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1 a. Failed to maintain evidence of financial responsibility,in violation of California <br /> 2 Health and Safety Code section 25292.2(a); <br /> 3 b. Failed to properly locate monitoring equipment to detect a leak in the underground <br /> 4 storage tank system, in violation.of California Code of Regulations,title 23 section 2630(d); <br /> 5 c. Spill container failed to collect any hazardous substance to prevent hazardous <br /> 6 waste from entering the subsurface environment, in violation of California Code of Regulations,title <br /> 7 23 section 2635(b)(1); <br /> 8 d. Failed to equip underground storage tanks with spill container and an overfill <br /> 9 prevention system that does not allow manual override,in violation of California Code of <br /> 10 Regulations,title 23 section 2635(b)(2); <br /> 11 e. Failed to install automatic line leak detectors on underground pressurized piping <br /> 12 capable of detecting 3-gallon per hour leak rate at 10 psi, in violation of California Code of <br /> 13 Regulations, title 23 section 2636(0(2); <br /> 14 f Failed to submit a completed Monitoring System Certification form to the Iocal <br /> 15 agency, in violation of California Code of Regulations,title 23 section 2638(d); <br /> 16 g. Failed to retain a copy of the permit and all conditions and attachments, including <br /> 17 monitoring plans at the facility, in violation of California Code of Regulations,title 23 section <br /> 18 2712(i); <br /> 19 h. Failed to identify and submit a signed statement to the local agency indicting the <br /> 20 designated underground storage tank operator for each facility, in violation of California Code of <br /> 21 Regulations,title 23 section 2715(a); and <br /> 22 i. Failed to check that all required testing and maintenance for the underground <br /> 23 storage tank system have been completed, and document the dates these activities occurred, in <br /> 24 violation of California Code of Regulations,title 23 section 2715(c)(5). <br /> 25 llf <br /> 26 fll <br /> 27 111 <br /> 28 111 <br /> -3- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />