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Under which circumstance may a local agency NOT revoke or modify a UST permit?

  1. Violation of permit terms

  2. Misrepresentation to obtain the permit

  3. Failure to submit a renewal request

  4. A change in UST operational conditions

The correct answer is: Failure to submit a renewal request

A local agency is generally empowered to revoke or modify a UST permit in various situations, such as violations of the permit terms, misrepresentation during the permit application process, or significant changes in operational conditions that would require a reassessment of the permit's validity. However, the failure to submit a renewal request does not intrinsically justify the agency's authority to revoke or modify the permit. The renewal process is typically a procedural requirement meant to ensure that a facility maintains current operational standards and complies with regulatory requirements. If a facility neglects to submit a renewal request, it may lead to performance issues or non-compliance, but it doesn't necessarily imply wrongdoing that is directly associated with the integrity or safety of the underground storage tank system itself. The local agency may have procedures to address such failures, often allowing for grace periods or opportunities for correction prior to permit action. This understanding highlights that while other circumstances involve clear breaches of rules or heightened risks, failing to renew is more about administrative oversight and can often be rectified without the need to revoke or modify a permit.