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ADMINISTRATIVE CIVIL LIABILITY COMPLAINT ORDER NO. R5-2005-0530 -7- <br /> MR. <br /> 7- <br /> MR. FRANK AND MRS. SHERRI GUINTA,AND MR.JAMES AND MRS. MARILYN RAMSEY <br /> GUINTA ENTERPRISES <br /> FRANKS ONE STOP <br /> SAN JOAQUIN COUNTY <br /> is, or probably will be, discharged into the waters of the state and creates, or threatens to create, a <br /> condition of pollution or nuisance, shall upon order of the regional board, clean up the waste or <br /> abate the effects of the waste, or, in the case of threatened pollution or nuisance, take other <br /> necessary remedial action, including, but not limited to, overseeing cleanup and abatement efforts.. . <br /> Upon failure of any person to comply with the cleanup or abatement order, the Attorney General, at <br /> the request of the board, shall petition the superior court for that countyfor the issuance of an <br /> injunction requiring the person to comply with the order. In the suit, the court shall have <br /> jurisdiction to grant a prohibitory or mandatory injunction, either preliminary or permanent, as the <br /> facts may warrant." <br /> 30. Existing data and information about the Site indicate that waste has been discharged or is <br /> discharging at the Site, which is owned or operated, or was formerly owned or operated by the <br /> Dischargers named in this Order. CWC Section 13304(c)(1)provides that: ". . . the person or <br /> persons who discharged the waste, discharges the waste, or threatened to cause or permit the <br /> discharge of the waste within the meaning of subdivision (a), are liable to that governmental agency <br /> to the extent of the reasonable costs actually incurred in cleaning up the waste, abating the effects of <br /> the waste, supervising cleanup or abatement activities, or taking other remedial action." <br /> 31. Due to the recalcitrance of the Dischargers, the Regional Board is currently conducting work <br /> required by the Order. Section 13304(b)(1) of the CWC provides that: "The regional board may <br /> expend available money to perform any cleanup, abatement, or remedial work required under the <br /> circumstances set forth in subdivision (a), including, but not limited to, supervision of cleanup and <br /> abatement activities that, in its judgment, is required by the magnitude of the endeavor or the <br /> urgency for prompt action needed to prevent substantial pollution, nuisance, or injury to any waters <br /> of the state. The action may be taken in default of, or in addition to, remedial work by the waste <br /> discharger or other persons, and regardless of whether injuctive relief is being sought. " <br /> 32. CWC Section 13267(b)(1)provides that: "In conducting an investigation specified in subdivision <br /> (a), the regional board may require that any person who has discharged, discharges, or is suspected <br /> of having discharged or discharging, or who proposes to discharge waste within its region, or any <br /> citizen or domiciliary, or political agency or entity of this state who has discharged, discharges, or <br /> is suspected of having discharged or discharging, or who proposes to discharge, waste outside of its <br /> region that could affect the quality of waters within its region shall furnish, under penalty of <br /> perjury, technical or monitoring program reports which the regional board requires. The burden, <br /> including costs, of these reports shall bear a reasonable relationship to the need for the report and <br /> the benefits to be obtained from the reports. In requiring those reports, the regional board shall <br /> provide the person with a written explanation with regard to the need for the reports, and shall <br /> identify the evidence that supports requiring that person to provide the reports." <br /> 33. CWC Section 13350 states, in part, that: "(a)Any person who (1) violates any cease and desist <br /> order or cleanup and abatement order hereafter issued, reissued, or amended by a regional board <br />