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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 />d) Violation of §25246 in that defendants failed to submit <br />to the Department a hazardous waste facility closure and main <br />tenance report estimating cost of closure and subsequent main- <br />tenance. <br />THIRD CAUSE OF ACTION <br />(AIR POLLUTION) <br />ACTIONS FOR CIVIL PENALTIES FOR LOADING ORGANIC <br />LIQUIDS IN VIOLATION OF SECTION 412 OF THE SAN <br />.TnAnTTTTT /`nrTATTV ATO nnTTrlmTnWl nT1m111m T <br />24. The People reallege and incorporate by reference <br />paragraphs 1 through 23. <br />25. At all times material to this action, defendants, and <br />each of them, operated their facility in violation of the San <br />Joaquin County Air Pollution Control District Rules and <br />Regulations as described in Exhibit 2. Exhibit 2 is incorporated <br />herein by reference as though fully set forth herein at length. <br />26. Section 412 of the San Joaquin County Air Pollution <br />Control District Rules and Regulations is attached as Appendix 1 <br />for the court's convenience. <br />27. Defendants, and each of them, violated the provisions of <br />5412 of the San Joaquin County Air Pollution Control District <br />Rules and Regulations. Said acts include but are not limited to <br />the following violations of said rules: <br />a) Failure to maintain and operate the loading device and <br />the vapor collection systc - ;uch a manner as to prevent liquid <br />leaks and be vapor tight on October 23, 1985 as set forth in <br />Exhibit 2 at #21; <br />b) Failure to maintain and operate the loading device and <br />the vapor collection system in such a manner as to prevent liquid <br />12. <br />