Public Workspaces

Comment 368
Accepted (Resolved)
61i78r1.pdf (Revision 0)
Approval of 61i78r1 (Regenerated/Reactivated Media)
Comment Submitted by
Richard Sakaji
2008-04-16 17:55:31
I agree with the intent of the modifications and do not object to the proposed modifications per se. I am concerned that someone may interpret the NSF 61 requirements as applying to water utilities that regenerate on-site, even though that wasn't the original intent. I would not want to see these requirements imposed on a water utility that regenerates its own media (e.g., IX media) for the sole purpose of producing drinking water.

I apologize if this issue had been covered, but I could not find a specific exclusion that would cover utilities that practiced on-site regeneration. In fact I assume their product maintains their NSF 61 certification even after they have regenerated their media. If not, are they in violation of state statute for not using MSF certified materials?

Also, citation of the USEPA "public water system" definition should be referenced, e.g., 40 CFR 141.2.
Submitter Proposed Solution
Maybe a line in the introduction indicating that the regeneration/reactivation requirements do not apply to water systems that produce potable water, regenerate their own treatment media, and do not sell, barter, trade, or pass along their media to another water system or water treatment facility, are specifically excluded from this requirement would suffice.
Developer Response
Please see the attachment for the response to your comments. A reply indicating whether this response satisfactorily addresses your comments is appreciated on or before July 15, 2008.
Supporting File: Purkiss-Sakaji-response.pdf