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I <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />waste, including but not limited to the requirements to maintain, for a period of three (3) years, <br />training documentation for each employee involved in the handling of hazardous waste; <br />g. Treated, stored, disposed of, transported, and offered for transportation, <br />hazardous waste without having received and used aproper identification number from 'the U.S. <br />Environmental Protection Agency or DTSC for the originating facility, in violation of Title 22 of <br />the California Code of Regulations section 66262.12, subdivision (a); <br />h. Failed to determine if a generated waste was a "hazardous waste" as required <br />by Title 22 of the California Code of Regulations section 66262.11, and, where such waste was <br />hazardous, failed to handle the hazardous waste in accordance with the requirements of Chapter <br />6.5 of the Health and Safety Code and its implementing regulations in Title 22 of the California <br />Code of Regulations, including but not limited to section 66265.172 (compatible contents), and <br />section 66265.177 (placing incompatible waste streams in the same container); <br />i. Failed to properly label containers of accumulated hazardous waste, in violation <br />of Title 22 of the California Code of Regulations section 66262.34, subdivision (f); <br />j. Failed to* keep containers of hazardous waste closed, except when removing or <br />adding hazardous waste, in violation of Title 22 of the California Code of Regulations section <br />66265.173; <br />k. Failed to retain copies of all consolidated hazardous waste manifests for three <br />years, in violation of Health and Safety Code section 25160.2, subdivision (b)(3), and Title 22 of <br />the California Code of Regulations section 66262,40, subdivision (a). As used in this paragraph <br />"manifest" means a shipping document originated and signed by a generator of hazardous waste <br />that contains all of the information required by law and that complies with all applicable federal <br />and state regulations, and includes but is not limited to, receipts; <br />1. Failed to at all times have in place a hazardous waste contingency plan and <br />emergency procedures for each Covered Facility in the State of California, in violation of Title 22 <br />of the California Code of Regulations sections 66265.51 through 66265.56; <br />m. Failed to maintain and operate the Covered Facilities so as to minimize the <br />possibility of a fire, explosion, or any unplanned sudden or non -sudden- release of hazardous <br />10 <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief <br />Case No. RG09457686 <br />