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OTHER PROVISIONS <br />4.1. Additional Enforcement Actions. By issuance of this Order, the Department <br />does not waive any right to take further enforcement actions within its jurisdiction <br />involving either Respondent(s) or the Site. <br />4.2. Penalties for Noncompliance. Failure to comply with the terms of this Order <br />may subject Respondent to costs, penalties, and/or damages as provided by Health <br />and Safety Code, section 25188, and other applicable provisions of law. <br />4.3. Parties Bound. This Order shall apply to and be binding upon Respondent, <br />and its officers, directors, agents, employees, contractors, consultants, receivers, <br />trustees, successors, and assignees, including but not limited to individuals, partners, <br />and subsidiary and parent corporations. <br />4.4. Privileges. Nothing in this Consent Agreement shall be construed to require <br />any party to waive any privilege, including without limitation, attorney-client and attorney <br />work -product. However, the assertion of any privilege shall not relieve any party of its <br />obligations under this Consent Order. <br />4.5. Time Periods. "Days" for the purpose of this Order means calendar days. <br />4.6. Compliance with Waste Discharge Requirements. Respondent shall <br />comply with all applicable waste discharge requirements issued by the State Water <br />Resources Control Board or a California regional water quality control board. <br />PENALTY <br />5. Based on the foregoing DETERMINATION OF VIOLATIONS, the Department <br />sets the amount of Respondent's penalty at $123,000. <br />LODI CHROME <br />M <br />HW CA 20040427 <br />ENFORCEMENT ORDER <br />