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1 <br /> I Regulations section 2638(a); <br /> 2 e. Failure to test secondary containment by January 1,2003, in violation of Title 22 of <br /> 3 the California Code of Regulations section 2637(x); <br /> 4 f. Failure to equip secondary containment,including under-dispenser containment,with <br /> 5 continuous monitoring system, in violation of California Code of Regulations section 2636(f)(1); <br /> 6 g. Failure to install and maintain monitoring equipment that is capable of detecting a leak <br /> 7 at the earliest possible opportunity, in violation of California Code of Regulations section 2630(d); <br /> 8 h. Failure to develop a monitoring and response plan in violation of California Code of <br /> 9 Regulations 2632(d); <br /> 10 i. Failure to retain a written maintenance and monitoring record in violation of <br /> 11 California Code of Regulations section 2712(b); <br /> 12 j. Failure to obtain a permit or authorization from the appropriate permitting agencies <br /> 13 prior to repairing an underground storage tank system at 515 W. 11 Tx STREET,TRACY, <br /> 14 CALIFORNIA; <br /> 15 k. Failure to notify the appropriate authority prior to changing monitoring procedures, <br /> 16 such as replacing the leak sensor detection equipment and/or monitoring system so as to ensure that <br /> 17 only leak detection equipment approved by the California State Water Resources Control Board was <br /> 18 installed. <br /> 19 SECOND CAUSE OF ACTION <br /> 20 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25100 ET SEQ. <br /> 21 (HAZARDOUS WASTE CONTROL ACT) <br /> 22 13. Paragraphs 1 through 12, above are incorporated herein by reference. Plaintiff is <br /> 23 informed and believes and based upon such information and belief alleges that beginning at an exact <br /> 24 date that is unknown to plaintiff,but within five(5)years prior to the filing of this complaint(CCP <br /> 25 §338.1),defendants engaged in acts in violation of Health and Safety Code section 25100 et seq., <br /> 26 including but not limited to the following: . <br /> 27 a. Failure to treat, store, dispose of,or transport,or offer for transportation,hazardous <br /> 28 waste without first having received an identification number,in violation of California Code of <br /> Complaint for Injunction,Civil Penalties and Other Relief Page 4 <br />