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A Case of Mistaken Identity?
A new company needed a permit for proposed wastewater discharge. The regulatory agency rejected its application for a proposed discharge of 15 parts per thousand of a chemical of concern. The company improved its process with a reduced discharge of 15 ppm. The agency again rejected the discharge limitation as too high. The company went back, and after further refinement, was able to propose a 15 ppb discharge. When the agency again rejected the application, the company advised that it was impossible to achieve lower than 15 ppb with current technology. The agency responded that it was not that pp-stuff that was the concern, it was the 15.
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