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.� ►■/ <br /> 1 operation of an underground storage tank containing petroleum. "Operator" includes any <br /> city, county, or district, or any agency or department thereof, but does not include the <br /> 2 state or any agency or department thereof, or the federal government. (Cal. H & S Code § <br /> 25299.20) <br /> 3 <br /> (o) "Owner" means the owner of an underground storage tank containing petroleum. <br /> 4 "Owner" includes any city, county, or district, or any agency or department thereof, but <br /> does not include the state or any agency or department thereof, or the federal government. <br /> 5 (Cal. H & S Code § 25299.21) <br /> 6 (p) "Site" means a parcel of real property or adjacent parcels under common ownership or <br /> control. (Cal. H & S Code § 25299.23.1) <br /> 7 <br /> (q) "Tank", "underground storage tank," "underground tank system," and"tank system" <br /> 8 have the same meaning as defined in Section 25281, except that"tank", "underground <br /> storage tank," "underground tank system," and"tank system" mean only those tanks <br /> 9 which are defined as petroleum underground storage tanks under the federal act. <br /> (Cal. H & S Code § 25299.24) <br /> 10 <br /> (r) Other definitions. For purposes of this chapter, "board," "regional board," "local <br /> 11 agency," "person," "unauthorized release," and facility" shall have the same meanings as <br /> defined in Section 25281. Any other term used in this chapter which is not defined by <br /> 12 this article has the same meaning as defined in Section 25281. (Cal. H & S Code <br /> § 25299.25) <br /> 13 <br /> 42. Defendant DOES 1 through 100 are connected and responsible for the acts complained of <br /> 14 <br /> below. Their real names are unknown at this time, and the People will amend this complaint at a <br /> 15 <br /> later date when the true identities of DOES 1 through 100 are discovered. <br /> 16 <br /> VI <br /> 17 <br /> FIRST CAUSE OF ACTION <br /> 18 <br /> Violations of Underground Storage Tank Laws (Health and Safety <br /> 19 Code § 25280 et.seq. and C.C.R. Title 23, Division 3) <br /> 20 43. Plaintiff reallege and incorporates herein as though fully set forth Paragraphs 1 through <br /> 21 42 this Complaint. Plaintiff is informed and believes and based on such information and belief <br /> 22 alleges that beginning at an exact date that is unknown to plaintiff, but within five (5) years (C.P. <br /> 23 §338.1) prior to the filing of this complaint, defendants have committed daily violations of <br /> 24 Health and Safety Code Chapter 6.7, including but not limited to: <br /> 25 43(a) Violation of any of the applicable requirements of the permit issued for the operation of <br /> 26 the underground tank system. (Health& Safety Code §25299(a)(2)); <br /> 27 43(b). Failure to maintain records, as required by this chapter. (Health and Safety Code <br /> 28 § 25299(a)(3)); <br /> H:\HO?AEWYOUNGlCA5MUNOCAL\COWLAIN,WPU 9 <br />