 | Vol. 7 No. 3 Winter 1999 |
| A Newsletter About New Jersey's Water Quality Programs |
| The analytical sensitivity needed for a specific parameter is obvious, however, it is not always so clear under monitor-only requirements. |
NJPDES discharge to surface water permits are referred to as "self-reporting" permits because the program depends on self-monitoring and reporting by permittees. This monitoring and reporting poses a critical question for permittees: Is the detection level for the analytical methods used sensitive enough to meet permit requirements?
The analytical sensitivity needed for a specific limited parameter (or other specified enforceable level) is obvious, however, monitor-only requirements are not always so clear. This is particularly true for toxic pollutants where relatively low instream concentrations may be of environmental concern. Complicating the situation further, the sensitivity of the analytical method can be affected by the chemical-physical characteristics of each specific effluent.
In developing monitor-only permit requirements, the division's goal is to ensure that the permittee knows the necessary level of analytical sensitivity required. In this way, time and money is not wasted collecting monitoring data that can not be utilized for its intended purpose.
In order to achieve that goal, the division commonly includes Recommended Quantitation Levels (RQLs) in permits. A parameter's RQL represents the lowest concentration that can be measured by most laboratories. Accordingly, data with detection levels at or below the RQL are acceptable to the division.
Permittees often ask whether a permit requires them to have detection levels at least as sensitive as RQLs. Permits require a justification for an alternate quantitation level whenever a permittee or its laboratory determines a pollutant detection level will not be at or below the RQL. Failure to submit a justification is a permit violation. Upon review by the division, these justifications are either accepted or the division will work with the permittee to establish an alternate quantitation level to ensure all data collected is usable.
If you have any questions on about RQLs, please contact Jeffrey Reading, Chief, Bureau of Point Source Permitting Region 1, at (609) 633-3869.