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1.2. The parties enter into this Consent Agreement to avoid the expense of litigation and to carry out promptly the corrective action described below. This Agreement is not intended to waive the rights of any party regarding, or to release or relieve any obligation of, Reggie Mason (Mason) individually or dba Lodi Chrome in relation to the matters herein. 1.3. Respondent is the owner of a hazardous waste facility located at 316 North Main Street, Lodi, California 91016 (Facility). 1.4. Larsson leased the property to Mason. Lodi Chrome is a plating facility and part of its operations generated various hazardous waste streams including cyanide, chromium, copper, nickel, and corrosive and fine hazardous powder from chrome polishing operations. 1.5. The terms used in this Consent Agreement are as defined in California Code of Regulations, title 22, section 66260.10, except as otherwise provided. 1.6. Respondent agrees to implement all Department approved workplans and to undertake all actions required by the terms and conditions of this Consent Agreement, including any portions of this Consent Agreement incorporated by reference. 1.7. Respondent waives any right to request a hearing on this Consent Agreement pursuant to Health and Safety Code section 25187. FINDINGS OF FACT 2.1. On September 7, 2005, the Department issued an Enforcement Order (Docket HWCA No. 20040427), to Mason for the violations of the Hazardous Waste Control Law, Chapter 6.5 of Division 20 of the California Health and Safety Code, section 251000, et seq., and its implementing regulations set forth at California Code of Regulations, title 22, division 4.5, sections 66250, et seq., pertaining to the storage, handling, management, and disposal of hazardous waste including failure to remove significant quantities of spilled hazardous waste fine powder from chrome polishing LODI CHROME Docket SRPD RPDD06/07SCC-4378 CORRECTIVE ACTION CONSENT AGREEMENT 2