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I at a point which is not authorized, in violation of Health and Safety Code section 25189.2(c); <br /> 2 b. Treated, stored, disposed of, transported or offered to transport hazardous <br /> 3 waste without having an Identification Number, in violation of California Code of Regulations, title <br /> 4 22 section 66262.12(a); <br /> 5 C. Failed to determine if that waste is a hazardous waste, in violation of <br /> 6 California Code of Regulations,title 22 section 66262.11; <br /> 7 d. Failed to retain copies of any test results, waste analyses, or other <br /> 8 determinations for at least three (3) years from the date the waste was last sent to on-site or off-site <br /> 9 treatment, storage, or disposal, in violation of California Code of Regulations, title 22 section <br /> 10 66262.40(c); <br /> 11 e. Failed to have a contingency plan for the facility, in violation of California <br /> 12 Code of Regulations, title 22 section 66265.51(a); <br /> 13 f. Failed to describe in the contingency plan the actions facility personnel shall <br /> 14 take in response to fires, explosions, or any unplanned sudden or non-sudden release of hazardous <br /> 15 waste constituents to air, soil, or surface water at the facility, in violation of California Code of <br /> 16 Regulations,title 22 section 66265.52; <br /> 17 g. Failed to maintain a copy of the contingency plan and all revisions at the <br /> 18 facility, in violation of California Code of Regulations, title 22 section 66265.53(a); <br /> 19 h. Failed to train facility personnel in hazardous waste management procedures <br /> 20 relevant to their positions, in violation of California Code of Regulations, title 22 section <br /> 21 66265.16(a); <br /> 22 i. Failed to train facility personnel within six (6) months after the date of their <br /> 23 employment or assignment to a facility, or to a new position at a facility, in violation of California <br /> 24 Code of Regulations, title 22 section 66265.16(b); <br /> 25 j. Failed to provide facility personnel with an annual review of the initial training <br /> 26 in hazardous waste management procedures relevant to their positions, in violation of California <br /> 27 Code of Regulations, title 22 section 66265.16(c); <br /> 28 k. Failed to maintain a written description of the type and amount of both <br /> -3- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />