Joint Committee on Drinking Water Treatment Units

I support standardized language to reduce the minimum run time from 4h to 1h. Following an overnight rest or any other rest period longer than 2 h, no effluent samples shall be collected until a minimum of 1-h cycling operation has been completed following the rest period, except for required active agent sampling.

I do not agree with reducing the number of sample points from 11 to 5, without also changing the acceptance criteria to ALL product water sample concentrations demonstrate a greater than or equal to 80.0% reduction. Currently to qualify for a chloramine reduction claim, the system shall reduce the concentration of chloramine from the influent challenge so that, prior to the final sample point establishing capacity, 90% of the product water sample concentrations demonstrate a greater than or equal to 80.0% reduction of the influent water concentration at each sampling point. Samples collected at the final sample point establishing capacity shall demonstrate a greater than or equal to 80.0% reduction of the influent water concentration at each sampling point.

Changes to the acceptance criteria and sampling plan would apply to both Chloramine and Chlorine Reduction claims, as upon the determination of a reduction capacity for chloramine, systems may also claim reduction of chlorine to the same reduction capacity as that demonstrated for chloramine.

Section 7.1.3 Optional Sampling is not necessary. This is an option offered by the individual certifying body.