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�• Mr. Michael Feeley <br /> Page 2 <br /> minimized. This will eliminate the existing problem of <br /> conditions that are hard to interpret or are actually <br /> in conflict with the regulations. Also, errors of <br /> omission will be less likely. <br /> * This simplified permit will be less time consuming for <br /> staff to assemble and write. Technical staff will be <br /> able to spend more time reviewing submittals in support <br /> of the permit applications, thereby promoting better <br /> overall quality of :the applications. <br /> * This simplified permit will be easier for enforcement <br /> staff to use when inspecting facilities. They will not <br /> need to become familiar with many pages of permit <br /> conditions as at present. <br /> * <br /> If adopted as a statewide model permit for all types of <br /> facilities, this simplified permit document will ensure <br /> greater statewide consistency in permit language. <br /> The enclosed document was reviewed by DTSC's legal staff. <br /> They found it to be superior to the historical permit format by <br /> virtue of its clarity and enforceability. They also determined <br /> that adopting this new " y reference" approach to permit language <br /> is consistent with*the authorization California received to <br /> implement the Resource Conservation and Recovery Act (RCRA) , and <br /> that the authorization does not dictate the use of any particular <br /> RCRA permit format. <br /> Finally, we believe that this effort to improve permit <br /> language is supportive of efforts undertaken by the U.S. <br /> Environmental Protection Agency (USEPA) in implementing the <br /> National Performance Review Recommendations. ---Specifically, _this <br /> proposed simplified permit is in keeping with a recommendation <br /> for State/USEPA joint approaches to administrative streamlining <br /> of the permit process. <br /> We request that you review the enclosed proposed permit <br /> modification and provide DISC with your comments. Region 1 DTSC <br /> staff have received some oral comments from US A's liaison, but <br /> '�we would like written comments and the associated recommended <br /> changes from your technical and legal staff. our permitting and <br /> legal staff would be happy to meet with your staff to discuss any <br /> issues of concern. We request USEPA's writtencomments within <br /> two weeks of your receipt of this letter. <br />