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1 <br />2 <br />4 <br />5 <br />6 <br />7 <br />9 <br />10 <br />11 <br />12 <br />17 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />2.1 <br />22 <br />2.3 <br />24 <br />25 <br />26 <br />27 <br />28 <br />hazardous wastes. This framework, contained in Hazardous Waste Control Law, Chapter 6.5 of <br />Division 20 of the health and Safety Cade,. section 25100 et sect. (°"H WCL" or "Chapter 6.5") and <br />its implementing regulations,. which are found at California Cade of Regulations, title 22, section <br />662607 1 et seq., mandates a "cradle to grave' system_ The I.1WCl, system is maintained to record <br />the registration, tracking, storgge; treatment, and disposal of hazardous wastes and to provide for <br />the protection of the public from the potential risks posed by hazardous wastes. <br />14. The HWCL is the :California analog of the federal Resource Conservation and <br />Recovery Act, 42 U.&C. section 6901 et se : (``RCRA"). Pursuant to state and federal law, the. <br />Cali1`ornia Department of Toxie Substances Control (` DTSC") adminitsters the HWCL in lieu cif <br />f6deral administration ofRCRA. in California. (See Health & Saf. Code, §:251 01, subd. (d).) <br />Federal law prohibits California from imposing "9ny requirements less stringent than those <br />authorized under [RCRA] " (42 U.S.C. § 6.29.) <br />15. The HWCL has in certain instances a more inOus.ive definition of hazardouswaste <br />than does federal law Hazardous wastes that are regulated under California law but not federal <br />law are known as "non-RCRA hazardous wastes:" (.Health & .Sal. Code., § 25117.9;) <br />16. Companies that accurnulate or .generate hazardous waste in the course: of their <br />operations and send that. waste offsite for manapment;are, subject to certain regulatory <br />requirements. (See Cal. Code Regs., tit. 22, § 66162.l E1 et seq.) <br />17. It is unlawful for any person to transport hazardous waste's unless the person holds <br />a valid registration issued by the DISC, and it is unlawful for any person to transfer custody of a <br />hazardous waste to a transporter who does not hold a valid registration. (Health &- Sal Cade, <br />?5163, .s.ubd. <br />18_ Chapter 6.7 of Division. 20 of the Health and Safety Code regulates the <br />underground storage of hazardous substances in the State of California. It establishes <br />requirements to "ensure that newly constructed underground storage tanks meet appropriate <br />standards and that existing tanks be properly maintained, inspected, tested, and upgraded. so that <br />the health, property, and resources- of the people of the state will be protected." (Health & Saf <br />Cade, § 25280, subd. (b).) <br />7 <br />COMPLAINT FOR PERMANENT INJUNCTION, CIVIL PENALTIES AND OTHER EQU[TABLE RCLIEI~ <br />