Frequent Questions

What should I do if my state does not seek authorization for the RCRA streamlined permit modification procedure?

While we have encouraged all authorized states to adopt the streamlined permit modification procedure, we recognize that some may choose not to. If your state has not picked up this procedure, we suggest that you meet with your state permit writer to discuss what options are available to you that will still allow you to meet your HWC NESHAP compliance date. Some options may include: (1) using the existing permit modification procedures, which generally will be either a Class 2 or 3 RCRA permit modification, (2) requesting a temporary authorization under 40 CFR §270.42(e), or (3) applying for a compliance extension under 40 CFR §§63.6(i)(4) and 63.1213. Another mechanism that is available to facilities that are in the process of renewing their RCRA permits is to incorporate the MACT-related equipment and process changes in the RCRA permit renewal application. 

For more information regarding these potential options, see the RCRA Streamlined Permit Modification Fact Sheet  (PDF, 368 KB) in this Toolkit.

Have more questions? Submit a request