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1 a. Failed to have at all times at least one employee either on facility premises or on <br /> 2 call with the responsibility for coordinating all emergency response measures, in violation of <br /> 3 California Code of Regulations, title 22 section 66262.34(d)(2); <br /> 4 b. Failed to retain a copy of each signed manifest for three (3) years or until the <br /> 5 generator receives a signed copy from the designated facility which received the waste, in violation <br /> 6 of California Code of Regulations, title 22 section 66262.40(a); <br /> 7 c. Failed to submit to the Department of Toxic Substance Control a legible copy of <br /> 8 the manifest with some indication that the generator has not received confirmation of delivery within <br /> 9 sixty(60) days from the date the hazardous waste was accepted by the initial transporter, in violation <br /> 10 of California Code of Regulations,title 22 section 66262.42(c); and <br /> 11 d. Failed to retain a copy of consolidated manifest for at least three (3)years, in <br /> 12 violation of Health and Safety Code section 25160.2(b)(3). <br /> 13 SECOND CAUSE OF ACTION <br /> 14 VIOLATION OF HEALTH AND SAFETY CODE SECTIONS 25500 ET SEQ. <br /> 15 (HAZARDOUS MATERIALS RELEASE RESPONSE PLANS AND INVENTORY) <br /> 16 9. Paragraphs 1 through 8, above are incorporated herein by reference. Plaintiff is informed <br /> 17 and believes and based upon such information and belief alleges that beginning at an exact date that <br /> 18 is unknown to Plaintiff,but within five(5)years prior to the filing of this Complaint,Defendant <br /> 19 engaged in acts in violation of Health and Safety Code sections 25500 et seq., including but not <br /> 20 limited to the following: <br /> 21 a. Failed to complete and/or submit a site map, in violation of Health and Safety Code <br /> 22 section 25505(a)(2); <br /> 23 b. Failed to provide training for all new employees and annual training, including <br /> 24 refresher courses, for all employees in safety procedures in the event of a release or threatened <br /> 25 release of hazardous material,in violation of Health and Safety Code section 25505(a)(4); and <br /> 26 c. Failed to document training electronically or by hard copy and retain for a <br /> 27 minimum of three(3) years, in violation of Health and Safety Code section 25505(a)(4). <br /> 28 <br /> -3- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />