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I • • <br />1 <br />2 <br />3 <br />41 <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 />g. Failed to manage universal waste batteries in a way that prevents releases of any <br />universal waste or component of a universal waste to the environment, in violation of California Code <br />of Regulations, title 22 section 66273.13(x); <br />h. Failed to label or mark the universal waste to identify the type of universal waste, in <br />violation of California Code of Regulations, title 22 section 66273.14; <br />i. Accumulated universal waste for longer than one (1) year from the date the <br />universal waste is generated, or received from another handler, in violation of California Code of <br />Regulations, title 22 section 66273.15(a); <br />j. Failed to train all employees who handle or have responsibility for managing <br />universal waste, in violation of California Code of Regulations, title 22 section 66273.16; <br />k. 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 />1. Failed to maintain modified emergency coordinator information, in violation of <br />• . • • 11111 •• • <br />waste handler's facility to another facility, in violation of California Code of Regulations, title 22 <br />section 66273.39(c); <br />n. Failed to retain each record of each shipment of universal waste sent from the <br />universal waste handler's facility to another facility for at least three (3) years from the date of <br />departure of the corresponding shipment of universal waste, in violation of California Code of <br />Regulations, title 22 section 66273.39(d)(2). <br />61 1 )XV.11110 WU 1 <br />1 1 III I 1 1 I <br />11. Paragraphs 1 through 10, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on such information and belief alleges that beginning at an exact <br />date that is unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint (CCP <br />§338.1), Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seg, <br />2 <br />VERIFIED COMPLAINT <br />