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2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <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 />FOURTH CAUSE OF ACTION <br />(Violations of Hazardous Materials Release Response Plans and Inventory Laws) <br />(Health & Saf. Code Chapter 6.95 (§ 25500 et seq.); Cal. Code Regs., tit. 19, § 2650 et seq.) <br />49. The People reallege all previous paragraphs. <br />50. Chapter 6.95 of Division 20 of the Health and Safety Code (section 25500 et seq.) <br />require businesses to, among other things, provide training to employees, retain training records, and <br />maintain applicable permits and hazardous materials response plans and inventories. <br />51. Defendant failed to comply with Chapter 6.95 and its implementing regulations set <br />forth ai California Code of Regulations, title 19, section 2650 by, among other things, failing to <br />maintain the required hazardous materials response plans and inventories, training records, and <br />applicable permits required for the Facilities; and unless enjoined by order of the Court, Defendant <br />may or will continue in the course of conduct as alleged in this Complaint. <br />52. Each violation of Health and Safety Code sections 25504 to 25508.2, inclusive, and <br />section 25511, and any applicable permit, rule, regulation, standard, or requirement issued or <br />promulgated pursuant to those sections, discovered within five (5) years of commencing this action, <br />exclusive of any applicable tolling periods and those set forth in paragraph 15 above, subjects <br />Defendant to a separate and additional civil penalty under Health and Safety Code section 25515.2, <br />subdivision (b), or alternatively, under section 25515.2, subdivision (a). <br />53. Based on the above, the People request injunctive relief against Defendant under <br />Health and Safety Code section 25515.6, and civil penalties under Health and Safety Code section <br />25515, as described in the People's prayer for relief. <br />FIFTH CAUSE OF ACTION <br />(Violations of Unfair Competition Law) <br />(Bus. & Prof. Code, § 17200 et seq.) <br />54. The People reallege all previous paragraphs. <br />55. Within four (4) years of the date of commencement of this action, exclusive of any <br />applicable tolling periods and those set forth in paragraph 15 above, Defendant engaged in, and <br />continues to engage in, unlawful acts, omissions, and practices that constitute unfair competition <br />within the meaning of Business and Professions Code sections 17200 through 17208, as alleged in <br />paragraph 32 and in the First through Fourth Causes of Action; and unless enjoined by order of the <br />-16- <br />COMPLAINT FOR INJUNCTIVE RELIEF, CIVIL PENALTIES, AND OTHER RELIEF <br />