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1 f ) Violating § 67140 : Lack of Contingency Plan. <br /> 2 g ) Violating § 67141 : Failure to keep a Contingency Plan <br /> 3 at the facility at all times, and failure to distribute this plan <br /> 4 to local emergency response agencies . <br /> 5 h ) Violating § 67144 : Failure to assign an emergency <br /> 6 coordinator. <br /> 7 i ) Violating § 66371 : Failure to possess a Hazardous Waste <br /> 8 Facility Permit. <br /> 9 13 . Defendant, and each of them, knowingly, intentionally, <br /> I <br /> 10 or negligently violated the provisions of Section 25189 (b) , (c) <br /> 11 and (d) of the California Health and Safety Code by violating the <br /> 12 Hazardous Waste Control Act. Said violations include, but are <br /> 13 not limited to, the following: <br /> 14 a ) Violating § 25154 : Operating a facility, to-wit: R.V. <br /> 15 Circuits which generates hazardous and/or extremely hazardous <br /> 16 waste in violation of applicable laws and regulations . <br /> 17 SECOND CAUSE OF ACTION <br /> 18 VIOLATION OF BUSINESS & PROFESSIONS <br /> 19 CODE SECTION 17200 ET SEQ. <br /> 20 (Unfair/Unlawful Business Practices ) <br /> 21 14 . Plaintiff realleges and incorporates by reference as <br /> 22 though set forth in full herein paragraphs 1 through 1�1, <br /> 23 inclusive. <br /> 24 15 . Plaintiff is informed and believes and therefore <br /> 25 alleges that , beginning on an unknown date, but at least within <br /> 26 the four years prior to the filing of this complaint, and con- <br /> 27 tinuing to the present, the defendants , and each of them, have <br /> 28 <br /> 5 . 14 �,/ <br />