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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 />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 />In. Failed to at all times have in place a hazardous waste contingency plan and <br />emergency procedures for each Covered Facility in the State of California, in violation of <br />California Code of Regulations, Title 22, sections 66265.51 through 66265.56; <br />n. Failed to implement, maintain and comply with an employee training <br />program meeting the requirements of Health and Safety Code section 25504, subdivisions (a) <br />and (c), and California Code of Regulations, Title 19, section 2732, pertaining to hazardous <br />materials, and business and area plans; <br />o. Failed to implement and maintain a business emergency plan for <br />emergency response to a release or threatened release of hazardous materials, in violation of <br />Health and Safety Code section 25503.5; <br />P. 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 California Code of Regulations, Title 19, section 2729; <br />q. Failed to maintain and operate the Covered Facilities so as to minimize the <br />possibility of a fire, explosion, or any unplanned sudden or non -sudden release of hazardous <br />waste or hazardous waste constituents to air, soil or surface water which could threaten human <br />health or the environment, in violation of California Code of Regulations, Title 22, section <br />66265.31; <br />r. Failed to maintain containers holding hazardous waste at the Covered <br />Facilities so as to prevent leaks, in violation of California Code of Regulations, Title 22, <br />section 66265.173; <br />S. Failed to maintain adequate aisle space in hazardous waste storage areas at <br />the Covered Facilities, in violation of California Code of Regulations, Title 22, section <br />66264.35; <br />t. Failed to conduct weekly inspections of hazardous waste storage areas at <br />the Covered Facilities, in violation of California Code of Regulations, Title 22, section <br />66264.174. <br />-5- <br />COMPLAINT FOR INJUNCTION, CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />