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I Regulations, title 22 section 66265.173(x); <br /> 2 t. Failed to inspect areas used for container storage or transfer, at least weekly, in <br /> 3 violation of California Code of Regulations,title 22 section 66265.174; <br /> 4 U. Failed to mark and manage an emptied container or an inner liner from a <br /> 5 container larger than five (5) gallons, which previously held a hazardous material, including but not <br /> 6 limited to hazardous waste, in violation of California Code of Regulations, title 22 section <br /> 7 66261.7(f); <br /> 8 V. Accumulated hazardous waste onsite longer than ninety (90) days without a <br /> 9 permit or grant of interim status, in violation of California Code of Regulations, title 22 section <br /> 10 66262.34(a); and <br /> 11 W. Failed to completely label or mark each container or portable tank used for <br /> 12 onsite accumulation of hazardous waste, in violation of California Code of Regulations, title 22 <br /> 13 section 66262.34(f). <br /> 14 SECOND CAUSE OF ACTION <br /> 15 VIOLATION OF HEALTH AND SAFETY CODE SECTIONS 25500 ET SEQ. <br /> 16 (HAZARDOUS MATERIALS RELEASE RESPONSE PLANS AND INVENTORY) <br /> 17 9. Paragraphs 1 through 8, above are incorporated herein by reference. Plaintiff is <br /> 18 informed and believes and based upon such information and belief alleges that beginning at an exact <br /> 19 date that is unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint, <br /> 20 Defendant engaged in acts in violation of Health and Safety Code sections 25500 et seq., including <br /> 21 but not limited to the following: <br /> 22 a. Failed to establish and implement a business plan for emergency response to a <br /> 23 release or threatened release of hazardous material, in violation of Health and Safety Code section <br /> 24 25507(a); <br /> 25 b. Failed to electronically submit a hazardous materials business plan annually to <br /> 26 the statewide information management system, in violation of Health and Safety Code section <br /> 27 25508(a)(1)(A); <br /> 28 C. Failed to review and certify, on or before the annual due date, that the <br /> -5— <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />