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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />a <br />in <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 i <br />27 <br />28 <br />otherwise located at the Facility as a result of a spill or container breakage or other <br />means, or product returned by a customer to that Facility, is a waste, and if so, <br />whether it is a "hazardous waste," in violation of California Code of Regulations, <br />title 22, section 66262.11; <br />f. Failed to segregate incompatible hazardous waste items at the Facilities, in <br />violation. of California Code of Regulations, title 22, section 66265.177; <br />g. Failed to accumulate hazardous waste in a lined or compatible container at the <br />Facilities, in violation of California Code of Regulations, title 22, section <br />66265.172; <br />h. Failed to keep containers of hazardous waste closed and/or sealed at the Facilities, <br />except when removing or adding hazardous waste, in violation of California Code <br />of Regulations, title 22, section 66265.173; <br />i. Failed to maintain adequate aisle space at the Facilities to allow the unobstructed <br />movement of personnel, fire protection equipment, spill control equipment, and <br />decontamination equipment in an emergency, in violation of California Code of <br />Regulations, title 22, section 66265.35; <br />j. Failed to conduct daily inspections of hazardous waste tank systems and maintain <br />records at the Facilities, in violation of California Code of Regulations, title 22, <br />section 66265.195; <br />k. Failed to conduct daily tank inspections of discharge control equipment, <br />monitoring equipment and waste level at the Facilities, in violation of California <br />Code of Regulations, title 22, section 66262.34, subdivision (d)(2) and Title 40 of <br />the Code of Federal Regulations, section 262.16, subdivision (b)(3)(iii); <br />1. Failed to properly manage, identify the date of accumulation, and label containers <br />of hazardous waste at the Facilities, in violation of California Code of <br />Regulations, title 22, section 66262.34; <br />in. Failed to include all required information in the hazardous waste tank system <br />assessment documentation at the Facilities, in violation of California Code of <br />-$— <br />COMPLAINT FOR INNNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF <br />