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I f. Failed to maintain a copy of the contingency plan and all revisions at the facility, in <br /> 2 violation of California Code of Regulations, title 22 section 66265.53(a); <br /> 3 g. Failed to have at least one employee either on facility premises or on call with the <br /> 4 responsibility for coordinating all emergency response measurers, in violation of California Code of <br /> 5 Regulations,title 22 section 66265.55; <br /> 6 h. Failed to contain any lamp in a closed container or package that is structurally <br /> 7 sound, adequate to prevent breakage,and compatible with the contents of the lamp, in violation of <br /> 8 California Code of Regulations,title 22 section 66273.33(b)(1); <br /> 9 i. Failed to immediately clean up and place in.a closed container any lamp this is <br /> 10 broken and/or shows evidence of leakage or damage that could cause the release of mercury or other <br /> 11. hazardous constituents to the environment, in violation of California Code of Regulations,title 22 <br /> 12 section 66273.33(b)(2); <br /> 13 j. Failed to label or mark the universal waste to identify the type of universal waste <br /> 14 with the phrase"Universal Waste-Lamp(s)", in violation of California Code of Regulations,title 22 <br /> 15 section 66273.34(c); <br /> 16 k. Failed to demonstrate the length time that the universal waste has been <br /> 17 accumulated from the date it became a waste or was received, in violation of California Code of <br /> 18 Regulations,title 22 section 66273.35(b); <br /> 19 1. Failed to determine if that waste is a hazardous waste, in violation of California <br /> 20 Code of Regulations,title 22 section 66262.11; <br /> 21 m. Failed to retain a copy of each signed manifest for three (3)years or until the <br /> 22 generator receives a signed copy from the designated facility which received the waste, in violation <br /> 23 of California Code of Regulations, title 22 section 66262.40(a); <br /> 24 n. Failed to retain a copy of consolidated manifest :for at least three(3)years,in <br /> 25 violation of Health and Safety Code section 25160.2(b)(3); <br /> 26 o. Failed to use a bill of lading to record the transfer of used oil filters,in violation of <br /> 27 California Code of Regulations,title 22 section 66266.130(c)(5); <br /> 28 p. Failed to maintain and operate facility to minimize the possibility of a Fire, <br /> -6-... <br /> __..._.__._........._...._..__._.._...............__.................... ---------._.._...._.. <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />