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I otherwise located at the Facility as a result of a spill or container breakage or other <br /> 2 means, or product returned by a customer to that Facility, is a waste, and if so, <br /> 3 whether it is a"hazardous waste,"in violation of California Code of Regulations, <br /> 4 title 22, section 66262.11; <br /> 5 f. Failed to segregate incompatible hazardous waste items at the Facilities, in <br /> 6 violation.of California Code of Regulations, title 22, section 66265.177; <br /> 7 g. Failed to accumulate hazardous waste in a lined or compatible container at the <br /> 8 Facilities, in violation of California Code of Regulations, title 22, section <br /> 9 66265.172; <br /> 10 I h. Failed to keep containers of hazardous waste closed and/or sealed at the Facilities <br /> 11 except when removing or adding hazardous waste, in violation of California Code <br /> 12 of Regulations, title 22, section 66265.173; <br /> 13 i. Failed to maintain adequate aisle space at the Facilities to allow the unobstructed <br /> 14 movement of personnel, fire protection equipment, spill control equipment, and <br /> 15 decontamination equipment in an emergency, in violation of California Code of <br /> 16 Regulations, title 22, section 66265.35; <br /> 17 j. Failed to conduct daily inspections of hazardous waste tank systems and maintain <br /> 18 records at the Facilities, in violation of California Code of Regulations, title 22, <br /> 19 section 66265.195; <br /> 20 k. Failed to conduct daily tank inspections of discharge control equipment, <br /> 21 monitoring equipment and waste level at the Facilities, in violation of California <br /> 22 Code of Regulations, title 22, section 66262.34, subdivision(d)(2) and Title 40 of <br /> 23 the Code of Federal Regulations, section 262.16, subdivision(b)(3)(iii); <br /> 24 1. Failed to properly manage, identify the date of accumulation, and label containers <br /> 25 of hazardous waste at the Facilities, in violation of California Code of <br /> 26 i Regulations, title 22, section 66262.34; <br /> 27 in. Failed to include all required information in the hazardous waste tank system <br /> 28 assessment documentation at the Facilities, in violation of California Code of <br /> -$— <br /> COMPLAINT FOR INNNCTIVE RELIEF,CIVIL PENALTIES,AND OTHER RELIEF <br />