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I the liquid or vapor phase of the hazardous substance stored in the underground tank is released into <br /> 2 the environment, ,in violation of Health and Safety Code Section 25290.1(e); <br /> 3 h Failed to design and construct an underground storage tank system with a <br /> 4 monitoring system capable of detecting the entry of the hazardous substance stored in the primary <br /> 5 containment into the secondary containment,in violation of Health and Safety Code Section <br /> 6 25291(b); <br /> 7 i. Failed to maintain evidence of financial responsibility,in violation of Health and <br /> 8 Safety Code Section 25292.2(a); <br /> 9 j. Failed to implement a monitoring program approved by the local agency and <br /> 10 specified in the underground storage tank operating permit, in violation of California Code of <br /> I 1 Regulations,title 23 section 2632(b); <br /> 12 k. Failed to equip all secondary containment, including under-dispenser containment <br /> 13 spill control or containment systems with a continuous monitoring system, in violation of California <br /> 14 Code of Regulations,title 23 section 2636(f)(1); <br /> 15 1. Failed to install automatic line leak detectors on underground pressurized piping <br /> 16 capable of detecting 3-gallon per hour leak rate at 10 psi,in violation of California code of <br /> 17 Regulations, title 23 section 2636(f)(2); <br /> 18 in. Failed to perform annual monitoring certification and leak detector testing,in <br /> 19 violation of California Code of Regulations,title 23 section 2638(a); <br /> 20 n. Failed to submit a completed Monitoring System Certification form to the local <br /> 21 agency,in violation of California Code of Regulations,title 23 section 2638(d); <br /> 22 o. Failed to report or record any unauthorized release from the underground storage <br /> 23 tank,in violation of California Code of Regulations,title 23 section 2650(b); <br /> 24 p. Failed to inform the local agency of any changes to the Underground Storage Tank <br /> 25 Operating Permit Application within thirty(30)days,in violation of California Code of Regulations, <br /> 26 title 23 sections 2711(b); <br /> 27 q. Failed to file Underground Storage Tank Operating Permit Application-Facility <br /> 28 Information and Underground Storage Tank Operating Permit Application- Tank Information and <br /> 6 <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />