The EPA guideline for chlorine exposure is based on exposure to 4.0 ppm free chlorine when there is no CYA. EPA never considered the fact that 97.2% of the chlorine is bound to CYA at pH 7.5, 30 ppm CYA and 2.0 ppm free chlorine, or that 98.35% of the chlorine in the water is bound to CYA at pH 7.5, 30 ppm CYA and 4.0 ppm free chlorine. So swimmer exposure to chlorine when using 30 ppm or more of CYA is only 1.5 to 2.8% of the free chlorine level in the water. For example, at 4.0 ppm free chlorine, swimmers are exposed to only 0.11 ppm chlorine (4.0 × 0.028= 0.112). If there is 4.0 ppm of free chlorine with no CYA, swimmers are exposed to the whole 4.0 ppm. CYA keeps exposure to chlorine low. If using borate at 50 ppm, the free chlorine requirement is lowered to 5%. So you can have up to 80 ppm CYA because 5% of 80 is 4.0 ppm.