To echo the comments of Jason Churchill, I don't believe it is in the Department's best interests to allow NSF 245 certification in lieu of in-field testing such as that currently required under GMP #147.  First the testing protocol allows for suspension of testing should either temperature or alkalinity fall below predetermined thresholds.  Although such action would prevent the test resuls from showing performance failures, the systems in the real world will have to survive liquid temperatures below 50 degrees fahrenheight or low alkalinities.  Secondly, the test does not have a numerical standard, it is a claim of percentage reduction (currently 50%).  This claim can be just barely reached by a technology.  I other words, there is no reward for doing better than 50% reduction, which is a modest accomplishment.

You may want to have an abbreviated field testing protocol for a technology that has successfully passed standard 245, but don't eliminate it altogether.