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1 <br />2 <br />4 <br />5 <br />6 <br />7 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />Is <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />absorbed bsorbed with absorbent were transported to the return centor by an unlicensed hauler and without <br />a manifest as required by law. <br />33. In September 2005, an inspection of the WakMart store at 479 McKinley Street in <br />Corona, Riverside County, revealed that spills of waste oil were being cleaned with absorbent and <br />then thrown in the municipal trash. <br />34, In April 2002, local officials in Solario County, California received a citizen report <br />of a child playing on a pile of yellowish, colored powder near the, garden department at a Wal- <br />Mart store in Vacaville, California. The Deputy. Agriculture. Commissioner was dispatched atid <br />observed piles of multi -colored unknown fertiliser type substances and torn sacks of ammonium <br />sulfate. Subsequent investigations revealed. that for a period of severalars, the Vacaville Wal- <br />Mart <br />Mart had failed to comply with California environmental laws related to the storage, handling, <br />and disposal of hazardous waste and -materials„ namely Nntilizers, pesticides, arid herbicides sold <br />in its garden center. <br />35. In late 2,005, the Attom.ey General's Office joined with the District Attorneys' <br />offices in various counties in the. State of Californiatcrzoordlme investigation of Wal -Mar. The <br />investigation focused on violations of California laws regarding illegal disposal, transportation, <br />and storage of hx/,ardous wastes, as well as compliance with h.azardous materials management <br />plan requirements for each California rac-11ity. <br />36. As a result of the above -referenced investigation, P 1: 1 r 0 believes <br />Nairitiff i 9 inro m. � do d be i v - <br />and thereupon alleges that Wat-Mart has violated -provisions of the following statutes, including <br />implernenting regulations associated with each of the statutes and any related permit, rule, <br />standard, or requirement issued or promulgated pursuant to these statutes, at California Facilities <br />within the time period applicable to this action-. Chapter 6.5 of the Health and Safety Code, <br />section 25 100 et seq., Chapter 6.7 of the Health and Safety Code, section 25290 et seq., and <br />Chapter 6.95 of the Health and Safety Code, section 25500 et seq. <br />37 Plaintiff is informed and believes and thereupon alleges that Wal-Mart engaged in <br />conduct or failed to act in a manner that violated provisions of the statutory and legal <br />requiren't,ents identified in the preceding paragraph, including but not limited to the following: <br />COMPLAINT FOR PERMANENT INJUNCTION, CML PENALTMS AND OTHER EQUITABLE RELIEF <br />