Laserfiche WebLink
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 />b. Failed to label or mark containers used for onsite accumulation of hazardous waste, <br />in violation of California Code of Regulations, title 22 section 66262.34(0; <br />c. Failed to keep hazardous waste containers closed except when adding or removing <br />waste, in violation of California Code of Regulations, title 22 section 66265.173(a); <br />d. Failed to comply with the requirements of managing and recycling used oil filters, <br />in violation California Code of Regulations, title 22 section 66266.130; <br />e. Failed to maintain all communication or alarm systems, spill control, or <br />decontamination equipment, in violation of California Code of Regulations, title 22 section <br />166265.33; <br />f. Stored hazardous waste on site greater than 180 days, in violation of California <br />Code of Regulations, title 22 section 66262.34(d); <br />g. Failed to maintain signed copy of each manifest for at least three years, in violation <br />of California Code of Regulations, title 22 section 66262.40(a); <br />h. Failed to determine status of hazardous waste when manifest copy is not received, <br />in violation of California Code of Regulations, title 22 section 66262.42(a); <br />i. Failed to submit an Exception Report, in violation of California Code of <br />Regulations, title 22 section 66262.42(b); and <br />j. Failed to retain for at least three years, a copy of manifest or bill of lading which <br />identities shipping of spent lead -acid storage batteries, in violation of California Code of <br />Regulations, title 22 section 66266.81(a)(4)(13). <br />SECOND CAUSE OF ACTION <br />VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br />(UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br />8. Paragraphs 1 through 7, above are incorporated herein by reference. Plaintiff is informed <br />and believes and based on such information and belief alleges that beginning at an exact date that is <br />unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint (CCP §338.1), <br />Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., including <br />but not limited to the following: <br />-3- <br />FIRST AMENDED VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />