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The following review questions and considerations provide guidance for conducting a
5-year permit review report for
facilities that have been issued full permits. Many of these
questions may not apply in every case.
Objective: Determine whether specific permit terms or conditions have been
effective in contributing to overall compliance. For example, if a permit
contains a condition establishing specific litter control measures, and those
measures have been implemented, yet there are still frequent citations or
violations of the litter control standard, that condition is probably not
effective and should be revised.
Permit
- Are there any terms or conditions in the permit which specify design
features, methods, or procedures directed toward compliance with State
minimum standards or CEQA mitigation measures?
- Have they been implemented?
- What is the overall compliance history with respect to those standards for
which there is a specific term or condition in the permit?
- Does the permit condition need to be revised or removed from the permit?
State Minimum Standards
- What is the overall compliance history with respect to State Minimum
Standards?
- Is there a specific permit term or condition specifying design features,
methods, or procedures to improve the level of compliance?
- Does the review of past violations or areas of
concern indicate a need for additional permit terms and conditions, or
monitoring requirements?
Complaints
- Does a review of the LEA's complaint log indicate a
need for additional permit terms and conditions?
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Objective: Determine whether terms and conditions are appropriate in
light of changes in other permits, statutes, and/or regulations which may have
occurred since the permit was issued or last revised. Determine whether terms or
conditions have become obsolete as a result of the passage of time. It is also
sometimes useful to look at older permit documents to make sure no changes
were overlooked during a previous permit revision or review.
Permits
- Have there been any changes in any of the other permits applicable to the
site since issuance or the last review or revision of the Solid Waste
Facilities Permit (SWFP)?
- If so, do any of the changes in the terms or conditions of those permits
conflict with any term or condition of the SWFP?
- Are there other activities operating under one of
the regulatory tier permits that should be reflected in the SWFP?
- Does a review of LEA-approved RFI amendments
indicate a need for new or revised terms and conditions?
Regulations
- Have there been any changes in federal, State, or local statutes,
ordinances, or regulations since the issuance or the last review or revision
of the SWFP?
- If so, do any of those changes conflict with or negate any of the terms or
conditions of the SWFP, or necessitate the incorporation of additional terms
or conditions into the SWFP?
- Are there any pre-AB1220 conditions (such as RWQCB
or AQMD requirements) that need to be removed from the permit?
Terms and conditions
- Are there any terms or conditions containing action dates which have
passed?
- Have those conditions been satisfactorily met?
- Should the dates be revised or the condition removed from the permit?
- If there are violations of the terms and conditions, has a notice and order been issued to the operator?
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Objective: Based on a review of the documents of the Full
Permit Application and Permit Package Checklist ("The Laundry
List"), determine whether any other changes in design or operation might need
to be incorporated into a revised permit?
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Objective: Determine whether the terms and conditions of the permit
are appropriate in light of changes in surrounding land uses, waste stream
characteristics, waste collection and transport systems, service area
boundaries, etc. Have such changes resulted in conditions which
increase the potential occurrence of any of the environmental impacts which were
considered at the time the permit was issued or last revised, thereby requiring additional conditions to mitigate those potential impacts.
Surrounding land use
- Have there been any changes in land use or land use zoning of properties
adjacent to the facility since the permit was issued, or since the last time
the permit was revised or reviewed?
- If so, are the new uses more susceptible to environmental impacts or
susceptible to different kinds of environmental impacts than the previous
uses?
- Are additional terms or conditions needed to implement mitigation
measures identified as becoming necessary if, and when, anticipated changes in
surrounding land uses occurred?
Waste stream
- Have there been any changes in the characteristics of the waste stream
handled by the facility?
- If so, is there a need to incorporate special handling provisions for any
wastes into the permit conditions to prevent health, safety, or
environmental impacts?
Waste collection
- Have there been any changes in the waste collection and transport systems
utilized in the facility service area?
- If so, do such changes result in an increase in the number of vehicles
using the site?
- Has there been an increase in recycling and
diversion activities that should be reflected in the SWFP?
Service area boundaries
- Has there been a change in service area boundaries since the permit was
issued or was last revised or reviewed?
- Have the city limits of any cities within the service area expanded
through annexation?
- Have new cities been incorporated, and added to or removed from the
service area?
- Have new areas been added to or removed from the service area?
- Could the service area changes impact the types or
amounts of waste accepted?
Contracts and franchises
- Have new areas been added to or removed from the service area through
changes in contracts, franchises, or other agreements, or as a result of the
closure of some other facility?
- Do the new service area boundaries result in new or increased potential
for direct or indirect environmental impacts associated with the operation
of the facility?
- Are additional terms or conditions needed to ensure needed mitigation
measures are implemented?
- Has there been a change in operator or land owner as
a result?
Waste generation
- Have waste generation rates changed within the facility's
service area since the issuance or the last revision or review of the
permit?
- Were projections of future waste delivery rates to the facility considered
at the time of permit issuance or the last revision of the permit?
- What is the maximum waste delivery rate which is specifically
identified in those projections?
- Has the waste delivery rate to the facility exceeded the maximum rate
permitted?
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Objectives: Determine whether changes in facility design or operation,
statutes or regulations, surrounding land uses, waste generation rates, waste
stream characteristics, waste collection and transport systems, or service area
boundaries—which can be reasonably anticipated to occur in the next five
years—are likely to increase the potential for environmental impacts beyond that
which was considered when the permit was issued.
Design or operation
- Does the operator propose to make any changes in the facility design or
operation during the next five years which would be in conflict with any of
the permit specifications, or which have the potential to increase the
likelihood or magnitude of potential environmental impacts?
Facility closures
- Are there likely to be any facility closures during the next five years
which would result in a change in the size of the service area, or the
volume of waste delivered to the facility under review?
Future waste generation
- Using current waste projection estimates, is the amount of waste
anticipated during the next five year period likely to exceed the maximum
amount considered for acceptance at the time the permit was issued or
revised?
Adjacent land use
- Are there any anticipated changes in land use adjacent to the facility
which are likely to result in the need for permit terms or conditions to
prevent or mitigate potential environmental impacts?
Regulations packets
- Are there any regulations being developed, or recently adopted but not yet
effective, which are likely to require changes in the terms or conditions of
the permit in the next five years?
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