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1 <br />2 <br />3 <br />4 <br />5 <br />i 6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />including but not limited to oil and water, are on the List of <br />Chemical Names and Common Names (Title 22 Cal. Admin. Code <br />§66680) and meet the Department's definition of "hazardous waste" <br />as defined ;n said regulations. The oil .and water that spills <br />and collec� n the bermed area at the southeast section of <br />defendant's site at 2941 Navy Drive, Stockton, in proximity to <br />tanks 25, 26, and 27 is hazardous waste. <br />15. Defe nts, and each of them, intentionally violated <br />the provisions- §25189(c) of the California Health and Safety <br />Code. Said acts include but are not limited to the following: <br />a) Disposal of a hazardous waste at an unauthorized point <br />by pumping the oil and water waste from the bermed collection <br />area into the unlined pond/lagoon (hereinafter lagoon) imme- <br />diately adjacent to and east of defendant's site. Said illegal <br />disposal has occurred on a periodic basis during the three years <br />prior to the date of filing of this complaint; each day during <br />the three years constitutes a separate and distinct violation. <br />SECOND CAUSE OF ACTION <br />(HAZARPO'TS WASTE CONTROL ACT) <br />ACTIONS FOR CIVIL PENALTIES FOR VIOLATING PROVISIONS <br />OF CHAPTER 6.5, DIVISION 20 OF THE HEALTH AND SAFETY <br />CODE (25189(b)) BY VIOLATING PROVISIONS OF THE <br />REGULATIONS PROMULGATED PURSUANT TO THE CHAPTER. <br />16. The People reallege and incorporate by reference <br />paragraphs 1 through 15. <br />17. Section 25189(b) of the Health and Safety Code provides <br />as follows: <br />(A]ny person who intentionally or negligently viola- <br />tes any provision of this chapter or any permit, <br />rule, regulation, standard, or requirement issued or <br />promulgated pursuant to this chapter, shall be <br />5. <br />