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I Title 40 of the Code of Federal Regulations section 262.16, subdivision (b)(9)(iii); 2 aa. Failed to maintain hazardous waste management training documents and records 3 at the Facilities, in violation of California Code of Regulations, title 22, section 4 66265.16, subdivisions (d) and(e); 5 bb. Failed to prepare and maintain copies ofuniform hazardous waste manifests for 6 three (3) years at the Facilities, in violation of California Code of Regulations, title 7 22, section 66262.40, et seq.; and/or failed to retain documentation demonstrating 8 the applicability of claimed exemptions. As used herein"manifest"means a 9 shipping document originated and signed by a generator of hazardous waste that 10 contains all of the information required by law and that complies with all 11 applicable federal and state regulations, and includes, but is not limited to, 12 uniform hazardous waste manifests and receipts; 13 cc. Failed to have manifests signed by the Treatment, Storage, and Disposal Facility 14 available for inspection at the Facilities, in violation of California Code of 15 Regulations, title 22, section 66262.40 and Health and Safety Code section 25185, 16 subdivision (a)(4); 17 dd. Treated, stored, disposed of, transported, and/or offered for transportation at the 18 Facilities,hazardous waste without having received and used a proper 19 identification number from the U.S. Environmental Protection Agency or the 20 DTSC for the originating facility, in violation of California Code of Regulations, 21 title 22, section 66262.12, subdivision(a); 22 ee. Failed to properly empty a container, manage a non-empty container, or an inner 23 liner removed from a container,which previously held a hazardous material, 24 including hazardous waste, at the Facilities, in violation of California Code of 25 Regulations,title 22, section 66261.7; 26 ff Failed to maintain at the Facilities, a copy of the Contingency Plan and all its 27 revisions and/or to submit a copy to the local emergency agencies that may be 28 called upon to provide emergency services, in violation of California Code of I - I1 - COMPLAINT FOR INJUNCTIVE RELIEF,CIVIL PENALTIES,AND OTHER RELIEF