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