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I sheet,before the transport of hazardous waste off-site for transfer, treatment, <br /> 2 storage or disposal at the Facilities, in violation of California Code of Regulations, <br /> 3 title 22, section 66262.20; <br /> 4 nn. Failed to submit a legible copy of each hazardous waste manifest to DTSC within <br /> 5 thirty(30) days of each shipment at the Facilities of hazardous waste off-site or <br /> 6 into California, in violation of California Code of Regulations, title 22, section <br /> 7 66262.23, subdivision(a)(4); <br /> 8 oo. Failed to accumulate hazardous waste in a container or tank at the Facilities, in <br /> 9 violation of California Code of Regulations, title 22, section 66262.34, subdivision <br /> 10 (d)(2) and Title 40 of the Code of Federal Regulations, section 262.16; <br /> 11 pp. Failed to equip the Facilities with an internal communications or alarm system, a <br /> 12 device such as a telephone or hand-held two-way radio, portable fire <br /> 13 extinguishers, fire control equipment, spill control equipment, decontamination <br /> 14 equipment, and water at adequate volume and pressure, in violation of California <br /> 15 Code of Regulations, title 22, section 66262.34, subdivision (d)(2) and Title 40 of <br /> 16 the Code of Federal Regulations, section 265.32; and <br /> 17 qq. Failed to take all reasonable steps at the Facilities,to dispose, or arrange for the <br /> 18 disposal, of customer records within its custody or control containing personal <br /> 19 information, in violation of Civil Code section 1798.81 <br /> 20 33. Defendant's noncompliance with the above statutes and regulations threatened, and <br /> 21 continues to threaten, public health, public safety, and the environment. The People's stated claims <br /> 22 against Defendant in this Complaint do not include claims for performance of cleanup, corrective <br /> 23 action, or response action for any actual past or fiiture releases, spills, or disposals of hazardous <br /> 24 waste or hazardous substances that were. caused or contributed to by the Defendant at or from the <br /> 25 Facilities. <br /> 26 1 FIRST CAUSE: Or ACTION <br /> 27 (Disposal of Hazardous Waste at a Point Not Authorized) <br /> (Health & Saf. Code, §§ 25189, 25189.2) <br /> 28 34. The People reallege all previous paragraphs. <br /> - 13- <br /> COMPLAINT FOR INJUNCTIVE RELIEF,CIVIL PENALTIES,AND OTHER RELIEF <br />