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Smith, R.C. Tupas Jr. , and Celso Tupas signed Permanent <br /> 1 <br /> Injunction and Final Judgment pursuant to the Stipulation <br /> 2 <br /> admitting all allegations contained within Superior Court Case <br /> 3 <br /> No. 231300, including all of the alleged Hazardous Waste Control <br /> 4 <br /> Act violations (Attached as Attachment 3 and incorporated hereto <br /> 5 <br /> by said reference) . <br /> 6 <br /> Furthermore, on May 9, 1991, in Municipal Court Case No. <br /> 7 <br /> SM158592 , defendants' corporation R.V. Circuits, Inc. pled no <br /> 8 <br /> contest to violating Section 25189 . 5 (a) of the Health and Safety <br /> 9 <br /> Code, Hazardous Waste Disposal (Attached as Attachment 4 and <br /> 10 <br /> incorporated hereto by said reference) . Defendant was placed on <br /> 11 <br /> three years informal probation under the following terms and <br /> 12 <br /> conditions: <br /> 13 <br /> 1) Defendant to pay a $25, 000. 00 fine, $25, 000. 00 fine to <br /> 14 <br /> be suspended upon payment of $5, 000. 00 to the California <br /> 15 <br /> District Attorney's Hazardous Waste Training Fund within 90 days <br /> 16 <br /> of sentencing; <br /> 17 <br /> 2) Defendant to obey Section 25189 . 5 of the Health and <br /> 18 <br /> Safety Code. <br /> 19 <br /> Terms of probation were signed by R.C. Tupas, Jr. , Vice <br /> 20 <br /> President of R.V. Circuits. <br /> 21 <br /> On August 17, 1993 , a new complaint was received by PHS-EHD <br /> 22 <br /> through Rhonda Archbold, SMUD, regarding a complaint SMUD had <br /> 23 <br /> received by an anonymous worker who said she was being <br /> 24 <br /> physically exposed to hazardous waste. The complainant had <br /> 25 <br /> indicated that the facility was filled with containers of open <br /> 26 <br /> untreated hazardous waste. The complainant additionally <br /> 27 <br /> complained that the workers were standing in hazardous waste. <br /> 28 <br /> 3 <br />