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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 />g. Failed to properly label oil filters containing gasoline/diesel-commingled filters as <br />"used oil and gasoline filters", in violation of Health and Safety Code Section 25250.22(b)(1); <br />h. Failed to accumulate and store used oil and or used gasoline filters , in a closed and <br />II properly labeled container specifying the date of accumulation in violation of California Code of <br />11 Regulations, title 22 section 66266.130(c). <br />i. Failed to retain copies of bills of lading for the disposal of used oil and or used <br />gasoline filters for at least three years from the date of acceptance by the initial transporter, in <br />violation of California Code of Regulations, title 22 section 66266.130(c); <br />j. Stored hazardous waste onsite for more than 180 days, in violation of California <br />I Code of Regulations, title 22 section 66262.34(d); <br />k. Failed to maintain modified emergency coordinator information, in violation of <br />California Code of Regulations, title 22 section 66262.34(4)(2); <br />1. Failed to keep records for the previous three (3) years for each shipment of <br />I universal waste in violation of California Code of Regulations, title 22 section 66273.19; <br />SECOND CAUSE OF ACTION <br />VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br />(UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br />23. Paragraphs 1 through 21, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on 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 (CCP <br />§338.1), Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., <br />including but not limited to the following: <br />a. Failed to submit a statement identifying the current Designated Operator, in <br />violation of California Code of Regulations, title 23 section 2715(a); <br />b. Failed to maintain evidence of financial responsibility, in violation of Health and <br />Safety Code section 25292.2(a); <br />c. Failed to perform annual certification of monitoring equipment, in violation of <br />5 <br />