Mercury TMDLs in Georgia: A Recent Case Study
Dean, J. David
Andes, Frederic P.
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In February 2000, EPA Region 4 proposed a mercury TMDL for the Savannah River, precipitated by a 303(d) listing by the State of Georgia based on consumption guidelines for mercury in fish tissue. In December, 2000, EPA Region 4 re-proposed this TMDL in response to the large volume of comment received on its earlier proposal. In support of the TMDL, EPA sampled and analyzed mercury in fish tissue, sediments, water, soil, and effluents from various NPDES dischargers along Savannah River. This paper provides a summary of the major technical and legal concerns over the recently re-proposed mercury TMDL for the Savannah River and the data collection and analysis efforts used in support of this TMDL. In particular, the authors believe that EPA had no legal basis to propose the TMDL because impairment of the Savannah River for fishing was never demonstrated. In the development of the TMDL, EPA did not follow its own guidance for deriving ambient water quality criteria for the protection of human health. This paper concludes with a discussion of the impact of these recent developments on NPDES dischargers to the Savannah River.