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I t. Failed to have a Contingency Plan for the Facilities which is designed to minimize <br /> 2 hazards to human health or the environment from fires, explosions, or any <br /> 3 unplanned sudden or non-sudden release of hazardous waste or hazardous waste <br /> 4 constituents to air, soil, or surface water, in violation of California Code of <br /> 5 Regulations, title 22, section 66265.5 1, subdivision (a); <br /> 6 u. Failed to complete and submit a Hazardous Materials Inventory for the Facilities <br /> 7 to the Certified Unified Program Agency, in violation of Health and Safety Code <br /> 6 sections 25505, 25507, and 25508 and California Code of Regulations,title 19, <br /> 9 section 2654; <br /> 10 v. Failed to conduct weekly inspections of hazardous waste storage areas at each <br /> 11 Facility, in violation of California Code of Regulations, title 22, sections 66262.34 <br /> 12 and 66265.174; <br /> 13 w. Stored hazardous waste onsite beyond ninety(90)days at Facilities which did not <br /> 14 have a hazardous waste facilities permit from DTSC, in violation of California <br /> 15 Code of Regulations, title 22, section 66262.34, and Health and Safety Code <br /> 16 section 25201, subdivision(a); <br /> 17 x. Stored hazardous waste onsite beyond one hundred eighty(180) days at Facilities <br /> 18 which did not have a hazardous waste facilities permit from DTSC, in violation of <br /> 19 Health and Safety Code sections 25201, subdivision(a) and 25123.3, subdivision <br /> 20 (h)(1) and California Code of Regulations, title 22, section 66262.34, and Title 40 <br /> 21 of Code of Federal Regulations, section 262.16; <br /> 22 y. Failed to implement,maintain, and comply with an employee training program on <br /> 23 hazardous materials at the Facilities, in violation of Health and Safety Code <br /> 24 section.25505, subdivision(a)(4), and California Code of Regulations, title 19, <br /> 25 section 2659; <br /> 26 z. Failed to comply,with employee training obligations pertaining to the handling of <br /> 27 hazardous waste and emergency procedures at the Facilities, in violation of <br /> 28 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 />