Laserfiche WebLink
1 24. Plaintiff is informed and believes, and thereupon alleges, that at all times relevant to <br />2 this Complaint each of the Covered Facilities generated hazardous waste during every ninety (90) <br />3 day period. <br />4 25. -Examples of acts and/or Omissions conirnitted by Defendants which constitute <br />5 violations of California environmental laws and regulations are listed in the subparagraphs below. <br />6 These instances of violations- of California law are not an exhaustive. list of violations but are <br />7 alleged herein by way of examples of past, ongoing and persistent violations: <br />8 a. On June 26, 2009, ,Defendants, at a Covered Facility in Alameda County, <br />9 disposed mercury -containing light bulbs, batteries, and ignitable aerosol wastes into a trash <br />10 compactor for transportation by a garbage hauler not registered to transport hazardous waste, and <br />11 bound for a point not authorized to receive hazardous waste or universal waste. <br />12 b. On June 17, 2009, Defendants, at a Covered Facility in Alameda County, <br />13 disposed photo processing waste and ignitable aerosol waste into a trash compactor for <br />14 transportation by a garbage hauler not registered to transport hazardous waste, *and bound for a <br />15 1 point not authorized to receive hazardous waste or universal waste. <br />16 C. On May 27, 2009, Defendants, at a Covered Facility in Monterey County, <br />17 disposed ignitable aerosol wastes, regulated electronic waste ("e -waste" mercury -containing <br />18 light bulbs, and other hazardous waste into a trash compactor for transportation by a garbage <br />19 hauler not registered to; transport hazardous waste, and bound for a point not authorized to receive <br />20 hazardous waste, e -waste or other universal waste, <br />21 d. 'On May 21, 2009, Defendants, at a Covered Facility in Alameda County, <br />22 disposed photo processing waste, ignitable aerosol wastes, canisters of propane, e -waste, <br />23 mercury -containing light bulbs, corrosive liquid waste, medical waste, and other hazardous. waste <br />24 into a trash compactor for transportation by a garbage hauler not registered to transport hazardous <br />25 waste, and bound for a point not authorized, to receive hazardous waste, e -waste or other universal <br />26 waste. <br />27 e. On May 14, 2009, Defendants, at a Covered Facility in Alameda County, <br />28 disposed ignitable aerosol waste, e -waste, a mercury -containing light bulb and other universal <br />. 7 <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief <br />I Case No. RG09457686 <br />