Compliance Stategy: Mass vs. Concentration Limits

Last month, Tony Wagner, TRSA’s director of federal government relations, and I met with EPA officials to discuss compliance issues related to concentration limits and pH. We believe we made progress and will get at least some encouragement and assistance from EPA on mass vs. concentration limits. Therefore, we’ll focus this discussion on mass vs. concentration. We’ll deal with pH later as it may be more of a regulatory challenge.
 
During the initial review process, we provided EPA with comments related to mass vs. concentration, but we were unable to achieve our desired result of including industrial ...

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