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l <br /> waste, to wit, arsenic, chromium and hexavalent chromium <br /> compounds, and copper compounds at a point or points which <br /> were not authorized for the disposal of hazardous waste <br /> pursuant to the California Hazardous Waste Control Law. <br /> EVIDENCE: Witnesses 1 and 2 will testify that Marley <br /> discharged hazardous wastes into the ground in and around <br /> the retort pit and into an unlined pond. Both areas are <br /> unpermitted by the Department pursuant to the Hazardous <br /> Waste Control Law. Witness 1 observed this practice during <br /> a generator inspection on January 30, 1984. Photographs <br /> were taken. Witness 2 observed this practice during an <br /> inspection on September 22, 1981. (See footnote) <br /> COUNT 2: Marley Cooling Tower Company violated Section 25191 (d) (2) <br /> of the Health and Safety Code in that they knowingly stored <br /> and treated hazardous waste at a facility which did not have <br /> a permit for said storage and treatment issued by the <br /> California Department of Health Services and which was not <br /> authorized for said storage and treatment. <br /> EVIDENCE: Witnesses 1 and 2 will testify that an unlined <br /> pond containing hazardous wastes is located on the site for <br /> storage and treatment of these wastes. Witness 1 will <br /> further testify that no Department record exists concerning <br /> permits, applications, or any other documents which are <br /> necessarily filed before a hazardous waste facility permit <br /> is issued. (See footnote) <br /> V. Civil Violations <br /> COUNT 1: Marley Cooling Tower Company violated Section 25189 (b) (c) <br /> and (d) of the Health and Safety Code in that they inten- <br /> tionally and negligently disposed or caused the disposal of <br /> hazardous and extremely hazardous waste at a point which is <br /> not authorized. <br /> EVIDENCE: See evidence under Criminal Count 1. <br /> VI. Other Violations <br /> COUNT 1: Marley Cooling Tower Company violated Section 25159.6 <br /> of the Health and Safety Code in that they did not comply <br /> with regulations adopted by the United States Environmental <br /> Protection Agency pursuant to Public Law 84-580. <br /> Witness 3 will testify to the contents of Exhibit 1C and Exhibit 4. <br /> -2- <br />