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1 d ) Violation of 525246 in that defendants failed to submit <br /> 2 to the Department a hazardous waste facility closure and main- <br /> 3 tenance report estimating cost of closure and subsequent- main-._ <br /> 4 tenance. <br /> 5 THIRD CAUSE OF ACTION <br /> 6 (AIR POLLUTION) <br /> 7 ACTIONS FOR CIVIL PENALTIES FOR LOADING ORGANIC <br /> LIQUIDS IN VIOLATION OF SECTION 412 OF THE SAN <br /> 8 JOAQUIN COUNTY AIR POLLUTION CONTROL DISTRICT RULES. <br /> 9 <br /> 24 . The People reallege and incorporate by reference <br /> 10 <br /> paragraphs 1 through 23 . <br /> 11 25 . At all times material to this action, defendants , and <br /> 12 each of them, operated their facility in violation of the San <br /> 13 Joaquin County Air Pollution Control District Rules and <br /> 14 Regulations as described in Exhibit 2 . Exhibit 2 is incorporated <br /> 15 herein by reference as though fully set forth herein at length . <br /> 16 26 . Section 412 of the San Joaquin County Air Pollution <br /> 17 Control District Rules and Regulations is attached as Appendix 1 <br /> 18 for the court ' s convenience. <br /> 19 27 . Defendants, and each of them violated .the <br /> provisions of <br /> 20 <br /> §412 of the San Joaquin County Air Pollution Control District- . <br /> 21 Rules and Regulations . Said acts include but are not limited to <br /> 22 the following violations of said rules: <br /> 23 a ) Failure to maintain and operate the loading device and <br /> 24 <br /> the vapor collection syst: ;uch a manner as to prevent liquid <br /> 25 leaks and be vapor tight on October 23, 1985 as set forth in <br /> 26 Exhibit 2 at #21; <br /> 27 b) Failure to maintain and operate the loading device and <br /> 28 the vapor collection system in such a manner as to prevent liquid <br /> 12 . <br />