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In 2015, EPA updated the national recommended human health water quality criteria for 94 chemical pollutants to reflect the latest scientific information and to take into account current exposure factors (body weight, drinking water intake, fish consumption rate), bioaccumulation factors, and toxicity factors (reference dose, cancer slope factor). A comparison of the updated and previous ambient water quality criteria (AWQC) can be found here. Changes to exposure factors consist of the following:

  • Body Weight: EPA updated the default body weight for human health criteria to 80 kilograms (176 pounds). This represents the mean body weight for adults ages 21 and older. EPA’s previously recommended default body weight was 70 kilograms (154 pounds).
  • Drinking Water Intake: EPA updated the default drinking water consumption rate to 2.4 liters per day (0.63 gallons per day). This represents the per capita estimate of community water ingestion at the 90th percentile for adults ages 21 and older. EPA previously recommended a default drinking water consumption rate of 2 liters per day (0.53 gallons per day).
  • Fish Consumption: EPA updated the default fish consumption rate to 22 grams per day (0.77 ounces per day). This rate represents the 90th percentile consumption rate of fish and shellfish from inland and nearshore waters for the U.S. adult population 21 years of age and older. EPA’s previously recommended a default rate of 17.5 grams per day (0.62 ounces per day).

Not all of the changes resulted in more stringent criteria; some pollutants, such as chloroform, have less stringent criteria. But most are more stringent; for example, human health fish consumption criteria for the following pollutants have changed:

  • Acenaphthene decreased from 990 µg/l to 90 µg/l
  • Ethylbenzene decreased from 2,100 µg/l to 130 µg/l
  • Hexachlorobenzene decreased from 2.9×10-4 µg/l to 7.9×10-5 µg/l
  • Phenol decreased from 860,000 µg/l to 300,000 µg/l
  • Toluene decreased from 15,000 µg/l to 520 µg/l

According to the EPA, states must consider any new or updated national recommended water quality criteria as part of their triennial review. If states choose not to adopt new or revised water quality criteria, they must provide an explanation to EPA as to why they did not do so. Kentucky completed its triennial review in late 2015 and published updates to 401 KAR Chapter 10 in February 2016. Therefore, Kentucky will not be required to consider these revised criteria until the next triennial review in 2018. At that time, it is likely that most, if not all, of the revised criteria will be incorporated in Kentucky’s water quality standards.

William Shane is an Environmental Engineer at Smith Management Group. William can be reached at williams@smithmanage.com.

April 22, 2016

Local Limits: MAIL and Allocation

April 20, 2016

Energy Project Assessment District (EPAD) Proposed for Louisville

April 19, 2016

SMG Celebrates Earth Month





A local company engaged in manufacturing imported a small amount of a chemical substance defined under TSCA. Faced with a potential EPA enforcement action with penalties assessed for noncompliance under TSCA of up to $32,500 per day per violation, the company called SMG for help.


SMG analyzed the company’s current TSCA procedures and assisted the company in developing a proactive, cost-effective compliance procedure. SMG also facilitated a training program to educate employees about TSCA.

SMG worked with the company to develop mechanisms that assured adherence with the policies that were being implemented for compliance. Procedures to promptly correct any potential violations and prevent future violations were also put into place.


SMG was able to show that the company complied with the relevant TSCA regulations and was improving their TSCA policies and procedures to assure that future issues were less likely to occur. The company was not subjected to the proposed penalties and now has mechanisms in place to maintain TSCA compliance.