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7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />PNA for numerous violations of the HWCL and its implementing regulations. PNA's violations <br />2 were spread across much of the Facility site, in multiple buildings and exterior locations. <br />3 SPECIFIC ALLEGATIONS <br />4 FIRST CAUSE OF ACTION <br />(Unpermitted and Unauthorized Storage of Hazardous Waste) <br />g (Cal. Code Regs., tit 22, § 66262.34, subd. (a)) <br />25. Paragraphs 1 through 24 are realleged as if fully set forth herein. <br />26. California Code of Regulations, Title 22, section 66262.34, subdivision (a), limits the <br />time a hazardous waste generator may accumulate hazardous waste on-site without a permit or <br />grant of interim status from the Department to 90 days or less. <br />27. Since on or before August 24, 2010 and through at least December 14, 2010, <br />Defendants violated California Code of Regulations, Title 22, section 66262.34, subdivision (a) <br />by storing - in the bath basement area of the Lathrop Facility's maintenance shop - a 55-gallon <br />drum containing hazardous waste, such as waste oil and absorbents, for more than 90 days. The <br />drum's label bore an origination date of May 25, 2010. <br />28. Since on or before September 18, 2009 and through at least December 14, 2010, <br />Defendants violated Califomia Code of Regulations, Title 22, section 66262.34, subdivision (a), <br />by storing - in a building know as the "butler" building - a 55-gallon drum of hazardous waste <br />containing non-empty aerosol cans and glass primer (Toluene and Methanol) for more than 90 <br />days. The drum's label bore an origination date of June 20, 2009. <br />29. Based on the above, the Department is entitled to injunctive relief against Defendants <br />under Health and Safetj' Code section 25181 and civil penalties under Health and Safety Code <br />section 25189, subdivision (b) or section 25189.2, subdivision (b), for each day during which <br />each violation of California Code of Regulations, Title 22, section 66262.34, subdivision (a) <br />occurred or continued. <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 />COMPLAINT FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF