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1 §338.1), defendants engaged in acts in violation of Health and Safety Code section 25100 et seq., <br /> 2 including but not limited to the following: <br /> 3 a. Disposed or caused disposal of hazardous waste at an unauthorized point or stored <br /> 4 hazardous waste at an un-permitted facility, in violation of Health and Safety Code section 25189.5; <br /> 5 b. Failed to determine if a waste is a hazardous waste, in violation of California Code of <br /> 6 Regulations, Title 22, section 66262.11; <br /> 7 C. Facility not maintained to minimize the release of a hazardous waste, in violation of <br /> 8 California Code of Regulations, Title 22, section 66265.31; <br /> 9 d. Failed to maintain all communication or alarm systems, spill control, or decon <br /> 10 equipment, in violation of California Code of Regulations, Title 22, section 66265.33; <br /> 11 e. Stored hazardous waste onsite for longer than 90 days without a permit or <br /> 12 authorization , in violation of Health and Safety Code section 25201(a); <br /> 13 f. Failed to properly label containers of hazardous waste, in violation of California Code <br /> 14 of Regulations, Title 22, section 66262.34; <br /> 15 g. Failed to keep containers of hazardous waste closed except when adding or removing <br /> 16 hazardous waste, in violation of California Code of Regulations, Title 22, section 66265.173(a); <br /> 17 h. Failed to keep signed copies of manifests for three (3) years, in violation of California <br /> 18 Code of Regulations, Title 22, section 66262.40(a); <br /> 19 i. Failed to keep a copy of the consolidated manifest for three(3) years, in violation of <br /> 20 Health and Safety Code section 25160.2; <br /> 21 j. Failed to retain a copy of manifest or bill of lading for spent lead acid batteries for <br /> 22 three(3) years, in violation of California Code of Regulations, Title 22, section 66266.81(a)(4)(B); <br /> 23 k. Failed to maintain completed personnel training records, in violation of California <br /> 24 Code of Regulations, Title 22, section 66265.16. <br /> 25 <br /> 26 <br /> 27 <br /> 28 /// <br /> Complaint for Injunction, Civil Penalties and Other Relief Page 3 <br />