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1 <br /> 1 . <br /> I violation of California Code of Regulations, title 23 section 2638(a); <br /> 2 r. Failed to submit a completed Monitoring System Certification form to the local <br /> 3 agency within thirty (30)days after completion of the inspection, in violation of California Code of <br /> 4 Regulations,title 23 section 2638(d); and <br /> 5 s. railed to annually perform automatic line leak detector tightness test, in violation <br /> 6 of Health and Safety Code section 25291(#). <br /> 7 <br /> SECOND CAUSE OF ACTION <br /> 8 <br /> VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> 9 (HAZARDOUS WASTE CONTROL ACT) <br /> 10 12. Paragraphs 1 through 11,above are incorporated herein by reference. Plaintiff is <br /> 11 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 12 date that is unknown to Plaintiff,but within five(5)years prior to the filing of this Complaint(CCP <br /> 13 §338.1),Defendants engaged in acts in violation of Health and Safety Code §25100 et sect., including; <br /> 14 by not limited to the following: <br /> 15 a. Treated, stored,disposed of,transported or offered to transport hazardous waste <br /> 1.6 without having an Identification Number, in violation of California Code of Regulations,title 22 <br /> 17 section 66262.12(a); <br /> 18 b. Failed to completely label or mark each container or portable tank used for onsite <br /> 19 accumulation of hazardous waste, in violation of California Code of Regulations,title 22 section <br /> 20 66262.34(f); <br /> 21 c. Failed to label containers as "drained used oil filters" and show initial date of <br /> 22 accumulation or receipt on each container of drained used oil filters, in violation of California.Code <br /> 23 of Regulations,title 22 section 66266.130(c)(3); <br /> 24 d. Failed to keep container holding hazardous waste closed during transfer and <br /> 25 storage, except when it is necessary to add or remove waste, in violation of California Code of <br /> 26 Regulations,title 22 section 66265.173(a); <br /> 27 e. Stored hazardous waste onsite longer than one hundred eighty(180)days,in <br /> 28 violation of California Code of Regulations,title 22 section 66262.34(4); <br /> -5 - <br /> VER.IFIED COMPLAIN"r FOR INJUNC T[ON,CIVIL PENALTIES,AND OT14ER RELIEF <br />