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l <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 />j. Failed to retain for at least three years, a copy of manifest or bill of lading <br />which identities shipping of spent lead -acid storage batteries, in violation of California Code of <br />Regulations, title 22 section 66266.8 1 (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 />20. Paragraphs 1 through 19, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on such information and belief alleges that beginning at an <br />exact date that is unknown to Plaintiff, but within five (5) years prior to the filing of this <br />Complaint (CCP §338.1), Defendants engaged in acts in violation of Health and Safety Code. <br />section 25280 et seq., including but not limited to the following: <br />a. Failed to maintain written monitoring and maintenance records on-site, in <br />violation of California Code of Regulations, title 23 section 2712(b); <br />b. Failed to maintain evidence of financial responsibility, in violation of Health <br />and Safety Code section 25292.2; <br />c. 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 />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 />11 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 />125291(b); <br />f. Failed to record results of each inspection by the designated underground <br />storage tank operator in a monthly inspection report, in violation of California Code of <br />Regulations, title 23 section 2715(c); <br />31 <br />VERIFIED COMPLAINT <br />