One minor suggestion regarding the definition of "storage" =  >200 gallons of waste. There often seems to be confusion (between inspectors and "storage facilities")  of how to calculate the 200 gallons; also there is some confusion as to whether the calculation is actual waste stored or potential to store waste. Sounds like it should be simple - but this has been a point of contention for a few facilities.

Additionally, typically medical waste is not calculated/tracked, by RMW industry standards, in gallons. It is calculated or tracked  in pounds or tons. Has DEQ considered changing the units of waste to be more inline with industry standards?

Section 810 - Amendment of permits only addresses temporary authorizations; but does not address permanent permit amendments. This regulation should, at least,  reference PBR amendments in 9VAC20-81, in order to provide guidance for amendments submission and approvals.