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1 FIRST CAUSE OF ACTION <br />2 VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br />3 (UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br />4 16. Plaintiff is informed and believes and based on such information and belief, alleges that <br />5 beginning at an exact date that is unknown to Plaintiff, but within five (5) years prior to the filing of <br />6 this Complaint (CCP §338.1), Defendants engaged in acts in violation of Health and Safety Code, <br />7 section 25280 et seq., including but not limited to the following: <br />g a. Failed to annually test the spill contaimnent structure, in violation of Health and <br />9 Safety Code section 25284.2; <br />10 b. 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 />12 containment into the secondary containment, in violation of Health and Safety Code section <br />13 25291(b); <br />14 c. Failed to annually perform automatic line leak detector tightness test, in violation <br />15 of Health and Safety Code section 25291(f); <br />16 d. Failed to maintain evidence of financial responsibility, in violation of Health and <br />17 Safety Code section 25292.2(a); <br />18 e. Illegally abandoned or closed or temporarily ceased to operate an underground tank <br />19 system, in violation of Health and Safety Code section 25298(a); <br />20 f. Failed to install and maintain monitoring equipment capable of detecting a leak at <br />21 the earliest possible opportunity, in violation of California Code of Regulations, title 23 section <br />22 2630(d); <br />23 g. Failed to implement a monitoring program approved by the local agency and <br />24 specified in the underground storage tank operating permit, in violation of California Code of <br />25 Regulations, title 23 section 2632(b); <br />26 h. Failed to install and maintain monitoring system in the interstitial space of a double <br />27 walled underground storage tank, in violation of California Code of Regulations, title 23 section <br />28 2632(c)(2); <br />VEVIFIETS CO i 1' i' 1 ! <br />