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2 <br />3 <br />4 <br />5 <br />6 <br />10 <br />Il <br />12 <br />13 <br />14 <br />15 <br />t6 <br />17 <br />18. <br />19 <br />20, <br />21 <br />22, <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />28. In Juile.2005, an inspection of the Wal-Mart store at 605 Fletcher Parkway in El <br />Cajon revealed that used. automotive batteries were haphazardly stored, tipped over and leaked <br />suffurk, acid on the asphalt pavement., where the acid dried. <br />29- In October 2005, an inspection of tbP, Wal-Mart store, at 3382 Murphy Canyon <br />Road in San Diego revealed that absorbent contaminated with a spilled hazardous: material, paint, <br />was thrown into the trash. Similarly, at 170 Townteriter Pgr-kAyay in Santee, Wal-Mart <br />employees cleaned up hazardous spills and left the used Absorbent to be thrown out in the trash <br />30. In January of 2005, employees at the Wal-Mart store at 26502 'Powiw Center <br />Park -way in F'ooth ill. Ranch, Orange County, disposed of expired fertilizers, and other garden <br />products by spreading them out in a planter beh-ind the store. When Orange County District strict <br />Attorney Investigators (who had beery alerte'dio the disposal by an employee complaint to: the <br />Irvine Ranch WaterDiarlict) arrived, the fortilizer wa-s.observed in small piles, spread throughout <br />the 10 foot by 200 foot planter arid, due lo rain, was, seen goirtgJato the storm drain, Laboratory <br />tests of this fertilizer Confirmed it to be hazardous. During the,subsquent investigation, one of <br />the employees who disposed of the waste noted fie had:b.ecn employing, this practice of fertili7er <br />disposal for approximatq1yonoyear. <br />1, In August -2.005, inspeotors at Transfer Stati <br />on in Riverside <br />County discovered lags of -the possu",-AMS,ZE,0 at, the bottom -ara -load of trash that came <br />from a Wal-Mart store in Rialto, in San Boxnardino, County. Riverside- County District Attorney <br />investigators, Riverside County Environmental.Health, I . 4azardous Materials Division Specialists <br />and the ,Riverside .Courtly WasAo.Matjagt'-rnent Department responded to the transfer station, <br />finding 77 of the 8 pound bags of pesticide in the load, Upon examinati gi of the EPA. registered <br />Pesticide, investigators from: the County of Riverside Agricultural Commissioner's Office <br />determined that the Rialto VaWW had viofated ,CAHiforrua law rel -ated to the- proper disposal of <br />waste pesticides. <br />32. InSepte ber20105jnspectiow of the Wal-Mart store located at 470: McKinley <br />gn <br />Street in Coruna and the store -at,-32225 Highway 79 in Temecula, both in Riverside County, <br />revealed that.hazardous wastes in daftiaged:oontainem and spills of hazardous chemicals that were <br />A <br />COMPLAINIT FOR. PERMANENT INJUNCTION, CIVIL PENALTIES AND OTHER EQUITABLE RELIEF <br />