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10 <br />11 <br />12 <br />13 <br />14 <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 />compliance audits shall evaluate Target's compliance with Chapter 6.5 and 6.95 of Division 20 of <br />the Health and Safety Code, and their implementing regulations. The environmental compliance <br />audits shall also evaluate the implementation and effectiveness of Target's ESIM program and <br />any other environmental compliance program implemented by Target to maintain compliance <br />with Chapter 6.5 and 6.95 of Division 20 of the Health and Safety Code. The environmental <br />audit reports referenced above shall include, but not be limited to, a complete description and <br />discussion of all environmental audit objectives, scope, and criteria, audit activities, audit findings <br />and audit conclusions, recommendations and shall identify and discuss all audit evidence <br />considered or relied upon to support the audit conclusions. The environmental audit reports shall <br />also contain a brief description of any written advisements of violation, including formal Notices <br />of Violation and inspection reports directed to any Target Facility by any local, state or federal <br />agency that identifies any violation of any environmental protection law relating to the <br />management of any hazardous material or waste. Such reports shall also include, but not be <br />limited to, a brief description of the disposition of any such noted violations including whether <br />Target paid any fines, costs or other payments and what corrective measures, if any, were taken <br />by Target. Within 30 days after receipt by the People of each environmental audit report, Target <br />shall provide the People with a plan to correct any deficiencies raised in the environmental audit <br />reports. <br />6. ENFORCEMENT OF FINAL JUDGMENT ON CONSENT AND PENALTIES <br />The People may move this Court for additional relief for any violation of any provision of <br />this Final Judgment on Consent, including but not limited to, contempt, additional injunctive <br />provisions, or additional penalties consistent with the provisions of this Final Judgment on <br />Consent. Nothing in this Final Judgment on Consent shall limit any rights of the People to seek <br />any other relief or remedies provided by law, or the rights of Target to defend against any request <br />of the People for such other relief or remedies. <br />7. MATTERS COVERED BY THIS FINAL JUDGMENT ON CONSENT <br />7.1. This Final Judgment on Consent is a final and binding resolution and settlement of all <br />claims, violations or causes of action alleged by the People in the FAC (attached as Exhibit A) <br />8 <br />on consent in eeome v. <br />