Wastewater & Storm Water Management

SMG routinely assists our clients in applying for and obtaining NPDES permits (storm water and industrial waste water) and local pretreatment permits. SMG frequently develops and assists our clients with preparation of related management plans such as SPCCs, SWPPPs, BMPs and GPPs.

1/Anti-Degradation Alternative Analysis


A client wanted to renew their NPDES wastewater discharge permit and was asked to do a Socioeconomic Demonstration and Alternatives Analysis (SDAA) (previously known as a high quality alternatives analysis (HQAA)), also known as an “anti-degradation analysis”. Not knowing what to do, they contacted SMG for help.


The SDAA is designed to protect high quality waters within the state by preventing additional pollution from harming existing water quality conditions, while not prohibiting essential economic and social development in the region. SMG analyzed alternative and enhanced treatment technologies and source reduction strategies at the project location, and analyzed the project’s impact on both social and economic factors in the region. SMG was able to show that abandonment of the project would result in a significant impact on the socioeconomic development of the region.


The client was approved to continue development of their business with no changes to their operation or other detrimental permit restrictions.

2/NPDES Permitting


A municipality’s NPDES wastewater discharge permit had restrictive permit limits that were costing the city money in treatment costs. Also, the state’s reasonable potential analysis, prepared during the NPDES permit renewal process, proposed monitoring and limits for additional parameters that the city felt were not justified. Not knowing how to respond, the city contacted SMG for help.


SMG determined the basis for the restrictive limits inclusion on the permit. It turned out the limits had been applied based on a regulation that had been since overturned. The state concurred and returned normal secondary treatment limits to the permit.

Next, SMG reviewed the city’s sampling results and compared them with the results of the state’s reasonable potential analysis. SMG found that many of the proposed requirements were based on sampling results from one particular year. A closer look at the data showed inconsistencies, such as effluent sampling results that were significantly higher than influent sampling results. SMG convinced state regulators to agree that the data should be excluded from the analysis. After completing a second reasonable potential analysis using the revised data, the additional monitoring and limits from the proposed permit were removed.


The city no longer had to spend extra money on additional treatment to meet the overly restrictive permit limits. The plant operator could breathe easier knowing that there was a greater margin of error in operating the city’s wastewater treatment plant.

In addition, by proactively challenging proposed permit requirements, the city avoided having additional limits and monitoring added to their NPDES permit and saved money by not having to regularly sample for these parameters.

3/Pretreatment Local Limits


A city engaged SMG because local industries were complaining about their pretreatment permit limits and the city was not getting economic development inquiries from industry regarding new or expanded operations. Existing local limits appeared to be more stringent than what seemed reasonable.


SMG reviewed the city’s Sewer Use Ordinance, influent, effluent, and sludge sampling results, Pretreatment Reports, and the NPDES Permit. In comparing the city’s local limits with other treatment plants’,

SMG found:

The city’s limits were more stringent than other comparable plants;

The city’s permit and local limits had not been updated as a result of the closure of a major industry that changed the treatment plant’s industrial loading; and

The city’s treatment plant capacity has been upgraded in the NPDES permit, but this had not been taken into consideration during pretreatment program evaluations.

Based on these factors SMG helped the city re-evaluate their local limits.


SMG re-evaluated and developed technically valid and effective pretreatment local limits. SMG coordinated with city officials and state regulators during the re-evaluation process. As a result, the local limits for many important parameters were made less stringent and several other parameters were removed due to site-specific conditions at the wastewater treatment plant. The city now feels that it can keep its existing industries happy and potentially attract new industry to the area.