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1 g. Failed to properly label oil filters containing gasoline/diesel-commingled filters as <br /> 2 "used oil and gasoline filters", in violation of Health and Safety Code Section 25250.22(b)(1); <br /> 3 h. Failed to accumulate and store used oil and or used gasoline filters ,in a closed and <br /> 4 properly labeled container specifying the date of accumulation in violation of California Code of <br /> 5 Regulations,title 22 section 66266.130(c). <br /> 6 i. Failed to retain copies of bills of lading for the disposal of used oil and or used <br /> 7 gasoline filters for at least three years from the date of acceptance by the initial transporter, in <br /> 8 violation of California Code of Regulations, title 22 section 66266.130(c); <br /> 9 j. Stored hazardous waste onsite for more than 180 days, in violation of California <br /> 10 Code of Regulations, title 22 section 66262.34(d); <br /> 11 k. Failed to maintain modified emergency coordinator information, in violation of <br /> 12 California Code of Regulations,title 22 section 66262.34(4)(2); <br /> 13 1. Failed to keep records for the previous three(3)years for each shipment of <br /> 14 universal waste in violation of California Code of Regulations, title 22 section 66273.19; <br /> 15 <br /> 16 SECOND CAUSE OF ACTION <br /> 17 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br /> 18 (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br /> 19 23. Paragraphs 1 through 21, above are incorporated herein by reference. Plaintiff is <br /> 20 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 21 date that is unknown to Plaintiff,but within five(5)years prior to the filing of this Complaint(CCP <br /> 22 §338.1), Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., <br /> 23 including but not limited to the following: <br /> 24 a. Failed to submit a statement identifying the current Designated Operator, in <br /> 25 violation of California Code of Regulations, title 23 section 2715(a); <br /> 26 b. Failed to maintain evidence of financial responsibility, in violation of Health and <br /> 27 Safety Code section 25292.2(a); <br /> 28 c. Failed to perform annual certification of monitoring equipment, in violation of <br /> 5 <br />