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1 Plaintiff, the People of the State of California ex rel. Deborah 0. Raphael, Director of the <br />2 Department of Toxic Substances Control ("the Department"), allege the following. <br />3 STATEMENT OF THE CASE <br />4 1. Defendant, Pilkington North America, Inc. ("PNA"), a Delaware Corporation, owns <br />5 and operates a hazardous waste facility at 500 East Louise Avenue, Lathrop, California ("Lathrop <br />6 Facility"). At the Lathrop Facility, during all times relevant herein, PNA and Does 1-20 <br />7 (collectively "Defendants") generated and continue to generate hazardous waste from the <br />8 manufacturing of float glass. Defendants also, as part of their operations at the Lathrop Facility, <br />9 stored and continue to store hazardous waste generated during the manufacture of float glass. In <br />10 addition. Defendants, generated and stored, and continue to generate and store, electronic and <br />11 universal waste at the Lathrop Facility. <br />12 2. While conducting their operations. Defendants violated numerous provisions of <br />13 California's Hazardous Waste Control Law, Health and Safety Code Sections 25100 et seq. (the <br />14 "H WCL") and its implementing regulations, including but not limited to unauthorized storage of <br />15 hazardous waste, including universal waste, unlawful disposal of hazardous waste, failure to <br />16 make a waste determination, failure to provide or document employee training in the handling of <br />17 hazardous waste, failure to complete, update or implement a hazardous waste contingency plan. <br />18 and failure to properly label hazardous waste, including universal waste. <br />19 3. Unless enjoined by order of this Court, Defendants may or will continue in the course <br />20 of conduct alleged herein. <br />21 4. The Department hereby seeks civil penalties from and injunctive relief against <br />22 Defendants for violations of the HWCL and its implementing regulations. <br />23 THE PARTIES <br />24 5. The Department is a public agency of the State of California organized and existing <br />25 j under and pursuant to Health and Safety Code section 58000 et seq. The Department is the state <br />26 agency that administers and enforces the HWCL. <br />27 <br />28 <br />6. Plaintiff Deborah 0. Raphael is the Director of the Department. <br />; 2 <br />COMPLAINT FOR CIV IL PENALTIES AND INJUNCTIVE RELIEF <br />1