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• y <br /> 4r STATE OF CALIFORNIA <br /> ENVIRONMENTAL PROTECTION AGENCY ;;';'� �'° .° ;; �� HEALTH <br /> DEPARTMENT OF TOXIC SUBSTANCES CONTROL <br /> P 1 2• E 1 <br /> In the Matter of: ) Docket No. DO 93/94-1002 <br /> J.R. Simplot Company ) STIPULATION AND ORDER <br /> 15777 Howland Road } <br /> Lathrop, California 95330 } Health and Safety Code <br /> } Section 25187 <br /> Respondent.' } <br /> The State Department of Toxic Substances Control <br /> (Department) and J.R. Simplot Company (Respondent) enter into <br /> this Stipulation and Order (Order) and agree as follows: <br /> 1. A dispute exists regarding the Enforcement Order issued <br /> by the Department on March 18, 1994. (Attached as Exhibit 1. ) <br /> 2. The parties wish to avoid the expense of further <br /> litigation and to ensure prompt action to achieve the Schedule <br /> for Compliance below. <br /> 3. Jurisdiction exists pursuant to Health and Safety Code <br /> (HSC) Section 25187. <br /> 4 . Respondent waives any right to a hearing in this matter. <br /> 5. This Order shall constitute full settlement of the <br /> violations alleged in the Enforcement Order, but does not limit <br /> the Department from taking appropriate enforcement action <br /> concerning other violations. <br /> SCHEDULE FOR COMPLIANCE <br /> 6. Respondent shall comply with the following: <br /> 6.1.1. On February 4, 1994, Respondent provided to the <br /> Department photographs which documented correction of <br /> 1 <br /> S <br />