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universal waste handler's facility for at least three (3) years from the date of receipt of the <br />corresponding shipment of universal waste, in violation of California Code of Regulations, title 22 <br />section 66273.39(d)(1); <br />Failed to contact the transporter and/or the owner or operator of the designated <br />facility to determine the status of hazardous waste within thirty-five (35) days of the date the waste <br />was accepted by the initial transporter without a copy of the manifest with the handwritten signature <br />of the owner or operator of the designated facility, in violation of California Code of Regulations, <br />title 22 section 66262.42(a); <br />Failed to submit an Exception Report to the Department within forty-five (45) days <br />of the date the waste was accepted by the initial transporter without a copy of the manifest with the <br />handwritten signature of the owner or operator of the designated facility, in violation of California <br />Code of Regulations, title 22 section 66262.42(b); <br />Failed to maintain and operate facility to minimize the possibility of a fire, <br />explosion, or any unplanned sudden of non-sudden release of hazardous waste, in violation of <br />California Code of Regulations, title 22 section 66265.31; <br />Failed to keep container holding hazardous waste closed during transfer and <br />storage, except when it is necessary to add or remove waste, in violation of California Code of <br />Regulations, title 22 section 66265.173(a); <br />1. Failed to retain, at generator's place of business for at least three (3) years, a legible <br />copy of each manifest or bill of lading which identifies spent lead-acid storage batteries shipped to a <br />person who stores or uses, reuses, recycles or reclaims the batteries or their components, in violation <br />of California Code of Regulations, title 22 section 66266.81(a)(4)(B); and <br />m. Failed to label containers as "drained used oil filters" and show initial date of <br />accumulation or receipt on each container of drained used oil filters, in violation of California Code <br />of Regulations, title 22 section 66266.130(c)(3). <br />THIRD CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />- 5 - <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />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