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Permit Modifications Report: Safeguarding the Environment in the Face of Changing Business Needs

The purpose of this report is to describe the changing nature of RCRA hazardous waste permitting work.

This report demonstrates how adequate and effective state permitting programs are vital, not only for initial permits, but also throughout the permit term to enable necessary permit maintenance activities. Permit conditions frequently need to be revised during the permit term to address evolving facility conditions in response to business changes, as well as changes in applicable regulatory requirements.

Key findings from the report include:

  • The majority of initial facility permits have been issued and the permit-related workload has shifted to maintenance of the expanded workload of permitted facilities.
  • Permit maintenance and permit modifications are critical to enable improved business operations while protecting the environment.
  • On average every year, there are 826 modifications approved and 117 renewals issued.
  • Permit modifications outnumber permit renewals 7 to 1, with 17 percent of permit modifications requiring “substantial” changes on par with initial permit issuance with regard to complexity, workload, and public participation requirements.
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