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I violated Health and Safety Code Chapters 6.7 and 6.75,including but not limited to: <br /> 2 9a. Failure to obtain a permit from the appropriate local agency to operate an <br /> 3 underground storage tank in violation of Health and Safety Code §25284; <br /> 4 9b. Failure to property close an underground storage tank in violation of Health and <br /> 5 Safety Code § 25298(a); <br /> 6 9c. Failure to demonstrate to the appropriate local agency that the proper investigation <br /> 7 for releases and all appropriate corrective actions have been taken at the site of an abandoned or <br /> 8 closed underground storage tank, in violation of Health and Safety Code §25298(c)(1); <br /> 9 9d. Failure to demonstrate to the appropriate local agency that all residual amounts of the <br /> 10 hazardous substance or hazardous substances which were stored in the tank system prior to its <br /> I 1 closure have been removed,properly disposed of and neutralized,in violation of Health and <br /> 12 Safety Code § 25298(cx4); <br /> 13 10. Plaintiff is informed and believes and based on such information and belief alleges <br /> 14 that beginning at an exact date that is unknown to plaintiff, but within five(5)years prior to the <br /> 15 filing of this complaint(CCP §338.1),defendants DAVID FISCH and FISCH <br /> 16 ENVIRONMENTAL CONSTRUCTION have violated Health and Safety Code Chapters 6.7 by <br /> 17 assisting other businesses, individuals, or entities within San Joaquin County to violate said <br /> 18 chapters, including but not limited to: <br /> 19 10a. Failure to properly close an underground storage tank in violation of Health and <br /> 20 Safety Code §25298(a); <br /> 21 l Ob. Failure to demonstrate to the appropriate local agency that the proper investigation <br /> 22 for releases and all appropriate corrective actions have been taken at the site of an abandoned or <br /> 23 closed underground storage tank, in violation of Health and Safety Code §25298(c)(1); <br /> 24 10c. Failure to demonstrate to the appropriate local agency that all residual amounts of <br /> 25 the hazardous substance or hazardous substances which were stored in the tank system prior to its <br /> 26 closure have been removed,properly disposed of and neutralized, in violation of Health and <br /> 27 Safety Code § 25298(c)(4). <br /> 28 <br /> 3 <br />