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1 §338.1),Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., <br /> 2 including but not limited to the following: <br /> 3 a. Failed to annually test the spill containment structure,in violation of Health and <br /> 4 Safety Code section 25284.2; <br /> 5 b. Failed to prevent structural weakening of secondary containment, in violation of <br /> 611 Health and Safety Code section 25291(a)(2); <br /> 7 c. Failed to design and construct an underground storage tank system with a <br /> 8 monitoring system capable of detecting the entry of the hazardous substance stored in the primary <br /> 9 containment into the secondary containment, in violation of Health and Safety Code section <br /> 10 25291(b); <br /> 11 d. Failed to maintain evidence of financial responsibility, in violation of Health and <br /> 12 Safety Code section 25292.2(a); <br /> 13 e. Failed to install and maintain monitoring equipment capable of detecting a leak at <br /> 14 the earliest possible opportunity, in violation of California Code of Regulations,title 23 section <br /> 15 2630(d); <br /> 16 f. Failed to equip underground storage tank with a spill container and an overfill i <br /> 17 prevention system, in violation of California Code of Regulations,title 23 section 2635(b)(1); <br /> 18 g. Failed to perform annual certification of monitoring equipment, in violation of <br /> 19 California Code of Regulations,title 23 section 2638(a); <br /> 20 h. Failed to perform annual line leak detector test of monitoring equipment, in <br /> 21 violation of California Code of Regulations,title 23 section 2638(a); <br /> 22 i. Failed to record or report any unauthorized release from the underground storage <br /> 23 tank,and any spill or overfill, in violation of California Code of Regulations,title 23 section <br /> 24 2650(b); <br /> 25 j. Failed to maintain written monitoring and maintenance records on-site, in violation <br /> 26 of California Code of Regulations,title 23 section 2712(b); <br /> 27 k. Failed to identify and submit a signed statement to the local agency indicating the <br /> 28 4 <br /> VERIFIED COMPLAINT <br />