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2. <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />101 <br />ll <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />is <br />19 <br />2.0 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />50 Wal-Mart has violated. the hazardous Nvaste handling and storage requirements <br />applicable to its California Facitities by virtue of the acts described in paragraph 37 above, <br />51 Each violation of hazardous waste handling and storage requ i rements that the <br />People discovered within five years of commencing this actio -n, exclusive of any applicable <br />tolling periods and those set f6rth in paragraph 25 herein, subjects WakMart to a separate and <br />additional civil penalty under Health and Safety Code section 251 &9,.or alternatively under <br />section 25189.2. <br />52. Based on the above, the People request injunctive relief against Wal-Mart under <br />Health and Safety Code section 25181, and civil penalties apinst Wal-Mrattund0 Health _ and <br />Safety Code section. 25199 or 25189:2, as described in the People's prayer for r0lef. <br />FOURTI-I CAUSE OF ACTION. <br />(Violation of Underground Tank System Requirements) <br />(Health & Safety Code Chapter 6.7 andImplementing Regulations) <br />53 Plainti fr real leps paragraph.s I through 52, inclusive. <br />54. Within. rive years Of commencing this action, exclusive of any applicable tolling <br />peri -ods and those set forth in paragraph 25 herein, Wal-Mart has violated Chapter 6.7 of the <br />Health and Safety Code at certain California Facilities, by installing -and operating underground <br />tank Tions. s <br />ystems that do not comply with Chapter 6.7 and. its implenne ting regulations. <br />, !, <br />tia <br />55, Based on the above, the, People request injunctive relief Wal-Mart -Mart under <br />t, '15 , I <br />Health. and Safety Code section 25299.0 1, as described in the People',s prayer.forrolief <br />Fwril CA vsE OF ACTION <br />(Violations of Hazardous Materials. Release Response Plarisand inventory Laws) <br />56. Plaintiff realte-ges paragraphs I through 55, inclusive.' <br />57 Wal-Mart is liable for civil penalties as set forth in Health and Safety Code section <br />25514 for each and every separate violation of Health and Safety Code sections 25503.5 to <br />25505, inclusive, and sections 25508 to 25510, inclusive, and any applicable permit, rule, <br />regulation, standard, or requirement issued or promulgated pursuant thereto which occurred <br />within five years after thediscovery of the facts constituting -grounds for commencing the action <br />Is <br />COMPLAINT FOR PERMANENT INJUNCTION, CIVIL PENALTLES AND oTHLR EQUITABLE RELIEF <br />