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r <br /> I verified that the Benzene is at least 99.5% pure. <br /> 2 9. A spill of the Benzene would be devastating to the environment and the public at large. <br /> 3 Given the, molecular properties of Benzene, it is capable of quickly seeping through the ground, and could <br /> 4 reach tho'ground water within a matter of days. In addition, because Benzene evaporates at a very low <br /> 5 temperature, a spill of the Benzene would likely release lethal vapors into the air. Thus, a spill of Benzene <br /> 6 would pose a significant health threat to human life, especially given the close proximity of residential <br /> 7 homes to the premises. <br /> 8 10. The cost of cleaning up a spill of the Benzene would be staggering. Even if the Benzene is <br /> 9 cleaned up before it seeps into the ground water, the cost would be at least $50,000, and could exceed <br /> 10 $500,000. If the Benzene were to reach the ground water, the cost of cleanup could be substantially <br /> :.i <br /> I more. <br /> 12 1 l. Inaddition to the threat of a Benzene spill, the approximately ninety (90) containers also <br /> 13 pose a significant environmental threat. Although I have not yet verified the contents of any of the <br /> 14 containers, it appears that many contain sulphuric acid and various petroleum products. Many of the <br /> 15 container;.,appear to be leaking and/or deteriorating into the ground. Photographs of some of these <br /> 16 containers are attached hereto as Exhibit "B". These containers should be cleaned up immediately. <br /> 17 12. - I have been informed that Mr. Alexander is being allowed to remain on the Premises for <br /> 18 the sole purpose of operating a kiwifruit processing business. Although ave visited the Premises on <br /> 19 several occasions, I have never observed any activity that I can identify as related to the processing of <br /> 20 kiwifruit. To the contrary, on each occasion, I have observed the processing/bottling room,+and the <br /> I 21 kiwifruit processing equipment sitting idle. <br /> .i . <br /> 22 13. 1 have also been informed that no other parties are supposed to be using any portion of the <br /> 23 Premises. However, I have observed the operation of a driftwood business on the Premises. <br /> 24 <br /> 25 <br /> 26 <br /> 27 , <br /> 28 <br /> 3 <br />