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I materials at the California Facilities that are retall Stores, including aerosol products, f6rtillZeTS. 2 ignitable liquids-,paint esticides,pool chemicals,.and other flammable or corrosive materials. 31 p 3 Wal-Mart also generates quantities of hazardous waste at the California Facilities from spills and 4 releases of hazardous materials,:and from customer returns of hazardous items. 5 Darbridant Wal-Mart is, or at all times.rolevant to the claims in this complaint was, 6 legally responsible for compliance,wfth`flio provisions of thel-lealth.end Safety Code, including Chapters 6.5,.6.7 and 6,95 of Division 20,at its California Rarcilities, The People are informed 7 1 and believe and..thereon allege. that Wal-Mart Is i responsible for the operations of the California Facilities,that Wal-mart.watro-is.ttie-hazardous materials and hazardous waste mann gem ent ' 10 decisions at those Californ-Ja Facilities,that Wal-Mart took actions that caused the violations 1 € alleged herein,and that Wal-Mart'swharity,control and actions at thoseCalifornia Facilities and in conducting business in California are such that Wal-Mart could have taken action to 12 pre'ven-tthe violations.,att.,aged herein. 13 .4efhied in Health and Safety Code section 2511 S. 14 Wal-Mart is:a"business,"asAned in Health d,e and Safety Code section 25501, subdivision(d) 15 I I_ In this Ct nmplamnl Nllaen Glerenoeis.made to-any act of Wal-Mart., such allegations 16 1 shall include acts.,ofthe.owners,dfficers directors,agents,employms, or 17 representatives of Wal-Mart that supervise, control or direct its employees,,and agents white [8 engaged in the-management,direction.,operation or control of the a ff irs of tho business organization and dd i so while actirig within the course and scope of e m- ployment or agency of 20 Wal &lart_ 21 -JURISDICTION AND VENUE 22 12. Venue is proper in this county pursuant to Health and Safety Code section:25183 23 in that certain of the violations alleged in the Complaint occurred in the County of San Diego and 24 that certain.other statewide violations.alleged in the Complaint are related to such violations. 25: TIAS Court has jurisdiction pursuant to.Article 6, section 10 of'the California Constitution. 2.6 STAMORY AND REGULATOW BACKGROUND 227 11 The State of California has enacted a comprehensive statutory and regulatory 28 framework for the generation, handling,treatment.,storage,transportation,and disposal of COMPLAINT FOR PE.kMANENT INJUNCTfON,CIVIL PENALTIES AND OTHER EQUITABLE RELIEP