SITE INFORMATION AND CORRESPONDENCE

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1 liable for a civil penalty not to exceed twenty-five thousand dollars ( $25 , 000 ) for each violation of a 2 separate provision or, for continuing violations , for each day that violation continues. 3 4 18 . Title 22 Cal . Admin. Code §66078 provides: 5 "Generator " means any person, by site, whose act or process produces hazardous waste identified or 6 listed in Article 9 or 11 of this chapter or whose act first causes a hazardous waste to become subject 7 to regulation. " 8 19 . Title 2.2. -'al . Admin. Code §66508 provides in relevant 9 part: 10 " (b) A generator who accumulates hazardous waste 11 for more than 90 days is an operator of a storage facility and is subject to the requirements of 12 Articles 17 through 32 and the permit requirments of Article 6 . . . " 13 20 . Defendants , beginning at a date unknown to 14 plaintiff , but within three years from the date of filing of this 15 complaint, and continuing through this date have operated ST 16 SERVICES in violation of the laws of the State of California as 17 set forth more fully herein. 18 21 . Regulations issued pursuant to the Hazardous Waste 19 Control Act are set forth at Title 22 Cal . Admin. Code §§66001 - 20 67651. Wastes and hazardous materials referred to herein 21 possessed, stored, disposed of, and handled by the defendants, 22 including but not limited to oil and water, are on the List of 23 Chemical Names and Common Names (Title 22 Cal . Admin. Code 24 §66680 ) contained in said regulations , and meet the Dep: is 25 definition of "hazardous waste" as defined in said regulations . 26 The oil and water that spills and collects in the 'bermed area at 27 the southeast section of defendant ' s site in proximity to tanks 28 25, 26, and 27 is hazardous waste . 6 .