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I <br /> I f. Failed to obtain and keep current all required hazardous waste generator <br /> 2 permits required by county and local ordinances; <br /> 3 g. Failed to comply with employee training obligations as set forth in <br /> 4 California Code of Regulations,Title 22,section 66265.16,pertaining to the handling of <br /> 5 hazardous waste, including but not limited to the requirement to maintain,for a period of three <br /> 6 years,training documentation for each employee involved in hazardous waste handling; <br /> 7 h. Treated,stored,disposed of,transported,and offered for transportation, <br /> 8 hazardous waste without having received and used a proper identification number from the <br /> 9 U.S.Environmental Protection Agency or the California Department of Toxic Substances <br /> 10 Control for the originating facility,in violation of California Code of Regulations,Title 22, <br /> 11 section 66262.12(a); <br /> 12 i. Failed to determine if a generated waste was a"hazardous waste"as <br /> 13 required by California Code of Regulations,Title 22, section 66262.11,and,where such waste <br /> 14 was hazardous,failed to handle the hazardous waste in accordance with the requirements of <br /> 15 Chapter 6.5 of the Health& Safety Code and its implementing regulations in the California <br /> s <br /> 16 Code of Regulations,Title 22,including but not limited to section 66265.172(compatible <br /> F <br /> 17 contents),and section 66265.177(placing incompatible waste streams in the same container); <br /> 18 j. Failed to properly label containers of accumulated hazardous waste,in <br /> 19 violation of California Code of Regulations,Title 22, section 66262.34; <br /> 20 k. Failed to keep containers of hazardous waste closed,except when <br /> 21 removing or adding hazardous waste,in violation of California Code of Regulations,Title 22, <br /> 22 section 66265.173; <br /> E <br /> 23 1. Failed to retain copies of all consolidated hazardous waste manifests for <br /> 24 three years,in violation of Health and Safety Code section 25160.2(b)(3)and California Code <br /> 1 <br /> 25. of Regulations,Title 22,section 66262.40(a). As used in this paragraph"manifest"means a <br /> 26 shipping document originated and signed by a generator of hazardous waste that contains all of <br /> 27 the information required by law and that complies with all applicable federal and state 1 <br /> 28 regulations, and includes but is not limited to,bills of lading; <br /> .4.. <br /> COMPLAINT FOR INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />