UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     GUIDANCE FROM HOTLINE COMPENDIUM
                                                                            WSGH23
                                                              Date Issued: October 1989
SUBJECT:   Public Notification Requirements

SOURCE:    Carl Reeverts
Title 40 CFR Section 141.32 sets forth public notification requirements for public water systems
operating under exemptions or variances.  While this section defines specific notification
requirements concerning time schedules and notification channels, it does not address the public
notification requirements for consecutive public water systems.

In the case of a consecutive system receiving water from a supplier operating under an
exemption, who is responsible for informing the customers of the consecutive system that the
supplier has an exemption from the SDWA requirements, the primary water  system or the
consecutive system?

       Response:

       A consecutive system is a public water system and must meet all the National Primary
       Drinking Water Regulations (NPDWRs) that the supplier must meet.  In the
       circumstance where the supplier has an exemption but the consecutive system does not,
       the consecutive system is responsible for notifying its customers after receiving notice of
       the exemption from the primary supplier.

       In the preamble of the final Public Notification Rule (related to the special lead public
       notice), the water supplier which supplies or sells water to another community or
       non-community water system is expected to provide notice to the receiving system.  In
       turn, the receiving system is expected to provide its customers with a public notice (52
       FR41544).

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