Permitting Strategies & Reasonable Potential Analysis
Water quality based limitations (WQBLs) are imposed in wastewater permits when it is determined that technology based limitations are not sufficient to protect water quality (40 CFR 125.3). These limitations are based on state and federal water quality standards, as well as the assimilative capacity of the receiving stream.
EPD has developed a number of permitting strategies and reasonable potential analysis procedures to aid in the determination of effluent limitations in NPDES wastewater permits. More information on the development of limitations may be found on the Water Quality Modeling page.
NPDES
Reasonable Potential Procedures
Per- and Polyfluorinated Substances (PFAS) Strategy
The Division has developed a
Draft
PFAS Strategy
for the implementation of PFAS requirements in wastewater permits. A public meeting to present the draft strategy and solicit feedback was held March 13, 2025, at 1:00 pm using the Zoom platform. Information about the public meeting, as well as the method for submitting comments, is available in this
public
notice
. A copy of the slides presented at the meeting are
available
here
.
Nutrient Reduction Strategies
In September 2023, EPD finalized Georgia's roadmap for the development of a comprehensive Nutrient Reduction Strategy for point and nonpoint source discharges. This document builds upon a draft roadmap focused on the development of a comprehensive nutrient permitting strategy for point sources that went through public review and feedback beginning in 2022. The document addresses existing laws, guidance documents, and permitting strategies, as well as EPD's proposed actions and timelines for revising or developing various related strategies and plans.
Roadmap
for Developing and Updating Nutrient Reduction Strategies
Guidance
for Developing a Comprehensive Nutrient Optimization Plan
Ammonia
-
Ammonia
NPDES Strategy
-
Flexibilities
for States Applying EPA’s Ammonia Criteria Recommendations (EPA-820-F-13-001)
-
Ammonia
Reasonable Potential Analysis Procedure for NPDES Permits, May 2017
Phosphorus
In 2011, EPD issued the memo Strategy for Addressing Phosphorus in NPDES Permitting which defined a framework for establishing effluent limits and monitoring requirements for permitted point source discharges. As part of EPD’s finalized Roadmap for Developing and Updating Nutrient Reduction Strategies (2023), the Division committed to developing and revising nutrient-related strategies and plans.
The Division is proposing revisions to the 2011 Phosphorus Strategy. A public notice was issued on March 1, 2024 and a public meeting to present the proposed changes and solicit feedback was held on April 4. The Division is accepting comments on the proposed revisions through May 15.
Total Residual Chlorine
Whole Effluent Toxicity
Bacteria Strategy
Bacteria Equivalency Strategy for Using the Optimal Indicator Organisms for WQS and NPDES Permitting (Bacteria Strategy)
During the 2013 Triennial Review, Georgia adopted E. coli and enterococci as the pathogen indicators for waters designated as recreation where primary contact recreational activities such as swimming, water skiing, and white-water boating occur. As part of the 2019 Triennial Review, Georgia adopted E. coli and enterococci criteria for waters designated as fishing, coastal fishing, and drinking water to protect secondary contact recreators who may inadvertently ingest water. The Bacteria Equivalency Strategy for Using the Optimal Indicator Organisms for WQS and NPDES Permitting (Bacteria Strategy) provides a framework for the implementation of the changes to the bacteria criteria for water quality monitoring, 303(d)/305(b) listing purposes, Total Maximum Daily Loads, and wastewater and stormwater permitting.