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I introductory and continuing training for each employee, in violation of California Code of 2 Regulations,title 22 section 66265.16(d); 3 1. Failed to retain a copy of each signed manifest for three (3) years or until the 4 generator receives a signed copy from the designated facility which received the waste, in violation 5 of California Code of Regulations, title 22 section 66262.40(a); 6 in. Failed to contact the transporter and/or the owner or operator of the designated 7 facility to determine the status of the hazardous waste within thirty-five (35) days of the date the 8 waste was accepted with a copy of the manifest without the handwritten signature of the owner or 9 operator of the designated facility, in violation of California Code of Regulations, title 22 section 10 66262.42(a); 11 n. Failed to submit an Exception Report to the Department of Toxic Substance 12 Control within forty-five (45) days of the date the waste was accepted by the initial transporter 13 without a copy of the manifest with the handwritten signature of the owner or operator of the 14 designated facility, in violation of California Code of Regulations,title 22 section 66262.42(b); 15 0. Failed to submit to the Department of Toxic Substance Control a legible copy 16 of the manifest with some indication that the generator has not received confirmation of delivery 17 within sixty (60) days from the date the hazardous waste was accepted by the initial transporter, in 18 violation of California Code of Regulations, title 22 section 66262.42(c); 19 P. Accepted, treated, stored or disposed of hazardous waste at a facility without 20 holding a hazardous waste facility permit, in violation of Health and Safety Code section 25201(a); 21 q. Failed to maintain and operate facility to minimize the possibility of a fire, 22 explosion, or any unplanned sudden or non-sudden release of hazardous waste, in violation of 23 California Code of Regulations,title 22 section 66265.31; 24 r. Failed to transfer hazardous waste in a container not in good condition to a 25 container that is in good condition, in violation of California Code of Regulations, title 22 section 26 66265.171; 27 S. Failed to keep container holding hazardous waste closed during transfer and 28 storage, except when it is necessary to add or remove waste, in violation of California Code of -4- VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF