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1 <br />1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />a <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 />h. In the event of non -receipt of a copy of the manifest with the handwritten signature of <br />the owner or operator of the designated facility, Defendant failed to contact the transporter <br />and/or the owner or operator of the designated facility which was to receive any hazardous <br />waste to determine the status of the hazardous waste within thirty-five (35) days of the <br />date the waste was accepted by the initial transporter, as provided by Title 22 of the <br />California Code of Regulations section 66262.42. <br />i. Failed to maintain a program for the lawful storage, handling and accumulation of <br />hazardous waste, and for the lawful segregation of hazardous -waste items that are in <br />leaking containers, as provided by Health & Safety Code section 25123.3 and California <br />Code of Regulations, Title 22, sections 66262.34, 66265.173 and 66265.177. <br />j. Failed to maintain properly designated and designed hazardous waste storage areas, <br />which included the segregation of hazardous wastes, and failed to conduct weekly <br />inspections of hazardous waste storage areas, at each Facility, as required by California <br />Code of Regulations, Title 22, sections 66262.34 and 66265.174. <br />k. Failed to implement, maintain, and submit to the respective administering agency (as <br />defined in Health and Safety Code sections 25501 and 25502), a complete hazardous <br />materials business plan, as required by Health and Safety Code sections 25504 and 25505 <br />and California Code of Regulations, Title 19, section 2729, as applicable. <br />1. Failed to continuously implement, maintain, and submit to.the respective <br />administering agency (as defined in Health and Safety Code sections 25501 and 25502), a <br />complete hazardous materials business plan, as required by Health and Safety Code <br />sections 25504 and 25505 and California Code of Regulations, Title 19, section 2729, as <br />applicable. <br />m. Failed to comply with all employee training obligations required by California Code <br />of Regulations, Title 22, section 66265.16, pertaining to the handling of hazardous waste, <br />including, but not limited to, the requirement to maintain for a period of three (3) years, all <br />training documentation for each employee involved in hazardous waste handling at any <br />Facility. <br />9 <br />Complaint For Permanent Injunction, Civil Penalties And Other Equitable Relief <br />