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1 <br />On March 31, 1993, PI s bmitted a Part A <br />and Part B application for use of their closed <br />detonation vessel unit to t eat LX -14 waste <br />explosives. This applicati n was revised on <br />November, 1996, to addr ss deficiencies <br />found in the original sub ittal and is now <br />considered complete. <br />Enforcement <br />DTSC conducted inspecti <br />ns of the facility in <br />1987, 1989, 1991, 1995 <br />d 1996. Violations <br />observed between 1987 - <br />1991 included <br />inadequate labeling of co <br />tainers, incomplete <br />inspection logs, failure t <br />list home addresses <br />of emergency coordinato <br />s in the contingency <br />plan, having an open con <br />ainer of waste, lack <br />of warning signs, and in <br />dequate waste <br />analysis plan. All violati <br />ns have been <br />addressed in response to <br />eports of Violations <br />issued after each inspecti <br />n. <br />DTSC's inspection on Ja <br />uary 24, 1995, <br />revealed no violations. <br />The most recent <br />inspection conducted on <br />ovember 14, 1996, <br />resulted in minor violati <br />ns involving manifest <br />errors, an out-of-date co <br />tingency plan and <br />open containers. These <br />iolations were <br />corrected by December <br />, 1996. <br />V. Proposed Draft Permit <br />Draft permit conditions imposed on a facility <br />are based on regulatory standards, CEQA <br />findings and the facility s permit application. <br />All terms and condition of the draft permit <br />are required pursuant t Title 22, California <br />Code of Regulations, C apters 14 and 20. As <br />a result, DTSC is prop sing a draft permit for <br />Primex consisting of th following sections: <br />Section I. Findings - ontains a brief <br />chronology of permitti g activities up to the <br />present and findings related to CEQA. <br />March 1997 <br />F <br />Section II. General Conditions - contains <br />conditions related to the facility's general <br />administration and includes such matters as <br />facility design, waste analysis, security, <br />inspections, personnel training, preparedness <br />and prevention, contingency planning, record <br />keeping, reporting, closure, financial <br />assurance, liability insurance and incapacity of <br />owners. <br />Section I1I. Specific Conditions - contains <br />requirements for the safe operation of each <br />unit and includes design specifications and <br />operating procedures, limits on operating <br />parameters, monitoring and inspection <br />procedures, and closure plans. <br />Section IV - Corrective Action for Solid <br />Waste Management Units Schedule of <br />Compliance - contains a summary of <br />completed and ongoing corrective action for <br />identified solid waste management units and <br />provisions for newly -identified units <br />VL Compliance with CEQA <br />The California Environmental Quality Act <br />(CEQA) is a state law which requires that, for <br />every activity which fits the definition of <br />"project," impacts on the environment be <br />evaluated. An Initial Study is performed to <br />determine the scope of the environmental <br />document which must be prepafed to identify <br />any significant impacts. If the Initial Study <br />concludes that there are significant impacts <br />associated with the project, an EIR is <br />prepared, otherwise a Negative Declaration is <br />prepared. <br />The initial study that DTSC conducted for this <br />project involved an evaluation of the potential <br />impacts to soil, surface and ground water, air <br />quality, public services and utilities, and <br />public health, posed by the projeet. After <br />considering the information provided by <br />Primex on all phases of project planning, <br />Pa -e 4 <br />