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Potential Class I Violations <br /> Hazardous Materials Business Plan Program <br /> • Fails to submit or implement a business plan after previously cited for not having a business <br /> plan. <br /> • Failure to submit a business plan for a high hazard facility and an emergency response <br /> occurs. <br /> • Failure to report a release or threatened release to OES and/or the UPA that results in an <br /> Emergency Response and/or offsite release. <br /> • Any Class H violation that is not corrected within given compliance timeframes. <br /> • Failure to conduct training of employees in high hazard high volume facilities. <br /> Underp,round Storage Tank(UST)Program <br /> • Tampering with monitoring equipment so the equipment is no longer capable of detecting <br /> a leak at the earliest possible opportunity. <br /> • Failure to obtain a UST Operating Permit <br /> • Failure to have functional leak detection equipment, including failure to repair leak <br /> detection equipment. <br /> • Failure to have secondary containment,including failure to repair secondary containment. <br /> • Failure to properly close a UST. <br /> • Failure to conduct well proximity Enhanced Leak Detection. <br /> California Accidental Release Prevention Program(CalARP). <br /> • No incident investigation conducted for catastrophic releases. <br /> • Failure of the owner or operator to submit an initial RMP after notice from the UPA. <br /> • Failure to update the RMP that requires a revise Offsite Consequence analysis, within 6 <br /> months of change and after notice from the UPA. <br /> • Not completing action items from internal and/or external compliance audits, internal <br /> hazard reviews or PHAs, incident investigations,etc. after notice. <br /> Hazardous Waste Prog am <br /> • Disposal at a location not authorized to receive the hazardous waste(Illegal Disposal). <br /> • Incompatible wastes stored or accumulated adjacent to each other with no physical barrier <br /> for separation. <br /> • Failure of a Large Quantity Generator (LQG) to have adequate and complete tank <br /> assessments. <br /> • Failure of a Large Quantity Generator (LQG) to install secondary containment for <br /> hazardous waste tanks and/or a release has occurred and/or high hazard waste. <br /> • Failure to use a registered hauler. Shipping without a manifest, consolidated manifest, or <br /> Violation Classification Guidance for UPAS Page 12 <br />