Translating criteria into pollutant limits

States often rely on EPA guidance documents when developing criteria for specific pollutants. These guidance documents typically contain many caveats. For example, they might note that a given pollutant is easily tolerated by some organisms but very poorly tolerated by others, or that synergistic effects have been noted when the pollutant in question is found with certain others.

Unfortunately, such caveats are frequently overlooked when permits are written that allow increased levels of pollutants. It is worth gathering a few of these EPA guidance documents for pollutants of special concern in your area. When permits are issued or renewed, make sure that the EPA’s numeric pollutant criteria recommendations are being applied with full consideration of site-specific issues that the EPA intended.

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