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water, in violation of Health and Safety Code section 25291(e); <br />Failed to implement a monitoring program approved by the local agency and <br />specified in the underground storage tank operating permit, in violation of California Code of <br />Regulations, title 23 section 2632(b); and <br />Failed to maintain a copy of the monthly inspection record and all attachments for <br />the previous twelve (12) months, in violation of California Code of Regulations, title 23 section <br />2715(e). <br />SECOND CAUSE OF ACTION <br />VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br />(HAZARDOUS WASTE CONTROL ACT) <br />9. Plaintiff is informed and believes and based on such information and belief alleges that <br />beginning at an exact date that is unknown to Plaintiff, but within five (5) years prior to the filing of <br />this Complaint (CCP §338.1), Defendants engaged in acts in violation of Health and Safety Code <br />§25100 et seq., including by not limited to the following: <br />Failed to retain a copies of consolidated manifests for at least three (3) years, in <br />violation of Health and Safety Code section 25160.2(b)(3); <br />Treated, stored, disposed of, transported or offered to transport hazardous waste <br />without having an Identification Number, in violation of California Code of Regulations, title 22 <br />section 66262.12(a); <br />Stored hazardous waste onsite longer than one hundred eighty (180) days, in <br />violation of California Code of Regulations, title 22 section 66262.34(d); <br />Failed to label or mark containers used for onsite accumulation of hazardous waste, <br />in violation of California Code of Regulations, title 22 section 66262.34(f); <br />Failed to retain copies of signed manifest for at least three (3) years from the date <br />the waste was accepted by the initial transporter, in violation of California Code of Regulations, title <br />22 section 66262.40(a); <br />Failed to label universal waste to identify type of universal waste, in violation of <br />California Code of Regulations, title 22 section 66273.34(f); <br />'Failed to retain each record of each shipment of universal waste received at the <br />- 4 - <br />\TER I H IA) COMPI A INT FOR TNIT INCTTON_ CIVIT, PENALTIES ANT) OTTTER RF.LIEF <br />I <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