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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 />Regulations, title 22, section 66265.53; <br />gg. Failed to properly manage, mark, and store universal waste at the Facilities, in <br />violation of Health and Safety Code section 25201.16 and California Code of <br />Regulations, title 22, sections 66273.33 — 66273.36; <br />hh. Failed to submit a written response within. thirty-five(35) days of receiving an <br />official notice of inspection citing a violation of hazardous waste law or regulation <br />at the Facilities, in violation of Health and Safety Code sections 25185, <br />subdivision (c)(3) and 25187.8, subdivision (b); <br />ii. Failed to notify the property owner in writing, for Facilities located on leased or <br />rented real property, that the Facility is subject to and in compliance with <br />Hazardous Materials Business Plan requirements, in violation of Health and <br />Safety Code section 25505.1; <br />J. Failed to maintain and operate the Facilities in a manner to minimize the <br />possibility of a fire, explosion, or any unplanned release of hazardous waste to air, <br />soil, or surface water that could threaten human health or the environment, in <br />violation of California Code of Regulations, title 22, section 66265.31 and Title 40 <br />of Code of Federal Regulations, section 265.31; <br />kk. Failed to submit an Exception Report to DTSC after the generator did not receive <br />a copy of the manifest with the handwritten signature of the owner or operator of <br />the designated facility which was to receive the hazardous waste within forty-five <br />(45) days of the date the waste was accepted by the initial transporter at the <br />Facilities, in violation of California Code of Regulations, title 22, section <br />66262.42; <br />11. Failed to properly manage, mark and store containers of drained used oil or uel <br />filters at the Facilities, in violation of Health and Safety Code section 25250.22 <br />and California Cade of Regulations, title 22, section 66266.130, subdivision <br />(c)(3); <br />mm. Failed to prepare a hazardous waste manifest and, if necessary, a continuation <br />-12- <br />COMPLAINT FOR INJUNCTIVE RELIEF, CNIL PENALTIES, AND OTHER RELIEF <br />