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