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1 accumulation of hazardous waste, in violation of California Code of Regulations,title 22 section <br /> 2 66262.34(f); and <br /> 3 i. Failed to keep container holding hazardous waste closed during transfer and <br /> 4 storage, except when it is necessary to add or remove waste, in violation of California Code of <br /> 5 Regulations,title 22 section 66265.173(a). <br /> 6 SECOND CAUSE OF ACTION <br /> 7 VIOLATION OF HEALTH AND SAFETY CODE SECTIONS 25500 ET SEQ. <br /> 8 (HAZARDOUS MATERIALS RELEASE RESPONSE PLANS AND INVENTORY) <br /> 9 16. Paragraphs 1 through 15, above are incorporated herein by reference. Plaintiff is <br /> 10 informed and believes and based upon such information and belief alleges that beginning at an exact <br /> 11 date that is unknown to Plaintiff,but within five (5)years prior to the filing of this Complaint, <br /> 12 Defendant engaged in acts in violation of Health and Safety Code sections 25500 et seq., including <br /> 13 but not limited to the following: <br /> 14 a. Failed to complete and/or submit a site map, in violation of Health and Safety Code <br /> 15 section 25505(a)(2): <br /> 16 b. Failed to submit emergency response plans and procedures for a release or <br /> 17 threatened release of a hazardous material, in violation of Health and Safety Code section <br /> 18 25505(a)(3); <br /> 19 c. Failed to provide training for all new employees and/or annual refresher training <br /> 20 for all employees in safety procedures in the event of a release or threatened release of hazardous <br /> 21 material, which is documented and made available for a minimum of three (3)years, in violation of <br /> 22 Health and Safety Code section 25505(a)(4); <br /> 23 d. Failed to have emergency response plan and procedures,the inventory of <br /> 24 hazardous material and the site map readily available to personnel of the business or the unified <br /> 25 program agency, in violation of Health and Safety Code section 25505(c); <br /> 26 e. Failed to complete and/or submit a hazardous materials inventory for all reportable <br /> 27 materials on site, in violation of Health and Safety Code section 25506(a); <br /> 28 £ Failed to establish and implement a business plan for emergency response to a <br /> -5- <br /> < —. A, T n n T� rKTTY rnrnmTf-V.T nTT TTY DU7.T AT T'TRQ A NM(YPT-MT? RFT M-P <br />