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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 §66508 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 />