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kanagement Nemo 89-8 (Re,# - 9) Page 4 o variances will be issued for qualified temporary household hazardous waste collection events sponsored by local governmental agencies using a standard variance format. o All decisions to issue a variance, other than for temporary household hazardous waste collection events sponsored by local governmental agencies, are to be made by the Regional iLdministrator. Enforoaaent: In the pact, the Department has focused most of its resources on facilities that are subject to regulation under the federal Resource conservation and Recovery Act (RCRA) . There are many non-RCRA facilities that are operating without the required California permit. The Department, however, does not have adequate resources at the present time to address the thousands of facilities in the non-RCRA universe through the regular permitting process. This places many facilities in the position of operating in violation of law with no timely resources for obtaining a permit. Therefore, the Department wishes to -Lacus enforcement resources on the highest priority activities during the transition period prior to promulgation of PSR regulations for PBR candidate non-RCRA activities. Surveillance and Enforcement program staff will continue to inspect PBR candidate facilities through routine inspections and in response to complaints , and will continue to take appropriate enforcement action in those instances where public health and safety or the environment is threatened. As PBR candidate facilities that do not threaten public health and safety or the environment are discovered and investigated through routine inspections and in response to complaints, they will be handled as detailed below. on-site Facilities: Until appropriate PBR regulations are effective for their activities, all on-site (as defined in Section 25117.12 , Division 200 HSC) PBR candidate facilities, including those that are now authorized by permit, interim status or variance, 'will be expected to comply with generator requirements at a minimum. Generator requirements include basic generator standards as well as interim status standards for training, container management, and tank management as referenced in Section 66262. 94 of title 22., CaIifarnia Coda of Regulations. Penalties should be assessed, on. appropriate, only for violations of generator requirements. Once appropriate PSR regulations are effective .for their activities, they will be.,, .required to comply with those requirements.