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2 <br />3 <br />4 <br />5 <br />6 <br />ll <br />1.2 <br />13 <br />14 <br />15 <br />1.6 <br />17 <br />I& <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 Park -way in El <br />Cajon revealed that used. automotive batteries: were haphazardly stored, tipped overand leaked <br />sulfuric acid on the asphalt pavement., where the acid dried. <br />29- In October 2005, an inspection of the 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, Si ilarly, at 170 Town Center Parkway 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 265.02 'Powiw Center <br />Parkway in F'ooth ill. Ranch, Orange County, disposed of expired fertilizers, and other garden,. <br />products by spreading thern out in a planter behind the store. When Orange County District strict <br />Attorney lilveAiglatom, (Who ba Won, alerwd.io the disposal int to: t <br />d albyanemployeecompa the <br />Irvine Ranch Water District) arrived, the fertilizer was.obsorved in small piles, spread throughout <br />the 10 foot by 200 foot planter arid, due lo rain, was, seen going oto the storm drain. Laboratory <br />tests, of this fertilizer confinned 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 fertili7cr <br />disposal for approximately *no year. <br />131, In August -2005, inspactats at lbo.Robort Nelson. Transfer Station iii Riverside <br />County discovered bogs of -the pest AM-AZEM at the bottom, o -fa load of trash that came <br />from a Wal-Mart store,in Rialto. In San 80,mudino, County. Riverside County District Attorney <br />investigators, Rivetside County 'Environmental Health, I 4azardous Materials Division Specialists <br />and thoRivers.i.de Count)' WasAo.managgawnt: Department responded to the transfer. station, <br />finding 77 of tho 8 pound bags ofpesticide in the load, 'Upon examination of the EPA. registered <br />pesticide, investigators from ,the Ciaunty of Riverside Agricultural Commissionees Office <br />determined that the RiAlto"WalMM' <br />had viQIp1ed,CAI'iM1 fo 'a law related to the proper disposal of <br />waste pesticides. <br />32. In September 2005, inspectiow of the Wal-Mart store located at 470: McKinley <br />Street. "in Coruna od. e.store-at,32225 Highway 79 in. 7'ernemla, both in&iversideCounty, <br />revealed that haurdous wastes in damaged pontaintm and spills of hazardous chemicals that were <br />A <br />COMPLAINT FOR. PERMANENT INJUNCTION, C1 VIL PENALTIES AND OTHER EQUITABLE RELIEF <br />