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1 31. Based on the above, the People request injunctive relief against Defendant under <br />2 Health and Safety Code section 25181, and civil penalties under Health and Safety Code section <br />3 25189 or 25189.2, as described in the People's prayer for relief. <br />4 SECOND CAUSE OF ACTION <br />(Unauthorized Transportation of Hazardous Waste) <br />5 (Health & Saf. Code, §§ 25163, 25189, 25189.2; Cal. Code Regs., Title 22, § 66263.23) <br />6 <br />7 32. Plaintiff realleges paragraphs 1 through 31, inclusive. <br />8 33. Chapter 6.5 of the Health and Safety Code prohibits the unauthorized <br />9 transportation of hazardous waste. Section 25163 prohibits the transportation of hazardous waste <br />10 without a valid registration from the DTSC. California Code of Regulations, title 22, section <br />11 66263.23(b) prohibits the transportation of hazardous waste to a location not permitted or <br />12 otherwise authorized by the DTSC to receive the waste. <br />13 34. Defendant has engaged in the transportation of hazardous waste without a valid <br />14 registration from the DTSC, from Defendant's Facilities to unauthorized locations, in violation of <br />15 Health and Safety Code section 25163 and California Code of Regulations, title 22, section <br />16 66263.23. <br />17 35. Each act of unauthorized transportation that occurred within five (5) years before <br />18 the discovery of the facts constituting grounds for commencing the action on these claims, in <br />19 addition to the Tolling Period set forth in paragraph 13 herein, and each day the waste was <br />20 allowed to remain at such point without the immediate filing of a report of the deposit with the <br />21 DTSC, subjects Defendant to a separate and additional civil penalty under Health and Safety <br />22 Code section 25189, or alternatively under section 25189.2. <br />23 36. Based on the above, the People request injunctive relief against Defendant under <br />24 Health and Safety Code section 25181, and civil penalties under Health and Safety Code section <br />25 25189 or 25189.2, as described in the People's prayer for relief. <br />26 THIRD CAUSE OF ACTION <br />(Violation of Hazardous Waste Handling and Storage Requirements) <br />27 (Health & Safety Code Chapter 6.5 and Implementing Regulations) <br />28 37. Plaintiff realleges paragraphs 1 through 36, inclusive. <br />11 <br />Complaint For Permanent Injunction, Civil Penalties And Other Equitable Relief <br />