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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 />t. Failed to have a Contingency Plan for the Facilities which is designed to minimize <br />hazards to human health or the environment from fires, explosions, or any <br />unplanned sudden or non -sudden release of hazardous waste or hazardous waste <br />constituents to air, soil, or surface water, in violation of California Code of <br />Regulations, title 22, section 66265.5 1, subdivision (a); <br />u. Failed to complete and submit a Hazardous Materials Inventory for the Facilities <br />to the Certified Unified Program Agency, in violation of Health and Safety Code <br />sections 25505, 25507, and 25508 and California Code of Regulations, title 19, <br />section 2654; <br />v. Failed to conduct weekly inspections of hazardous waste storage areas at each <br />Facility, in violation of California Code of Regulations, title 22, sections 66262.34 <br />and 66265.174; <br />w. Stored hazardous waste onsite beyond ninety (90) days at Facilities which did not <br />have a hazardous waste facilities permit from DTSC, in violation of California <br />Code of Regulations, title 22, section 66262.34, and Health and Safety Code <br />section 25201, subdivision (a); <br />x. Stored hazardous waste onsite beyond one hundred eighty (180) days at Facilities <br />which did not have a hazardous waste facilities permit from DTSC, in violation of <br />Health and Safety Code sections 25201, subdivision (a) and 25123.3, subdivision <br />(h)(1) and California Code of Regulations, title 22, section 66262.34, and Title 40 <br />of Code of Federal Regulations, section 262.16; <br />y. Failed to implement, maintain, and comply with an employee training program on <br />hazardous materials at the Facilities, in violation of Health and Safety Code <br />section. 25505, subdivision (a)(4), and California Code of Regulations, title 19, <br />section 2659; <br />z. Failed to comply with employee training obligations pertaining to the handling of <br />hazardous waste and emergency procedures at the Facilities, in violation of <br />California Code of Regulations, title 22, section 66262.34, subdivision (d)(2) and <br />-10- <br />COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF <br />