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Why aren facilities required to submit their initial certification at the time the BMR is due?

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Why aren facilities required to submit their initial certification at the time the BMR is due?

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Initial certifications are due no later than November 6, 1999, although they may be submitted earlier. The BMR measures the baseline performance of the facility, but the initial certification cannot be made until the facility has invested time (and often money) to gather the information needed to make the compliance decisions (i.e., zero discharge or P2 alternative) that are documented in the initial certification.

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