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I contain a north orientation , loading areas , internal roads , adjacent streets , <br /> 2 storm and sewer drains , access and exit points , emergency shutoffs , <br /> 3 <br /> evacuation staging areas , hazardous material handling and storage areas , <br /> 4 <br /> 5 and emergency response equipment . <br /> 6 3 . 6 The Respondents violated HSC § 25505 (a) ( 3 ) , failed to establish <br /> 7 and /or submit emergency response procedures for a release or threatened <br /> 8 release . The emergency response procedures were not completed and <br /> 9 submitted to CERS . <br /> 10 3 . 7 The Respondents violated HSC § 25505 (a) (4 ) , failed to submit a <br /> 11 <br /> 12 training program or program is not reasonable or adequate for facility . A <br /> 13 training program had not been submitted . Training programs for all <br /> 14 employees and annual training , including refresher courses , shall include <br /> 15 safety procedures for the event of a release or threatened release of a <br /> 16 hazardous material , including , but not limited to , familiarity with the facility ' s <br /> 17 emergency response plans and procedures . These training programs may <br /> 18 take into consideration of each employee . <br /> 19 <br /> 20 3 . 8 The Respondents violated HSC § 25508 . 23 failed to annually review <br /> 21 and certify that the business plan is complete , accurate , and up to date . <br /> 22 The business plan information had not been reviewed and resubmitted in <br /> 23 the California Environmental Reporting System ( CERS ) annually . The <br /> 24 hazardous materials inventory shall be submitted by January 15 of each <br /> 25 calendar year and may be submitted beginning November 1 of the previous <br /> 26 <br /> year. <br /> 27 <br /> 28 3 . 9 The Respondents violated HSC § 25505 (a ) (4 ) , failed to provide or <br /> - 3 - <br /> CONSENT ORDER Intsel Steel West California LLC <br />