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J t <br /> 1 FIRST CAUSE OF ACTION <br /> 2 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> (HAZARDOUS WASTE CONTROL ACT) <br /> 3 <br /> 15. Paragraphs 1 through 14, above are incorporated herein by reference. Plaintiff is <br /> 4 <br /> informed and believes and based on such information and belief alleges that beginning at an exact <br /> 5 <br /> date that is unknown to Plaintiff, but within five (5)years prior to the filing of this Complaint(CCP <br /> 6 <br /> §338.1), Defendants engaged in acts in violation of Health and Safety Code §25100 et seq., including <br /> 7 <br /> by not limited to the following: <br /> 8 <br /> a. Disposed of, or attempted to dispose of, liquid latex paint in the land or into the <br /> 9 <br /> waters of the state, in violation of Health and Safety Code section 25217.1; <br /> 10 <br /> b. Stored hazardous waste onsite longer than one hundred eighty (180)days, in <br /> 11 <br /> violation of California Code of Regulations, title 22 section 66262.34(d); <br /> 12 <br /> c. Failed to label or mark containers used for onsite accumulation of hazardous waste, <br /> 13 <br /> in violation of California Code of Regulations, title 22 section 66262.34(f); <br /> 14 <br /> d. Failed to maintain and operate facility to minimize the possibility of a fire, <br /> 15 <br /> explosion, or any unplanned sudden or non-sudden release of hazardous waste, in violation of <br /> 16 <br /> California Code of Regulations,title 22 section 66265.31; <br /> 17 <br /> e. Failed to keep container holding hazardous waste closed during transfer and <br /> 18 <br /> storage, except when it is necessary to add or remove waste, in violation of California Code of <br /> 19 <br /> Regulations,title 22 section 66265.173(x); <br /> 20 <br /> f. Failed to manage universal waste batteries in a way that prevents releases of any <br /> 21 <br /> universal waste or component of a universal waste to the environment, in violation of California Code <br /> 22 <br /> of Regulations, title 22 section 66273.13(x); <br /> 23 <br /> g. Failed to label or mark the universal waste to identify the type of universal waste, in <br /> 24 <br /> violation of California Code of Regulations, title 22 section 66273.14; <br /> 25 <br /> h. Accumulated universal waste for longer than one (1)year from the date the <br /> 26 <br /> universal waste is generated, or received from another handler, in violation of California Code of <br /> 27 <br /> Regulations,title 22 section 66273.15(a); <br /> 28 <br /> 4 <br /> VERIFIED COMPLAINT <br />