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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />2, <br />24 <br />25 <br />26 <br />27 <br />28 <br />b. Failed to maintain all couununication or alarm systems, spill control, or <br />Jecontamination equipment, in violation of California Code of Regulations, title 22 section <br />56265.33; <br />c. Stored hazardous waste on site greater than 180 days, in violation of California <br />Code of Regulations, title 22 section 66262.34(d); and <br />d. Failed to retain for at least three years, a copy of manifest or bill of lading which <br />identities shipping of spent lead -acid storage batteries, in violation of California Code of <br />Regulations, title 22 section 66266.81(a)(4)(B). <br />SECOND CAUSE OF ACTION <br />VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br />(UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br />--8 Paragfaphs'1 through 7, above are incorporated herein by reference. Plaintiff is informed <br />and believes and based on such information and belief alleges that beginning at an exact date that is <br />unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint (CCP §338.1). <br />Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., including <br />but not limited to the following: <br />a. Failed to maintain written monitoring and maintenance records on-site, in violation <br />I of California Code of Regulations, title 23 section 2712(b); <br />b. Failed to maintain secondary containment system which prevented any releases <br />I from flowing to a collection sump located at the low point of underground piping, in violation of <br />I California Code of Regulations, title 23 section 2636(e)(1); <br />c. Failed to maintain a copy of the monthly inspection record and all attachments for <br />I the previous twelve (12) months, in violation of California Code of Regulations, title 23 section <br />2715(e); <br />d. Failed to perform periodic testing of secondary containment system, in violation of <br />California Code of Regulations, title 23 section 2637(a); and <br />e. Failed to provide training by a designated underground storage tank operator for <br />I facility employees on the proper operation and maintenance of the underground storage tank system <br />SECOND AMENDED VERIFIED COMPLAINT FOR INJUNCTION, CIVIL. PENALTIES, SAND OTHER RELIEF <br />