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