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S <br /> 1 IV <br /> 2 GENERAL ALLEGATIONS <br /> 3 34. Defendants UNOCAL and TOSCO are engaged in the business of, among other things, <br /> 4 the exploration, development and production of petroleum, the refining and transportation of <br /> 5 petroleum and petroleum products and the marketing of petroleum products on the U.S. West <br /> 6 Coast. <br /> 7 35. Defendants UNOCAL and TOSCO market gasoline and other refined petroleum products <br /> 8 to both consumers and resellers within the State of California and elsewhere. <br /> 9 36. Defendants UNOCAL and TOSCO as part of its gasoline marketing operation currently <br /> 10 owns and/or operates and did own and/or operate numerous underground storage tanks located <br /> 11 within the County of San Joaquin which are or wee used to store UNOCAL and TOSCO branded <br /> 12 gasoline for sale to consumers. Defendants UNOCAL and TOSCO currently own and/or have <br /> 13 owned certain real property located within the County of San Joaquin wherein underground <br /> 14 storage tanks were owned and/or operated by individuals or entities other than Defendants <br /> 15 UNOCAL and TOSCO. <br /> 16 37. The gasoline marketed by UNOCAL and TOSCO at all times herein contains, among <br /> 17 other chemicals, benzene, CAS Number 71432, and Toluene, CAS Number 108883, which are <br /> 18 chemicals known by the State of California to cause cancer or reproductive toxicity pursuant to <br /> 19 Proposition 65. The gasoline marketed by UNOCAL and TOSCO at all times relevant herein <br /> 20 also contains the chemicals Ether, Xylene and the gasoline additive Methyl-tert-butyl-ether <br /> 21 (hereinafter referred to as MTBE). <br /> 22 38. Plaintiff is informed and believes and on such belief alleges that there have been <br /> 23 numerous unauthorized releases of UNOCAL and TOSCO branded gasoline to the soil and <br /> 24 groundwater of the County of San Joaquin from underground storage tanks currently or <br /> 25 previously owned and/or operated by Defendants, UNOCAL and TOSCO, or onto land owned by <br /> 26 UNOCAL and TOSCO,which unauthorized releases have resulted in the contamination of <br /> 27 County soil and groundwater with petroleum hydrocarbons, benzene,toluene, ether, xylene, and <br /> 28 MTBE. Defendants have failed to take appropriate corrective action to remedy the impact of <br /> H:SHOME\WOUNGICASFMUNOCAL�COMPLAM.WPD 6 <br />