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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 />FIRST CAUSE OF ACTION <br />VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br />(HAZARDOUS WASTE CONTROL ACT) <br />19. Paragraphs 1 through 18, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on such information and belief alleges that beginning at an <br />exact date that is unknown to Plaintiff, but within five (5) years prior to the filing of this <br />Complaint (CCP §338.1), Defendants engaged in acts in violation of Health and Safety Code <br />§25100 et seq., including by not limited to the following: <br />a. Failed to maintain and operate facility to minimize the possibility of a fire, <br />explosion, or any unplanned sudden or non -sudden release of hazardous waste, in violation of <br />California Code of Regulations, title 22 section 66265.31; <br />b. Failed to label or mark containers used for onsite accumulation of hazardous <br />waste, in violation of California Code of Regulations, title 22 section 66262.34(f); <br />c. Failed to keep hazardous waste containers closed except when adding or <br />removing 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 <br />filters, 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 <br />violation 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 <br />received, 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 />5 <br />VERIFIED COMPLAINT <br />