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Does the treatment system have to be fully tested and operational at the time the initial certification statement is submitted?

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Indirect dischargers must set up milestones for achieving compliance with the PFPR rule by November 6, 1999; therefore, it is possible that the treatment system may be tested following submission of the initial certification statement. However, the system must be fully operational by the agreed date of compliance or November 6, 1999, whichever is earlier. Direct dischargers may also submit the initial certification statement before the issue, reissue, or renewal of their permit is complete. In such a situation, the treatment system may not yet be fully operational.

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