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1 <br />12 <br />13 <br />27 <br />(a) On June 15, 2007, the CUPA inspection report notified PNA's Lathrop Facility <br />2 that it had failed to comply with numerous aspects of Califomia's hazardous waste laws and <br />3 regulations. The violations included failure to properly label containers of hazardous waste, <br />4 , failure to keep containers of hazardous waste closed except when adding/removing hazardous <br />5 , waste, failure to maintain a complete contingency plan and storage of universal waste on-site for <br />6 i more than a year. <br />7 (b) On March 3 and April 17, 2009, as a result of two inspections, the CUPA <br />8 I notified PNA's Lathrop Facility that it had failed to comply with an even greater number of <br />9 I California hazardous waste regulations. As in 2007, the Lathrop Facility failed to maintain a <br />10 complete contingency plan and stored universal waste on site for more than a year. Other <br />11 'violations included failing to have an emergency coordinator. <br />(c) On June, 30, 2010, the CUPA's inspection report notified PNA's Latlirop <br />acility that once again it had failed to comply with several of Califomia's hazardous waste <br />14 regulations. As in 2007, the Lathrop Facility failed to completely label containers of hazardous <br />I j <br />15 waste and, as in 2009, the Facility failed to have an emergency coordinator. The Department's <br />I j <br />16 inspection in December 2010 would also reveal imlabeled or incompletely labeled hazardous <br />17 waste and a failure to update the Facility's contingency plan to reflect a change in emergency <br />18 coordinators. The CUPA inspection also notified the Lathrop Facility that it had stored hazardous <br />19 ,waste on site longer than 90 days without a permit or authorization and had not maintained <br />20 .complete personnel training records - two violations that the Department's inspectors would see <br />21 again just six months later in their December 2010 inspection. <br />22. On or about December 14 and 15, 2010, the Department inspected PNA's Lathrop <br />23 Facility ("2010 the Department Inspection") for compliance with the HWCL and its <br />24 iniplementing regulations. The Department's inspectors discovered violations of the HWCL and <br />s implementing regulations. <br />23. On December 15, 2011, the Department provided PNA with a summary of violations. <br />24. On or about February 9, 2011, the Department sent PNA an inspection report <br />25 i <br />26 <br />28 indicating its findings for the 2010 DTSC Inspection. The Department's Inspection Report cited <br />:l 6 <br />COMPLAINT FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF