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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />IM <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 />designated facility which was to receive the hazardous waste within forty-five (45) days of the <br />date the waste was accepted by the initial transporter, in violation of Title 22 of the California <br />11 Code of Regulations section 66262.42, subdivision (b); <br />U. Failed to complywith the requirements of Title'40 of the Code of Federal <br />J Regulations section 262.34, subdivisions (d) — (f), requiring generators to designate an employee <br />at all times as the emergency coordinator and post the required information listed on Section <br />262,34, subdivision (d)(5)(i) - (iv), in violation of Title 22 of the California Code of Regulations <br />section 66262.34, subdivision (d)(2); <br />V. Failed to properly manage, mark, and store hazardous waste aerosol cans, in <br />I violation of section 25201.16 of the California Health and Safety Code; <br />w. Failed to properly manage, mark store and relinquish universal waste, in <br />violation of Title 22 of the California Code of Regulations sections 66273.3-1(a), 66273.8(b), <br />66273.13 - 66273.16 (repealer filed 2-4-2009) and sections 66273.33 — 66273.36, by improperly <br />disposing of such waste; <br />X. Failed to keep a record with the information required by section 66273.39-, <br />subdivision (a)(1) — (3), of each shipment of universal waste received at the universal waste <br />handler's facility, in violation of Title 22 of the California Code of Regulations section 66273.39; <br />. . y. Failed to implement, maintain and comply with, an employee training program <br />meeting the requirements of Health and Safety Code section 25504, subdivisions (a) and (c), and <br />Title 19 of the California Code of Regulations section 2732, pertaining to hazardous materials, <br />and business and area plans; <br />Z. Failed to implement and maintain a business emergency plan for emergency <br />response to a release or threatened release of hazardous materials, in violation of Health and <br />Safety Code section 25503.5, <br />aa. Failed to implement, maintain or to submit to the administering agency (as <br />defined in Health and Safety Code sections 25501 and 25502), a complete hazardous materials <br />business plan for each Covered Facility, in violation,of Health and Safety Code sections 25504 <br />and 25505 and Title 19 of the California Code of Regulations section 2729; <br />12 <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief <br />Case No. RG09457686 <br />