Comments on Straw Ballot 401i1r1
Submitted by Rob Herman, NSF International
Section 4.2.3.6 – Should be removed since this section has been removed recently from all DWTU
standards.
Section 7.2.1.1 – This language infers that general claims for EDC and PPCP reduction may be made
when anyone of the list of organic chemicals are tested under 7.2.1. This is not prohibited in Section 8
therefore a manufacturer could test to a single compound on the list (table 7) and make a general EDC
or PPCP claim on their product. This is most likely not the intent of this section, however, the
prohibition against general category claims should be included in Section 8. If the desire is to link the
EDC or PPCP general claim against the listed contaminant, language should be spelled out. For example,
“Ibuprofen (a pharmaceutical)” or “This product reduces the Endocrine Disruptor compounds estrone
and Bisphenol A…”
Table 7 – There are several concerns with this table.
1. The number of significant figures displayed on this table are excessive and have no value
when the analytical method has significant variance and these levels cannot be reported to
these number of significant figures. This is true for both influents and effluents.
2. The maximum effluent concentrations for some of these compounds are below 20 ng/L
which greatly increases the uncertainty of the methods. Pass/fail levels should be at
concentrations (when there are not health effects limits or MCLs) that can be well
quantified with good precision and accuracy so false failures and false passes are avoided as
much as possible. These compounds should have the maximum effluent levels modified to
20 ng/L. The note #2 requires only a measurable maximum effluent concentration, this
should require that the maximum effluent concentration be set at a level that can be
reliably measured with good precision and accuracy.
3. The Methods of Analysis column is written as a specific requirement of the Standard. Since
there are no USEPA published methods to use for these specific compounds, this column
should be changed to state “Typical” or “Recommended” Methods of Analysis so the
information is informative. I also recommend that LCMS be included for all substances.
4. The number of significant figures of the effluent values and the apparent desire to allow a
minimum 85% reduction claim for these contaminants, I recommend that the influent
values and effluent values be rounded to levels that are more consistent between
contaminants so that if combining the contaminants is possible, the performance of the
combination is simplified which would increase the likelihood of success. The following
table provides some recommendations on Influent and Effluent levels. These levels were
chosen using the following criteria:
a. Setting levels so that analytical precision and accuracy is improved.
b. Grouping substances with similar maximum effluent levels so that the influents will
fall within the linear range of the instrument calibration at equivalent dilutions.
c. Maintaining the desire for 85% or better minimum reduction.
Substance
Neprobamate
Current
Target
Influent
430
Suggested
Target Influent
400
Current
Maximum
Effluent
64
Suggested
Maximum
Effluent
60
Phenytoin
Atenolol
Carbamazepine
TCEP
TCPP
DEET
Metaolachlor
Trimethoprim
Ibuprofen
Naproxen
Estrone
Bisphenol A
Linuron
Nonyl phenol
190
260
1400
4700
5100
970
1600
13
320
80
23
2200
81
1040
200
200
1400
5000
5000
1400
1400
140
400
140
140
2000
140
1400
28
39
210
705
765
145
240
2
48
12
3.5
330
12
156
30
30
200
700
700
200
200
20
60
20
20
300
20
200
7.2.1.3 Analytical Methods – This section references Section 2 which I doubt contains the methods
required for these analyses.
7.2.1.7.1 Plumbed-in systems without reservoirs and all faucet-mounted systems – This section should
include a statement that POE products are included for this method or a separate section created for
POE products.
7.2.1.7.3 Pour through – this section should be updated to include the newly revised and proposed pour
through language. This current language makes no sense.