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xanagement Nemo 99-9 (Ra J) Page 2 affected facilities , in one rulamaking, of their responsibilities under law, rather than by issuing individual permits facility by facility. The Department focus will shift from the pre-audit of permit applications to the imposition of industry-specific performance standards and subsequent emphasis on inspections and enforcement efforts. The Department plans to address non-RCRA regulated treatment activities requiring State authorization through the PDR process, except fort o incinerators (other than non-RCRA regulated incinerators used solely for treatment of fuel contaminated soils) o waste oil recycling facilities o activities involving land application of hazardous waste (this includes landfills, land treatment, surface impoundment&, injection wells and waste piles, other than non-RCRA regulated waste piles for treatment of soils contaminated with fuels, metals, or solvents) o treatment of reactive or extremely hazardous waste in addition to treatment activities, transporters handling only used oil by transferring from one container or tank to another, pumping, Packaging, and/or storing at a transfer station/facility for less than 144 hours will be addressed under PBA. All other transfer stations/facilities must comply with Management Nemo 90-9. On-site storage of spent dry cleaning wastes will also be addressed under PBR. This management memo applies only to those activities described in the preceding two paragraphs as planned for inclusion under PDR. The Department believes that the PBR approach will decrease duplication of efforts, is ,the pest use of limited resources, and will provide statewide consistendj . In doing ■o, the PBR approach will allow permitting staff time to be available for those facilities with waste streams and processes which have the greatest potential for detrimental impact to public health and the environment if improperly managed. The Department anticipates adoption of the on-site Fixed Treatment Unit PBR regulation by the fall of 1991, and will request an effective date of January 1, 1992. This delayed effective data is being requested so that the effective date of the regulations will eerresand to the effective date of pendina legislation which would have a large impact on the PBR program. The applicabilif•y of. the PBR approach to off-site facilities is more complex and limited , and the regulation of these until any PBR rulemaking for these facilities is completed creates problems in terms of enforcement mod otzrating equity.