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I SECOND CAUSE OF ACTION 2 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25500 ET SEQ. 3 (HAZARDOUS MATERIALS RELEASE RESPONSE PLANS AND INVENTORY) 4 10. Paragraphs 1 through 9, above are incorporated herein by reference. Plaintiff is 5 informed and believes and based upon such information and belief alleges that beginning at an exact 6 date that is unknown to plaintiff,but within four(4) years prior to the filing of this complaint, 7 defendants engaged in acts in violation of Health and Safety Code section 25500 et seq., including 8 but are not limited to the following: 9 a. Violation of Health and Safety Code section 25503.5(a), being a business that 10 handles a hazardous material or a mixture containing a hazardous material that has a quantity at any 11 one time during the reporting year equal to, or greater than, a total weight of 500 pounds, or a total 12 volume of 55 gallons, or 200 cubic feet at standard temperature and pressure for compressed gas, 13 including but not limited to: 14 1. CHLORINE; 15 2. HYDROCHLORIC ACID; 16 3. PHOSPHORIC ACID; 17 4. POTASSIUM PERMANGANATE; 18 5. SODIUM HYDROXIDE; 19 6. SULFER DIOXIDE; 20 7. SULFURIC ACID; 21 failed to establish and implement a business plan for emergency response to a release or threatened 22 release of a hazardous material for 1010 INDUSTRIAL DRIVE, STOCKTON, CALIFORNIA; 23 b. Violation of Health and Safety Code section 25504(b),business plan failed to 24 include emergency response plans and procedures in the event of a reportable release or threatened 25 release of a hazardous material, including but not limited to the following: 26 1. Immediate notification to the San Joaquin County Office of 27 Emergency Services and to the appropriate local emergency rescue personnel; 28 2. Procedures for the mitigation of a release or threatened release to Complaint for Injunction,Civil Penalties and Other Relief Page 4