EPA/600/S-14/190
May 2014
U.S. EPA Water Technology Innovation Cluster Leaders Meeting-
"Successfully Supporting Early-Stage Companies:
The Role of Technology Testing"
March 24-26,2014
Cincinnati, Ohio
Meeting Summary Report
Developed by:
The Scientific Consulting Group, Inc.
Gaithersburg, Maryland 20878-1409
Under EPA Contract No. EP-C-08-010
Work Assignment No. 4-44
Environmental Technology Innovation Clusters Program
Immediate Office of the Assistant Administrator
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
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DISCLAIMER
This report was funded by the U.S. Environmental Protection Agency (EPA) under EPA Contract
Number EP-C-08-010 (Work Assignment Number 4-44) to The Scientific Consulting Group, Inc. EPA
does not endorse the purchase or sale of any products or services from companies mentioned in this
document. This report has been subjected to the Agency's peer and administrative reviews and has been
approved for publication as an EPA document. The views expressed by individual speakers/participants
are their own, and do not necessarily reflect those of EPA.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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ACKNOWLEDGEMENTS
The U.S. EPA Office of Research and Development (ORD) wishes to extend its appreciation to the
following speakers and panelists for sharing their expertise and perspectives: Robert Adair, Convergent
Water Technologies; Dean Amhaus, The Water Council; Ned Bartlett, Bowditch & Dewey, LLP; Bruce
Bartley, NSF International; Jim Bell, Bio-Microbics, Inc.; Veronica Blette, EPA Office of Water (OW);
Scott Bryan, Imagine H2O; Jeff Davidson, Ohio EPA; Peter Gallant, ENDETEC/Veolia Water Solutions
and Technologies; Ellen Gilinsky, EPA OW; Sally Gutierrez, EPA ORD; Teresa Harten, EPA ORD;
George Heufelder, Barnstable County Department of Health and the Environment; Earl Jones, Liberation
Capital; Lek Kadeli, EPA ORD; Richard Magee, New Jersey Corporation for Advanced Technology;
Kurt Marx, University of Washington, Tacoma; Stephen McKnight, Fourth Economy Consulting; Brent
Mecham, Irrigation Association; Brian Mergelas, WaterTAP; Jeff Moeller, Water Environment Research
Foundation; Fred Mussari, BCR Environmental Corporation; Paul O'Callaghan, Blue Tech Research; Gil
Pezza, Michigan Economic Development Corporation; Maggie Theroux, EPA ORD; Alan Vicory,
Stantec Consulting/Confluence; and David Zoldoske, California State University, Fresno.
The following EPA ORD staff aided in the planning, implementation and logistical coordination for the
meeting: Cheryl Abrams, Ryan Connair, Julius Enriquez, Sally Gutierrez, Michelle Haan, Teresa Harten,
Evelyn Hartzell, Maggie Theroux and Abby Waits.
Logistical support for the meeting also was provided by The Scientific Consulting Group, Inc., under
contract to EPA.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 Hi
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) hosted a meeting of the Water Technology Innovation
Cluster Leaders from March 24-26, 2014, at the Andrew W. Breidenbach Environmental Research Center
in Cincinnati, Ohio. Approximately 60 individuals attended. The meeting was organized to bring together
various stakeholders who have a dedicated interest in water technology innovation and implementation.
Participants included members of each of the clusters in various stages of development, government
officials, water technology developers and entrepreneurs, utility representatives, and testing facility
representatives—all of whom expressed an interest in increasing collaboration and starting a productive
conversation on the topic of technology testing. The focus of this meeting was to identify and discuss the
difficult issues surrounding the testing of innovative technologies that must be addressed before a new
water technology can go to market.
The goals of this workshop were to: (1) increase the cluster leaders' level of knowledge regarding past
and current water technology testing programs, facilities and requirements; (2) learn from the experiences
of technology vendors in getting innovative, commercial-ready products to the marketplace, including the
use of testing, permitting and labeling programs; (3) discuss model approaches for technology testing that
benefit early-stage companies and identify the role(s) of cluster organizations; and (4) encourage cluster
leader networking and collaboration.
Many of the participants gave presentations outlining their own involvement and experiences in this field.
The audience heard presentations from U.S. EPA and Ohio EPA personnel, cluster members, water
innovation organization leaders and business owners. In addition to the primary presentations, three panel
sessions gave additional participants the opportunity to talk about their experiences and foster group
discussions.
The meeting culminated with a facilitated brainstorming session and group discussion regarding water
technology testing. The goal of this discussion was to create a list of best management practices (BMPs)
and challenges that would enable the clusters to determine where and how they can make an impact.
Participants first identified the BMPs that they had employed or hoped to employ to successfully test new
technologies and bring them to market. The list of BMPs that were acknowledged was extensive and
primarily focused on:
• Good communication and engagement between stakeholders.
• Organization and collaboration in testing.
• High-level of knowledge of the goals, market, regulations and other stakeholders' positions.
• Thorough data collection and tracking.
Participants discussed the challenges that developers face when testing their new technologies and offered
ideas for how to tackle the issues at hand:
• Standards and reciprocity concerns primarily focused on the lack of national standards and
permitting reciprocity across states for regulatory acceptance, which leads to high costs and lengthy
time frames for testing and approval. States often do not have a clear picture of their own needs (or
the resources to determine what those needs are), and many of them are reluctant to embrace
reciprocity for various reasons. It is very difficult for developers to understand the complex and
continually changing regulatory landscape.
> Ideas for improvement: Creation of a collection of technology testing data that states can
share and use to make their own independent decisions. Development of jointly approved
testing protocols (e.g., EPA is working with the states of Ohio, Kentucky and Indiana to
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 iv
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develop a joint protocol for ultraviolet testing). Establishment by EPA of global standards for
method performance for as many analytical methods as possible. Creation of a
comprehensive list of certification criteria that each state requires.
• Financing difficulties were the most frequently discussed challenges throughout the entire meeting.
Participants brought up the fact that the amount of money entering the water market is decreasing,
and venture capitalists tend to avoid environmental technologies because of the constantly changing
regulatory environment. Technologies are expensive to test and come with high risks. The
requirement that technologies be piloted in each state leads to prohibitively high costs for getting a
technology into the national market. It is difficult to develop metrics to quantify the economic and
social benefits of green technologies and green infrastructure, which makes it harder to obtain
funding.
> Ideas for improvement: Applying core competencies of successful industries to the water
technology industry. Utilizing the water clusters for networking and funding opportunities.
Educating the public of the benefits of water technology as a means to garner support.
Utilizing local resources, capital and expertise. Moving away from pilot projects that are not
scalable or sustainable.
• Lack of knowledge and collaboration tends to occur among businesses because they see each other
as competitors—however, it is clear that cooperation would be useful given the difficult environment
surrounding green technologies.
> Ideas for improvement: Recognition that collaboration is beneficial because all of the
clusters have the same overarching goals. Development of peer-to-peer groups and sharing of
best practices among water clusters and utilities. Creation of a national database of testing
programs and test beds.
> Please see Appendix B for the summaries of eight successful testing programs.
• End-user engagement is lacking and leads to a lack of identification of the needs of the market.
> Ideas for improvement: Develop methods for engaging and managing the end-user, as this
will help developers to define system and product requirements. Create an accessible system
in which users can easily share their experiences, product reviews and performance ratings
for a technology.
• Other challenges included: utilities' reluctance to adopt new technologies because of the high risk
and mandate to protect public health; reliance on pilot projects as a hindrance to success; lack of
field-based accreditation options; how to enable and adopt a systems-holistic approach to water
management; and how to address the EPA Environmental Technology Verification Program legacy.
The meeting ended with a session to brainstorm the agenda for the next meeting.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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CONTENTS
Disclaimer ii
Acknowledgements iii
Executive Summary iv
Contents vi
Abbreviations and Acronyms vii
Introduction and Overview 1
Welcome, Introductions and Meeting Objectives 1
Keynote Speakers 1
Instructions and Preparation for Afternoon Facilitated Group Discussion 2
Building a Credible Testing Program—Overview of Testing Issues in Water Technology
Commercialization 2
Panel Discussion: National and State Testing and Labeling Programs 3
WaterSense® Overview of Certification and Labeling 3
Michigan Water Technology Testing Program 4
NSF International: Testing and Certification 4
Washington State's Technology Assessment Protocol—Ecology (TAPE) Emerging Technologies
Program 5
Leaders Innovation Forum for Technology (LIFT) Technology Evaluation Program 5
The New Jersey Corporation for Advanced Technology (NJCAT) 6
Discussion 7
Panel Discussion: Operating and Maintaining a Technology Testing Center 8
Massachusetts Alternative Septic System Test Center 8
International Center for Water Technology and Center for Irrigation Technology 9
Emerging Technology—A State's Permitting Perspective 10
Imagine FfcO—Experience in Permitting and Testing 11
Discussion on Financing of Testing Facilities and Technologies 11
Panel Discussion: Experiences of Businesses in the Testing, Approval and Permitting Process 13
Experience With an Alternate Test Procedure Study for an Automated Escherichia co///Total
Coliform Method 13
Innovative Septic System Technology Testing and State Permitting 14
Experiences of Businesses Obtaining the WaterSense® Label for Irrigation Controllers 14
Delivering Next-Generation Stormwater Technologies by Harnessing the Power of Collaborative
Effort 15
Biosolids Class A/B Designation Through EPA Pathogen Equivalency Committee Process 15
Discussion 15
Ontario, Canada—Perspective and Approach to Water Technology Testing 16
Facilitated Discussion Session: Best Practices and Challenges Regarding Water Technology Testing
Facilities, Programs and Requirements 17
Discussion Session: Draft Agenda for Next Meeting 20
Appendix A: Participants List 23
Appendix B: Program Descriptions 25
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 vi
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ABBREVIATIONS AND ACRONYMS
ACE
ANSI
AWWA
BMP
EGA
EPA
ETV
LIFT
NJCAT
NJDEP
ORD
OW
PCR
SORA
SOWC
STEPP
SWAT
TAPE
uv
WEF
WEFTEC
WERF
(American Water Works Association) Annual Conference and
Exposition
American National Standards Institute
American Water Works Association
best management practice
Environmental Compliance Approval
U.S. Environmental Protection Agency
Environmental Technology Verification (Program)
Leaders Innovation Forum for Technology
New Jersey Corporation for Advanced Technology
New Jersey Department of Environmental Protection
Office of Research and Development
Office of Water
polymerase chain reaction
State Onsite Regulators Association
Southern Ontario Water Consortium
Stormwater Testing and Evaluation of Products and Practices
Smart Water Application Technologies
(Washington State's) Technology Assessment Protocol—Ecology
ultraviolet
Water Environment Federation
Water Environment Federation's Annual Technical Exhibition and
Conference
Water Environment Research Foundation
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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INTRODUCTION AND OVERVIEW
The U.S. Environmental Protection Agency (EPA) Water Technology Innovation Cluster Leaders
Meeting was held March 24-26, 2014, in Cincinnati, Ohio. The purpose of this workshop was to:
(1) increase cluster-leader level of knowledge regarding past and current water technology testing
programs, facilities and requirements; (2) learn from the experiences of technology vendors in getting
innovative, commercial-ready products to the marketplace, including the use of testing, permitting and
labeling programs; (3) discuss model approaches for technology testing that benefit early-stage companies
and identify the role(s) of cluster organizations; and (4) encourage cluster leader networking and collab-
oration. Nearly 60 individuals attended.
MARCH 24, 2014
Participants met for a networking hour and group dinner to commence the meeting.
MARCH 25, 2014
Welcome, Introductions and Meeting Objectives
Sally Gutierrez, Director, Environmental Technology Innovation Clusters Program, Office of Research
and Development (ORD), EPA
Ms. Sally Gutierrez welcomed the participants to Cincinnati and the largest federal water research facility
in the United States. The federal government has sponsored water research in Cincinnati for 101 years.
Ms. Gutierrez next had the participants introduce themselves.
Keynote Speakers
Ellen Gilinsky, Senior Policy Advisor, Office of Water (OW), EPA, and Lek Kadeli, Acting Assistant
Administrator, ORD, EPA
Dr. Ellen Gilinsky stated that communities and individuals are beginning to change how they think about
water. Although the water supply had been thought to be limitless, communities now are dealing with
water issues related to its finite supply. There is a strong desire to use the resource intelligently and ensure
that the manner in which water is treated and used serves as an economic driver that promotes urban
revitalization and sustainability. Aging water infrastructure is a challenge. Wastewater increases as the
population increases, and because of the sheer volume, contaminants and nutrients also have increased
despite advances in treatment quality. It is important to manage water resources, and technology
innovation is fundamental to a sustainable future and progress toward clean and safe water. EPA desires
to support technology innovation, which also acts as an economic driver. The United States would like to
be a leader in innovative water technologies.
EPA released the Blueprint for Integrating Technology Innovation into the National Water Program
(Version 1.0) to highlight the Agency's activities in this area and identify opportunities to increase
innovation, including improving and greening the country's infrastructure. Technology innovation will
increase the resiliency of water infrastructure and help rebuild infrastructure in the smartest manner
following natural disasters such as hurricanes. Technology innovation is needed to decrease consumption
of natural resources; water reuse is an important activity, which technology innovation can help. The term
"wastewater" is evolving into "water resource recovery" because the water is not waste. States and
localities are turning to EPA regarding the safety of water reuse. Helping communities provide safe
drinking water is important. The blueprint, which is a living document, will provide a stronger business
case for technology innovation, provide information about current technology development, and frame a
broader range of Agency actions to move technology innovation forward.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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Mr. Lek Kadeli discussed the importance of moving technology innovation and ideas into commerce
while ensuring that the regulatory environment does not become an obstacle. The current challenges
regarding water resources are different from those of the past. EPA faced obvious environmental prob-
lems when it was created and has made progress on those, but today's challenges are more subtle,
difficult to define, socially complex and multidisciplinary; the solutions will affect many groups, with
technology innovation playing an increasingly important role. It is necessary to adopt a systematic
approach to solve the current problems, and stakeholders must be included. In addition to solving
environmental problems, the goal is to help communities. EPA supports water technology clusters
because they have adopted a systematic approach, bringing together a wide variety of stakeholders from
various sectors affected by similar regional water challenges who are able to respond to these complex
challenges. The Cincinnati water technology cluster began in 2010 when EPA brought together water
industry stakeholders in the Ohio River Valley—this cluster officially became Confluence in 2011. Mr.
Kadeli provided examples of the great progress made in water technology innovation, noting that it is
important to engage a broad group of stakeholders to address an issue, beginning with defining the
problem and ultimately delivering results. The outcome is a collective vision with mutually beneficial
goals that enables all parties to mobilize resources to realize stronger, more enduring solutions. Mr.
Kadeli encouraged collaboration among clusters, which will benefit all.
Instructions and Preparation for Afternoon Facilitated Group Discussion
Maggie Theroux, Senior Cluster Development Specialist, ORD, EPA
Ms. Maggie Theroux provided instructions to the participants regarding how the afternoon facilitated
group discussion would be administered.
Building a Credible Testing Program—Overview of Testing Issues in Water Technology
Commercialization
Teresa Harten, Team Lead, EPA Cincinnati Water Cluster, ORD, EPA
Ms. Teresa Harten explained that technology purchasers, regulators, vendors and financiers rely on
technology testing for a variety of reasons, including making decisions, writing regulations, attracting
funding and improving technology. Credible testing is performed by an objective third-party testing
organization with stakeholder involvement and is fair, transparent and peer reviewed. Selection of those
technologies that will be tested may be driven by users' challenges, vendors and innovation, or an
organization's expertise. Many questions regarding stage of technology development and fairness must be
considered and answered during the process, which should be transparent. Testing organizations also
must consider issues of outcome, branding and financing. Test plan development includes determining
which entities to involve as well as test scoping (e.g., balancing speed and cost with completeness and
certainty). Ms. Harten described a case study (arsenic removal technology verifications and arsenic
demonstration program) to illustrate scoping. The range of testing programs includes voluntary testing,
mandatory testing, industry standards compliance, state-only programs and industry-led programs. It may
be feasible to explore a network of testing organizations with reciprocity among the organizations;
connecting the network to an international system and/or other networks provides another avenue of
exploration.
Questions/Answers and Discussion
Although the EPA Environmental Technology Verification (ETV) Program performed customized testing,
there may be a method to benchmark, share and obtain insights about the technologies. Are ETV case
studies available? The protocols and test plans are available on the ETV website, as well as three volumes
of case studies, which focus on environmental and human health outcomes by technology categories.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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Who paid for the arsenic technology demonstrations? Congress mandated the program, so tests were
government-funded with a very specific $20-million appropriation. The program was unique in that the
government purchased the technologies, (www.epa.gov/nrmrl/wswrd/dw/arsenic/where.html.')
Are regional variations in ETVprotocols allowed? Although certain parts are standardized, there is some
ability to modify the protocols.
The future role of a network of testing organizations may be expanded to verify certain protocols that are
being used onsite. There is a definite need to examine new models.
PANEL DISCUSSION: NATIONAL AND STATE TESTING AND LABELING PROGRAMS
Moderator: NedBartlett, Partner, Bowditch & Dewey, LLP (New England Water Innovation
Network)
WaterSense® Overview of Certification and Labeling
Veronica Blette, WaterSense* Branch Chief, OW, EPA
Ms. Veronica Blette explained that WaterSense® is a labeling program for commercial-ready water
technologies to foster innovation. It is not an incubator. It smartly uses resources (EPA, manufacturers,
licensed certifying bodies, retailers and other partners) to provide independent third-party credibility,
certifying that EPA criteria have been met. WaterSense® uses a variety of factors, such as national water
savings, water efficiency and independent certification, to determine which products to label. To date,
11,000 products have been labeled, including lavatory faucets, irrigation controllers, tank-type toilets and
new homes. Since 2006, WaterSense® labeled products are estimated to have saved 487 billion gallons of
water, reduced water-related energy consumption by 64.7 billion kilowatt hours, and saved consumers
$8.9 billion in water and energy bills. The goal is to reach $1 trillion in savings by the end of the current
year.
The product-certification process includes 274 manufacturing partners across six product categories, six
accredited and EPA-licensed certifying bodies, and three internationally recognized accreditation bodies.
Each group has different roles, responsibilities and credentials. The responsibilities of manufacturers
include designing and submitting compliant products, abiding by WaterSense® guidelines, and
contracting with accredited and licensed certifying bodies. Among their responsibilities, certifying bodies
must evaluate the manufacturers' production processes, maintain a list of certified products and provide
the list to EPA, and conduct annual surveillance and product retesting. Accreditation bodies evaluate,
accredit and oversee certifying body capability and competence to certify products to the WaterSense®
certification system and specifications. WaterSense® responsibilities include developing and maintaining
certification system requirements and specifications; policing use of the label and protecting the
trademark; and marketing the label to consumers, utilities and designers.
Ms. Blette described the steps of the product-certification process, which begins with a manufacturer
partnering with EPA and applying to a certifying body for certification. After the certifying body
conducts the product evaluation, the body authorizes the manufacturer to use the WaterSense® label and
notifies EPA, which maintains an online registry of labeled products. The certifying body continues to
conduct ongoing conformity assessment. The cost of the process is market-driven, and the Agency is not
involved in transactions between the manufacturer and certifying body. The program benefits manu-
facturers as it helps them to market and sell water-efficient products. Through 2012, manufacturers have
reported that more than 119 million labelled products have been shipped.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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Michigan Water Technology Testing Program
GHPezza, Director, Water Technologies Initiative, Michigan Economic Development Corporation
Mr. Gil Pezza focused on the activities undertaken in Michigan surrounding water technologies. He noted
that having too much water creates a feeling of complacency in many, which makes it difficult to rally for
support around this issue. To successfully obtain support in the economic development community, it is
key to illustrate that water technologies benefit the economy and create jobs. In Michigan, water
technology innovation drivers and needs include economic development initiatives, regional strategies
centered around water or the "Blue Economy," the state's mandate to protect and preserve its waters,
market opportunities, attraction of water-dependent companies, end users, and regulation. One of
Michigan's Water Technologies Initiative focal points is facilitating pilot tests of innovative technologies.
Technologies have been end-user driven, and Michigan's strategy for financing has been ad hoc based on
each project. Operation and maintenance funds from utilities that could be applied to pilot projects were
identified in some cases, and cost-sharing occurred in others. Regional plans involving innovation
technologies—similar to those of Oakland and Macomb counties in Michigan—have been developed.
Mr. Pezza pointed out that fragmentation in the water industry has prevented the formation of advocacy
groups to lobby for prioritization of funds for water. One manner by which to accomplish this is to focus
on water technologies to bring together environmental organizations and industry. It is necessary to create
a nexus between academia and end users via engineering consulting firms and prioritize state-level water
issues by shattering state agency "silos" and developing a consensus plan around water with all of the
various regions in the state. Mr. Pezza recommended creating a virtual water team to align the strategy
and establishing a funding mechanism to jump start water technology programs. Development of a market
strategy also is needed.
Questions and Answers
What are your observations about the innovation of U.S. companies and entrepreneurs compared to those
in Israel? U.S. companies and entrepreneurs are just as good, but Israel has a different innovation
environment; entrepreneurs there are allowed to fail before further innovating and getting funded.
Companies should engage their state's department of environmental quality (or the equivalent) before
performing a pilot project.
NSF International: Testing and Certification
C. Bruce Bartley, Senior Technical Reviewer, Global Water Programs, Filtration Division,
NSF International
Mr. Bruce Bartley explained that NSF International is a global, independent public health and safety
organization whose mission is to protect and improve human health. It began in 1944 when the University
of Michigan School of Public Health received a grant from the Coca-Cola Company to develop standards
for soda fountain sanitation and overcome regulatory barriers. The organization involves and engages the
three groups that drive standards—industry, consumers and regulators. NSF International standards and
certification are recognized by the American National Standards Institute (ANSI) and internationally. The
organization's Global Water Program tests and certifies products related to residential and public water.
Certification to the NSF standard ensures that products meet regulatory requirements for the United States
and Canada and is a mark of distinction. Customers are assured that the product is safe for use in drinking
water and performs as advertised. Certified products are entered into an online directory of certified
drinking water system products. The cost of certification depends on the standard and testing facility
location, approximately $2,500-$7,500 annually and $2,500-$50,000 for testing.
Questions and Answers
Are the water reuse standards for residential or commercial use? The standards are aimed at residential
use; industry can choose residential or commercial certification at the time of testing.
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How didNSFInternational build reciprocity with other countries? It was a long and arduous process.
In those cases that a state body oversees the water program, would the state adopt the NSF protocol?
States have a number of options depending on the political and regulatory environment present. NSF
International surveys states regarding their policies every 2 years in an ongoing process because of the
constantly changing regulations and policies.
Does the NSF International process lend itself to innovative product certification? Innovative or not, any
technology dealing with water most likely needs to go through the process. NSF International handles
each case individually as it is received at the applied research center. There are enough standards and
protocols available that most products fit within one.
Washington State's Technology Assessment Protocol—Ecology (TAPE) Emerging
Technologies Program
Kurt Marx, Assistant Director for Clean Water Innovation, Center for Urban Waters, University of
Washington Tacoma
Mr. Kurt Marx explained that TAPE is the state of Washington's stormwater treatment certification
program for emerging treatment technologies for sediment, metals, phosphorus and oil. Permitting is the
driver for the program, which is referenced in regard to emerging technologies in the Stormwater
Management Manual for Western Washington. The state's Department of Ecology wants and needs new
stormwater treatment technologies to meet permit requirements and protect and improve water quality;
TAPE fills this need by allowing proven treatment systems to be utilized before the manual is updated,
approximately every 5 years. The program also provides vetted, consistent third-party performance data
to users. There are three certification levels with new development and redevelopment requirements for
treating stormwater; the program does not apply to retrofits or to industrial stormwater permits, which
must meet numeric effluent benchmarks. The TAPE program has approved 13 technologies, with 15
additional technologies active in various stages of the program. TAPE approval is a marketing tool for
those companies that participate, and jurisdictions outside of the state of Washington have benefited from
the program. Water clusters can play a role in helping early-stage companies bring their innovative water
technologies to the marketplace by locating test sites, minimizing costs and encouraging reciprocity. One
of the biggest challenges for technology companies is to find a testing/installation location.
Questions and Answers
Stormwater removal at airports (i.e., reducing open water that might attract birds) is a significant
market; does this use fall under industrial uses under the TAPE program? TAPE does not apply to
industrial permitting and is limited to technologies for removal of sediment, metals, phosphorus and oil; it
meets a narrow regulatory field (state regulatory requirements).
Leaders Innovation Forum for Technology (LIFT) Technology Evaluation Program
Jeff Moeller, Director of Water Technologies, Water Environment Research Foundation (WERF)
Mr. Jeff Moeller explained that LIFT is an initiative of WERF and the Water Environment Federation
(WEF) that moves technology into practice more quickly. LIFT focuses on new technologies with the
goal of accelerating innovation. The initiative includes a technology evaluation program, a people and
policy program, and an informal forum for research and development managers. The end-user driven
program includes a working group, which has grown from 25 facility-owner members to more than 250,
and a volunteer experts pool comprised of consultants, academics, equipment manufacturers and other
stakeholders. The LIFT Technology Evaluation Program provides a credible, we 11-documented vetting
system to screen new technologies, mitigates the risk and cost of innovative technology deployment,
facilitates collaboration for evaluating and testing new technologies, and provides peer-reviewed
information about these technologies.
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The LIFT Technology Scan Program provides a platform for vendors to introduce technologies; 28 new
technologies have been submitted since the pilot launched in November 2013. After LIFT's call for new
and innovative technologies, providers submit technology applications. WERF assembles panels of
experts and practitioners to review applications. Selected technologies are invited to present to LIFT
audiences that are appropriate to their technology readiness levels to garner interest in early adoption of
the technology. WERF also helps develop and manage independent, peer-reviewed technology
evaluations. Results and data are shared following the collaborative pilots, demonstrations and testing,
which occur at testing and demonstration facilities/sites with individualized quality assurance project
plans. The program focuses on demonstration and evaluation, rather than certification and validation, and
shares the costs and risks of technology innovation through partnerships.
Clusters can work with LIFT in several ways, including via the following avenues:
LIFT Technology Scan. Clusters that are working with technology providers should encourage these
providers to apply to the LIFT Technology Scan Program to help advance their technologies.
Collaborative Technology Demonstration/Evaluation Project. Many wastewater facilities that are WERF
subscribers are located in water clusters. These subscribers, in conjunction with a cluster, can initiate a
collaborative demonstration project process via a request letter to WERF at any time. Through this
process, WERF will work with the facility and cluster to identify additional agencies interested in
partnering to fund the demonstration and conduct an independent technology evaluation.
Peer Review of Demonstration/Evaluation Project. A WERF utility subscriber, in conjunction with a
cluster, can request to utilize WERF's expert peer-review process for a new technology demonstration
project it is conducting, which lends national credibility to the results. WERF currently is conducting peer
reviews of several biosolids-to-energy technologies in the San Francisco Bay area.
Questions and Answers
Some technologies in the water market have historically been applied to one sector but now have the
opportunity to be applied in a new sector; these are not new technologies but existing technologies with
new uses. Currently, there is no platform to increase the visibility of these products. Can LIFT play a role
in this? Yes, LIFT can play a role in this and is interested in technologies from other sectors. Increasing
visibility of technology in new sectors is a great discussion topic for this group.
The New Jersey Corporation for Advanced Technology (NJCAT)
Richard Magee, Technical Director, NJCAT
Dr. Richard Magee explained that the New Jersey Department of Environmental Protection (NJDEP) was
the impetus for establishing NJCAT in 1997 as a public-private partnership to accelerate emerging
environmental and energy technology deployment. Its technology verification program moved NJCAT
forward; NJCAT does not perform technology testing but rather conducts an evaluation program to verify
innovative environmental and energy technology performance claims using independent third-party
laboratory and field demonstration performance data. A vendor seeking an innovative technology
certification contacts NJCAT or NJDEP, and a preliminary assessment of the technology is performed.
The vendor submits the technology performance claims and supporting data to NJCAT, which uses
established protocols to verify the claims and sends the verification report to a peer-review team and
NJDEP. The final report must be approved by the NJCAT Board of Directors and submitted to NJDEP
for certification. The program expedites the use of new technology by NJDEP regulatory programs, and
information about the technology is included in NJCAT and NJDEP outreach and education programs.
Technologies are included in the appropriate state bid specifications, which increases the possibility of
selection. Dr. Magee noted that many states use the New Jersey Stormwater Management Rules, which
drive the verification and certification process by stipulating that manufactured treatment devices may be
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 6
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used to meet regulatory requirements provided the pollutant removal rates are verified by NJCAT and
certified by NJDEP. The recent economic situation has caused NJDEP to modify the process to rely on
laboratory testing because of the challenges and associated costs of field testing.
Panel Discussion
Mr. Ned Bartlett summarized the themes of the panel presentations, including the variety of drivers
(economic, regulatory, end user); reciprocity; and limitations on geographic jurisdiction and market share.
Mr. Pezza noted that one challenge of the water technology sector is that the technologies are too
expensive; cost is a driver. Dr. Magee said that manufacturers and product developers were responsible
for testing and verification costs. Mr. Pezza said that other industries (e.g., automotive industry) have
successfully accomplished bringing affordable products to the marketplace, and applying the core
competencies of successful industries to the water technology industry (i.e., cross-fertilization of
competencies among industries) would be beneficial.
Mr. Bartlett asked the participants about the potential role of water clusters in providing affordable
technology innovation. Mr. Richard Seline mentioned the balance around the public sector dictating what
the market will adopt. Some technologies have next-generation market value that goes unrealized. Mr.
Bartlett noted that the pharmaceutical industry excels at off-label uses of its products, but the water sector
has not been successful in this area.
Mr. Egils Milbergs thought that one role of water clusters could be to facilitate the sharing of users'
experiences with technologies in a system in which actual users provide reviews and performance ratings.
Mr. Bartlett summarized that the water clusters could establish an information-sharing clearinghouse. Ms.
Blette agreed that this would be helpful because utilities often do not adopt innovative technologies out of
fear of risks; reading reviews from their peers would help alleviate that fear. Mr. Marx noted that these
experiences already are being recorded via certain programs but are not always shared. Dr. Magee
commented that it is difficult to obtain follow-up on a technology's field performance. Also, the lack of
field testing required in some programs will cause the loss of a great deal of practical information.
Dr. Gilinsky stated that the issue of reciprocity needs to be solved, and the cluster format could provide
the solution. Ms. Ebie Hoist noted that testing criteria will evolve, and there always will be regional
components, but a "version control" mechanism needs to be established so that the "stamp of approval"
speaks to the time in history that a product was verified. A list of certification criteria necessary for each
state would provide developers with a blueprint for developing technologies that can be used in multiple
jurisdictions. Although Dr. Gilinsky did not think that most states had a clear picture of their specific
needs, Dr. Magee noted that some know their critical issues (e.g., Virginia and phosphorus). Some
developers try to cater to certain states' needs. Mr. Greg Carroll said that reciprocity is a great concept,
but states are reluctant to embrace automatic reciprocity. An interim goal toward the long-term goal of
reciprocity could be to collect a body of testing information so that states can make their own decisions.
EPA's ORD is working with Ohio, Kentucky and Indiana to develop a joint protocol for ultraviolet (UV)
testing.
Ms. Kirsten Melberg explained that the city of New Orleans is wanting to quantify the economic and
social benefits of technologies in addition to the environmental factors. She wondered whether any other
groups had begun to quantify these benefits. Mr. Pezza said that it is difficult to develop metrics to
quantify green infrastructure. Water clusters must explain the benefits, such as job creation and increased
quality of life, to states and municipalities. Water technologies offer these benefits, but this must be
proven before developers can obtain investments. His most difficult struggle within his organization is
explaining the immediacy of the direct impacts. Ms. Melberg said that her organization has begun to
develop a matrix to determine these measurements; she welcomes any advice other clusters may have.
Mr. Pezza said that Michigan's economic development plan may be of some help, and he offered to share
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 7
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it. Mr. Moeller said that the city of Portland (Oregon) has made a significant effort in attempting to
quantify green infrastructure benefits, and Mr. Bartlett added that the city of Philadelphia is heavily into
green infrastructure.
Mr. Seline said that his organization is attempting to determine the total procurement capacity
(technology only) of the 4,300 water authorities in Texas, and he wondered whether other organizations
had attempted anything similar. Ms. Blette said that surveys conducted under the Safe Drinking Water
and Clean Water Acts might provide this information. She also noted that technology costs are high
because technologies must be built to meet different states' specifications. Reciprocity is important, but
technologies that lend themselves to this should be selected.
Dr. Magee commented that many venture capitalists have moved away from environmental technologies
because of the continually changing regulatory environment.
PANEL DISCUSSION: OPERATING AND MAINTAINING A TECHNOLOGY TESTING CENTER
Moderator: Dean Amhaus, President and Chief Executive Officer, The Water Council
Massachusetts Alternative Septic System Test Center
George Heufelder, Director, Barnstable County Department of Health and the Environment
Via teleconference, Mr. George Heufelder explained that the Massachusetts Alternative Septic System
Test Center is operated by the Barnstable County Department of Health and the Environment and has
approximately 25 locations for the onsite septic system technology testing it has been performing since
1999. The center is funded via vendors and grants, and Barnstable County contributes staff time.
Activities are numerous and include product testing, facilitation of research and development of
proprietary products, research on nonproprietary treatment strategies, and work with vendors to develop
data for obtaining approvals from various jurisdictions. Potential clients generally contact the center via
telephone to discuss the available range of services. If the client does not know which testing protocol is
needed, the center discusses the goals and expectations, advises the client of the options, drafts and
conducts a sampling plan, and compiles the report. If the client knows the appropriate testing protocol, the
center clarifies goals and expectations, advises the client of the options, drafts and conducts a sampling
plan, and compiles the report. If an NSF protocol is required, the client is advised to contact NSF
International directly.
Onsite wastewater testing centers require attention 365 days a year, and directors must ensure that clients
develop reasonable expectations for their efforts and expenditures. It is important to meet with the
regulator to ensure that the vendor has been understood accurately. Regulators in some states may stop
the process based on their interpretations of state policies. Mr. Heufelder encouraged early-stage
companies to know the universe of their competitors' products and understand the regulatory frameworks
under which products will be approved. It also is important to hire a staff member who can describe the
product to a broad range of audiences. Also, dealing with regulators requires patience. Test centers can
assist with developing sampling plans at various stages of product development, work with regulators to
clarify information requirements, and compile data and performance reports for the various purposes.
Questions and Answers
What arrangements does the center have with wastewater utilities? Are universities involved? There are
no arrangements with wastewater utilities, of which there are only three or four public treatment plants on
Cape Cod, but the center monitors 1,400 systems with various technologies via a Web-based recording
system to help municipalities track their performance.
Does the center's model provide for maintenance via fees collected, or are other sources of funding
necessary? The operation can be administered entirely on client fees.
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How many devices are connected to the cloud? What is the future of cloud-connected devices? The center
encourages cloud-based monitoring devices, but there is not a great deal of activity in this area currently.
International Center for Water Technology and Center for Irrigation Technology
David Zo Idoske, Director, International Center for Water Technology, California State University,
Fresno (Fresno State)
Dr. David Zoldoske stated that the water cluster centered in Fresno, California, was established in April
2001 and identified three key areas of need in its strategic plan, which are to increase exports, develop a
workforce and establish a hydraulic testing laboratory. Using industry, Fresno State, EPA and the U.S.
Economic Development Administration as resources, the cluster raised more than $6 million for
laboratory equipment and facilities. With these funds, the Water and Energy Technology Incubator—
which includes almost 9,000 square feet of dedicated laboratory space—was built on the campus of
Fresno State and is the basis for the water cluster efforts. Dr. Zoldoske displayed images of several
components of the facility, including some of the few test pumps located west of the Mississippi River
and a degasser. An energy project in conjunction with the city of San Jose (California) is expected to have
a return on investment within 4 to 6 years. The International Association of Plumbing and Mechanical
Officials-certified/ANSI laboratory provides services for fee, including WaterSense® and witness testing
and product development. The center has adopted a policy of reporting only successful data so that
negative data are not used against developmental products. Dr. Zoldoske noted that the San Joaquin
Valley economic development model includes water and energy as key components. The water cluster
and the center work as partners, and the center helps businesses to succeed while promoting innovation.
In conclusion, Dr. Zoldoske pointed out the importance of using laboratory and field data to tell the whole
story.
Questions and Answers
Does the center's model provide for maintenance via fees collected, or are other sources of funding
necessary? The initial efforts were more opportunistic than programmatic, but now it is much more
programmatic, with a $4-million budget that includes some state support. The laboratory makes up
approximately 15 to 20 percent of the program, which is involved in a wide variety of projects, including
work in disadvantaged communities. The model ensures that the laboratory has synergies, and workforce
investment funding helps manage the water cluster. Integration of the various components, including
several start-up companies, provides support to the laboratory.
How many devices are connected to the cloud? What is the future of cloud-connected devices? Recently,
the Pacific Gas and Electric Company provided nearly $500,000 to establish the Agriculture Water
Energy Center, which focuses on collection of farm energy and water management. Some vendors work
in the cloud, bringing in amazing, inexpensive sensor technologies. There has been a rapid, tectonic shift
in the ability to collect data inexpensively.
Can any of the sensors be adapted to the wastewater sector? This should be possible, especially given the
discussion regarding cross-pollination of technologies across sectors.
Does the cluster still administer an export program? The cluster worked with Mexico, Brazil, Argentina
and Chile for 6 years on export of irrigation technologies. The cluster has reapplied for funds, but the
political landscape has changed, emphasizing a shift toward trade with China rather than South America,
and vendors are hesitant to trade with China for intellectual property reasons. The prior funding supported
about 50 percent of the costs to market products in South America. If there is a shift away from an
emphasis on China to more palatable countries for vendors, the cluster will re-examine its options.
California terminated its export program, so that avenue no longer is an option.
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INDIVIDUAL PRESENTATIONS
Emerging Technology—A State's Permitting Perspective
Jeff Davidson, Environmental Manager, Division of Drinking and Ground Waters, Southwest District
Office, Ohio EPA
Mr. Jeff Davidson described some of the conventional "wisdoms" surrounding emerging technology,
which no longer apply. Dealing with aging water plants and distribution systems is a significant
challenge, as water mains are reaching their life expectancy, tanks were designed for water quantity rather
than quality, and regulatory concerns have changed since their construction. Emerging contaminants have
resulted in new regulations for surface, drinking and ground water, but these regulations place a stress on
plants not designed for them. This provides a challenge for emerging technologies to solve. Mr. Davidson
mentioned the following emerging contaminants: harmful algal blooms, pharmaceuticals, personal care
products, cryptosporidium, legionella, viruses, disinfection byproducts and hexavalent chrome.
There are a number of source water quality and quantity issues (e.g., arsenic, Lake Erie algal blooms,
nutrient loading), and emerging technologies must perform across a wide range of water quality
conditions and operational challenges to be viable. Also, it is necessary to ensure a proper correlation
between technology complexity and operator expertise. Monitoring cannot be completely reliant on
automation to determine that the required inactivation is being achieved. Well-defined, simple operating
protocols for performing routine maintenance, troubleshooting operational issues, making adjustments,
and obtaining and installing replacement parts must be established. To ensure a system is sustainable,
infrastructure must be operable following decades of use, and water utilities cannot be reliant on a single
vendor for the long-term maintenance of proprietary technology. States also require contingencies for
when the technology fails or is out of service for routine and nonroutine circumstances, and states and
water utilities must have accurate information on the full cost of the technology over its entire life cycle.
Consumer expectations for water keep increasing, and utilities must meet these demands. Standards and
limitations of residual disposal also must be considered. Mr. Davidson concluded that there are many
considerations beyond the efficacy of the treatment that must be considered before technology is
employed, particularly at smaller public water systems.
Questions and Answers
There are many qualitative regulations; is there a value to quantitative regulations? The Midwest
increasingly is moving in this direction. Source water protection is a major issue, and the quantity issue
accompanies it. Obtaining water that is affordable to treat will drive quantitative regulations.
What is the trend regarding procurement of new technologies? Engineering consultants probably are the
biggest direct consumer in terms of information. The American Water Works Association (AWWA) and
Ohio EPA established a technology committee with consultants, water system representatives and state
regulators to discuss problems and how to solve them. The engineers brought forward information and
data about available, new technologies. Technologies are re-evaluated on a routine basis to determine
whether piloting can be decreased and other demonstration data can be accepted; this is an attempt to
increase the feasibility of introducing new technologies.
How are procurement methodologies playing out in terms of the pace of innovation? They are vetted by
the regulators more than they have been in the past now that there is more of a push for technology
adoption.
Can you provide a case study of an emerging technology introduced to your office? What are the criteria
for introducing new technologies? Are new technologies vetted across the state? Arsenic is the best
example. The regulation changed, so the office engaged in a 2-year process to review NSF International,
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EPA and other states' information on arsenic technologies. The new regulation drove the need to turn to
emerging technologies. The technology committee provides a great deal of input as well.
Sometimes a district is attempting to solve an issue for which the state does not have an answer, so the
district takes the lead in researching and proposing a solution, and then the results are adopted across
the state.
What is most helpful for states to implement new technologies? It is important that the technologies that
are applied be appropriate for the situation and not cause negative unintended consequences.
Imagine EhO—Experience in Permitting and Testing
Scott Bryan, Chief Operating Officer, Imagine H2O
Mr. Scott Bryan explained his organization's path-to-market programming. The business program
encourages innovation with an annual competition that identifies promising water innovations and
emerging businesses. The competition's top 12 companies advance to the Imagine IrbO accelerator, which
promotes winning ideas through in-kind resources, mentorship, investor introductions and beta customers.
Imagine IrhO's Accelerator Hub Partners Program currently includes five water clusters and expects to
grow during the current year. The program provides clusters with resources for local entrepreneurs and
opportunities to leverage the Imagine H2O competition to engage the innovation community. Mr. Bryan
described a case study regarding nontraditional financing, illustrating that the key to success is to utilize
local resources, capital and expertise. He encouraged clusters to help entrepreneurs move beyond pilot
projects, which are not always scalable or financially sustainable. Pilots can be an important step but do
not comprise a sound business model; beta customer engagements are superior. There is more room in the
water sector for business innovation versus technology innovation. Clusters can be a resource in helping
entrepreneurs work with market partners to understand the ultimate needs of end users and customers.
Mr. Bryan encouraged clusters to commit resources toward implementation opportunities rather than
simply focusing on marketing activities. Entrepreneurs also should engage with regulators so that they
understand the regulatory framework that guides product adoption. The water sector contains a complex
network of consultants, competitions, agencies, universities and so forth, which need to make themselves
available and more understandable for entrepreneurs. It is important for entrepreneurs to focus on end-
user agreement; clusters can encourage entrepreneurs to engage the end user.
Questions and Answers
What is your opinion of crowdsourcing? It is an interesting concept in general, but it is not seen often in
the water sector. There is a growth opportunity in the water sector, but the general public does not
understand water technologies, which is critical for crowdsourcing success.
There is a body of evidence that entrepreneurs, innovators and investors are trying to disrupt regulated
markets in an attempt to build innovative solutions. Can you comment on this? Some developers love
regulations and can build a successful business based on them, but there is a lack of clarity in certain areas
(e.g., greywater, direct potable reuse) that must be addressed before a wave of innovation enters the
sector. Although entrepreneurs and investors are not comfortable with the regulatory environment in these
areas, they are finding opportunities to monetize other areas within the water industry.
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WORKING LUNCH
Discussion on Financing of Testing Facilities and Technologies
Earl Jones, Member, Liberation Capital (New England Water Innovation Network), and Paul
O'Callaghan, Chief Executive Officer, BlueTech Research
Mr. Earl Jones introduced the discussion, noting that money entering the water sector is decreasing. The
current advice is for runders to begin in industrial water and then transition to municipal water. Today's
dialogue is important because it is necessary to move the sector away from spawning 20-year "overnight"
successes. The U.S. investment gap in the water sector is $250 billion, and problems are accelerating. The
single largest problem facing the sector is financing. Regulations provide difficulties for developers.
Finally, solving the challenge of reciprocity would be beneficial.
Mr. Paul O'Callaghan noted that the sector has many real challenges with no simple solutions. He
explained that BlueTech Research maps the water innovation landscape within four core practice areas:
water reuse and alternative water, energy and resource recovery, unconventional fossil fuels and water,
and smart water. The company tracks innovations, licensing and patents to map the sector in three ways:
thematically, from a technological perspective and by application. Energy and resource recovery is a
major investment theme in which BlueTech sees activity. Mr. O'Callaghan observed that the overall
objective of technology verification is to accelerate the adoption of solutions that meet client needs.
Innovation must meet client needs and should deliver its own value. Investors and developers should
recognize that the purpose of the water sector is not to deliver double-digit returns to investors; it is to
deliver water services in an efficient manner. Companies with technologies or solutions that meet client
needs can be successful, and there are examples of this. Entrepreneurs should adapt, however, to reflect
market realities, as opposed to expecting the water sector to change to meet their needs.
Mr. O'Callaghan provided a graphic representation of two "overnight success stories after 20 years."
These case studies included UV technology and ultrafiltration membranes. Early adopters are a key
element needed to help companies advance on the technology S-curve. He displayed another graph of the
revenue stages of BlueTech Innovation Tracker companies within the water sector, explaining that there
are a large number of companies at the prerevenue and early revenue stages. Next, there is a high rate of
attrition as companies attempt to move through the "valley of death" and reach a revenue bracket of $1 to
$10 million. Companies can stabilize in the $1 to $10 million range; the next step is to scale up to reach a
revenue range of $50 to $100 million. Companies must move past the pilot project stage successfully by
gathering the right data, testing on the appropriate waste stream, obtaining independent third-party
validation, and linking pilots to the next steps in the commercial process. Many companies do not do this.
One of the best uses of seed funding is to fund a demonstration facility at or near full scale, ideally with a
"flagship" client located relatively near the company's main office. Early adopters are an important
component of success. Verification is good, but performance is highly dependent on test conditions,
which vary.
When vetting a technology, BlueTech Research reviews available data, determining whether it has been
proven and at what scale and in what conditions. Fragmentation occurs in testing and validation—as it
does in the water industry as a whole—as a result of different technologies, applications, scales and
clients. Buyer confidence can be increased by sharing information among peers via the WEF discussion
forums, conference papers, and possibly crowdsourcing and social media. Other potential models include
the European Union ETV Pilot Programme, which covers water, waste and energy, and Canada's
nonprofit foundation, Sustainable Development Technology Canada™, a successful demonstration support
initiative.
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Discussion
Mr. Pezza wondered whether some water technologies are more attractive to investors. Mr. Jones said that
venture capitalists look at those with interesting returns on investment. Technologies that require
increased capital are less attractive. Sensors and similar technologies have a great deal of cachet right
now.
A participant asked about the best financial model given the 20-year S-curve. Mr. Jones thought that the
"headwind" in the marketplace is getting the product to market, particularly in the United States, which
has a fragmented regulatory landscape. It is important to assess the product's channel to the market rather
than whether the product is the best.
Mr. Davidson asked how to "sell" wastewater technology to the public. Mr. Jones responded that the
United States has not done an effective job with public outreach surrounding water. It is necessary to
educate the public that treatment comes with a cost. Singapore is a model for excellent public outreach
about water. Mr. O'Callaghan agreed that Singapore has done a great job making the field of water
exciting to the public, noting that education on this topic must be more accessible. Mr. Seline added that a
crisis sharpens the public's focus around an issue, and this year, the "water wars" and the question of
which entities "own" water have entered the public's consciousness. It is a public commodity, and this
crisis provides the opportunity to educate. The most significant challenge is convincing water purveyors
that innovative technologies are viable technologies.
Mr. Jones commented that collaboration among municipalities would create leverage. It is necessary to
think beyond technology innovation to organizational innovation. Yesterday's solutions will not meet
today's or tomorrow's problems.
Dr. Zoldoske was unsure how to reconcile the fact that local municipalities are required to solve their
water issues while being regulated from above.
PANEL DISCUSSION: EXPERIENCES OF BUSINESSES IN THE TESTING, APPROVAL AND
PERMITTING PROCESS
Moderator: Stephen McKnight, Vice President of Community and Market Assessments,
Fourth Economy Consulting (Water Economy Network)
Mr. Steven McKnight introduced the session, asking participants to consider what actions water clusters
can take to add value to the testing process.
Experience With an Alternate Test Procedure Study for an Automated Escherichia coli/Tota\
Coliform Method
Peter Gallant, Vice President of Regulatory Affairs, ENDETEC Sensor Group, Veolia Water Solutions
and Technologies
Dr. Peter Gallant described the ENDETEC method, an automated microbiology method that can provide
early alerts when water is contaminated by coliform bacteria. The company sought EPA approval for
compliance testing under the Total Coliform Rule. There are business benefits to EPA approval because
EPA has become the "gold standard" in countries around the world; key benefits of this approval include
investability, credibility and market access. Dr. Gallant briefly described his company's experience with
EPA's Alternate Test Procedure process, noting the excellent responsiveness of EPA staff. Despite this
responsiveness, the process is lengthy, and for investors and startups, time is the enemy. Investors will not
fund any product with regulatory risk, so multiyear delays can have a devastating effect on venture
capital.
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Dr. Gallant learned many lessons throughout the process, including the fact that EPA approval is just the
beginning of bringing a product to the marketplace. It also is important to engage states and understand
the regulatory framework because allowable methods vary by state. Accreditation requirements may
present significant barriers to automated microbial methods. Dr. Gallant recommended that EPA consider
adopting or establishing global standards for method performance for as many analytical methods as
possible and establish standard protocols and performance-based standards (e.g., Method 334). Clusters
should develop support resources to enable early-stage companies to mitigate regulatory risk. EPA and
clusters together should consider developing a "presubmission" program to provide feedback and a
roadmap to approval. He fears that the desired goal of instant notification of microbial water contamin-
ation may not be realized in the current landscape.
Questions and Answers
What is the cost of applying the technology to surface waters? A semiquantitative system for surface
water is available, but automated methods do not compete on cost. Surface water testing under the
Beaches Environmental Assessment and Coastal Health Act of 2000 is moving to polymerase chain
reaction (commonly known as PCR) rather than automated testing.
Innovative Septic System Technology Testing and State Permitting
Jim Bell, Executive Vice President, Bio-Microbics, Inc.
Mr. Jim Bell explained that his company is a global supplier of innovative water, wastewater and storm-
water treatment technologies. Its prime market is developing decentralized wastewater technologies.
Current NSF/ANSI onsite residential wastewater standards include Standard 40 and Standard 245, and the
new NSF Standard 350 deals with commercial and residential water reuse. The company has been testing
to NSF standards since 1996; this decision was driven by the states, some of which require meeting a
national standard in a manner that also meets state requirements. Costs for NSF testing begin at $50,000,
with annual certification fees ranging from $6,000 to $15,000, but it is essential to test to the standards
because all product sales are regulatory driven. Testing to NSF standards is the first step in obtaining state
approvals. Overcoming the fragmented regulatory landscape is difficult because states are entrenched
after 40 years of maintaining jurisdiction. This cannot be corrected, but there is a need to understand the
problem. Progress can be made in the emerging market of water reuse, and data sharing may help with
state reciprocity.
Questions and Answers
Is this the only system certified for NSF Standard 350? This system was the only one tested that used
ANSI itself as a certifier. Other technologies have used ANSI certifiers to test to NSF standards.
Can you elaborate on the push toward data sharing? The EPA Memorandum of Understanding
Regarding Cooperation in Decentralized Wastewater Management between the State Onsite Regulators
Association (SORA) and the National Onsite Wastewater Recycling Association, Inc. (a trade associa-
tion) addresses data sharing. A session at the upcoming SORA meeting will allow the regulators to agree,
with industry present, on the parameters that will allow data sharing among states. These will be pres-
ented to EPA. Another group may serve as the central repository for this information.
Experiences of Businesses Obtaining the WaterSense® Label for Irrigation Controllers
Brent Mecham, Industry Development Director, Irrigation Association
Mr. Brent Mecham explained that Smart Water Application Technologies (SWAT), established in 2002,
is a collaborative effort between municipal water providers and the irrigation industry that is managed by
the Irrigation Association. The mission is market transformation, and SWAT created a testing protocol to
validate manufacturer claims for smart controllers following the ISO standard-setting process. SWAT
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does not provide certification, only testing results. The SWAT testing protocol is used as the basis for
EPA's WaterSense® labeling program with a few modifications; EPA testing provides another validation.
The labeling process can provide many challenges, such as the need for the right weather conditions,
which can create a significant cost to small manufacturers. Irrigation controllers have had slow growth, as
the market has not embraced them, but drought and EPA's WaterSense® have become motivators for
adoption. SWAT results have been used as the basis for product rebates, and WaterSense® labeling has
become an alternate source for providing rebates. Soil moisture sensors, flow sensors, sprinklers and
nozzles, and valves may be investigated in the future. SWAT also is working through ANSI standards
developers to take the testing protocols to the next level to facilitate adoption by others.
Questions and Answers
Has there been pushback regarding recycled water and its application on the landscape? Green codes are
attempting to remove urban irrigation from the potable water supply, but the definition of the term
"potable" is an issue. A significant issue is the potential health hazard from plumbing codes that require a
purple pipe be used for all alternate water sources because of confusion that may arise from the various
treatment levels of the different water sources. Recycled water often is very useful for landscape irrigation
if the quality is sufficient to not harm plants.
Delivering Next-Generation Stormwater Technologies by Harnessing the Power of
Collaborative Effort
Robert Adair, President, Convergent Water Technologies
Mr. Robert Adair stated that his company breaks down barriers to innovation, delivers solution-oriented
distribution and enables innovators to reach a national market. Next-generation stormwater technologies,
including a high-performance modular biofiltration system, mostly are iterative technologies. It is
necessary to institutionalize innovation. Stormwater is an industry in the making; drainage and flood
control have evolved to include habitat protection and restoration and rainwater reuse, so the stormwater
moniker no longer is accurate. The green infrastructure paradigm is driven by necessity, and a lack of
national standards is a hindrance for the stormwater sector. The current timeline (2 to 3 years) and cost
($250,000 to $700,000) of testing should not be a hindrance to introducing new technologies; a better
testing regime is needed to meet critical objectives. The variety of regulations also decreases the ease of
moving technologies to the market. Mr. Adair advocates for a national verification program, Stormwater
Testing and Evaluation of Products and Practices (STEPP). STEPP would allow laboratory verification to
trigger market access, field monitoring results to trigger certification, and stormwater permits to drive
universal acceptance. Stormwater companies should think more like technology companies in regard to
innovation.
Biosolids Class A/B Designation Through EPA Pathogen Equivalency Committee Process
Fred Mussari, Vice President of Research and Development, BCR Environmental Corporation
Dr. Fred Mussari stated that innovation in biosolids treatment is necessary because infrastructure is aging,
underfunded and facing significant cost escalations. Landfill capacity, increasing regulations and
escalating energy use also drive the need for innovation. BCR Environmental Corporation's core
principles ensure that the company's actions are simple, environmentally responsible, economically
viable and sustainable. There are fundamental economic barriers to the majority of the market when
considering new biosolids treatment technologies, and most approved solutions do not have sustainable
economics at scale. The company views regulators as true partners in the permitting process, with nation-
al approval and broad market adoption as the ultimate goal.
Venture capitalists will not take the risk of building full-scale facilities to obtain regulatory approval for a
new process, but there is a mechanism to obtain approval for pathogen-reduction technologies. The EPA
Pathogen Equivalency Committee is a multidisciplinary volunteer committee that established a straight-
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forward process for approval. The theoretical approval process for biosolids treatment methods is simple
compared to the practical process. EPA approval is critical to early adoption and innovation success
(business velocity). To improve the adoption process, Dr. Mussari recommended that a Vector Attraction
Reduction Equivalency Committee be implemented to facilitate innovation. Also, better communication
is needed between EPA and state permitting authorities. Protection of public health and the environment
while developing new processes that are economically viable should be the primary goal. The process of
gaining regulatory approval for new biosolids treatment processes can be difficult but is necessary if new
technologies are to gain broad acceptance. Shortcutting the approval process in an effort to drive innova-
tion may have unintended consequences.
Panel Discussion
Mr. Milbergs thought that it is important to experiment with different types of regulatory solutions across
the country as a way to navigate the regulations and provide room for innovation. Dr. Gallant said that his
company has suggested that the traditional laboratory accreditation framework be adapted to become
field-based accreditation that still is based on federal approvals of the methods.
Mr. Seline asked Mr. Carroll whether EPA has a set of waivers to accelerate technology adoption in crisis
situations that could serve as a model for the adoption of innovative technologies. Mr. Carroll responded
that although this is not his area of expertise, he is aware of a waiver process for the best available
treatment technology to be applied when the standard cannot be met. His peers at EPA Headquarters deal
more with waivers.
Mr. McKnight summarized that it is critical for clusters to understand the regulatory process, policy
environment, market drivers and cost so that a course of action can be developed that decreases uncer-
tainty and builds relationships with industry partners undertaking the process.
INDIVIDUAL PRESENTATION
Ontario, Canada—Perspective and Approach to Water Technology Testing
Brian Mergelas, Chief Executive Officer, Water TAP
Dr. Brian Mergelas stated that Ontario has a significant number of water assets, including 102 water-
related research institutes, groups and centers. The province also has several assets in terms of testing
technologies. Ontario's technology acceleration is aimed at building capacity for water companies,
connecting end users to solution providers at the right time, and creating an environment for innovation.
Barriers to innovation include limited access to testing facilities, regulatory disincentives, financial issues
and the perceived risk of implementation. The Ontario Clean Water Agency is the largest in the province,
operating approximately 500 facilities. The agency tracks more than 60 companies with innovative
technologies and services and matches them to clients based on need. The Southern Ontario Water
Consortium (SOWC) brings together academia and industry to increase access to testing facilities and
includes six nodes that make it possible to perform testing: water treatment, wastewater treatment,
ecotoxicology, watershed management, sensor development, and water and wastewater analysis.
Showcasing Water Innovation is Ontario's $17-million program that funds 32 projects to promote
innovative and cost-effective management of community water resources; innovative projects save
money. A new process of multisite approvals has been established that is based on multisite approvals for
mobile treatment facilities. In this process, the technology proponent holds the Environmental Compli-
ance Approval (ECA), and the facility owner authorizes testing, acknowledging that effluent limits still
will be met. A new Comprehensive Certificate of Approval process allows pre-approval to accelerate
innovation, which the old process inhibited. For SOWC approvals, companies and researchers can access
facilities with no ECA requirement, and multisite approvals can be used. The Regional Public Works
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 16
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Commissioners of Ontario organization represents the 16 largest water providers in Ontario and facilitates
the sharing of best practices.
Dr. Mergelas agreed with earlier presenters that reliance on pilot projects can hinder success and noted
the importance of peer-to-peer groups in the adoption of innovative technologies. Underutilization is
another issue that must be addressed. Sharing best practices among the water clusters would be beneficial,
in addition to sharing best practices among utilities. Furthermore, testing protocols provide a common
language for innovation. One of WaterTAP's roles is to help coordinate efforts in the water sector,
creating visibility for technology companies and educating end users about opportunities to perform tests
and share results. WaterTAP also helps to foster better communications among end users to decrease risk
in the adoption of new technologies.
Questions and Answers
How many of the companies involved are startups? There are approximately 180 small companies, but it
is difficult to determine whether they are true startups. Among the 900 companies, there are a few large
companies, some midsize companies and a great number of small companies. The effort helps companies
that have some commercial traction.
Is there an opportunity present to collaborate outside of the province? WaterTap's role is to engage with
other clusters. Building bridges among the clusters and engaging with other clusters to promote water
technology companies is beneficial for all.
Do you see clusters as collaborators rather than competitors? Clusters have the same goals, to solve the
world's water problems, so collaboration benefits everyone.
How supportive is the Ontario government? The government has been very supportive and created an
organization to bring together activities and efforts already in place. Although WaterTAP's outreach is
heavily subsidized, it provides services for fees. Without the subsidies, WaterTAP would have to increase
its fees.
How does WaterTAP guide companies whose products may not be " ready for prime time"? The MaRS
Centre for Impact Investing deals with early-stage companies, so WaterTAP would recommend that the
company spend more time in MaRS. Also, the Ontario Centres of Excellence engage companies earlier in
the process than WaterTAP. The companies that WaterTAP helps have some commercial traction, with
WaterTAP helping to refine their product.
How are companies identified and over what period of time? Are all companies Ontario-based?
Companies were identified through a water asset map created from commercial databases and interviews.
The program is funded by the province, so the primary driver is a mandate to improve Ontario's
economy.
Often the largest cost of the accreditation is the time spent in the learning process. Can you describe the
multisite verification process? There is a broader challenge for companies to be able to obtain a permit
that recognizes that once a process has been demonstrated by one municipality, it should be easier to work
with other municipalities. A technology is considered proven in Ontario when it has been installed
successfully in three independent sites for 3 years.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 17
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FACILITATED DISCUSSION SESSION: BEST PRACTICES AND CHALLENGES REGARDING WATER
TECHNOLOGY TESTING FACILITIES, PROGRAMS AND REQUIREMENTS
Led by: Maggie Theroux, Senior Cluster Development Specialist, ORD, EPA
The desired outcome of the facilitated discussion was a list of best management practices (BMPs) and
challenges regarding water technology testing facilities, programs and requirements to help water cluster
leaders determine where and how they can have an impact.
The participants broke into six small groups to brainstorm BMPs and challenges and then met as a whole
to discuss them.
Identified, Categorized BMPs
Engage/Communicate
• Peer-to-peer communication.
• Utility engagement in early technology.
• Engaging the entrepreneurial ecosystem in clean water solutions.
• Identifying stakeholders early and engaging them transparently.
• Engaging stakeholders/end users to identify and leverage testing facilities.
• Partnering with industry, end users and academia.
• Ensuring that consulting engineer organizations are included in the dialogue.
• Communicating effectively with consulting engineers.
• Leveraging whenever possible.
Test
Testing roadmaps by application leading to a cluster/testing organization by application.
Articulating "dos" and "don'ts" for testing projects (e.g., define needed data).
Piloting early/field testing.
Establishing protocols for tests that are relevant to the community.
Verifying and validating data for end-user need and regulatory requirements.
Participating in an ISO effort to create a technology verification standard.
Laboratory specialization.
Multisite permitting.
Know
• Identifying social, environmental and economic goals.
• Getting a grasp of BMPs.
• Knowing your regulator and communicating early.
• Providing advice (e.g., guidance manual) to early-stage companies.
• "It's about the market, 'stupid'."
Match
• Matching technology needs with industry/regulatory requirements.
Track
• Keeping a score card with success and nonsuccess stories.
• Storing and communicating data.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 18
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• Retooling procurement from design/product-based to performance based.
• Implementing lean and continuous improvement in the regulatory system for predictability and
efficiency.
• "What will fill the void?"
Identified, Categorized Challenges
Funding
• Funding for regulator-relevant demonstration.
• Funding midstage; market penetration; "valley of death."
• Scalability (laboratory scale —> pilot plant —>• full scale): Alliances and partnerships are needed to
help depending on project scale because some larger companies may be innovative but still have
a funding gap.
End Users
• More end-user management.
• How to involve end users in defining system and product requirements (voice of the customer).
• Lack of identification of needs and processes (i.e., do not develop technologies that are in search
of a solution).
Standards and Reciprocity
• Lack of recognized standards across states for regulatory acceptance.
• Transjurisdictional issues.
• What is the pathway to more national standards, testing criteria and protocols?
• Regulatory uncertainty.
• Complex manufacturing/regulatory approval process; high cost; lengthy timeframe.
• The need to create best approval coordination for 50 states and 10 provinces with the long-term
goal of reciprocity.
• How to promote continued innovation in an existing technology without burdening the developer
with a new, extensive round of testing time and cost.
Knowledge Sharing
• Centralized knowledge-sharing forum.
• National database of testing programs and test beds.
Uncategorized
Risk transfer.
How to enable and adopt a "systems" holistic approach to water management (e.g., data, sensors).
The need for water technology organizations to have techniques to quantify economic impacts.
Marketing laboratory services to create awareness.
How to address ETV legacy in state regulations.
Where the product is in the development cycle: Where is the company on the commercial
pathway? Does the cluster have the ability to help? If a cluster has limited resources, should it
help those products further along in the development process? Does the cluster know of other
resources to which it can refer the developer?
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Discussion
Participants requested a list of those individuals who have implemented BMPs, including their contact
information, so that it would be easy to reach out if there were questions about how to implement certain
BMPs. Participants could volunteer to be points of contacts for the BMPs with which they have experi-
ence. This would make the list more meaningful and evidence-based.
Participants suggested that Dr. Mergelas provide a Webinar on BMPs.
A participant commented that he views challenges on different levels: individual; mezzo (organizational,
institutional); and meta, which is the level of meaningful outcomes. It is necessary to think about the
challenges at various levels, which then need to be woven together (input to process to outcome). The
challenges being discussed mostly are process challenges.
Some challenges are exacerbated in certain areas (e.g., funding from utilities vs. industry), so the problem
must be examined as a whole.
Voting
Considering that the ultimate goal of a water cluster is to expedite innovative technology to the market
and provide solutions to utilities, the participants voted on which challenges are most likely to impede this
goal. Each of the six small groups was given three votes, and multiple votes were allowed to be given to
one item.
The following categories received the following number of votes:
• Standards and reciprocity—6 votes
• Funding—5 votes
• End users—3 votes
• Knowledge sharing—3 votes
• How to enable and adopt a "systems" holistic approach to water management—1 vote
As the participants discussed the top vote-getters, the concept of reciprocity evolved into the lack of data
sharing. This issue also includes a lack of discussion among states (i.e., peer-to-peer communication)
regarding long-term experiences based on good science and data. Data should be viewed objectively; no
value judgments should be imposed on data. There also are different data needs, and it is necessary to
ensure the quality assurance/quality control of data.
When discussing the lack of national standards, participants thought that it was necessary to create best
approval coordination but were unsure about the pathway to accomplish this when considering the
political process and how to engage stakeholders. A roadmap must be defined. What is the landscape
from approach to approach or desired outcome to desired outcome? It varies among technology types
(wastewater, drinking water, etc.). There are standards relative to performance and to type of protocol.
The stormwater sector would benefit from NSF Standards 40 and 350. Some sectors in the water industry
have parts of standards on a national scale, and this needs to occur across all sectors. It is critical to know
the end point when developing standards.
Following the discussion period, participants were asked to comment about their opinions on the
facilitated discussion and workshop; they offered the following insights:
Pros
• The small group interaction and facilitated discussion were beneficial.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 20
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• The timekeeping was great.
• The speaker/attendee variety was excellent.
Cons
• Logistically, the space was awkward for meeting in small groups.
• More time and clearer criteria should have been provided for the group brainstorming session.
• Voting should have been done individually rather than by group.
• The facilitated discussion groups could have been aligned with the panel and speaker topics.
• Full sentences describing each of the BMPs and challenges should have been required to increase
clarity.
Ms. Theroux stated that the next step is to share the identified BMPs and challenges within each cluster
and network to further validate them.
DISCUSSION SESSION: DRAFT AGENDA FOR NEXT MEETING
Led by: Alan Vicory, Chair, Confluence Board of Directors and Principal, Stantec
Consultants
Ms. Gutierrez stated that the water technology cluster leaders had agreed to a series of three meetings; this
was the first. The next meeting will take place at the AWWA Annual Conference and Exposition (ACE)
in June in Boston. The third meeting will take place at the end of September at WEF's Annual Technical
Exhibition and Conference (WEFTEC) in New Orleans.
Participants noted the challenge of meeting for an entire day during a larger conference, which is why the
current plan is to meet on the last day of ACE. There is a great opportunity to leverage AWWA and other
key decision makers who will be present at the conference. There will be a large market showplace
(Innovation Pavilion), and CEOs and manufacturers will be present. It will be beneficial to discuss with
them how they can help clusters as partners as well as to obtain buy-in from them. The opportunity to
engage with other stakeholders is useful, and water cluster effectiveness can be increased by learning how
clusters can be of service to various stakeholders. Cluster representatives also can attend the meetings or
sessions of various groups (e.g., manufacturers or utilities councils). Meeting at the beginning of the
conference rather than the end will increase energy.
If the focus of the next meeting will be on the cluster network, the meeting should be held separate from a
larger conference. A 2-day retreat would be most advantageous for this. Mr. Seline explained that he had
convened a group of clusters to discuss vital issues, but because it was held at a larger conference, 25 key
individuals from outside of the clusters were present to provide crucial input throughout the day as well.
In regard to logistics at ACE, a room has been reserved for the group at the end of the conference, but it
could be changed to the Sunday the conference begins (June 8). Water cluster can present themselves at
the Innovation Pavilion being organized by Imagine FfcO and AWWA, which is an opportunity to
increase visibility. Booths will be available to a few clusters at a reduced fee, and companies from four
clusters already are represented at the pavilion. The conference has good programming (e.g., piloting, best
practices sessions) for clusters.
The participants discussed the potential formats for the next meeting. One participant suggested holding a
half-day meeting at the beginning of the conference to include an introduction to manufacturers. Another
participant described a meeting in which each participant had given a 3-minute TED-type talk to stimulate
discussion; this could be a model for the next meeting.
Another suggestion was to meet in smaller groups for a 2-hour discussion on various topics. It is import-
ant to accommodate the diversity of interests and expertise of the group and satisfy all expectations.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 21
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Leaders can take ownership of an issue identified at this meeting (e.g., knowledge-sharing platform) and
discuss them in small groups prior to ACE. These small groups could brainstorm solutions to the various
issues and report to each other during the water cluster meeting at ACE. The small groups also could meet
outside of the larger water cluster leaders group while attending ACE and report to the larger group.
There needs to be a top-down framework, but within the framework there must be organic flexibility
depending on motivation, interest and expertise.
One way to move some of the issues forward prior to the next meeting is to leverage efforts. Under the
LIFT program, WEF and WERF are co-funding a project entitled, "Creating the Space to Innovate." The
project will include a series of dialogs and a summit, and some of the issues covered relate to those
discussed during this meeting. There may be an opportunity for representatives from this group to
participate in this effort
A participant would like more discussion on the operation of water clusters (e.g., how financed,
administered) at the next meeting.
There is the possibility of a tour of a decommissioned pilot plant near Boston.
For the WEFTEC meeting in New Orleans, the clusters could organize a conference session to solicit
broader participation. Mr. Barry Liner explained that a room is reserved for the water cluster leaders on
Sunday, September 29, with lunch available. If the water cluster leaders would like to plan a program for
that time/location, it is possible. At the prior year's conference, programming introduced a networking
session. There also will be an Innovation Showcase Pavilion co-hosted by WEF, Imagine FfcO and
Blue Tech Research, with receptions on Monday and Tuesday evenings, and there are a few 10-foot-by-
10-foot booths available to innovation partners.
Mr. Alan Vicory thanked EPA for organizing the meeting. Ms. Gutierrez thanked her staff members for
organizing and the participants for attending and adjourned the meeting at 5:55 p.m.
MARCH 26, 2014
Participants were offered the opportunity to tour EPA's Test and Evaluation Facility in Cincinnati, Ohio.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 22
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APPENDIX A
U.S. EPA Water Technology Innovation Cluster Leaders Meeting
Participants List
Cheryl Abrams
U.S. Environmental Protection Agency
Robert Adair
Convergent Water Technologies
Evelyn Allen
Southern Ontario Water Consortium
Dean Amhaus
The Water Council
William Ball
University of Cincinnati
Ned Bartlett
Bowditch & Dewey, LLP
New England Water Innovation Network
Bruce Bartley
NSF International
Jim Bell
Bio-Microbics, Inc.
Veronica Blette
U.S. Environmental Protection Agency
Seth Brown
Water Environment Federation
Scott Bryan
Imagine H2O
Bonnie Buthker
Ohio Environmental Protection Agency
Greg Carroll
U.S. Environmental Protection Agency
Ryan Connair
U.S. Environmental Protection Agency
Jeff Davison
Ohio Environmental Protection Agency
Julius Enriquez
U.S. Environmental Protection Agency
Peter Gallant
Veolia Water Solutions and Technologies
Ellen Gilinsky
U.S. Environmental Protection Agency
Jon Grant
WaterTAP Ontario
Sally Gutierrez
U.S. Environmental Protection Agency
Michelle Haan
U.S. Environmental Protection Agency
Bill Hagstrand
NorTech Water
Teresa Harten
U.S. Environmental Protection Agency
Evelyn Hartzell
U.S. Environmental Protection Agency
Roy Haught
U.S. Environmental Protection Agency
Greg Heitzman
Louisville Metropolitan Sewer District
Ebie Hoist
Clean WaterNet
Erik Hromadka
Global Water Technologies
Earl Jones
Liberation Capital
New England Water Innovation Network
Lek Kadeli
U.S. Environmental Protection Agency
Melinda Kruyer
Confluence
Kristen LeBaron
The Scientific Consulting Group, Inc.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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Barry Liner
Water Environment Federation
Ron Lovan
Northern Kentucky Water District
Brenda Lucas
Southern Ontario Water Consortium
Richard Magee
New Jersey Corporation for Advanced
Technology
Kurt Marx
Center for Urban Waters at the University of
Washington Tacoma
Steve McKnight
Water Economy Network
Brent Mecham
Irrigation Association
Kirsten Melberg
New Orleans Water Innovation
Brian Mergelas
WaterTAP Ontario
Egils Milbergs
Center for Accelerating Innovation
Jeff Moeller
Water Environment Research Foundation
Michael Murphy
Massachusetts Clean Energy Center
Fred Mussari
BCR Environmental
Sarah Neiderer
District of Columbia Water and Sewer Authority
Paul O'Callaghan
BlueTech Research
Helle Petersen
Central Valley Business Incubator
Gil Pezza
Michigan Economic Development Corporation
Glenn Schrader
University of Arizona
Richard Seline
Regionnovate LLC
Chi Ho Sham
The Cadmus Group, Inc.
Harry Stone
Battelle
Maggie Theroux
U.S. Environmental Protection Agency
Alan Vicory
Confluence
Donna Vincent Roa
BlueTech Research
Abby Waits
U.S. Environmental Protection Agency
David Zoldoske
International Center for Water Technology at
California State University, Fresno
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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APPENDIX B
U.S. EPA Water Technology Innovation Cluster Leaders Meeting
Program Summaries
In advance of the Water Technology Innovation Cluster Leaders Meeting, EPA distributed short
summaries of several testing and labeling programs as background resource materials for the workshop.
This appendix contains those summaries as they were distributed to the meeting participants.1
This appendix contains summaries for the following programs:
• Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
• Leaders Innovation Forum for Technology (LIFT) Technology Evaluation Program
• New Jersey Energy and Environmental Technology Verification Program
• Pathogen Equivalency Committee (PEC) Process
• Technology Assessment Protocol-Ecology (TAPE)
• Toxic Substance Control Act (TSCA)
• U.S. EPA Clean Water Act (CWA) Alternative Testing Procedure (ATP) Program for Drinking Water
• U.S. EPA Clean Water Act (CWA) Alternative Testing Procedure (ATP) Program for Water Quality
• WaterSense®
1 Although these program summaries were prepared with input from representatives of the testing programs, EPA
cannot guarantee the accuracy of the summaries and does not accept any responsibility or liability for their accuracy,
content, completeness, legality or reliability.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 25
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Federal Insecticide, Fungicide and Rodenticide Act
(FIFRA)
Mandatory Administered by EPA OCSPP, Antimicrobials Division
Registration program Cost: $11,577 plus chemical or product registration fees
for antimicrobial disinfection Time: Up to several years
technologies http://www2.epa.gov/pesticide-registration/antimicrobial-
in the United States pesticide-registration
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA). EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality or reliability of the information contained in this document.
Overview
Technologies that claim to have antimicrobial effects are regulated as pesticides under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA). Water technologies/devices that, for example,
claim to perform microbial disinfection are subject to regulation under FIFRA, which is administered by
EPA's Office of Chemical Safety and Pollution Prevention (OCSPP), Antimicrobials Division. There are
two classifications: (1) if the antimicrobial technology uses chemicals, then it is regulated and must be
registered or (2) if a mechanical device claims antimicrobial effects without a specific chemical added to
the device, then it is regulated and does not need to be registered. EPA needs to understand what the
manufacturer is claiming regarding antimicrobial activity and how the device functions (chemical or
mechanical) to make that determination. For ultraviolet (UV) drinking water technologies, their approval
is handled by EPA's Office of Water and the UV Guidance Manual applies. If the technology uses
nanomaterials then it is also regulated by the Toxic Substance Control Act.
Process
For registration, the manufacturer should first visit the website listed above and then email the contact to
request a presubmission meeting to determine whether registration is necessary. The presubmission
meeting is free, and it is usually scheduled within 6 weeks of contacting the division. It is advisable that
the manufacturer hire a pesticide regulatory consultant to make sure that the technology is feasible and
accurate and applicable data can be gathered to prove it.
The manufacturer is expected to submit the information requested on the website to EPA 2 weeks prior to
the meeting. It is essential that applicants include a description of the proposed uses and how the product
works and label claims and any planned non-pesticidal label uses (a draft label would be preferred).
Presubmission information: http://www.epa.gov/oppad001/preapplmeet010.htm
During the meeting, risk managers and scientists review the process with the manufacturer to decide
exactly what the technology is trying to do, help them decide if they want to go through this process, and
make sure that they are prepared to develop a solid protocol. Only after a successful meeting will the
manufacturer be invited to develop a testing protocol or use an existing protocol from EPA's database.
Once a protocol gets approved and the technology/device registered, EPA redacts all identifying
information and publicly posts the protocol so that it can be used and adapted by other manufacturers.
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 26
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Outcome
The Agency shares the registration of new chemicals or products both online and through the public
comment process.
EPA has a database of pesticides and chemicals: EPA's Pesticides Chemical Search, online at
http://iaspub.epa.gov/apex/pesticides/f?p=chemicalsearch:l
For the hospital line of antimicrobial products, if a product fails efficacy testing after registration, then the
failing product is reported to the public under the Antimicrobial Testing Program:
http://www.epa.gov/oppad001/antimicrobial-testing-program.html
Protocol Development
Manufacturers develop their own testing protocols with review by the Antimicrobials Division or use an
existing approved protocol. Testing must not only determine that the pesticide is not harmful to humans
or the environment but also that the product supports the antimicrobial claims.
Cost
There is a registration service fee of $11,577.
In addition to the service fee, there are new Chemical or Product registration fees, which are listed in the
fee table: http://www.epa.gov/pesticides/fees/
Timeline
The process could take a few years, depending on the amount and scope of data needed.
Contact
Contact information for the Antimicrobials Division Ombudsman is listed on the website with the
registration manual: http://www2.epa.gov/pesticide-registration/pesticide-registration-manual
Additional Information
Possible sources for a list of pesticide regulatory consultants:
• American Chemistry Council (ACC): http://www.americanchemistry.com/
• Chemical Specialty Products Associations (CSPA:) http://www.cspa.org/
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LIFT Technology Evaluation Program
Voluntary Administered by Water Environment
Evaluation and demonstration program Research Foundation (WERF)
for wastewater, stormwater, and drinking Cost: Project specific
water technologies Time: Project specific
in North America www.werf.org/lift
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA) or WERF. EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality or reliability of the information contained in this document.
Overview
The LIFT Technology Evaluation Program is a technology testing, evaluation and demonstration program
administered by WERF for wastewater, stormwater and drinking water technologies. The process is
driven by municipal and industrial facility owner end users. WERF municipal and industrial facility
owner subscribers identify innovative technologies of interest and work collaboratively with technology
providers and others to evaluate/demonstrate them and move them into practice.
Manufacturers may apply to be considered through the LIFT Technology Scan program. The technology
evaluation process produces independent, peer-reviewed evaluations that can be used by facility owners
and their advisors to gain confidence in the performance of new technologies and adopt them more
quickly.
Evaluation Process
WERF uses LIFT Technology Scans to identify and conduct technology evaluations.
Application Technology providers may submit their products to a Technology Scan using a
standardized application form. The program is open to emerging, precommercial
and newly commercialized products. Established products seeking new
applications may also be considered. Conventional technologies are not eligible
under the program.
Technical Review An expert committee selected by WERF does an initial screening review of the
technical content and any claims as well as the technology readiness level to
confirm a likely match of the technology with its intended application.
Assessment by WERF coordinates presentations of technologies deemed of interest to end users
Interested Parties and assembles partnerships for technology pilots/demonstrations and independent,
third-party evaluations.
Evaluation WERF contracts with third parties to conduct evaluations/demonstrations to assess
performance of technology processes against design claims. Evaluations are
supported by the interested parties (i.e., sharing of costs and risks). Evaluations
also focus on scale-up and integration into facilities to optimize technologies and
speed adoption by facility owners.
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Final Report and WERF develops peer-reviewed evaluation reports and products that are publicly
Dissemination available (free for subscribers) and disseminated by WERF and WEF.
Technology evaluations may also be initiated under LIFT by end user facility
owners who identify a technology of interest and request WERF's help in
assembling collaborative partnerships and conducting an independent evaluation.
Outcome
LIFT uses a collaborative process that helps move new technologies into practice by managing risk. The
outcomes of this program include:
• A credible, well-documented vetting system to screen new technologies and processes.
• Ability to more rapidly deploy new technologies and remove existing impediments.
• Mitigation of the risk and cost of innovative technology deployment through partnerships.
• Facilitation of collaboration among facilities for the evaluation and testing of new technologies.
• Peer-reviewed information about emerging technologies.
WERF does not endorse a particular technology but rather provides the results/performance data and
includes the criteria that were used to evaluate performance.
Protocol Development
As the first step of an evaluation project, WERF brings together all project participants (e.g., technology
provider, facility owners, independent consultants) to develop the scope and objectives for the
demonstration/evaluation. All parties agree to a project Quality Assurance Project Plan (QAPP) that
includes a data collection plan and experimental plan. The QAPP must be approved by WERF's peer
review committee.
Cost
The cost is project specific. Costs have ranged from $25,000 to more than $1 million depending on the
nature and scope of the testing and evaluation.
Timeline
The estimated time to complete the testing and evaluation is project specific. The time has ranged from a
few months to a year or two depending on the nature and scope of the testing and evaluation.
Contact
JeffC. Moeller, P.E.
Director of Water Technologies
635 Slaters Lane, Suite G-110
Alexandria, VA 22314
(571)384.2104
imoeller(S),werforg
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New Jersey Energy and Environmental Technology
Verification Program
Mandatory
Verification program
for stormwater manufactured
treatment devices
in New Jersey
Administered by New Jersey Center for Advanced
Technology
Cost: $20,000 plus testing costs
Time: Approximately 6-12 months (depends on
dispute resolution, if required) plus testing time
http://www.njcat.org/
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA), the New Jersey Department of Environmental Protection, or the New Jersey Corporation
for Advanced Technology. EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality or reliability of the information contained in this document.
Overview
New Jersey's Energy and Environmental Technology Verification (EETV) Program verifies the
performance of stormwater manufactured treatment devices (MTDs). The program is administered by the
New Jersey Corporation for Advanced Technology (NJCAT), which has been designated as the official
third-party verification entity for the EETV Program. MTDs that complete the verification process receive
certification from the New Jersey Department of Environmental Protection (NJDEP), allowing the use of
that technology in the state of New Jersey.
Although this brief focuses on the verification process for MTDs, NJCAT and the EETV program also
verify a variety of other environmental and energy technologies.
Verification Process
To begin the MTD verification process, manufacturers must submit an MTD Verification Application to
NJCAT. NJCAT reviews the application to ensure that the planned testing program meets the NJDEP
protocol requirements.
NJCAT does not perform any technology testing. Manufacturers must have their technologies tested by
an independent third-party laboratory or under independent third-party supervision in their own
laboratories; they then submit a performance test report to NJCAT. NJCAT evaluates the data to verify
MTD performance.
Verification
application
Prior to commencing the planned laboratory testing program, the manufacturer
must provide an MTD verification application that provides the following
information: organization information, a general description of technology,
laboratory testing location, a statement of potential conflicts of interest, and a
quality assurance project plan.
NJCAT will review the manufacturer's verification application to ensure that the
laboratory testing will be conducted in strict accordance with the applicable
laboratory testing protocol and all NJDEP requirements.
On NJCAT approval, the manufacturer commences the laboratory testing in strict
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Quality control
Report preparation
accordance with the laboratory testing protocol.
NJCAT will review the laboratory test report for completeness and compliance
with the applicable laboratory protocol. Within 30 days of receipt of the test
report, NJCAT will meet in person or by telephone with the manufacturer to
discuss the report and issue a preliminary opinion regarding the manufacturer's
compliance with the protocol and, if not, specifying in detail the areas of
noncompliance with the protocol. If outstanding issues cannot be resolved, the
manufacturer may request submission of outstanding issues to a three-member
review panel.
Once any outstanding issues with the preliminary opinion have been resolved,
NJCAT will issue a final verification report within 90 days. The NJCAT-issued
verification report will then be posted for a 30-day public comment period. If
there are no public comment issues or the issues can be resolved, NJCAT will
finalize the report and notify NJDEP that the MTD has been verified.
If any issues resulting from public comments cannot be resolved, the issues are
submitted to a three-member review panel for resolution. The cost of the review
panel is the responsibility of the losing party. Based on the review panel's report
and NJCAT's response, the manufacturer can decide to address any unresolved
outstanding issues or end the process. If all issues have been resolved, NJCAT
will finalize a verification report.
Outcome
If the MTD passes the verification process, NJCAT will notify NJDEP that the final verification report
has been posted on the NJCAT website. NJDEP will then certify the technology for use in the state of
New Jersey. NJDEP only certifies MTDs for total suspended solids removal: 50 percent for
hydrodynamic sedimentation devices and 80 percent for filtration devices.
If the MTD does not pass the verification process, NJCAT will issue the final verification report to the
manufacturer. The manufacturer may resubmit the technology for verification after addressing concerns
raised in the verification process.
Protocol Development
The verification process requires laboratory testing of the MTD according to the New Jersey Department
of Environmental Protection Laboratory Protocol to Assess Total Suspended Solids Removal by a
Hydrodynamic Sedimentation Manufactured Treatment Device or the New Jersey Department of
Environmental Protection Laboratory Protocol to Assess Total Suspended Solids Removal by a Filtration
Manufactured Treatment Device, both dated January 25, 2013.
Testing must be conducted by or under the supervision of an independent third-party laboratory.
Cost
NJCAT's verification process requires a $20,000 fee. Manufacturers are responsible for testing costs.
Review panel costs are separate.
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Timeline
The verification process can take from 6-12 months depending on: (1) the completeness and compliance
of the test report, (2) the time to resolve issues with the test report, (3) the need for a test report review
panel, (4) the extent of public comments, (5) the time spent on the public comment resolution process,
and (6) the need for a verification review panel and the extent and complexity of the outstanding issues
raised by the public commenters.
Contact
Dr. Richard S. Magee
Technical Director
973-879-3056
rsmagee@rcn. com
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Pathogen Equivalency Committee (PEC) Process
Strongly suggested Administered by a committee of U.S. EPA & other
Review and recommendation agency experts
program Cost: No cost for PEC application; all other costs
for sewage sludge treatment extremely variable
processes Time: Variable
in a specific site (or nationwide) http://water.epa.gov/scitech/wastetech/biosolids/basic.cfm
#benefits
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA). EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality or reliability of the information contained in this document.
Overview
The Pathogen Equivalency Committee (PEC) consists of 10 experts from EPA and other agencies,
including the Centers for Disease Control and Prevention, who review applications from applicants
(often manufacturers) for new sewage sludge treatment processes seeking to establish equivalency to the
currently approved processes listed in 40 CFR Part 503 Subpart D. The Committee then makes
recommendations to relevant federal and/or state permitting authorities on the merits of the application.
An applicant must prove that his/her process can consistently reduce pathogens to levels comparable to
the reduction achieved by the listed Process to Further Reduce Pathogens (PFRPs) or Process to
Significantly Reduce Pathogens (PSRPs). An equivalency determination is required of the relevant
sludge/biosolids permitting authority, unless the treatment process falls under certain accepted sludge
disinfection Alternatives. Equivalency is generally recommended on a site-specific basis, unless the
applicant meets the requirements for the process to be considered suitable on a national level. Applicants
that successfully complete the process will be subject to approval by the relevant permitting authority,
after which they will be allowed to utilize their process to prepare the sewage sludge for land applications.
Application Process
Before applying, applicant should answer the following questions:
(1) Am I seeking PFRP or PSRP pathogen reduction equivalency?
• To answer this question, the applicant may need to conduct proof-of-concept studies to determine
which is most applicable, as well as the parameters and matrices within which the process will
operate.
(2) Does my process resemble or meet the operating conditions of any current alternatives listed in
40 CFR Part 503 Subpart D?
• If process resembles or meets the operating conditions of any of the established options available
under Class A for PFRP processes or Class B for PSRP processes, an equivalency
recommendation may not be necessary.
• If process resembles an established option but with one or more key differences, then the
applicant may be able to demonstrate equivalency with minimal testing, through a comparison of
operating conditions between the new process and the established one. This decision is made on a
case-by-case basis by the permitting authority and/or PEC.
• If process neither meets nor resembles an established option, applicant will need to determine
equivalency through testing using a Quality Assurance Project Plan (QAPP) that clearly
demonstrates how the pathogen is killed, whether by pressure, temperature, pH, chemical, etc.
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(3) Am I seeking site-specific or national equivalency?
• If treatment process (1) is to be used in different areas of the United States and (2) its
effectiveness is independent of the variety of climatic and other conditions that might be found in
differing locations, then a recommendation of national PFRP or PSRP may be useful.
Application Steps
Step 1 Applicant contacts the appropriate state or federal permitting authority using the following
website for contact info: http://water.epa.gov/scitech/wastetech/biosolids/locator.cfm. If PEC
involvement is appropriate, the authority will coordinate with PEC. If applicant is not currently
working with a specific waste water treatment plant, he/she should contact the PEC.
Step 2 Applicant develops a QAPP to provide a framework for the testing process, which will be
reviewed and approved by the PEC using a Completeness Checklist before testing commences.
Step 3 Applicant carries out QAPP and analyzes data.
Step 4 Applicant completes and submits pathogen reduction equivalency application package using
the detailed forms found on the website.
Testing Protocol
Equivalency can be demonstrated in one of two ways: (1) by comparing operating conditions to existing
PFRPs or PSRPs or (2) by providing performance and microbiological data. In general, sludge should be
sampled using accepted, state-of-the-art techniques for samples and analyzed using methods required by
40 CFR Part 503 Subpart D. The quality of data provided to PEC is extremely important, and EPA
evaluates the study design, accuracy of the data, and adequacy of results for supporting the conclusions
that are drawn. Full-scale operation data are most desirable but may be very difficult to obtain depending
on the pathogen in question.
A PFRP is a treatment process that is able to consistently reduce sewage sludge pathogens to acceptable
levels as detailed in the table below. This enables sludge to meet requirements for consideration as a Class
A sewage sludge. The PEC is concerned primarily with enteric viruses and viable helminth ova reduction,
because fecal coliform or Salmonella sp. require separate ongoing monitoring.
A PSRP is a process that consistently reduces the density of pathogens, viruses and/or parasites in mixed
sludge from a conventional plant by the amounts detailed in the table below. This enables sludge to meet
requirements for consideration as Class B sewage sludge. It is expected that some pathogenic
microorganisms will survive PSRP treatment.
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Criteria for Demonstrating Pathogen Reduction
Mandatory Minimum Requirements
PSRP Equivalency PFRP Ecjurealentf
Process Efficiency
Parameters:
Process Compliance
Parameters
3 log reduction of total enteric
viruses,and
2- > 2 log reduction of viable helminth
(Ascaris) ova, and
3. > 3 log reduction of fetal coliform
bacteria
Organism densities in the treated sludge of:
1. < I pfu 4 c, TS of total enteric
viruses, and
2. < } viable helminth (Ascaris) ova/4
g TS, and
3. < 1,000 MPN fecal coliform . g TS
Seveial optional organisms are listed in a separate table. EPA is collecting information on the fate of these
microorganisms tay different modes of treatment with the intent of gathering enough data to support their usefulness
as stnrogates in full-scale testing. Consider including as many of the optional analyses as feasible. The
measurement of all 01 some of optional organisms will enhance yotii demonstration by incieasing the level of
confidence associated with the process under investigation and will be helpful later when the process is tested on a
laiger scale. ( Criterion (3) Demonstration of Successful Scale-up.)
It is highly preferred that a process goes through the PEC equivalency review process. There are
Alternatives that a process may meet to bypass this process. Alternatives 3 and 4 for Class A (PFRP)
processes and Alternative 1 for Class B (PSRP) processes explain how this is possible—but there may be
one or more states that do not allow this.
Please refer to the table for requirements that both PSRP and PFRP processes must meet to be
recommended for equivalency. The applicant is responsible for identifying the process operating
parameters (e.g., time, temperature, pH) that are necessary and sufficient for achieving reductions in
pathogens needed for the process to be considered satisfactory. The applicant is responsible for utilizing a
suitable laboratory and using methods approved in the QAPP and with proper QA for all testing.
Outcome
The PEC considers each equivalency application on a case-by-case basis. The committee evaluates the
information on operating parameters and/or the sewage sludge that the applicant must provide. The PEC
then recommends one of four decisions about the process to the permitting authority:
(1) Full equivalency,
(2) Conditional or restrictive equivalency,
(3) Not equivalent, or
(4) More information necessary.
Around the time a recommendation is issued, PEC will request that the applicant create an operation and
maintenance (O&M) manual. The O&M manual may be provided to the permitting authority, but
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014
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generally stays with the PEC. It is important to note that the PEC's recommendations are typically
followed but are not formally binding. The permitting authority makes the final decision on equivalency.
Successful applicants are listed and described on PEC's website, and data may or may not be posted on
the permitting authority's site as well. Unsuccessful applicants' data are not shared publicly.
Cost
There is no cost for applying to PEC. The applicant is responsible for all costs associated with
development of a QAPP, research and completion of the application. These costs can range anywhere
from $100,000 to $1 million, depending on the degree of complexity and detail a project requires.
Timeline
PEC review of a completed application can take 3 or more months, which may be spread over several
years. This does not include the time the applicant takes to conduct proof-of-concept studies, create an
acceptable QAPP, and conduct all required testing.
Contact
Laura Boczek and Bob Brobst, PEC Co-Chairs
U.S. Environmental Protection Agency
26 West Martin Luther King Dr.
Cincinnati, OH 45268
boczek.laura@epa.gov
brobst.bob@iepa.gov
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Technology Assessment Protocol - Ecology
Mandatory
Testing and certification program
for stormwater treatment
technologies
in Washington
Administered by Washington Department of Ecology
Cost: $12,000 plus testing costs
Time: 6-30 months
http://www.ecy.wa.gov/programs/wq/stormwater/newtech
/index, html
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA) or the Washington Department of Ecology. EPA does not accept any responsibility or
liability for the accuracy, content, completeness, legality or reliability of the information contained in this document.
Overview
Washington's Technology Assessment Protocol - Ecology (TAPE) certifies short-detention, flow-based
stormwater treatment technologies. Technologies that successfully complete the TAPE process will
receive a General Use Level Designation (GULD) from the Washington Department of Ecology
(Ecology).
Certification Process
To obtain certification under TAPE, manufacturers must complete an initial application, design a Quality
Assurance Project Plan (QAPP), conduct testing, and submit a final Technical Evaluation Report (TER)
for review by Ecology.
Initial application
QAPP design
Field testing
Final evaluation
To begin the TAPE process, manufacturers must submit an initial application to
Ecology. The initial application must include preliminary performance data for the
technology, which may come from other testing programs.
Ecology and the Board of External Reviewers (BER) will review the application. If
Ecology considers the technology promising, Ecology will approve the technology
for a Pilot Use Level Designation (PULD) or a Conditional Use Level Designation
(CULD) based on the preliminary performance data.
Both PULD and CULD are limited-duration certifications that allow the
manufacturer to install the technology at a limited number of sites for testing
purposes.
After the initial application is accepted, the manufacturer must develop a QAPP to
evaluate the performance of the technology. Ecology and three members of the BER
will review the plan.
Once Ecology approves the QAPP, the manufacturer has 24 months to carry out the
study and submit a final TER to Ecology.
Ecology and the BER will evaluate the TER within 3 months, then Ecology will
issue a final decision. If Ecology approves the report, the technology receives a
GULD, certifying it for use in the state of Washington.
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Protocol Development
The manufacturer must develop the testing protocol and QAPP based on the requirements set out in TAPE
Technical Guidance Manual and in Ecology's Guidelines for Preparing Quality Assurance Project Plans
for Environmental Studies.
Site selection The testing protocol must involve field testing in at least one site in western
Washington or a comparable area representative of the Pacific Northwest.
The site should allow testing of the technology with influent flow rates and
pollutant concentrations representative of expected use scenarios.
Data collection Applicants should collect samples from a minimum of 12 sampling events over
a range of rainfall intensities. Data from more than one site can be combined to
meet the minimum of 12 events, provided tributary drainage from land use and
pollutant concentrations are comparable between sites. Applicants must collect
enough data to show significant statistical differences as outlined in the
protocol; therefore, more than 12 sampling events may be necessary.
Laboratory testing Laboratory testing may be used to supplement field testing but cannot replace it
entirely.
Outcome
Technologies approved by Ecology through TAPE will receive a GULD, certifying the technology for use
in the state of Washington. At the time of approval, Ecology will specify conditions for the GULD,
including the approved contaminants the technology can treat, design flow rate of the technology, and
required maintenance intervals. The GULD has no expiration date.
Technologies approved through TAPE may still require approval by local governments within
Washington. TAPE certification, however, is put forth as a guideline for local governments interested in
approving new technologies. Some state, county and municipal governments outside the state of
Washington acknowledge TAPE certification.
Cost
Certifying a technology through the TAPE process costs $12,000 plus the cost of the testing regimen.
Initial application fee $2,000
QAPP review fee $4,000
Review of technical evaluation report $6,000
Timeline
The review of the initial application requires at least 1 month. Following the review of the initial
application, Ecology will issue a PULD or CULD for the technology.
The manufacturer has 6 months to submit a study design and QAPP to Ecology after the PULD or CULD
is issued. QAPP approval may take up to 3 months.
Once Ecology approves the QAPP, the manufacturer will have 24 months to perform the study and either
submit a TER or file for an extension.
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Ecology will have 6 months to review the TER and issue a final determination.
Contact
Douglas C. Howie. P.E.
douglas.howie@ecy.wa.gov
360-407-6444
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Toxic Substance Control Act (TSCA)
Mandatory Administered by EPA OCSPP, Chemical Control Division
Review program Cost: $2,500 for PMN submission; all testing costs extremely
for new chemicals variable
in the United States Time: At least 90 days for PMN review, more for testing
http://www.epa.gov/oppt/newchems/
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA). EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality, or reliability of the information contained in this document.
Overview
The new chemical review program is not for a technology, per se, but for a new chemical that is not
already listed on the Toxic Substances Control Act (TSCA) Inventory. At least 90 days prior to
manufacture or import of a new chemical for general commercial use, a Premanufacture Notice (PMN)
must be filed with EPA under Section 5 of TSCA. During the review period EPA will assess the potential
risk to human health and the environment from the new chemical and may take action to prevent any
unreasonable risks including requiring testing before commercialization or identifying conditions to be
placed on the use of the new chemical before it enters into commerce.
TSCA applies to chemicals used in water technologies that involve filtering but not those claiming to
"kill" any microbes or particles. If the technology is claiming a pesticidal property such as antimicrobial
disinfection, then it is regulated under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA;
please see the FIFRA summary). Nanomaterials are considered chemical substances and are subject to
TSCA regulation. TSCA is administered by EPA's Office of Chemical Safety and Pollution Prevention
(OCSPP), Chemical Control Division.
Process
Manufacturers must first determine if the chemical substances they wish to submit are on the TSCA
Inventory. The public TSCA Inventory is available online at:
http://www.epa.gov/oppt/existingchemicals/pubs/tscainventory/howto.html. EPA also maintains a
separate confidential list of chemical substances that are on the TSCA Inventory that are not publicly
available.
When a manufacturer has a new chemical that is not on the inventory, a PMN must be submitted at least
90 days prior to the manufacture or import of the chemical. Before submitting a PMN you may arrange a
prenotice call with EPA. This is recommended for new technologies, such as water filtration using
nanomaterials. A PMN must include information such as specific chemical identity, use and anticipated
production volume. The PMN must also contain all reasonably ascertainable exposure and release
information and existing available environmental health and safety test data. TSCA does not require a
company to develop new data for a PMN submission, but it must submit all available or reasonably
ascertainable data. For example, 85 percent of PMN submissions contain no toxicity data.
EPA will review the available data and assess the potential human health and environmental risks of the
new chemical. If EPA determines that there is a potential unreasonable risk, it will take any action
necessary to prevent that risk including requiring toxicity or exposure testing and could include banning
the use of the chemical. EPA will usually allow the PMN submitter to market the new chemical on a
EPA Water Technology Innovation Cluster Leaders Meeting - March 24-26, 2014 40
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limited basis while toxicity studies are being conducted. If the technology is for water filtration, then a
long-term toxicity study may be required.
Outcome
When the PMN review period is completed, the PMN submitter may commercialize the PMN substance.
This may involve certain restrictions EPA has identified to prevent unreasonable risks during the PMN
review period. EPA would make this action effective through a 5(e) consent order or a Significant New
Use Rule, http://www.epa.gov/oppt/newchems/pubs/cnosnurs.htm
When the PMN submitter commences manufacture of the PMN substance, it is required to notify EPA. At
that point, EPA places the chemical on the TSCA Inventory.
Protocol Development
EPA usually requires testing according to standard protocols that it will identify. If a protocol for a new
test needs to be developed or the PMN submitter suggests a nonstandard protocol, EPA will work with
the PMN submitter to review that test protocol. The PMN submitter will usually have to develop any new
protocols.
Cost
There is a $2,500 fee for submitting a PMN. If testing is required, there will be additional costs. Longer
term tests, such as 90-day oral or inhalation studies, can cost between $300,000 (oral) and $700,000
(inhalation).
Timeline
At a minimum, the PMN review period is 90 days whether EPA makes any unreasonable risk findings or
not. If EPA develops regulations to prevent unreasonable risks that process could take another 3-6
months. If testing must be conducted before commercialization, then that process would take as long as
required to conduct the study and have EPA evaluate the results of the study and reevaluate the potential
risks.
Contact
For answers to questions about procedural, technical or regulatory requirements prior to submitting a
PMN, submitters can call a PMN prenotice coordinator:
David Schutz, 202-564-9262
Jim Alwood, 202-564-8974
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U.S. EPA Clean Water Act (CWA) Alternative Testing
Procedure (ATP) Program for Drinking Water
Mandatory Administered by U.S. EPA
Government evaluation Cost: No cost to apply, but applicant must pay for all
program required testing
for alternative/new drinking Time: 1 to 2 years after completed application
water method or procedure http://water.epa.gov/scitech/methods/cwa/atp/questions.cfm
in United States (nationwide)
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA). EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality or reliability of the information contained in this document.
Overview
The Alternative Testing Procedure (ATP) Program for Drinking Water is a government evaluation
program run by EPA to govern an applicant's use of alternative or new drinking water reference methods
or procedures under the National Primary Drinking Water Regulations of the Safe Drinking Water Act.
ATP evaluates two types of proposals:
(1) A modification of an EPA-approved reference method or procedure that uses the same determinative
technique and measures the same analyte(s) of interest.
(2) A proposal for a new method, which uses a different determinative technique to measure the same
analyte(s) of interest as an EPA-approved reference method.
ATP evaluates new and alternative microbiological and chemical methods using separate testing protocols
under one application process. Applicants are responsible for testing performance of the alternative or
new method as part of their applications, but EPA can provide assistance in developing study plans.
Applicants can only apply for nationwide use. It is mandatory that applicants get approval for an
alternative or new method. Applicants that complete the process and have their alternative or new method
approved via the expedited methods process will be able to use their method in all regulated entities and
laboratories across the country.
Evaluation and Approval Process
Step 1 Applicant designs a study plan that will test that the modified method produces results better
than or equal to those produced by an appropriate EPA-approved reference method for the
applicable combination of analyte and determinative technique.
Step 2 Applicant submits study plan design and the application form to the ATP program at the EPA
Office of Water, Office of Groundwater & Drinking Water, Technical Support Center.
The application form may be found on page 71 of the EPA Microbiological Alternate Test
Procedure Protocol for Drinking Water, Ambient Water, and Wastewater Monitoring Methods,
available here: http://water.epa.gov/scitech/methods/cwa/atp/questions.cfmtfaskEPA.
Step 3 The appropriate EPA body approves the study plan or makes suggestions that must be
incorporated before EPA will approve the plan.
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Step 4 Applicant conducts testing using his/her own resources and following the specific plans based
on analyte and determinative technique being tested.
Step 5 Applicant develops a comprehensive study report including all data, results and conclusions,
which he/she will send to the ATP program to be added to the application package.
Step 6 EPA will consider an application complete and will begin review once the application form,
study plan and study report are all in the hands of the ATP program.
Step 7 ATP will either accept or deny the alternative or new method, and EPA will send the applicant
a notification of the decision. Successful applications will then be forwarded to the expedited
methods program.
Step 8 Once the method has gone through this expedited process, it will be added to CFR 40 Part 141,
Appendix A.
Testing Protocol
The ATP Program generally requires either:
(1) A side-by-side method comparison study that compares the new method directly with a comparable
EPA-approved method, or
(2) A study that evaluates the new method's ability to meet quality control (QC) acceptance criteria of a
comparable EPA-approved method, where QC criteria has been set.
The ATP program covers various EPA-approved methods for a multitude of analytes, both
microbiological and chemical. For microbiological methods, the applicant should use a drinking water
certified laboratory to perform the evaluation as per the ATP protocol. The testing protocol can be found
online on the ATP website. For chemistry methods, however, because methods vary widely in their
chemistry and procedures, it is impossible to provide general guidance for the development of a robust
method. The applicant should identify critical points of each step in the procedure, address or control
these points in the method, and demonstrate that acceptable method performance is attained using all
procedural options specified in the method. The applicant is responsible for utilizing a suitable laboratory
and using the methods approved in the study plan and in accordance with quality assurance protocols.
Outcome
If ATP recommends the approval, it is forwarded for Expedited Method Approval. Once approved, the
applicant will receive documentation that he/she is approved to utilize the alternative or new method in all
regulated entities and laboratories.
Cost
There is no cost for applying for an ATP. The applicant is responsible, however, for all costs associated
with the application and research.
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Timeline
The timeline for completing an entire application is dependent on the timeliness and quality of the
applicant's work. Once an application has been accepted by the ATP program, the expedited process will
enable the method to be approved and formally adopted within 1 to 2 years.
Contact
For microbiological methods:
James Sinclair
Technical Support Center
Office of Groundwater and Drinking Water
Sinclair.james(g),epa.gov
513-569-7970
For chemical methods:
Steven Wendelken
Chemistry Drinking Water ATP Program
Technical Support Center
Office of Groundwater and Drinking Water
wendelken.steve@epa.gov
513-569-7491
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U.S. EPA Clean Water Act (CWA) Alternative Testing
Procedure (ATP) Program for Water Quality
Mandatory Administered by U.S. EPA
Government approval program Cost: No cost to apply, but applicant must pay for all
for alternative/new ambient required testing
water, wastewater, or sewage Time: 3 to 4 years after completed application
sludge method http://water.epa.gov/scitech/methods/cwa/atp/questions.cfm
in United States (nationwide or
limited use)
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA). EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality or reliability of the information contained in this document.
Overview
The Alternative Testing Procedure (ATP) Program for Water Quality is a government approval program
run by EPA to approve through rulemaking an applicant's alternative or new ambient water, wastewater
or sewage sludge methods for use as a compliance monitoring method under the National Pollutant
Discharge Elimination System (NPDES) program of the Clean Water Act (CWA).
ATP evaluates two types of proposals:
(1) A modification of an EPA-approved reference method or procedure that uses the same determinative
technique and measures the same analyte(s) of interest regulated under 40 CFR Partl36.
(2) A proposal for a new method, which uses a different determinative technique to measure the same
regulated analyte(s) of interest as an EPA-approved reference method.
For microbiological method proposals, ATP evaluates new and alternative methods using one protocol.
For chemical method proposals, ATP evaluates new methods separately from alternative methods in two
different protocols. Applicants are responsible for testing performance of the alternative or new method as
part of their applications. EPA provides assistance in developing study plans. Applicants can apply for
nationwide use (NW) or limited use (LU) approval. It is mandatory that applicants get approval for use of
any alternative or new method if they want laboratories to be able to use their methods for compliance
monitoring (i.e., methods in NPDES permits). Applicants that complete the NW process and have their
alternative or new method added to the Code of Federal Regulations will be able to have their method
used by all regulated entities and laboratories across the country. Methods approved for LU will only be
applicable in the single laboratory that they are approved for.
Process for Microbiological Method Proposals
Approval Process (NW use as default)
Step 1 Applicant designs a study plan that will test that the modified method produces results equal to
or better than those produced by an appropriate EPA-approved reference method for the
applicable combination of analyte and determinative technique.
Step 2 Applicant submits NW use study plan design and three copies of the application form and the
method to the ATP program at EPA Office of Water, Office of Science and Technology,
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Engineering & Analysis Division, for review.
In cases of limited use applications:
• Applicants in states that have the authority to administer CWA monitoring programs
will direct application materials to the Director of the State Agency issuing the NPDES
permit.
• Applicants in states that do not have the authority to administer CWA monitoring
programs will direct application materials to the EPA Regional ATP Coordinator.
Step 3 The appropriate EPA body will approve the study plan or make suggestions that must be
incorporated before EPA will approve the plan. The study plan must be approved before the
applicant can begin testing.
Step 4 Applicant will conduct testing using his/her own resources and following the approved study
plan based on the regulated analyte and determinative technique being tested. Applicant is
responsible for utilizing a suitable laboratory and using the methods approved in the study plan
and in accordance with quality assurance protocols.
Step 5 Applicant will develop a comprehensive study report including all raw data, statistical analyses,
results and conclusions (and the revised method if test results show that it needs revision), which
he/she will send to EPA to be added to the application package.
Step 6 EPA will consider an application complete and will begin review once the application form,
study plan, written method and study report have been received by EPA and are found to be
acceptable.
Step 7 If EPA accepts the alternative or new method, EPA will send the applicant a letter stating that
the method is acceptable. The application will then be recommended to the EPA Administrator
for approval through a federal rulemaking.
In cases of limited use applications: After reviewing the complete application, the appropriate
State or Regional EPA ATP Coordinator will provide applicant with an official letter of
approval or disapproval, and the process will be complete.
Step 8 For NW applications, once the alternative or new method has gone through the formal
rulemaking process, including a public comment period, and is approved, it will be added to
CFR 40 Part 136 as an approved method for the particular regulated analyte in the matrix in
which it was tested.
Testing Protocol
The ATP Program prefers either:
1. A side-by-side method comparison study that compares the new method directly with a comparable
EPA-approved method for new methods, or
2. A study that evaluates the new method's ability to meet quality control (QC) acceptance criteria of a
comparable EPA-approved method, where QC criteria has been set for alternative methods.
The ATP program covers various EPA-approved methods for a multitude of analytes, both
microbiological and chemical. Specific testing protocols for all analytes, method formats and reference
methods can be found online in three PDFs on the ATP website.
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Process for Chemical Method Proposals
ATP evaluates new chemical methods separately from alternative chemical methods. Applicants may
follow the same general application steps that are listed above but must take note of the following
differences in testing protocols:
New Methods: A new method is a set of procedures that has been written in the 17-section standard EPA
format, contains standardized QC elements and associated acceptable criteria, employs a determinative
technique different from those previously approved for a measurement of a given regulated analyte, and
employs a determinative technique that is as sensitive and selective as the previously approved
techniques. A new method involves a change to the determinative technique, and the applicant must use
the results of the validation study to develop acceptance criteria for the new combination of 40 CFR
Part 136 regulated analyte and determinative technique.
Alternative Methods: An applicant may submit an application for review and recommended approval of
a modified version of an approved 40 CFR Partl36 method or procedure(s) that uses the same
determinative technique which measures the same 40 CFR Part 136 regulated analyte(s) of interest as the
approved method. Applicants demonstrate method equivalency by meeting QC acceptance criteria
associated with EPA-designated approved Part 136 methods. ATP also distinguishes between "minor
modifications," which do not change the underlying chemistry of the approved method, and "major
modifications," which involve changing the underlying chemistry of the "front end" techniques. (See
Title 40 of the Code of Federal Regulations, Part 136.6.).
Alternative methods can be differentiated from new methods because an alternative method involves a
change to the "front end" of the method; in other words, those procedures which prepare the sample
and/or isolate the analyte(s) of interest from the sample matrix prior to identification and measurement.
New method validation and alternative method validation each have a three-tier process that classifies the
intended use of a new method and requires a validation study that is reflective of the level of use
associated with each tier:
Tier 1 Methods may only be used by a single laboratory (limited-use) for one or more matrix types.
Tier 2 Methods may be used by all laboratories (NW) for only one matrix type. Validation requires a
3-laboratory validation study.
Tier 3 Methods may be used by all laboratories (NW) for all matrix types and requires a 9-
laboratory validation study. The applicant is responsible for utilizing a suitable laboratory and
using the methods approved in the study plan and in accordance with quality assurance
protocols. Additional guidance on submission and validation of alternative methods and
development of QC acceptance criteria for new methods for regulated chemical analytes
including application forms may be found here:
http: //water, epa. gov/scitech/methods/cwa/atp/questions. cfm
Outcome
Once an alternative or new method is formally approved through rulemaking for NW and added to CFR
40 Part 136, entities may use the method for compliance monitoring under the NPDES program. To be
added to the CFR, the applicant's study report (which includes all associated data) is placed in the
rulemaking docket when the method is proposed as an approved method at 40 CFR Part 136 and will be
accessible to the public for public comment.
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In cases of limited use applications: Once an alternative or new method is approved for LU by the
appropriate authority (listed above) and a letter of approval is distributed to the applicant, the method is
permitted to be used in only the approved laboratory.
Cost
There is no cost for applying for an ATP. The applicant is responsible, however, for all costs associated
with the application and required research.
Timeline
The timeline for completing an entire application is dependent on the timeliness and quality of the
applicant's work. Once an application has been accepted by the ATP program and passed onto the EPA
Administrator for approval, it can take 3 to 4 years for it to be formally adopted into the CFR.
Contact
For new and alternative microbiological methods:
Robin K. Oshiro
Engineering and Analysis Division (4303T)
U.S. EPA Office of Water, Office of Science & Technology
Oshiro.robin(g),epa.gov or OSTCWAMethods(g),epa.gov
For new and alternative chemical methods:
Lemuel Walker
Clean Water Act ATP Coordinator (4303T)
Engineering and Analysis Division
U.S. EPA Office of Water, Office of Science & Technology
Walker.lemuel@epa.gov
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WaterSense
®
Voluntary Administered by U.S. EPA
Labeling program Cost: Variable
for plumbing products Time: Variable
Nationwide http://www.epa.gov/watersense/index.html
Disclaimer: This document does not necessarily reflect the official policies or views of the U.S. Environmental
Protection Agency (EPA). EPA does not accept any responsibility or liability for the accuracy, content,
completeness, legality or reliability of the information contained in this document.
Overview
WaterSense® is a certification and labeling program for water efficient products and new homes that meet
EPA-developed specifications. Showerheads, toilets, bathroom sink faucets, landscape irrigation
controllers, urinals, pre-rinse spray valves and new homes that are at least 20 percent more efficient than
standard products without sacrificing performance may be certified to use the WaterSense® label.
Certified products must use the WaterSense® label for packaging and promotion.
Certification Process
WaterSense® certification is a two-step process: manufacturers must enter into a partnership agreement
with EPA, then obtain certification from a third-party licensed certifying body (LCB).
Partnership Before applying for certification, manufacturers must sign a partnership agreement with
EPA. The partnership agreement can be completed online at
http://www.epa.gov/watersense/partners/partnership agreement.html
Certification After signing the partnership agreement with EPA, manufacturers need to contract
directly with an LCB to have their product certified. A full list of LCBs is available
online at http://www.epa.gov/WaterSense/about_us/cert_bodies.html.
The LCB will test the product to verify that it meets the WaterSense® specification. The
LCB will also assess production processes and review quality management systems, as
necessary.
Market Every year, EPA requires that each LCB must retest at least 15 percent of the
Surveillance WaterSense®-labeled products it has certified in each category to ensure that the
products still meet the appropriate WaterSense® specification. Half of the products to be
retested may be specified by EPA, whereas the other half are randomly chosen by the
LCB.
Products may be retested only once every 3 years.
Outcome
Once certification is complete, the LCB will provide the manufacturer with WaterSense® label and logo
files. The WaterSense® label can be applied to any packaging and promotional materials for the certified
product. The certification does not expire but may be revoked if the product fails retesting under market
surveillance (described above).
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The LCB will also notify EPA that the product is certified to use the WaterSense® label. The product will
be included on EPA's online registry of WaterSense®-certified products.
Protocol Development
Test protocols for WaterSense® certification are specified by EPA for each product type. These
specifications must be used by LCBs to certify the appropriate product types.
When developing a test protocol for a product type, EPA will first issue a notice of intent, requesting
input on technical issues. If EPA receives sufficient input, the Agency will develop a draft specification.
Where possible, EPA works with voluntary standards bodies (such as ASTM International) to develop
specifications. The draft specification will be released for public comment and stakeholder input, then
revised and either released as a revised draft or published as a final specification.
The specifications for each product type are available online at
http://www.epa.gov/WaterSense/partners/productjrogram specs.html.
Cost
Certification costs vary between certifying bodies but are expected to be comparable to other
certifications for plumbing products. There is no cost to enter into a WaterSense® partnership with EPA.
Retesting costs are borne by product manufacturers.
Timeline
Certification time varies between certifying bodies but is expected to be comparable to other certifications
for plumbing products.
Contact
WaterSense®
U.S. Environmental Protection Agency
Office of Wastewater Management (4204M)
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460.
(866) WTR-SENS (987-7367)
watersense@epa.gov
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