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1 the California Hazardous Waste Control Act are set forth in 2 Title 22 of the California Code of Regulations (CCR) Section 3 66001 et seq. . Recyclable materials possessed, stored, and 4 handled by the defendants including, but not limited to, zinc, 5 and pickling liquor and referred to herein meet the definition 6 of hazardous waste as defined in said regulations and/or Health 7 and Safety Code § 25117 and 5 25124 . Recyclable materials are 8 subject to regulatory restrictions which apply to hazardous 9 wastes. Health and Safety Code § 25143 . 2 and 25120. 5. 10 9 • Defendants, beginning at a date unknown to Plaintiff, 11 but within five years from the date of filing of this complaint 12 (CCP S 338 . 1) have operated in violation of the laws of the 13 State of California. As a result of their manufacturing 14 processes, defendant SUMIDEN generates recyclable materials 15 including approximately 2 , 000 tons per year of pickling liquor 16 (sulfuric acid) and 480 tons per year of zinc phosphate sludge. 17 Spent pickling liquor is listed by the federal Environmental 18 Protection Agency as a hazardous waste. In addition, SUMIDEN's 19 pickle liquor met California 's definition of hazardous waste 20 based on corosivity (low ph) . SUMIDEN' s zinc phosphate sludge 21 contains high concentrations of zinc which surpass the above 22 referenced regulatory criteria for hazardous waste. 23 10. From 1984 to 1987 , defendant SUMIDEN transported and 24 disposed of pickle liquor and spent zinc phosphate sludge as 25 hazardous waste. The zinc phosphate sludge was transported by 26 licensed hazardous waste haulers to a licensed hazardous waste 27 landfill. The pickle liquor was sent to a hazardous waste 28 recycler. In 1988, this practice was stopped. From 1988 until 3 rb, .... r. J"4-t•G'F.{ h•„].}{yr ... n MCC.;. ,-7'. 1* _,