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0 <br />1 22. Defendants, and each of them, knowingly, intentionally, <br />2 or negligently violated the provisions of Section 25189(b) of the <br />3 California Health and Safety Code. Said acts include but are not <br />4 limited to the following violations of Title 22 of the Cal. <br />5 Admin. Code: <br />6 a) Violations of 566508 in that defendants accumulated <br />7 hazardous waste onsite for greater than 90 days without a permit <br />8 and without having been granted an extension; in that the lagoon <br />9 is on property contiguous to defendant's property; and in addi- <br />10 tion, waste was accumulated for more than 90 days in defendants' <br />11 storage tanks; each day constitutes a separate and distinct <br />12 violation; <br />13 b) Violation of §67100 in that defendants failed to apply <br />14 to the Department for an Environmental Protection Agency <br />15 identification number; <br />16 c) Violation of §67102 in that defendants failed to obtain <br />17 a detailed chemical and physical analysis of a representative <br />18 sample of the hazardous waste before the storage or disposal of <br />19 hazardous waste; <br />20 d) Violation of §67103 in that defendants failed to secure <br />21 the active portion of the facility (the lagoon) against <br />22 unauthorized entry; <br />23 e) Violation of §67105 in that defendants' facility person - <br />24 nel who handle hazardous waste have not completed a program of <br />25 classroom instruction or on-the-job training to ensure the faci- <br />26 lity's compliance with the requirements of the Act; <br />27 f) Violations of §67106 in that defendants failed to take <br />28 <br />7. <br />