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M <br />0 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />2.5 <br />26 <br />27 <br />28 <br />flammable, toxic, or corrosive wastes and 2,250 pounds of aerosol wastes, to representatives of a - <br />11 regional food bank, which is a point not authorized to receive hazardous waste or universal waste. <br />1. In March 2002, containers of liquid pool chlorine were disposed of by a Target <br />employee into a trash compactor ata Covered Facility in Sacramento County, which is a point not <br />authorized to receive hazardous waste. The liquid pool chlorine reacted with other incompatible <br />materials in the trash compactor, resulting in a release of irritating fumes that led to evacuation of <br />the Covered Facility, an emergency response, and several individuals transported to local <br />hospitals. <br />26. Plaintiff alleges that Defendants, and each of them, at all times relevant hereto and <br />continuing from and after the date of filing of this Complaint, caused and/or performed each of <br />the acts.and/or omissions in violation of California law in the ownership. and/or operation of the <br />Covered Facilities as alleged below: <br />a. Delivered, or otherwise transferred custody or possession of, hazardous waste <br />to a person or entity that was not properly licensed and registered to transport hazardous waste, in <br />violation of California Health and Safety.Code section 25163, subdivision (a)(1); <br />b. Transported hazardous waste without being properly licensed and registered to <br />transport hazardous waste, in violation of California Health and Saf6ty Code section 25163, <br />subdivision (a)(1); <br />C. Disposed, or caused the disposal of, hazardous waste at a point not authorized, <br />in violation of Health and Safety Code section 25189; <br />d. Stored hazardous waste onsite beyond the. time permitted by law at a facility, <br />which did not have a hazardous waste storage permit .from the California Department of Toxic <br />Substances Control ("DTSC"), in violation of Title 22 of the California Code of Regulations <br />section 66262.34, and California Health and Safety Code section 25123.3, subdivision (h); <br />e. Failed to obtain and keep current all required hazardous waste generator <br />permits required by county and local ordinances; <br />f. Failed to comply with employee training obligations as set forth in Title.22 of <br />the California Code of Regulations section 66265.16, pertaining to the handling of hazardous <br />9 <br />First Amended Complaint for Preliminary and Permanent Injunction, Civil Penalties and Other Equitable Relief <br />. Case No. RG09457686 <br />