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1 Wastes and hazardous materials possessed, stored, and handled by <br /> 2 the defendants including, but not limited to, plating containing <br /> 3 acid, lead and copper, referred to herein meet the Department' s <br /> 4 definition of hazardous waste as defined in said regulations. <br /> 5 11 . The defendants, beginning at a date unknown to Plaintiff , <br /> 6 but within one year from the date of filing of this complaint, <br /> 7 and continuing through this date have operated R.V. Circuits in <br /> 8 violation of the laws of the State of California as set forth <br /> 9 more fully herein. <br /> 10 12. Defendants, and each of them, knowingly, intentionally, <br /> 11 or negligently violated the regulations contained in Title 22 of <br /> 12 the California Administrative Code and thus violated Section <br /> 13 25189 (b) of the California Health and Safety Code. Said viola- <br /> 14 tions include , but are not limited to, the following : <br /> 15 a ) Violating § 66471 : Failure to make a hazardous waste <br /> 16 determination pursuant to Article 9 or 11 of the California <br /> 17 Administrative Code. <br /> 18 b) violating § 66508 : Failure to label drums storing <br /> 19 hazardous wastes, and failure to comply with Preparedness and <br /> 20 Prevention, Contingency Plan, Emergency Procedures, and Personnel <br /> 21 Training regulations. <br /> 22 c ) Violating § 66493 : Failure to submit a Biennial report <br /> 23 of waste generation to the California Department of Health <br /> 24 Services . <br /> 25 d ) Violating § 67121 : Failure to provide spill control or <br /> 26 decontamination equipment. <br /> 27 e ) Violating § 67105 : Lack of training program for <br /> 28 employees. <br /> 4. <br />