Preface

• Author: Susan M. McMichael
• Pages: 17-17

Page xvii

Preface

Most people are unsure of how to address the complicated issues associated with Resource Conserva-

tion and Recovery Act (RCRA) permitting, federal facilities, and hazardous and radioactive mixed waste. e

sheer number of U.S. Environmental Protection Agency (EPA) rules alone (over 900) can be mind-boggling,

with new rules being issued each year. In the last decade alone, EPA issued several major new rules that sig-

nicantly impact RCRA permitting, including its Burden Reduction Initiative, which streamlined hundreds

of RCRA permit requirements, and increased use conditional exemptions and exclusions from some or a ll of

RCRA’s permit requirements. Additionally, many facilities received permits at a time when EPA and state per-

mitting authorities had little, if any, experience in permitting, and public participation was minimal. Since that

time, most facilities have sought permit modications based upon technological advancements and improve-

ments in waste management operations. Other facilities have reached their ve-year review and are in the

process of permit renewal following the expiration of their 10-year permit term.

e RCRA Permitting Deskbook provides a comprehensive, up-to-date guide that addresses all aspects

of RCRA permitting. Included also is a chapter on radioactive mixed waste that provides an historical over-

view of mixed waste regulation and the unique issues associated with facilities that manage this type of waste.

e deskbook is intended to assist attorneys, governmental regulators, environmental ma nagers, and citizen

activities to better understand and navigate through RCRA permit requirements, permit modications, permit

reviews, and renewa ls. It is built upon more than a decade of experience and incorporates lessons learned and

checklists to address common issues and mistakes in the permit process.