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
Ammonia
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Ammonia NPDES Strategy
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Flexibilities for States Applying EPA’s Ammonia Criteria Recommendations (EPA-820-F-13-001)
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Ammonia Reasonable Potential Analysis Procedure for NPDES Permits, May 2017
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Example Reasonable Potential Analysis Worksheet
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Sample Permit Conditions Ammonia Compliance Schedule and Recalculation Procedure – Industrial
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Sample Permit Conditions Ammonia Compliance Schedule and Recalculation Procedure – Municipal
Phosphorus
Total Residual Chlorine
Whole Effluent Toxicity
DRAFT Bacteria Strategy
Draft 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 proposed 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 proposed changes to the bacteria criteria for water quality monitoring, 303(d)/305(b) listing purposes, Total Maximum Daily Loads, and wastewater and stormwater permitting.
A stakeholder meeting to discuss the Bacteria Strategy was held on Tuesday, December 14.
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copy of the presentation is available for download.