EPA Water Sense Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis (RO) Systems March 10, 2022 ------- WaterSense Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems Table of Contents Baruch Ziser, TipaTech 2 Dave Fowler, Liquos 5 Eric Yeggy, Water Quality Association (WQA) 7 Shannon Murphy, Aquamor 16 Nan J Aberman, E.A.M Benelux B.V 25 Eugene Leung, California State Water Resource Control Board 26 1 March 10, 2022 ------- WaterSense Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems Commenter: Baruch Ziser Affiliation: TipaTech Comment Date: January 16, 2022 Email Text: Hello everyone Thank you for the opportunity you give us to state the worldview of Tipa Tech I assume domestic RO technologies will evolve and reach higher water flows and less water thrown into the Sewage water There are several methods for achieving the goal - Recycling water thrown into the sewer - an existing and cumbersome method with relatively low results relative to the price of the financial investment - Use of water emitted from the process in favor of watering the garden - a cumbersome and expensive method that requires a water pump, a reservoir tank for water storage, water treatment so that they do not become contaminated - Increasing the output of the membrane to 800 GPD and more - a great idea with little water released into the sewer and can be obtained at a reasonable price - Using UF MEMBRANE- At a filtration level of 0.01 micron the level of the smallest pollutants which are heavy metals and viruses is 0.014 micron so we will always know to give clean water This is our contribution first and foremost to humanity and only then to our loyal customer all over the world In our case we produced a faucet with two pouring options one from the first filter water with a cleaning of 0.01 micron and the second faucet in favor of boiling in a kettle an espresso machine and a water iron without calcium and magnesium You can see our product above Thank you very much Baruch Ziser Tipa LOTUS - The most advanced home water purifier Baruch Ziser Cell: +972(0)50-2611600 Fax: +972(0)77-4448057 E-mail: ziser@tipatech.co.il Website: www.tipatech.co.il 2 March 10, 2022 ------- EPA * WaterSense Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems Email Attachments: LO TUS MUST SOFTNER NO MAGNESIUM 4 NOFERRUM NO CALSIUM PURE SOFT WA TER Attachment 1: lotus must softener.jpg LOTUS MUST- 4 STAGES PURE WATER FILTER Micron rating : 0.01 jim. Reduce 99% of harmful substances L i' i'' • «i "¦ n' CmMCURMC BALLS Remove ihe residual chlorine. Adjust ihc water PH. make the water weak alkaline. GRANULAR ACM CARBON Effectively remove the peculiar smell.residual chlorine.and absorb the organic matter in water. TILL ROD PARTICLES Used to treat heavy metal impurity .and bacteria inhibition. UF MEMBRANE Ultra filtration membrane removes 99% of targeted pollutants including Cadmiuin.Mcrcury.TMMs.lead. arsenic.heavy metals, microorganisms and other harmful substances. A & Attachment 2: LOTUS MSUT WATER FILTER NEW1 .jpg 3 March 10, 2022 ------- * Comments on WaterSense® epa Notice of Intent (NOI) to Develop a Draft Specification for AA/atCl*SCTISC Point-of-Use Reverse Osmosis Systems Attachment 3. 4 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense Commenter: Dave Fowler Affiliation: Liquos Comment Date: February 5, 2022 Email Text: Hi, Thanks for creating this program. Liquos has been building high efficiency POU RO systems for a number of years. What strikes me first is the relative inefficiency of RO systems in general. Walk the aisle at WQA and we see the same systems, with conventional auto-shut off valves we've seen for over 30 years. I've always understood that net psi was key to building an efficient RO - thus, we've always used one or more permeate pumps in our applications. I believe greater emphasis should be placed on the definition of performance as a function of real world operation. Manufacturers label their systems at 100 GPD, when in fact taking into consideration compensation variables: Water Temp. / Feed PSI - Back PSI = Net psi, one quickly understands conventional shutoff systems are always operating (with air capture tanks) at their most inefficient zone. I think it important consumers understand the relationship of net operating psi (delta) and where an RO system is generally operating as being a key informative visual / graphic / icon or Silver / Gold / Platinum standard. Also, I think it important to require publishing a number folks can relate to, of an actual amount of water dumped to drain over a 5 year period —> if you drink 1 gallon of water per day // 2 gallons per day etc, this is how much water will be dumped to drain — so folks have an idea of just how much water is wasted. When I show customers the huge difference a permeate pump makes, they realize very quickly a conventional RO system is a "gas guzzler" and do not want anything to do with them. We want to reward companies to innovate with new technologies, such as water on water systems or high flux systems as well as the very reliable and performance enhancing permeate pump — which we have used to help create high production POU systems at offices serving 100 - 200 people daily, for both hydration and beverage dispensing needs. Liquos provides the drinking water for companies such as Google, Ebay, PayPal, Netflix... Regards, Dave 5 March 10, 2022 ------- WaterSense Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems Dave Fowler, CEO 650-280-9003 m 650.964.4200 o 6 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense Commenter: Eric Yeggy Affiliation: Water Quality Association (WQA) Comment Date: March 5, 2019 Email Text: I am submitting the attached comments on behalf of the Water Quality Association. Please contact me if you have any questions, or if you do not receive the attachment. Eric Yeggv I Director of Technical Affairs I Water Quality Association H 2375 Cabot Drive I Lisle, Illinois 60532 I @ 630-929-2539 or 630-505-0160, ext. 539 Click here to learn more about the value of being a WQA member. Email Attachment: See pages 8 through 15. 7 March 10, 2022 ------- WQA Comments submitted to EPA on 2/11/2022 This document contains comments from the Water Quality Association (WQA) regarding the EPA's Notice of Intent (NOI) to publish WaterSense specifications for Point-of-Use (POU) Reverse Osmosis (RO) drinking water treatment systems. The Water Quality Association is a not-for-profit association for the residential commercial, and industrial water treatment industry; representing more than 2,500 member companies around the globe. Our membership is comprised of equipment manufacturers, suppliers, dealers and distributors of water quality improvement products and services. Copied from the EPA's NOI: NSF/ANSI 330 does not provide definitions specific to RO systems. However, EPA has modified the NSF/ANSI 330 definitions above to define the following terms: • RO system: A system that incorporates a water treatment process that removes undesirable materials from water by using pressure to force the water molecules through a semipermeable membrane. • POU RO system: A plumbed-in or faucet-mounted RO system used to treat the drinking and/or cooking water at a single tap or multiple taps, but not used to treat the majority of water used for washing and flushing or other non-consumption purposes at a building or facility. Any batch RO system or device not connected to the plumbing system is considered a point-of-use RO system. • POE RO system: An RO system used to treat the water supply at the entry of a building or facility for drinking and for washing, flushing, or other non-consumption use. A POE RO system has a minimum initial clean-system flow rate of not less than 15 liters per minute at 103 kilopascals pressure drop and 18 ± 5 °C water temperature (not less than four gallons per minute at 15 psig pressure drop and 65 ± 10 °F water temperature). These definitions will be used for the purposes of this NOI and to inform future specification development related to this product category. EPA does not intend to differentiate between commercial and residential RO systems in its specification and therefore did not propose definitions for these terms. EPA is seeking input on these definitions and would also be interested in other accepted industry definitions. [Page 7-8] WQA Comment: We agree that these definitions are acceptable for use in this specification. Copied from the EPA's NOI: Based on research and conversations with stakeholders, EPA intends to exclude POE RO systems from the scope of a potential WaterSense specification. Not all end uses of water require or even benefit from the quality of water generated from an RO system (e.g., water used for toilet flushes, clothes washing, or bathing). While POE RO systems are generally more efficient due to their tendency to include electric booster pumps and/or recirculate some of the concentrate water, POE RO systems treat, and subsequently waste, more water on the whole than POU systems. WaterSense, therefore, does not want to encourage the use of oversized systems that subsequently generate significant water waste during the treatment process. WaterSense is pg-1 ------- seeking input on the intended scope of a potential specification that includes POU RO systems, as defined above, and excludes POE systems. [Page 8] WQA Comment: We agree that different specifications would be needed for POE versus POU RO systems. However, the proposed target rated efficiency level of 40% for POU RO systems would cause significant tradeoffs for the consumer. More on this aspect is included in our other comments. Copied from the EPA's NQI: EPA intends to limit the scope of a potential WaterSense specification to POU RO systems, as defined above, consistent with the applicability of NSF/ANSI 58. NSF/ANSI 58 does not differentiate among POU RO systems that are intended for residential or commercial applications; therefore, its scope is slightly broader than the ASSE 1086 standard, which is limited to residential POU systems. At this point in time, EPA does not see the need to limit a specification to residential POU RO systems and exclude POU products that may be used in commercial applications. Within the POU category, WaterSense also does not intend to distinguish among the different types of POU RO systems (e.g., countertop, undersink) in terms of the water efficiency or performance requirements. WaterSense is considering whether to include high-efficiency RO membranes in the scope of its specification to help distinguish them from typical membranes. This would help consumers identify appropriate high-efficiency replacement membranes for their system to ensure it continues to perform at its rated water efficiency. Additionally, it may encourage consumers with less efficient systems to purchase compatible high-efficiency membranes to increase the efficiency. As discussed in more detail in Section V Performance and Product Testing, ASSE 1086 includes test procedures to evaluate a high-efficiency membrane separate from an RO system, at least with respect to life span and performance. WaterSense is seeking feedback on whether labeling RO membranes would be beneficial to consumers and whether it is feasible to swap out the membrane in a typical RO system for a higher efficiency membrane to increase the system's water efficiency. [Page 8] WQA Comment: We would encourage the EPA to review the experience of the certification bodies in regards to manufacturers offering filter cartridges that "fit-in" other manufacturers filter housings. The EPA would encounter these same challenges if they were to embark on a WaterSense label that encourages manufacturers to sell RO membrane modules that "fit-in" other manufacturers RO systems. While there is nothing unethical or illegal about this practice, it creates a great many challenges when a third-party attempts to apply a certification (such as a WaterSense label) to these replacement products which are marketed to "fit-in" other branded systems. WQA would be happy to engage in a discussion with the EPA to highlight challenges we faced when attempting to implement a certification for "fits-in" products. Beyond the operational challenges which must be overcome when attempting to implement a certification scheme that covers "fits-in" replacement modules, the practice has historically created confusion with consumers and other end users who are seeking to understand if the "fits-in" replacement module will provide the same level of performance and protection. This can be especially concerning in cases where the treatment system is being used to protect consumers from health-related contaminants (e.g., lead release from premise plumbing or service lines, private well owners, high-risk individuals who are using a certified in-home water treatment system, etc.) Pg- 2 ------- Copied from the EPA's NQI: WaterSense is considering whether to include high-efficiency RO membranes in the scope of its specification to help distinguish them from typical membranes. This would help consumers identify appropriate high-efficiency replacement membranes for their system to ensure it continues to perform at its rated water efficiency. Additionally, it may encourage consumers with less efficient systems to purchase compatible high-efficiency membranes to increase the efficiency. Beyond potential consideration for labeling RO membranes, WaterSense does not intend for the specification to apply to other accessories or "add-on" devices intended to improve product efficiency, production rate, or otherwise impact the operation of an RO system. These products include a permeate pump, which is a non-electric device that can be used to retrofit a POU RO system to reduce the back pressure from the storage tank and therefore improve the system's water efficiency and performance. Other companion products include retrofit recirculation kits (used to recirculate the concentrate water as feed water) and any systems that divert RO reject water for other uses. If a POU RO system requires the use of a companion product to meet the requirements of a future specification, then WaterSense intends to require the companion product to be tested, packaged, and sold along with the system in order for the system to bear the WaterSense label. WaterSense is seeking feedback on its intent to exclude addon/ aftermarket companion products from the scope of the specification. [Page 9] WQA Comment: We agree that where companion products are required to meet the proposed WaterSense specification, it would be best to require that those system components be packaged and sold with the certified system. Applying the WaterSense label to those companion system components when they are sold separately could create confusion. Copied from the EPA's NQI: There are also a variety of hybrid RO systems within the marketplace that combine various methods of water treatment, including filtration and even ultraviolet (UV) disinfection. The additional treatment technologies may fall within the scope of other NSF/ANSI standards. For example, filters are tested and certified according to NSF/ANSI 42 Drinking Water Treatment Units—Aesthetic Effects and/or NSF/ANSI 53 Drinking Water Treatment Units—Health Effects. UV systems are tested and certified according to NSF/ANSI 55 Ultraviolet Microbiological Water Treatment Systems. The scope of NSF/ANSI 58 requires that systems with manufacturer claims that include components or functions covered under other NSF or NSF/ANSI standards must conform to those applicable requirements; therefore, EPA's understanding is that any RO system certified to NSF/ANSI 58 would also be required to have filters and other components certified to applicable standards. WaterSense intends to permit hybrid systems to earn the WaterSense label, provided the RO portion of the system meets the scope and all water efficiency and performance requirements of a future specification. WaterSense is seeking input on its intent to include hybrid systems within the scope of a specification. Further, WaterSense seeks feedback on whether it should require that components of hybrid systems be tested and certified to other applicable standards (e.g., NSF/ANSI 42 for filtration, NSF/ANSI 55 for UV). WQA Comment: We agree that this approach seems consistent with the approach suggested for companion system components and a good strategy to avoid confusion. Copied from the EPA's NQI: WaterSense intends to adopt the NSF/ANSI 58 testing procedures for recovery rating and efficiency rating. WaterSense is seeking feedback from stakeholders regarding the viability of using the NSF/ANSI 58 recovery rating and efficiency rating test methods to evaluate RO system water efficiency. [Page 9 — 11] Pg- 3 ------- WQA Comment: We agree that it makes sense to reference the long-established test procedures in NSF/ANSI58 for rated recovery and rated efficiency. Copied from the EPA's NQI: WaterSense is also considering adopting criteria to require RO systems to achieve a recovery rating of at least 40 percent and an efficiency rating (as applicable) of at least 40 percent. These criteria align with the requirements of ASSE 1086. WaterSense is seeking feedback from stakeholders on this proposed water efficiency criteria for POU RO systems. [Page 11] WQA Comment: We agree that different specifications would be needed for POE versus POU RO Systems. However, the proposed rated efficiency target of 40% seems unachievable for many of the current manufacturers and would cause significant tradeoffs for the consumer. A better strategy would be to broadly engage the entire industry by setting a rated efficiency goal that can be achieved by a broad section of the industry as demonstrated through existing third-party testing and certifications of RO systems that remove health-related contaminants. In general the EPA strives to ensure that WaterSense labeled products use 20% less water than average products in the same category. The EPA should investigate the proposed rated efficiency target in more detail and the relationship between this rating and the overall water usage of a product. For example, let's assume that the average certified POU RO system with health-related claims has a rated efficiency of 15%, and that the average household needs to obtain about 1000 gallons of treated drinking water per year from their POU RO system (based on the 1000 gallon challenge in the membrane life test from standard 1086). An average POU RO system operating with a 15% rated efficiency will require 6667 gallons of total water to generate that 1000 gallons of treated water. Were the EPA to establish a rated efficiency target of 20% for WaterSense labeled POU RO systems, the WaterSense labeled systems would require only 5000 gallons of total water to generate that 1000 gallons of treated water. This is a reduction of 1667 gallons of water use per year, per household, or at least a 25% reduction in overall water usage for the WaterSense labeled systems. The potential tradeoffs of meeting a 40% rated efficiency target should also be considered. These could include the life span of the membrane, contaminant removal, and price to the consumer. Copied from the EPA's NQI: Automatic shutoff devices are an important water-saving component applicable to RO systems. This device shuts off the flow of incoming water when the storage tank fills to a certain capacity, thereby stopping the treatment process, preventing the tank from overflowing, and preventing reject water when the system is not actively treating. This is a requirement included within ASSE 1086. Similarly, WaterSense intends to require that all RO systems be equipped with an automatic shutoff device. WaterSense is seeking input on whether requiring an automatic shutoff valve is a reasonable expectation for a water-efficient RO system. [Page 12] WQA Comment: We agree that it is reasonable to expect an RO system which is carrying the WaterSense label to have an automatic shutoff device. And this technology is readily available to all RO manufacturers through a variety of sources. WQA would encourage the EPA to seek input from the industry to establish guidelines that allow the use of a broad variety of shut-off devices (e.g., automatic shut-off valves, on/off solenoids, floats for non-pressurized tanks, etc.) Copied from the EPA's NQI: During discussions with stakeholders, some indicated that it may be possible for consumers to make modifications or changes to the system after purchase that would decrease product efficiency. For example, a customer could replace the RO membrane within a high-efficiency RO system with a less efficient membrane, either by accident or to save on Pg-4 ------- maintenance costs. It is also possible that the consumer could replace the storage tank with a different size. WaterSense is seeking feedback on the likelihood of these post-purchase modifications and the magnitude of their effect on the RO system's water efficiency. WaterSense is also seeking suggestions on how to encourage and inform consumers to purchase appropriate replacement parts to maintain their system's water efficiency. [Page 12] WQA Comment: We agree that strategies utilized to meet the very aggressive goal of 40% rated efficiency target might result in significant tradeoffs from a consumer perspective. Establishing a less aggressive rated efficiency target might go a long way towards preventing these types of tradeoffs which could undermine consumer confidence in the WaterSense label, and encourage these types of post-purchase modifications. It is also important for the EPA to consider that a program structure which encourages these types of post-purchase modifications might compromise system performance (in addition to the rated efficiency) and consumers may no longer be receiving the same level of protection from health-related contaminants in their drinking water. This could result in unintended consequences where systems were being used to protect private well owners, high-risk individuals, and other members of the general public. Copied from the EPA's NQI: WaterSense has not identified field studies to date that assess actual water savings associated with more efficient RO systems compared to inefficient systems. Further, while EPA has anecdotally heard that an estimated one million POU RO systems are sold annually, the exact product market is unknown. WaterSense is seeking RO system market data and usage data to assess the impact of a potential WaterSense specification on potential water savings. [Page 12] WQA Comment: While we do not have data that directly answers the question of potential water savings, some general conclusions can be made based on existing certifications. The proposed specification is based on a 40% rated efficiency target. None of the POU RO systems which we have currently certified meet this proposed rated efficiency target. This suggests that the EPA would make a larger impact on overall water usage by setting a rated efficiency target that most manufacturers would be capable of achieving with existing technology, and without utilizing design tradeoffs that would be undesirable from a consumer and public health perspective. Copied from the EPA's NQI: WaterSense is considering requiring that all labeled products conform to the applicable requirements of NSF/ANSI 58 to ensure adequate contaminant reduction performance criteria are met. NSF/ANSI 58 only requires the system to meet a minimum of 75 percent TDS reduction. Beyond this, any contaminant reduction claims made by the manufacturer must be verified by test data generated under the requirements of NSF/ANSI 58. WaterSense is seeking feedback from stakeholders regarding the viability of requiring that WaterSense labeled RO systems meet all of the requirements of NSF/ANSI 58, including the 75 percent TDS reduction requirement. [Page 13] WQA Comment: We agree that it would be reasonable to expect POU RO systems with the WaterSense label be required to meet all of the requirements in NSF/ANSI 58. It is important to note that as the EPA has pointed out, the health-based reduction claims in NSF/ANSI 58 are optional (not required). Only the TDS claim is a required claim. If the rated efficiency target is set too high, the tradeoffs necessary for many manufacturers to achieve that target might result in a large number of WaterSense labeled RO systems that only remove TDS. WQA encourages the EPA to explore a less aggressive rated efficiency target that can be achieved by a broad range of manufacturers using existing technology and without these types of undesirable tradeoffs for the consumer. Pg- 5 ------- Copied from the EPA's NQI: WaterSense is considering incorporating the ASSE 1086 membrane life test procedures and criteria into a potential specification to ensure the RO membrane will have adequate resistance to fouling and maintain its water efficiency and performance overtime. WaterSense is seeking feedback from stakeholders regarding the viability of using the ASSE 1086 membrane life test methods to evaluate membrane lifespan and RO system performance. [Page 14] WQA Comment: The membrane life test in 1086 is intended to ensure that the RO membrane will last for approximately one year (i.e., based on 1000 gallons). WQA would encourage the EPA to further investigate their assertion that "in most cases an RO system will require... RO membrane replacement every one to three years." During the 2018 WQA convention and exposition there was a presentation from three different manufacturers on the topic of "Innovations in Residential RO Recovery". The consensus of the presenters at that time was that membranes are typically replaced every 5-10 years. This appears to be a tradeoff which might be undesirable to consumers. Copied from the EPA's NQI: WaterSense is considering whether to require that the efficiency rating (for systems with a storage tank) or recovery rating (for systems without a storage tank) be displayed on the product, product packaging, and associated specification sheet. Because efficiency rating and recovery rating are technical terms with detailed testing procedures and somewhat similar definitions, the distinction between the two values may not be clear to consumers. WaterSense is also concerned that presenting the efficiency/recovery rating as a percentage may be confusing to consumers and may not effectively convey the water efficiency of the device. As discussed earlier, many manufacturers advertise a "pure-to-waste" ratio in addition to or instead of efficiency/recovery rating, which may be more comprehensible but does not appear to be a standardized metric. There are no specific testing procedures for determining pure-to-waste ratio, and the term is sometimes used synonymously with recovery rating, efficiency rating, or neither. For this reason, WaterSense is considering defining the term "treated-to-waste ratio" as the ratio equivalent of the efficiency rating (for systems with a storage tank) or recovery rating (for systems without a storage tank), as applicable, of a given RO system. For example, using Equation 1 on page 10, an RO system with an efficiency rating of 40 percent would have a 1:1.5 treated-to-waste ratio. WaterSense is considering requiring the treated-to-waste ratio on product packaging and documentation to more easily convey the RO system water efficiency to consumers. WaterSense is seeking input on the proposed "treated-to-waste ratio" definition and any other reasonable ways to mark products, product packaging, and specification sheets that would be easy for the consumer to understand. [Page 14-15] WQA Comment: We have no objection to this approach. Copied from the EPA's NQI: How should WaterSense incorporate packaging/labeling requirements that clarify what is certified under the WaterSense label, especially in the case of hybrid systems? For hybrid systems that use additional treatment technologies (e.g., UV), product marking should specify that the WaterSense label and criteria apply solely to the RO portion of the treatment process. If WaterSense decides not to require certifications or criteria pertaining to the additional treatment technology(ies), WaterSense is seeking input on how to incorporate packaging/labeling requirements that clarify which treatment technology is certified under the WaterSense label. [Page 15] WQA Comment: Since the proposal on page 9 implies that hybrid systems would only be evaluated and labeled as a complete system, and the hybrid components or "companion products" could not carry the WaterSense label by themselves, the problem would seem to take care of itself. In Pg- 6 ------- summary, to avoid consumer confusion, we would encourage the EPA to follow the same convention they are proposing for system components or "companion products". Copied from the EPA's NQI: WaterSense's goal is to promote the adoption of water-efficient products. In many cases, RO systems are not the most water-efficient drinking water treatment solution for a given application. EPA intends to use careful and considerate messaging so as not to promote the use of RO systems over other water treatment technologies that may be equally or more appropriate. Instead, the intent of the WaterSense POU RO system specification is to help consumers who already intend to purchase an RO system identify the most water-efficient options. WaterSense is seeking input on messaging that can be used so as not to promote the purchase of RO systems when they are not necessary. [Page 15] WQA Comment: We would be amenable to a conversation on this aspect but would need more detail regarding the EPA's intent in order to provide input or suggestions. Copied from the EPA's NQI: Anecdotally, EPA has observed that more efficient RO systems tend to be more expensive than average systems. Similarly, based on a review of available products online, higher efficiency RO systems sometimes have more expensive membranes than average systems, with relatively similar lifespans. However, during conversations with EPA, some manufacturers have stated that it is possible to produce and sell high-efficiency systems, filters, and membranes at similar costs to standard systems and components. WaterSense is unclear whether some high- efficiency membranes require more frequent replacement, which would increase maintenance costs. WaterSense is seeking input on the impact of high-efficiency systems on product and maintenance costs. [Page 15] WQA Comment: We cannot comment on specific pricing due to anti-trust concerns. In general, the membrane life test in 1086 is intended to ensure that the RO membrane will last for approximately one year, or more accurately 1000 gallons. On many systems RO membrane replacement is currently recommended at longer frequency. This would suggest a tradeoff related to maintenance cost. And WQA would encourage the EPA to further explore with the industry any cost tradeoffs that would be necessary to achieve the proposed 40% rated efficiency target. One way to minimize cost tradeoffs for the consumer would be to establish a less aggressive rated efficiency target that could be achieved using current technology by a broad range of manufacturers, thereby promoting healthy competition for WaterSense labeled products in order to keep pricing down. Copied from the EPA's NQI: Most POU RO systems (particularly under-sink models) do not use energy. However, some more efficient RO systems use electric pumps to achieve greater efficiency/recovery ratings. These systems may have an energy tradeoff to consider. WaterSense is interested in understanding the current market for RO systems that use energy, particularly as it relates to improving efficiency; whether a WaterSense specification would increase the use of electric pumps to achieve greater efficiencies; and how much energy these types of systems typically consume. This information will help the program assess and convey the potential water/energy tradeoffs to consumers. WaterSense is seeking input on the efficiency gains possible from incorporating an electric pump in a system and how much energy these systems tend to use. [Page 16] WQA Comment: We recognize that there would be a tradeoff here given the currently proposed 40% rated efficiency target, but would refer the EPA to the manufacturers to obtain accurate figures on energy usage and rated efficiency gains. pg-1 ------- Copied from the EPA's NQI: EPA has not identified any data suggesting there are potential impacts of concern with respect to the discharge of a concentrated waste stream from RO systems. High- efficiency RO systems will produce more concentrated reject water; however, this reject water is blended with other wastewater from a residence or business, and any resulting increase in contaminants is expected to be negligible. EPA does not have data on specific impacts to onsite septic systems. The amount of wastewater generated from a POU RO system is minimal when compared to other typical residential water uses, such as from toilets, bathing, and clothes washing. Further, an RO system does not add any additional minerals or contaminants to the wastewater (but rather concentrates contaminants from the incoming water supply). If anything, WaterSense expects a potential specification will promote RO systems that reduce the wastewater being directed to the septic system compared to typical RO systems. However, it is possible a septic system could be impacted depending on a variety of factors. WaterSense is seeking input on whether RO systems contribute any negative impacts to wastewater and wastewater treatment systems, including septic systems, and whether those impacts are exacerbated with high-efficiency systems. [Page 16] WQA Comment: We agree that RO Systems do not add any chemicals to the overall waste stream which would not be present were the system removed. And we are not aware of any scientific studies suggesting that discharge to septic systems would cause any concerns. Pg- 8 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense Commenter: Shannon Murphy Affiliation: Aquamor Comment Date: February 14, 2022 Email Text: Please find attached comments pertaining to the Water Sense RO initiative. Sincerely, Color Key Black font - Text copied directly from the EPA WaterSense NOI Bold Black font - Highlights specific aspects from the NOI that the EPA is seeking comments on Blue font - Comments NSF/ANSI 330 does not provide definitions specific to RO systems. However, EPA has modified the NSF/ANSI 330 definitions above to define the following terms: • RO system: A system that incorporates a water treatment process that removes undesirable materials from water by using pressure to force the water molecules through a semipermeable membrane. • POU RO system: A plumbed-in or faucet-mounted RO system used to treat the drinking and/or cooking water at a single tap or multiple taps, but not used to treat the majority of water used for washing and flushing or other non- consumption purposes at a building or facility. Any batch RO system or device not connected to the plumbing system is considered a point-of-use RO system. • POE RO system: An RO system used to treat the water supply at the entry of a building or facility for drinking and for washing, flushing, or other non- consumption use. A POE RO system has a minimum initial clean-system flow rate of not less than 15 liters per minute at 103 kilopascals pressure drop and Shannon Murphy VP Business Development & Compliance Aquamor, LLC. Cell: 951-587-5287 42188 Rio Nedo | Temecula, Ca. 92590 Email Attachment: WaterSense NOI for POU RO Systems 16 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense 18 ± 5 °C water temperature (not less than four gallons per minute at 15 psig pressure drop and 65 ± 10 °F water temperature). These definitions will be used for the purposes of this NOI and to inform future specification development related to this product category. EPA does not intend to differentiate between commercial and residential RO systems in its specification and therefore did not propose definitions for these terms. EPA is seeking input on these definitions and would also be interested in other accepted industry definitions. [Page 7-8] These definitions appear to be accurate and acceptable. Based on research and conversations with stakeholders, EPA intends to exclude POE RO systems from the scope of a potential WaterSense specification. Not all end uses of water require or even benefit from the quality of water generated from an RO system (e.g., water used for toilet flushes, clothes washing, or bathing). While POE RO systems are generally more efficient due to their tendency to include electric booster pumps and/or recirculate some of the concentrate water, POE RO systems treat, and subsequently waste, more water on the whole than POU systems. WaterSense, therefore, does not want to encourage the use of oversized systems that subsequently generate significant water waste during the treatment process. WaterSense is seeking input on the intended scope of a potential specification that includes POU RO systems, as defined above, and excludes POE systems. [Page 8] Agree that POE RO Systems should initially be excluded. EPA intends to limit the scope of a potential WaterSense specification to POU RO systems, as defined above, consistent with the applicability of NSF/ANSI 58. NSF/ANSI 58 does not differentiate among POU RO systems that are intended for residential or commercial applications; therefore, its scope is slightly broader than the ASSE 1086 standard, which is limited to residential POU systems. At this point in time, EPA does not see the need to limit a specification to residential POU RO systems and exclude POU products that may be used in commercial applications. Within the POU category, WaterSense also does not intend to distinguish among the different types of POU RO systems (e.g., countertop, undersink) in terms of the water efficiency or performance requirements. WaterSense is considering whether to include high-efficiency RO membranes in the scope of its specification to help distinguish them from typical membranes. This would help consumers identify appropriate high-efficiency replacement membranes for their system to ensure it continues to perform at its rated water efficiency. Additionally, it may encourage consumers with less efficient systems to purchase compatible high-efficiency membranes to increase the efficiency. As discussed in more detail in Section V Performance and Product Testing, ASSE 1086 includes test procedures to evaluate a high-efficiency membrane separate from an RO system, at least with respect to life span and performance. WaterSense is seeking feedback on whether labeling RO membranes would be beneficial to consumers and whether it is feasible to swap out the membrane in a typical RO system for a higher efficiency membrane to increase the system's water efficiency. [Page 8] 17 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense We agree that there is a benefit to labeling membranes and systems under a Water Sense program We believe that the WaterSense labeling should focus on POU RO Systems. Much like NSF 58, the program should focus on the complete RO System and the replacement membrane. Agree that it should not concern itself with distinction of various types of POU RO systems, just that it should address POU RO as a whole and complete unit. A complete system will include evaluation of the RO Membrane as used within the system. As such the RO Membrane would be advertised as being a WaterSense high efficiency replacement RO Membrane, however this would only be for use in the WaterSense certified system(s). RO Systems are dependent upon the entire system and not just the RO Membrane to achieve proper performance. As such, an RO Membrane in one system may be able to achieve high efficiency, if used in a different, evaluated or unevaluated system may not be able to achieve the same performance due to the design of the complete system. As such EPA should stick to the guidelines of a specific RO Membrane being certified within a complete system as a water sense device. The standard should not evaluate nor promote a mix and match approach for rather complicated and variable in design POU RO systems. For example some manufacturers include/install check valves into the replacement membrane and some do not. If a consumer were to simply use one within the other the system would not function properly and in fact would be less efficient. Additionally many engineered systems today encapsulate the membrane within an engineered housing which is not simply interchangeable. Therefore we suggest it is NOT feasible to simply swap membranes in today's marketplace. WaterSense is considering whether to include high-efficiency RO membranes in the scope of its specification to help distinguish them from typical membranes. This would help consumers identify appropriate high-efficiency replacement membranes for their system to ensure it continues to perform at its rated water efficiency. Additionally, it may encourage consumers with less efficient systems to purchase compatible high-efficiency membranes to increase the efficiency. Beyond potential consideration for labeling RO membranes, WaterSense does not intend for the specification to apply to other accessories or "add-on" devices intended to improve product efficiency, production rate, or otherwise impact the operation of an RO system. These products include a permeate pump, which is a non-electric device that can be used to retrofit a POU RO system to reduce the back pressure from the storage tank and therefore improve the system's water efficiency and performance. Other companion products include retrofit recirculation kits (used to recirculate the concentrate water as feed water) and any systems that divert RO reject water for other uses. If a POU RO system requires the use of a companion product to meet the requirements of a future specification, then WaterSense intends to require the companion product to be tested, packaged, and sold along with the system in order for the system to bear the WaterSense label. WaterSense is seeking feedback on its intent to exclude addon/ aftermarket companion products from the scope of the specification. [Page 9] 18 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense As stated above, the scope should be limited to only evaluation on complete POU RO Systems. Additional appurtenances or parts which can be added on to existing RO's where they may provide benefit will ultimately need to be evaluated/certified as a complete system to validate that it meets defined requirements. There are also a variety of hybrid RO systems within the marketplace that combine various methods of water treatment, including filtration and even ultraviolet (UV) disinfection. The additional treatment technologies may fall within the scope of other NSF/ANSI standards. For example, filters are tested and certified according to NSF/ANSI 42 Drinking Water Treatment Units—Aesthetic Effects and/or NSF/ANSI 53 Drinking Water Treatment Units—Health Effects. UV systems are tested and certified according to NSF/ANSI 55 Ultraviolet Microbiological Water Treatment Systems. The scope of NSF/ANSI 58 requires that systems with manufacturer claims that include components or functions covered under other NSF or NSF/ANSI standards must conform to those applicable requirements; therefore, EPA's understanding is that any RO system certified to NSF/ANSI 58 would also be required to have filters and other components certified to applicable standards. WaterSense intends to permit hybrid systems to earn the WaterSense label, provided the RO portion of the system meets the scope and all water efficiency and performance requirements of a future specification. WaterSense is seeking input on its intent to include hybrid systems within the scope of a specification. Further, WaterSense seeks feedback on whether it should require that components of hybrid systems be tested and certified to other applicable standards (e.g., NSF/ANSI 42 for filtration, NSF/ANSI 55 for UV). Current Certification agencies have policies pertaining to this issue. If the manufacturer is making claims associated with the additional hybrid systems, then those claims would need to be certified. If however the manufacturer IS NOT making additional claims covered under the scope of the affiliated standards, then the device would not require additional certification. For example, if a POU RO system has a UV attached to it, the manufacturer may clam that it has a UV Module, however if it is not making any reduction claims associated with the UV, then they would be exempt from requiring formal certification to NSF 55. If however they are making either NSF 55 class A or Class B reduction claims for the system, then they would be required to have these claims substantiated through formal certification of this add on device. Current requirements within the relevant standards provide guidance on labeling and differentiation as to what is specifically certified in cases like these - we would recommend a similar approach. WaterSense intends to adopt the NSF/ANSI 58 testing procedures for recovery rating and efficiency rating. WaterSense is seeking feedback from stakeholders regarding the viability of using the NSF/ANSI 58 recovery rating and efficiency rating test methods to evaluate RO system water efficiency. [Page 9-11] This is understood to be a recognized long terms industry standard. WaterSense is also considering adopting criteria to require RO systems to achieve a recovery rating of at least 40 percent and an efficiency rating (as applicable) of at least 40 19 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense percent. These criteria align with the requirements of ASSE 1086. WaterSense is seeking feedback from stakeholders on this proposed water efficiency criteria for POU RO systems. [Page 11] Rather than use ASSE 1086 as the benchmark, it would be more prudent to start out with a program where there is a high but manageable efficiency rating developed. A review of all certified RO systems should be conducted (NSF, IAPMO, WQA) and obtain a total list of all certified product and their efficiency rating. From there set some bar where a group of products currently certified demonstrably meet the Water Sense standard. We believe you are looking for incremental improvements and obtainable goals. In regards to ASSE 1086, Definition of a valuable standard is the response from the industry to obtain certification to this standard to provide definable value add differentiation to a product line. Through this certification the intent is to market a product to this new value add standards requirements which in turn provides market value and increased sales to offset heavy burden costs to obtain the certification. One example of this is NSF Standard 401. Upon completion of the development of NSF 401, there was immediate response from the industry to obtain certification to this standard. Today there are hundreds if not thousands of products currently certified at the different agencies which carry these claims. Looking at ASSE 1086; launched in 2019 and to date upon review of the various listing agencies no products are certified to this standard. There is no benefit to the industry nor the public if a standard is developed and no products are certified to the standard. In reviewing with RO Industry experts, the standard was developed with a small number of participants without broader oversight and input from the manufacturing and RO industry. A critical part of Standards development is to have proper depth and breadth of individuals to work with, develop and validate through testing the standard as it is being developed. Care must also be taken where creation of a monopoly is created within a market through the development of a very narrow standard. Agencies must be aware of the market and make sure that through regulation a monopoly situation does not occur with obvious ramifications for the consumer. Automatic shutoff devices are an important water-saving component applicable to RO systems. This device shuts off the flow of incoming water when the storage tank fills to a certain capacity, thereby stopping the treatment process, preventing the tank from overflowing, and preventing reject water when the system is not actively treating. This is a requirement included within ASSE 1086. Similarly, WaterSense intends to require that all RO systems be equipped with an automatic shutoff device. WaterSense is seeking input on whether requiring an automatic shutoff valve is a reasonable expectation for a water- efficient RO system. [Page 12] Automatic shutoff devices are installed on all POU RO devices that we are aware of so we are in agreement with this requirement, however if a standard is set to a specific efficiency rating, then the design of the product is irrelevant provided it meets the requirements of the standard. We would caution against making the standard too complex with small details like requiring an ASOV and look at overall system efficiency ratings as the benchmark. 20 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense During discussions with stakeholders, some indicated that it may be possible for consumers to make modifications or changes to the system after purchase that would decrease product efficiency. For example, a customer could replace the RO membrane within a high-efficiency RO system with a less efficient membrane, either by accident or to save on maintenance costs. It is also possible that the consumer could replace the storage tank with a different size. WaterSense is seeking feedback on the likelihood of these post-purchase modifications and the magnitude of their effect on the RO system's water efficiency. WaterSense is also seeking suggestions on how to encourage and inform consumers to purchase appropriate replacement parts to maintain their system's water efficiency. [Page 12] This is related to our previous comments regarding membrane swapping. We recommend certifying a system and the components of the system as a system and following guidelines set within standard 58. It is not possible to Certify post installation options to meet the standard. Best to keep it simple and have a list of WaterSense certified products. Overall the goal of increased efficiency will drive the industry and will benefit the consumer and the environment. Some consumers may indeed swap components or otherwise modify the system after purchase however that will be the exception not the norm in our opinion. WaterSense has not identified field studies to date that assess actual water savings associated with more efficient RO systems compared to inefficient systems. Further, while EPA has anecdotally heard that an estimated one million POU RO systems are sold annually, the exact product market is unknown. WaterSense is seeking RO system market data and usage data to assess the impact of a potential WaterSense specification on potential water savings. [Page 12] It would be difficult to obtain true and useful data for statistically accurate information to properly develop end conclusions as to a national water savings hypothesis. WaterSense is considering requiring that all labeled products conform to the applicable requirements of NSF/ANSI 58 to ensure adequate contaminant reduction performance criteria are met. NSF/ANSI 58 only requires the system to meet a minimum of 75 percent TDS reduction. Beyond this, any contaminant reduction claims made by the manufacturer must be verified by test data generated under the requirements of NSF/ANSI 58. WaterSense is seeking feedback from stakeholders regarding the viability of requiring that WaterSense labeled RO systems meet all of the requirements of NSF/ANSI 58, including the 75 percent TDS reduction requirement. [Page 13] WaterSense is considering incorporating the ASSE 1086 membrane life test procedures and criteria into a potential specification to ensure the RO membrane will have adequate resistance to fouling and maintain its water efficiency and performance over time. WaterSense is seeking feedback from stakeholders regarding the viability of using the ASSE 1086 membrane life test methods to evaluate membrane lifespan and RO system performance. [Page 14] Agreed - 21 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense Success of a system in the marketplace is driven by consumers looking at initial as well as long term maintenance costs. Preference would be to keep the requirements simple and focus on the efficiency aspect of the standard. Products will be successful or fail based upon consumer awareness. WaterSense is considering whether to require that the efficiency rating (for systems with a storage tank) or recovery rating (for systems without a storage tank) be displayed on the product, product packaging, and associated specification sheet. Because efficiency rate and recovery rating are technical terms with detailed testing procedures and somewhat similar definitions, the distinction between the two values may not be clear to consumers. WaterSense is also concerned that presenting the efficiency/recovery rating as a percentage may be confusing to consumers and may not effectively convey the water efficiency of the device. As discussed earlier, many manufacturers advertise a "pure-to-waste" ratio in addition to or instead of efficiency/recovery rating, which may be more comprehensible but does not appear to be a standardized metric. There are no specific testing procedures for determining pure-to-waste ratio, and the term is sometimes used synonymously with recovery rating, efficiency rating, or neither. For this reason, WaterSense is considering defining the term "treated-to-waste ratio" as the ratio equivalent of the efficiency rating (for systems with a storage tank) or recovery rating (for systems without a storage tank), as applicable, of a given RO system. For example, using Equation 1 on page 10, an RO system with an efficiency rating of 40 percent would have a 1:1.5 treated-to-waste ratio. WaterSense is considering requiring the treated-to-waste ratio on product packaging and documentation to more easily convey the RO system water efficiency to consumers. WaterSense is seeking input on the proposed "treated-to-waste ratio" definition and any other reasonable ways to mark products, product packaging, and specification sheets that would be easy for the consumer to understand. [Page 14 — 15] Efficiency and Recovery ratings are already on the Performance Data Sheet. Adding more marketing / literature requirements to the product packaging is over burdensome and for the most part confusing to the consumer. More to point - We would suggest that you require certification agencies to have efficiency and recovery ratings displayed on the online listings. This will allow consumers when they are researching products to be able to quickly see within the online listings of a product what the recovery and efficiency ratings are for all certified RO System. How should WaterSense incorporate packaging/labeling requirements that clarify what is certified under the WaterSense label, especially in the case of hybrid systems? For hybrid systems that use additional treatment technologies (e.g., UV), product marking should specify that the WaterSense label and criteria apply solely to the RO portion of the treatment process. If WaterSense decides not to require certifications or criteria pertaining to the additional treatment technology(ies), WaterSense is seeking input on how to incorporate packaging/labeling requirements that clarify which treatment technology is certified under the WaterSense label. [Page 15] In the thread of keeping things simple, WaterSense should develop a logo for the POU RO market specifically. All POU RO systems meeting the requirements water sense program for RO systems can bear the WaterSense mark regardless of whether it is a hybrid or non- 22 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense hubris system as long as the entire system is certified to the appropriate standard. The additional costs of these systems will allow the market place to determine if these additional technologies are required or valuable. WaterSense's goal is to promote the adoption of water-efficient products. In many cases, RO systems are not the most water-efficient drinking water treatment solution for a given application. EPA intends to use careful and considerate messaging so as not to promote the use of RO systems over other water treatment technologies that may be equally or more appropriate. Instead, the intent of the WaterSense POU RO system specification is to help consumers who already intend to purchase an RO system identify the most water-efficient options. WaterSense is seeking input on messaging that can be used so as not to promote the purchase of RO systems when they are not necessary. [Page 15] Again, in keeping things simple, develop a logo and allow products to bear that logo when they are certified or meet the "efficiency" requirements of WaterSense. This does not promote the use of RO, just that it meets an "efficiency" standard. Anecdotally, EPA has observed that more efficient RO systems tend to be more expensive than average systems. Similarly, based on a review of available products online, higher efficiency RO systems sometimes have more expensive membranes than average systems, with relatively similar lifespans. However, during conversations with EPA, some manufacturers have stated that it is possible to produce and sell high-efficiency systems, filters, and membranes at similar costs to standard systems and components. WaterSense is unclear whether some high-efficiency membranes require more frequent replacement, which would increase maintenance costs. WaterSense is seeking input on the impact of high- efficiency systems on product and maintenance costs. [Page 15] The market will balance this out on its own, so would not include cost evaluations within the standard. The ability to meet a standard does not dictate success in selling the product. A simple approach of product to standard should be maintained and from there allow the market to balance itself out pertaining to costs through competition. Most POU RO systems (particularly under-sink models) do not use energy. However, some more efficient RO systems use electric pumps to achieve greater efficiency/recovery ratings. These systems may have an energy tradeoff to consider. WaterSense is interested in understanding the current market for RO systems that use energy, particularly as it relates to improving efficiency; whether a WaterSense specification would increase the use of electric pumps to achieve greater efficiencies; and how much energy these types of systems typically consume. This information will help the program assess and convey the potential water/energy tradeoffs to consumers. WaterSense is seeking input on the efficiency gains possible from incorporating an electric pump in a system and how much energy these systems tend to use. [Page 16] Again, any data developed pertaining to this will mostly be theoretical. If the intent is to develop a WaterSense initiative, better to keep on point with Water Savings. If broad reaching evaluations of waste, energy, lifecycle evaluations, etc are part of the program, then anticipation would be that this would take extensive research, time and money to develop accurate and meaningful data. In my history, I have experienced some standards taking well over 10 years when the scope of the standard starts to become too broad. Additionally as 23 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense stated above these components add costs - let competition and the market drive these issues. If two systems meets the standard the consumer will chose based on price. This is also why it is important not to set an "efficiency" standard too high such that it drives unusual system designs and expense and means that few if any systems or only very expensive systems will be able meet this standard. EPA has not identified any data suggesting there are potential impacts of concern with respect to the discharge of a concentrated waste stream from RO systems. High-efficiency RO systems will produce more concentrated reject water; however, this reject water is blended with other wastewater from a residence or business, and any resulting increase in contaminants is expected to be negligible. EPA does not have data on specific impacts to onsite septic systems. The amount of wastewater generated from a POU RO system is minimal when compared to other typical residential water uses, such as from toilets, bathing, and clothes washing. Further, an RO system does not add any additional minerals or contaminants to the wastewater (but rather concentrates contaminants from the incoming water supply). If anything, WaterSense expects a potential specification will promote RO systems that reduce the wastewater being directed to the septic system compared to typical RO systems. However, it is possible a septic system could be impacted depending on a variety of factors. WaterSense is seeking input on whether RO systems contribute any negative impacts to wastewater and wastewater treatment systems, including septic systems, and whether those impacts are exacerbated with high-efficiency systems. [Page 16] There have been several papers / studies which show that RO Systems do not negatively or meaningfully impact the overall waste stream. We agree that there is no meaningful impact. 24 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense Commenter: Nan J Aberman Affiliation: E.A.M Benelux B.V. Comment Date: February 16, 2022 Email Text: Dear Jessica, Thank you very much for the presentation, Let me introduce myself. My name is Nan J Aberman from The Netherlands. I have been in the business of water filtration since 2008. we are a manufacturer of POU anti-bacteria filters (mainly for the showers) Is RO system WaterSense is your product? are you making it? One of the main issues is the systems also can generate a significant amount of water waste during operation. I saw that your high-efficiency RO system with a 40 percent efficiency rating would send approximately 1,430 gallons of water down the drain per year. What if it can be "0" zero? Above this, the RO system will reduce much more than it needs, such as minerals the body needs; any attempt to return the minerals artificially is less effective to the body and can cause long-term damage. In The Netherlands, we have excellent water quality. However, we will need a high- quality anti-bacteria system. In addition, we will need a sentiment scale filter in some places. I know a company that gives you better results than an RO system with zero wastewater. It is a local U.S product. It has an EPA registration, and IAPMO checks it. Do you think this can interest you or ERG company? I will see you on the call, Kind regards, Nan J Aberman E.A.M Benelux B.V +31614190490 25 March 10, 2022 ------- EPA Comments on WaterSense® Notice of Intent (NOI) to Develop a Draft Specification for Point-of-Use Reverse Osmosis Systems WaterSense Commenter: Eugene Leung Affiliation: California State Water Resource Control Board Comment Date: February 16, 2022 Email Text: Good Afternoon: I am the person that made the suggestion to separate the POU RO into two subgroups - pump assisted and system pressure. I am the primary technical person working on POU devices, implementation of POU devices at PWS and the voting member on NSF/ANSI DWTU standard. I want to touch base with your team and let you know what we are working on and I believe the Watersense RO rating idea is great - and important - given the severe drought here in California. Also, I want to provide a little back story for the need for the two categories- the reason being that RO systems working off of distribution system feed pressure have limited capability in reducing nitrate concentration. A pump assisted unit may use tighter membranes and can have higher nitrate rejection. I feel it will be extremely important to allow the two separate groups and clearly discuss the need for the pump assisted category as the pump allows for the use of tighter RO membranes and may be needed to achieve the needed contaminant reduction to use a POU device as a compliance treatment technology. Finally, we are working on a white paper on the use of POU/POE. We will be having stakeholder groups from WQA in our call and will touch of many these topics. Would you like to be a participant of our stakeholder meeting that is coming up next month? Please let me know if we can have a follow-up Teams or Zoom meeting. Thanks, Eugene Eugene H. Leung, P.E. Drinking Water Treatment Technical Specialist Technical Operations Section, Division of Drinking Water California State Water Resources Control Board (510) 620-3460 euaene.leuna@waterboards.ca.aov 26 March 10, 2022 ------- |