LEA Advisory #21 (Revised)—July 26, 2001

Format for Permit Review Reports

Statute and Regulation require that Local Enforcement Agencies (LEA) review each Solid Waste Facility Permit at least once every five years from the date of issuance. The Permit Desk Manual (rescinded in 1998 and replaced by the Permit Toolbox in 2001) provided guidance to LEAs on how to conduct permit reviews. However, the majority of that guidance was given in the form of questions that LEAs should keep in mind during the review process. With regard to the preparation of the Permit Review Report, the Permit Desk Manual did not provide a recommended format or a standardized form for use by LEAs. As a result, Permit Review Reports submitted by LEAs have varied widely in form and content.

From a practical standpoint, an LEA conducts a permit review every time a change in the design or operation of the facility occurs or is proposed. However, the result of that review is rarely documented in a Permit Review Report unless the facility is due for a five year review. The purpose of this advisory is to provide LEAs with a recommended format that will allow quick and easy documentation of the permit review process.

In addition to a title or subject line identifying the submitted document as a Permit Review Report for a specific facility, there are four key components to a complete Permit Review Report:

1. A List of the Documents Reviewed
2. A List of Findings Made (including page references)
3. A List of Conclusions Reached Regarding Permit Status and the need for Revision/Suspension/Revocation of the Permit
4. A List of the Directives Given to the Operator

Also see the Conclusions and Directives Chart in the Permit Toolbox.

In other words, to be complete, a Permit Review Report should answer these questions:

• What did you look at?
• What did you find?
• What did you conclude?
• What did you tell the operator to do?

The attached form (Word, 743 KB) is provided as an example. At this time, use of the form is highly recommended, but not required. Both electronic and hard copies of the form can be requested from the Permits Branch of the Board.

Other Resources:

• Permit Toolbox Permit Review Page
• LEA Advisory No. 24: When are 5-Year Permit Review Reviews Due?
• LEA Advisory No. 52: Documentation of "No Change" During Permit Review

If you have any additional questions please contact your Permitting and Inspection Branch representative.

Sincerely,

Original signed by:

Deputy Director
Permitting and Enforcement Division

Attachment 

Five-Year Permit Review Report Form: Word (743 KB) or PDF (113 KB)

Publication #232-95-003

The intent of the advisories is to provide guidance to Local Enforcement Agencies (LEA) in performing their duties. Guidance, for this purpose, is defined as providing explanation of the Board’s regulations and statutes.

Unless included by reference in the LEA's Enforcement Program Plan (EPP), advisories are not enforceable in the same manner as regulations because they have not been adopted through the formal rulemaking process (see Government Code sections 11340.5 and 11342.6). Advisories do not take precedence over statute or regulation.