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1 ql Violations of §66472 (b) in that defendants disposed of <br /> 2 hazardous waste without having received an Environmental <br /> 3 Protection Agency identification number; the exact number of <br /> 4 illegal disposals is unknown to Plaintiff at the time of filing <br /> 5 but is known to be no less than 10; each dispoa' constitutes a <br /> 6 separate and distinct violation; <br /> 7 23 . Defendants, and each of them, knowingly, intentionally <br /> 8 or negligently violated the provisions of §25189( b` cif the <br /> 9 California Health and Safety Code; said acts inclua,- ., ut are not <br /> 10 limited to the following violations of Chapter 6 .5, Division 20 <br /> 11 of the Health and Safety Code: <br /> 12 a ) Violations of §25154 in that defendants have handled, <br /> 13 stored, or disposed of hazardous waste in a manner not provided <br /> 14 for in Chapter 6 .5; <br /> 15 b) Violations of §25174 in that defendant has failed to pay <br /> 16 the required fee to the State Board of Equalization for disposal <br /> 17 of the wastes; the exact number of illegal disposals is unknown <br /> 18 to Plaintiff at the time of filing but is known to be no less <br /> 19 than 10; each disposal constitutes a separate and distinct vi;1.1- <br /> 20 tion; <br /> 21 c) Violations of §25189. 5 in that defendants disposed of <br /> 22 hazardous waste at a facility which does not have a permit or at <br /> 23 a point (the lagoon ) which is not authorized according to Chapter <br /> 24 6 .5; said illegal disposal has occurred on a periodic basis <br /> 25' during the three years prior to the date of filing of this <br /> 26 complaint; each day during the three years constitutes a separate <br /> 27 and distinct violation; <br /> 28 <br /> 11. <br />