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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />1 1 <br />1 2 <br />13 <br />1 4 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />hazardous material and the site map readily available to personnel of the business or the unified <br />program agency, in violation of Health and Safety Code section 25505(c); <br />e. Failing to complete andlor submit a hazardous materials inventory for all <br />reportable materials on site, in violation of Health and Safety Code section 25506(a); <br />f. Failing to review and certify, on or before the annual due date, that the information <br />management system is complete, accurate, and in compliance, in violation of Health and Safety Code <br />section 25508.2; and <br />g. Failing to electronically submit a hazardous materials business plan annually to the <br />statewide information management system, in violation of Health and Safety Code section <br />25508(a)(1). <br />5. Defendant with actual or constructive knowledge of this Injunction, only in so far as they <br />are doing business in the State of California,. in the course of Defendant's MEDICAL WASTE <br />DISPOSAL activities, are pursuant to California Business and Professions Code, section 17204 <br />hereby permanently enjoined from: <br />a. Violating Health and Safety Code sections 25100 et seq., described in paragraph <br />3 — 3d above; <br />b. Violating Health and Safety Code sections 25500 et seq., described in paragraph <br />4 — 4g above; and <br />c. Failing to ensure that leachate is controlled to prevent contact with the public, in <br />violation of California Code of Regulations, title 27 section 20790; <br />d. Contributing or causing to be contributed, directly or indirectly a discharge into the <br />City storm drainage system of any pollutant, wastewater, or any substance or material which <br />interfered with the operation or performance of the City storm drainage system or violate the City's <br />NPDES permit, in violation of Stockton Municipal Code section 13.16.060; <br />e. Discharging which resulted in or contributing to a violation of the City's NPDES <br />permit, in violation of Stockton Municipal Code section 13.16.120; <br />f. Failing to maintain all property and landscaping in compliance with the conditions <br />of their use permit and the requirements of the Development Code, in violation of Stockton <br />-3- <br />PERMANENT INJiJNCTION AND FINAL JiJDGMENT PURSUANT TO STIPULATION