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L Failingto label containers of h=- rolous waste before transporting hazardous waste <br /> 2 from California Facilities, in v'olation of California Code of Regulatio <br /> nz, title 22, <br /> section 662623)I; <br /> 4 j Failing to prepare and maintain hazardous waste manifests, in violation of <br /> 5 California Code.of Regulations, title 22, section 66200 et seq.; <br /> 6 k. Failing to operate underground uank systems in compliance with Chapter 6.7 of the <br /> 7 Health and Safety Code and its implementing regulations at Ca lifamia Facilities; <br /> 1. Faili4g to establish and implement business plans for California Fhcilitles,. <br /> including training in safetyprocedures in the event of a release, In violation o <br /> f <br /> 1 0 Health and Safety Code section 255.04; <br /> m. Failing to maintain inventories ofhazardous materials, and to submit,certify, and <br /> 11 <br /> modify as necessary business plans for California Facilities, in violation of flealth <br /> 12 <br /> and Safety Code sections 2.5505,225509,and 25510. <br /> 13 <br /> 38� Wal-Mart's noncompliance threatened public health and safety and the <br /> 14 <br /> environment. <br /> IS <br /> FIRST CAUSE OF ACTION <br /> 16 (Disposal of.Hazardous Waste at a Point not Authorized) <br /> 17 <br /> (health &Saf.Code, §§251.89, 25189-2) <br /> 18 <br /> 39. Plaintiff realleges paragraphs I through 38, inclusive, <br /> 19 40. Health and Safety.Code sections 25189 and 25189.2 prohibit the disposal of <br /> 20 hazardous waste at a point not authorized under Chapter 6.5. Section 25189,subdivision (c) <br /> 21 prohibits the intentional or negligent disposal of hazardous waste at an unauthorized point, and <br /> 22 section 25189.2,subdivision (c)prohibits the disposal of hazardous waste at an unauthorized <br /> 23 point as a matter of strict liability <br /> 24 41, Wal-Mart has disposed or caused the disposal of hazardous waste from its <br /> 25 California Facilities at unauthorized points, in violation of California Health and Safety Code <br /> 26 sections 25189 and 25189.2. <br /> 27 42. Each disposal of hazardous waste at an unauthorized point that the People <br /> 28 discovered within five years of commencing this action., exclusive of any applicable tolling <br /> 13 <br /> COMPLAINT FOR PERMANENT!INJUNCTION,CIVIL PENALTIES AND OTimm EQUITABLE RELIEF <br />