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I In. Failed to at all times have in place a hazardous waste contingency plan and <br /> 2 emergency procedures for each Covered Facility in the State of California,in violation of <br /> 3 California Code of Regulations,Title 22,sections 66265.51 through 66265.56; <br /> 4 n. Failed to implement,maintain and comply with an employee training <br /> 5 program meeting the requirements of Health and Safety Code section 25504,subdivisions(a) <br /> 6 and(c), and California Code of Regulations,Title 19,section 2732,pertaining to hazardous <br /> 7 materials,and business and area plans; <br /> 8 0. Failed to implement and maintain a business emergency plan for. <br /> 9 emergency response to a release or threatened release of hazardous materials,in violation of <br /> 10 Health and Safety Code section 25503.5; <br /> 11 P. Failed to implement,maintain or to submit to the administering agency(as <br /> 12 defined in Health and Safety Code sections 25501 and 25502), a complete hazardous materials <br /> 13 business plan for each Covered Facility,in violation of Health and Safety Code sections 25504 <br /> l 14 and 25505 and California Code of Regulations,Title 19,section 2729; <br /> 15 q. Failed to maintain and operate the Covered Facilities so as to minimize the <br /> 16 possibility of a fire, explosion,or any unplanned sudden or non-sudden release of hazardous { <br /> 17 waste or hazardous waste constituents to air,soil or surface water which could threaten human <br /> 18 health or the environment,in violation of California Code of Regulations,Title 22,section <br /> r <br /> 19 66265.31; <br /> 20 r. Failed to maintain containers holding hazardous waste at the Covered <br /> 21 Facilities so as to prevent leaks,in violation of California Code of Regulations,Title 22, <br /> 22 section 66265.173; <br /> 23 S. Failed to maintain adequate aisle space in hazardous waste storage areas at <br /> 24 the Covered Facilities,in violation of California Code of Regulations,Title 22, section <br /> 25 66264.35; <br /> 26 t. Failed to conduct weekly inspections of hazardous waste storage areas at <br /> 27 the Covered Facilities, in violation of California Code of Regulations,Title 22,section <br /> 28 66264.174. <br /> -5- <br /> COMPLAINT FOR INJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br /> z <br />