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