As detailed in the Fall 2002 edition of the NJ Discharger, DEP Commissioner Bradley M. Campbell announced an initiative to fully implement the existing numeric Water Quality Criteria (WQC) for total phosphorus (see State Implements Numeric Water Quality Criteria for Total Phosphorus).

The DEP has begun issuing NJPDES permits with water quality based effluent limitations for phosphorus and a compliance schedule for implementation. These permits also afford dischargers an opportunity to demonstrate (with site-specific studies) why a limit may not be appropriate. Specifically, the Surface Water Quality Standards prescribe two conditions, which must be satisfied to demonstrate that a new or more stringent phosphorus limitation is not appropriate. The SWQS state, in part, that 1) "phosphorus as total phosphorus shall not exceed 0.1 in any stream, unless it can be demonstrated that it is not a limiting nutrient and 2) total phosphorus will not otherwise render the waters unsuitable for the designated uses." Permittees wishing to pursue this optional study should obtain the Technical Manual for Phosphorus Evaluations, which includes designing an appropriate workplan, sampling protocol and data submission to the DEP. This manual can be accessed at the Division of Water Quality website at: www.state.nj.us/dep/dwq/techmans/phostcml.pdf.

When appropriate, affected permittees on a shared watershed are encouraged to undertake optional studies jointly so that redundant efforts can be eliminated and more integrated approaches found. Such approaches may include trading between point sources and between point and non-point sources.

If you have any questions regarding phosphorus evaluations, please contact Pilar Patterson, Chief, Bureau of Point Source Permitting Region 2, at (609) 292-4860.