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1 <br />2 <br />3 <br />4 <br />5 <br />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 />q) Violations of §66472(b) in that defendants disposed of <br />hazardous waste without having received an Environmental <br />Protection Agency identification number; the exact number of <br />illegal disposals is unknown to Plaintiff at thr time of filing <br />but is known to be no less than 10; each dispoe;: constitutes a <br />separate and distinct violation; <br />23. Defendants, and each of them, knowingly, intentionally <br />or negligently violated the provisions of §25189(b` the <br />California Health and Safety Code; said acts inclua ut are not <br />limited to the following violations of Chapter 6.5, Division 20 <br />of the Health and Safety Code: <br />a) Violations of §25154 in that defendants have handled, <br />stored, or disposed of hazardous waste in a manner not provided <br />for in Chapter 6.5; <br />b) Violations of §25174 in that defendant has failed to pay <br />the required fee to the State Board of Equalization for disposal <br />of the wastes; the exact number of illegal disposals is unknown <br />to Plaintiff at the time of filing but is known to be no less <br />than 10; each disposal constitutes a separate and distinct vi-,'. - <br />tion; <br />C) Violations of §25189.5 in that defendants disposed of <br />hazardous waste at a facility which does not have a permit or at <br />a point (the lagoon) which is not authorized according to Chapter <br />6.5; said illegal disposal has occurred on a periodic basis <br />during the three years prior to the date of filing of this <br />complaint; each day during the three years constitutes a separate <br />and distinct violation; <br />11. <br />