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J <br /> 1 9 . Defendants, beginning at a date unknown to Plaintiff, <br /> 2 but within five years from the date of filing of this complaint <br /> 3 (CCP § 338 . 1) , and continuing through this date have operated in <br /> 4 violation of the laws of the State of California as set forth <br /> 5 more fully herein. <br /> 6 10. Defendants violated regulations contained in Title 22 <br /> 7 of the California Code of Regulations and thus violated Section <br /> 8 25189 (b) of the California Health and Safety Code. Said <br /> 9 violations include, but are not limited to, the following: <br /> 10 a. Violations of § 66472 : Treatment, storage and/or <br /> 11 disposal of hazardous waste without obtaining the required EPA <br /> 12 generator identification number; <br /> 13 b. Violations of § 66480: Shipping hazardous waste <br /> 14 off-site without Uniform Hazardous Waste manifests . <br /> 15 C. Violations of § 66471: Failure to make hazardous waste <br /> 16 determination for waste placed in dumpsters and put into <br /> 17 sanitary sewer system. <br /> 18 d. Violations of § 66480 : Failure to submit biennial <br /> 19 reports. <br /> 20 e. Violations of § 67105: Failure to adequate train <br /> 21 facility personnel in hazardous waste managment and failure to <br /> P2 maintain records of such training. <br /> 23 f. Violations of § 67141: Failure to have a contingency <br /> 24 plan. <br /> 25 g. Violations of § 67243 and § 66508 : Storage of <br /> 26 hazardous waste in open and unlabeled containers . <br /> 27 11. Defendants violated the provisions of Section 25189 (b) , <br /> 28 c) and/or (d) of the California Health and Safety Code by / <br /> 4 <br />