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I sheet, before the transport of hazardous waste off-site for transfer, treatment, 2 storage or disposal at the Facilities, in violation of California Code of Regulations, 3 title 22, section 66262.20; 4 nn. Failed to submit a legible copy of each hazardous waste manifest to DTSC within 5 thirty (30) days of each shipment at the Facilities of hazardous waste off-site or 6 into California, in violation of California Code of Regulations, title 22, section 7 66262.23, subdivision (a)(4); 8 oo. Failed to accumulate hazardous waste in a container or tank at the Facilities, in 9 violation of California Code of Regulations, title 22, section 66262.34, subdivision 10 (d)(2) and Title 40 of the Code of Federal Regulations, section 262.16; 11 pp. Failed to equip the Facilities with an internal communications or alarm system, a 12 device such as a telephone or hand-held two-way radio, portable fire 13 extinguishers, fire control equipment, spill control equipment, decontamination 14 equipment, and water at adequate volume and pressure, in violation of California 15 Code of Regulations, title 22, section 66262.34, subdivision (d)(2) and Title 40 of 16 the Code of Federal Regulations, section 265.32; and 17 qq. Failed to take all reasonable steps at the Facilities, to dispose, or arrange for the 18 disposal, of customer records within its custody or control containing personal 19 information, in violation of Civil Code section 1798.81 20 33. Defendant's noncompliance with the above statutes and regulations threatened, and 21 continues to threaten, public health, public safety, and the environment. The People's stated claims 22 against Defendant in this Complaint do not include claims for performance of cleanup, corrective 23 action, or response action for any actual past or fiiture releases, spills, or disposals of hazardous 24 waste or hazardous substances that were. caused or contributed to by the Defendant at or from the 25 Facilities. 26 1 FIRST CAUSE: Or ACTION 27 (Disposal of Hazardous Waste at a Point Not Authorized) (Health & Saf. Code, §§ 25189, 25189.2) 28 34. The People reallege all previous paragraphs. -13- COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF