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Managcmant Memo 89-8 (Rev )) Pegs 7 .CPION: Regional offices are instructed not to issue variances or Interim Status Documents to PBR candidate facilities, except for the following: o variances may be considered for PBR candidate facilities only op pane-by-c{� basis and, a variance should be issued for a facility whose waste streams and/or processes are to be covered by PER only in extraordinary situations. o Variances will be issued for qualifying temporary household hazardous waste collection events sponsored by local governmental agancies using a standard variance format. The Regional Administrator shall be responsible for determining it an extraordinary situation warrants the issuance of a variance. Any variances issued after the date of this Management Memo shall be time-limited to the date that PBR regulations are effective for the specific category of facility which received the variance. This guidance does not . pertain to the processing and issuance of variances for Research, Development and Demonstration permits. Existing policy and procedures for these variances will continue to be utilized. allowing is guidance on variance requests and enforcement action for facilities that are s�Cfected by this Management Memo. Existing Variances: Existing variances for PER .andidate facilities will not be renewed when they expire. All PER ;:egulations will contain a provision that will rescind any and all variances previously issued to a facility for activities covered in that set of regulations. A facility subject to the PER regulations may then elect to operate pursuant to PER, go through the full permitting process, convert to generator status only, or request a variance. Now Variance Requests/Existing Unresolved Variance Requests: New variance requests and outstanding variance requests for facilities planned for PER should bs har4led in the following canner: o The regional offices will send a letter to each applicant, except for temporary household hazardous waste collection events sponsored by local governmental agencies, with a new or outstanding variance rac-iest notifying them that the Department is not currently issuing variances for operations subject to PBR. If an applicant balieves they have an extraordinary case, they should be directed to resubmit their variance request along with a check for the required fee.