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I a. Disposing,or causing the disposal of, hazardous waste at a point not authorized, in
<br /> 2. violation. of Health and Safety Code sections 25 189 and 25 18.9.2, including to
<br /> 3 drains at California Facilities, onto the surfiace or subsurface of the ground at
<br /> 4 unauthorized locations,and at non-h=rdous landfills and other locations not
<br /> 5 authorized to receive hazardous waste;
<br /> 6 b. Transporting hazardous waste at, to, from and between California Facilities on
<br /> 7 Wal-martand Sam's Club vehicles without a valid registration Issued by the,
<br /> VTSC, in violation of Health and Safety Cade sectio ri 2516 3T
<br /> c. Transporting hazardous waste to unauthorized locations, including,without
<br /> 9
<br /> 10 limitation,Wal-Dart. t,reum and dist bution centers, in
<br /> n violation of(
<br /> Code of Regulations, title 22,section 66263.23;
<br /> ll
<br /> d, Failing todeten-nine whether items return
<br /> 12 ed by c u
<br /> stomers to California Facilities,
<br /> and wastes- generated at California.Facilities via spills, container break, e,and
<br /> 13
<br /> other means, were hazardous wastes, in violation of California Code of
<br /> 14
<br /> Regulations.,title 22, section 66262,11;
<br /> is
<br /> e. Failing to handle hazardous. waste front customer returns to Calif6mia Facilities,
<br /> 16
<br /> and hazardous:Waste,generated at California Facilities by spills,contalner
<br /> 17 breakage,and other means; in accordariec with thereqwremenkof Chapterapter 6.5 Of
<br /> 18 the Health & Safety Code and its implementing regulations in the California Code
<br /> 19
<br /> of Regulations,Title 22.
<br /> 20 E Failing to treat returned or discarded non-empty aerosol cans at California
<br /> 21 Facilities as universal waste or hazardous waste, in violation of California Code of
<br /> 22 Rcgulaflon.s,title 22, Chapter 23, section 6.6273,1 etqeq.
<br /> 23 g. Falling to oompty with,employee training obligations pertaining to handling of
<br /> 24 hazardous waste,at California Facilities, in violation of California Code of
<br /> 25 Re Title 22,section 662965.16.
<br /> 26 h. Failing to manage, identify the date of accumulation, and label containers of
<br /> 27 hazardous waste at California Facilities, in violation of California Code of
<br /> 28 Regulations,.title 22, section 66262.34;
<br /> 12
<br /> COMPLAINT FORPLAWANENTINJUNCTION,CIVIL PENALTIES AND OTHER EQUITABLE RELIEF
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