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I Underground Storage Tank Monitoring Plan with the local government agency,in violation of <br /> 2 California Code of Regulations,title 23 section 2711(c); <br /> 3 r. Failed to maintain written monitoring and maintenance records on-site, in violation <br /> 4 of California Code of Regulations,title 23 section 2712(b); <br /> 5 s. Failed to retain a copy of the permit and all conditions and attachments,including <br /> 6 monitoring plans at the facility,in violation of California Code of Regulations,title 23 section <br /> 7 2712(i); <br /> 8 t. Failed to identify and submit a signed statement to the local agency indicating the <br /> 9 designated underground storage tank operator for each facility,in violation of California Code of <br /> 10 Regulations,title 23 section 2715(a); <br /> I 1 u. Failed to maintain a copy of the monthly inspection record and all attachments for <br /> 12 the previous twelve(12)months,in violation of California Code of Regulations,title 23 section <br /> 13 2715(e); <br /> 14 v. Failed to equip underground storage tanks with a spill container and an overfill <br /> 15 prevention system that does not allow manual override,in violation of California Code of <br /> 16 Regulations,title 23 section 2635(b)(2); <br /> 17 w. Failed to provide training by a designated underground storage tank operator for <br /> 18 facility employees on the proper operation and maintenance of the underground storage tank system <br /> 19 once every twelve(12)months,in violation of California Code of Regulations,title 23 section <br /> 20 2715(f); <br /> 21 x. Failed to comply with underground storage tank repair and upgrade requirements, <br /> 22 in violation of California Code of Regulations,title 23 section 2661; <br /> 23 y. Failed to annually test the tightness of the automatic line leak detector, in violation <br /> 24 of Health and Safety Code section 25291(f); <br /> 25 z. Failed to record any unauthorized release from an underground storage tank with <br /> 26 secondary containment,in violation of California Code of Regulations,tide 23 section 2650(c); <br /> 27 aa. Failed to report and record to the local agency any unauthorized release, in <br /> 28 violation of California Code of Regulations,title 23 section 2650(e);and <br /> 7 <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />