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Jack Vrmeer, Supervisor <br />Page 2 <br />Question 3 What is the legal authority to allow practices, <br />not in permit, to be done prior to the issuance of <br />a modified permit? <br />Answers PRC 44004 requires that no operator shall make a <br />significant change in the design or operation. If <br />the operator wishes to change the design or <br />operation, he shall file an application for <br />revision of the existing solid waste facilities <br />permit. It is staff's opinion that PRC 44002 <br />refers only to significant and nonsignificant <br />changes. <br />Question 4 Interpretation of 14 CCR 18211 <br />Answer: It is staff's opinion that the implementation of <br />nonsignificant changes at a permitted facility <br />prior to the issuance of a modified Solid Waste <br />Facilities Permit (SWFP) would not constitute a <br />violation of law (Title 14 California Code of <br />Regulations, Section 18211). <br />The proposed project should be reflected in an <br />amendment to the site's Report of Facility <br />Information. Following the LEA's determination <br />and approval of the proposed nonsignificant <br />change, the operator may implement the project at <br />the site and file an application for permit <br />modification. <br />Thank you providing me with the opportunity to confirm our <br />position on this matter. If I can be of further assistance, <br />please call me at (916) 327-9347 or Beatrice Cuenca at <br />(916) 327-9351. <br />Sincerely, <br />Martha Vazquez, Manager <br />Permits Branch <br />Permitting and Compliance Division <br />Nrmeerltr <br />:Andersen <br />