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1 of said Defendants, and while acting within the course and scope of their duties. <br /> 2 FIRST CAUSE OF ACTION <br /> 3 VIOLATION OF HEALTH AND SAFETY CODE SECTION 251.00 ET SEQ. <br /> (HAZARDOUS WASTE CONTROL ACT) <br /> 4 <br /> 10. Paragraphs 1 through 9, above are incorporated herein by reference. Plaintiff is informed <br /> 5 <br /> and believes and based on such information and belief alleges that beginning at an exact date that is <br /> 6 <br /> unknown to Plaintiff, but within five(5)years prior to the filing of this Complaint(CCP §338.1), <br /> 7 <br /> Defendants engaged in acts in violation of Health and Safety Code §25100 et seq.,including by not <br /> 8 <br /> limited to the following: <br /> 9 <br /> a. Failed to maintain modified emergency coordinator information,in violation of <br /> 10 <br /> 11 California Code of Regulations,title 22 section 66262.34(d)(2); <br /> b. Failed to label or mark containers used for onsite accumulation of hazardous <br /> 12 <br /> 13 waste, in violation of California Code of Regulations,title 22 section 66262.34(f); <br /> 14 c. Failed to train facility personnel in hazardous waste management procedures <br /> 15 relevant to the positions in which they are employed, in violation of California Code of Regulations, <br /> 16 title 22 section 66265.16; <br /> 17 d. Failed to maintain and operate facility to minimize the possibility of a fire, <br /> 18 explosion,or any unplanned sudden or non-sudden release of hazardous waste, in violation of <br /> 19 California Code of Regulations,title 22 section 66265.31; <br /> 20 e. Failed to keep container holding hazardous waste closed during transfer and <br /> 21 storage,except when it is necessary to add or remove waste, in violation of California Code of <br /> 22 Regulations,title 22 section 66265.173(a); <br /> 23 SECOND CAUSE OF ACTION <br /> VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br /> 24 (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br /> 25 11. Paragraphs 1 through 10, above are incorporated herein by reference. Plaintiff is <br /> 26 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 27 date that is unknown to Plaintiff, but within five(5)years prior to the filing of this Complaint(CCP <br /> 28 3 <br /> VERIFIED COMPLAINT <br />