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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 />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />a. Failed to maintain written monitoring and maintenance records on-site, in violation <br />of California Code of Regulations, title 23 section 2712(b); <br />b. Failed to maintain evidence of financial responsibility, in violation of Health and <br />Safety Code section 25292.2; <br />c. Failed to maintain secondary containment system which prevented any releases <br />from flowing to a collection sump located at the low point of underground piping, in violation of <br />California Code of Regulations, title 23 section 2636(c)(1); <br />d. Failed to implement a monitoring program approved by the local agency and <br />specified in the underground storage tank operating permit, in violation of California Code of <br />Regulations, title 23 section 2632(b); <br />e. Failed to design and construct an underground storage tank system with a <br />monitoring system capable of detecting the entry of the hazardous substance stored in the primary <br />containment into the secondary containment, in violation of Health and Safety Code Section <br />25291(b); <br />f. Failed to record results of each inspection by the designated underground storage <br />tank operator in a monthly inspection report, in violation of California Code of Regulations, title 23 <br />section 2715(c); <br />g. Failed to maintain a copy of the monthly inspection record and all attachments for <br />the previous twelve (12) months, in violation of California Code of Regulations, title 23 section <br />2715(e); <br />h. Failed to comply with underground storage tank repair and upgrade requirements, <br />in violation of California Code of Regulations, title 23 section 2661; <br />i. Failed to perform periodic testing of secondary containment system, in violation of <br />California Code of Regulations, title 23 section 2637(a); <br />j. Failed to inform the local agency of any changes to the Underground Storage Tank <br />Operating Permit Application within thirty (30) days, in violation of California Code of Regulations, <br />title 23 section 2711(b); <br />k. Failed to identify and submit a signed statement to the local agency indicating the <br />-4- <br />FIRST AMENDED VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />