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r <br /> I Regulations section 66262.12(x). <br /> 2 THIRD CAUSE OF ACTION <br /> 3 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25500 ET SEQ. <br /> 4 (HAZARDOUS MATERIALS RELEASE RESPONSE PLANS AND INVENTORY) <br /> 5 - 14. Paragraphs 1 through 13, above are incorporated herein by reference. Plaintiff is <br /> 6 informed and believes and based upon such information and belief alleges that beginning at an exact <br /> 7 date that is unknown to plaintiff,but within four(4)years prior to the filing of this complaint, <br /> 8 defendants engaged in acts in violation of Health and Safety Code section 25500 et seq., include but <br /> 9 are not limited to the following: <br /> 10 a. Violation of Health and Safety Code§25503.5(x),being a business that <br /> 11 handles a hazardous material or a mixture containing a hazardous material that has a quantity at any <br /> 12 one time during the reporting year equal to,or greater than, a total weight of 500 pounds,or a total <br /> 13 volume of 55 gallons, or 200 cubic feet at standard temperature and pressure for compressed gas, <br /> 14 including but not limited to GASOLINE, failed to establish and implement a business plan for <br /> 15 emergency response to a release or threatened release of a hazardous material for 515 W. 11TH <br /> 16 STREET,TRACY,CALIFORNIA; <br /> 17 b. Violation of Health and Safety Code§25504(b),business plan failed to <br /> 18 include emergency response plans and procedures in the event of a reportable release or threatened <br /> 19 release of a hazardous material,including but not limited to the following: <br /> 20 1. Immediate notification to the San Joaquin County Office of <br /> 21 Emergency Services and to the appropriate local emergency rescue personnel; <br /> 22 2. Procedures for the mitigation of a release or threatened release to <br /> 23 minimize any potential harm or damage to persons,property,or the environment; <br /> 24 3. Evacuation plans and procedures, including immediate notice,for the <br /> 25 business site; <br /> 26 C. Violation of Health and Safety Code §25504(c), failed to provide training for <br /> 27 all new employees and annual training,including refresher courses, for all employees in safety <br /> 28 procedures in the event of a release or threatened release of a hazardous material,including,but not <br /> Complaint for Injunction,Civil Penalties and Other Relief Page 5 <br />