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