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I below, are in violation of the law and public policy of the State of California. Unless enjoined <br /> 2 and restrained by an order of this court, the Defendant will continue to retain the means to <br /> 3 engage in unlawful action and practices and courses of conduct set out below. <br /> 4 GENERAL ALLEGATIONS <br /> 5 8. Subject to the terms of the tolling agreement identified in Paragraph 8, Plaintiff is <br /> 6 informed and believes and thereupon alleges that GMRI has engaged in the following actions at <br /> 7 its Covered Facilities within the applicable statute of limitations: <br /> 8 a. Violation of Health and Safety Code section 25503.5(a), by being a business that <br /> 9 handles a hazardous material or a mixture containing a hazardous material that has a quantity at <br /> 10 any one time during the reporting year equal to, or greater than, a total weight of 500 pounds, or <br /> 11 a total volume of 55 gallons, or 200 cubic feet at standard temperature and pressure for <br /> 12 compressed gas, and failed to establish and implement a business plan for emergency response <br /> 13 to a release or threatened release of a hazardous material for each of the Covered Facilities; <br /> 14 b. Violation of Health and Safety Code section 25504(b),by having a business plan that <br /> 15 failed to include emergency response plans and procedures in the event of a reportable release or <br /> 16 threatened release of a hazardous material, including but not limited to the following: <br /> 17 1. Immediate notification to the administering agency and to the appropriate <br /> 18 local emergency rescue personnel; <br /> 19 2. Procedures for the mitigation of a release or threatened release to minimize <br /> 20 any potential harm or damage to persons, property, or the environment; <br /> 21 3. Evacuation plans and procedures, including immediate notice, for the business <br /> 22 site; <br /> 23 c. Violation of Health and Safety Code section 25504(c),by failing to train all new <br /> 24 employees and annual training, including refresher courses, for all employees in safety <br /> 25 procedures in the event of a release or threatened release of a hazardous material, including,but <br /> 26 not limited to, familiarity with the plans and procedures specified in Health and Safety Code <br /> 27 section 25504(b); <br /> 28 <br /> 3 <br /> ......... ............. ....... ..nom...T.cc .wm xwin�rnvc ucr icc <br />