Hampshire Department of Health & Welfare
State Laboratory Building
Hazen Drive
Concord, New Hampshire  03301
(603) 271-2747

Director
Water Supply and Pollution Control Commission
Prescott Park
105 Loudon Road
Concord, New Hampshire  03301
(603) 271-3503

NEW JERSEY

Chief
Program Operation Section
Bureau of Water Pollution Control
Division of Water Resources
Department of Environmental Protection
1474 Prospect St.
Trenton, New Jersey  08625
(609) 292-0566

NEW YORK

Chief
Bureau of Shellfisheries
New York State Department of Environmental Conservation
Building 40
State University of New York
Stony Brook, New York  11794
(516) 751-7900, ext. 282
                         A-4

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NORTH CAROLINA

Head
Sanitation Branch - Sanitary Engineering Section
Division of Health Services
North Carolina Department of Human Resources
Box 2091
Raleigh, North Carolina 27602
(919) 733-2261

Supervisor
Shellfish Sanitation Unit - Sanitation Branch
Sanitary Engineering Section
Division of Health Services
North Carolina Department of Human Resources
Box 769
Morehead City, North Carolina -28557
(919) 726-6827

OREGON

Chief
Office of Protective Health Services
Oregon Department of Human Resources
1400 S.W. 5th
Portland, Oregon  97201
(503) 229-5954

Director
Water Quality Programs
Oregon Department of Environmental Quality
1234 S.W. Morrison
Portland, Oregon  97205
(503) 229-5324

RHODE ISLAND

Chief
Division of Water Supply and Pollution Control
Rhode Island Department of Health
75 Davis Street
Providence, Rhode Island 02903
(401) 277-2234

SOUTH CAROLINA

Director
Division of General Engineering Services
South Carolina Department of Health & Environmental Control
J. Marion Sims Building
2600 Bull Street
Columbia, South Carolina 29201
(803) 758-5544
                         A-5

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TEXAS

Director
Division of Shellfish Sanitation Control
Texas Department of Health Resources
1100 West 49th Street
Austin, Texas  78756
(512) 458-7510

VIRGINIA

Director
Bureau of Shellfish Sanitation
Virginia State Department of Health
109 Governor Street
Room 1117
Richmond, Virginia  23219
(804) 786-7937

Director
Division of Sanitary Engineering
Virginia State Department of Health
Room 927 Madison
109 Governor Street
Richmond, Virginia  23219
(804)786-6277

Director
Bureau of Applied Technology
Virginia State Water Pollution Control Board
2111 North Hamilton Street
Richmond, Virginia  23230
(804) 786-1411

WASHINGTON

Chief
Office of Environmental Programs
Washington Department of Social and Health Services
Box 1788
Olympia, Washington  98504
(206) 753-5955

Head
Water & Waste Section
Washington Department of Social and Health Services
Box 1788
Olympia, Washington  98504
(206) 753-5954
                         A-6

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                         APPENDIX B
                FOOD AND DRUG ADMINISTRATION
                      REGIONAL OFFICES
REGION I
Maine
New Hampshire
Vermont
Massachusetts
Rhode Island
Connecticut

REGION II
New York
New Jersey
Puerto Rico
REGION III
Pennsylvania
Delaware
Maryland
Virginia
W. Virginia

REGION IV
Kentucky
Tennessee
N. Carolina
S. Carolina
Georgia
Florida
Alabama
Mississippi

REGION V
Ohio
Indiana
Michigan
Illinois
Wisconsin
Minnesota
Shellfish Consultant
DHEW, PHS, FDA
109 Holton St.
Winchester, MA  01890
(617) 223-5850
Director, National Consultants Br.
DHEW, PHS, FDA
350 Third Avenue
Brooklyn, NY  11232
(212) 965-5043

Director, Investigations Br.
DHEW, PHS, FDA
2nd and Chestnut Sts.
Room 900
Philadelphia, PA  19106
(215) 597-7727

Regional Director
DHEW, PHS, FDA
880 W. Peachtree St., NW
Atlanta, GA  30309
(404) 881-4265
Director, National Consultants Br.
DHEW, PHS, FDA
175 W. Jackson, Rm. A-1945
Insurance Exchange Bldg.
Chicago, IL  60604
(312) 353-5863
                           B-l

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    REGION VI
    Arkansas
    Louisiana
    Oklahoma
    Texas
    N.  Mexico

    REGION VII
    Iowa
    Missouri
    Nebraska
    Kansas
    REGION VII
    N.  Dakota
    S.  Dakota
    Montana
    Wyoming
    Colorado
    Utah

    REGION IX
    Arizona
    California
    Hawaii
    Nevada
    Guam
    Am. Samoa

    REGION X
    Washington
    Oregon
    Idaho
    Alaska
Director, National Consultants  Br,
DHEW, PHS, FDA
500 S. Ervey St.
Suite 470-B
Dallas, TX  75201
(214) 749-7221

Deputy Regional Food and
  Drug Director
DHEW, PHS, FDA
1009 Cherry St.
Kansas City, MO  64106
(816) 374-5521

Director
Investigations Br.
DHEW, PHS, FDA
500 U. S. Custom House
Denver, CO  80202
(303) 837-4915
Regional Shellfish Consultant
ERD for Compliance
DHEW, PHS, FDA
50 United Nations Plaza
Room 568
San Franciso, CA  94102
(415) 556-5437

Director, Investigations Br.
DHEW, PHS, FDA
909 1st Avenue
Seattle, WA   98174
(206) 442-5300
                            B-2
*U.S. Government Printing Office: 1977-780-454/4 Region 8

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