Real Environmental Work

Discussion with one of my favorite regulators
"Want to talk about the test report, it was above the limits you have proposed"
-We were testing a change in the system and the storm caused power failures and an upset"
"Yes but the VOC's were high"
-Yes, the fact that the tests were done in upset conditions and testing was stopped because we couldn't get a stable system. That was covered in the letter attached to the report."
"Yes but you were higher than the proposed permit limits."
-Well, we can propose higher limits, since this is new
"You've demonstrated that you can acheive those limits at another facility"
-Well, that was run under normal conditions and not in an upset, and we know that one facility is pretty much like another...
"I know you've tested at other facilities, but each one is site-specific"
-Well, if you are concerned, we can request an increase in the limits"
"You can't, you've shown you can make them at another facility, you either need to retest before the permit or retest after the permit is issued"
-What if retest in stable conditions shows slightly higher than at the other facility, since the results are site-specific, can we then change the limits?
"You can't, you've shown that you can do it at another facility"

Makes one feel a bit dense, and trapped in some circular logic. This is real environmental work at it's finest.