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,wool L <br /> 1 FIRST CAUSE OF ACTION <br /> 2 VIOLATIONS OF HEALTH AND SAFETY CODE <br /> 3 SECTION 25280 ET SEQ. (UNDERGROUND STORAGE OF <br /> 4 HAZARDOUS MATERIALS) <br /> 5 8. Plaintiff is informed and believes and based on such information and belief <br /> 6 alleges that beginning at an exact date that is unknown to plaintiff, but within five (5) years prior <br /> 7 to the filing of this complaint(CCP §338.1), defendants engaged in violated Health and Safety <br /> 8 Code Chapter 6.7, including but not limited to: <br /> 9 a. Operating gasoline pumps without a permit after January 1, 2003, in <br /> 10 violation of Health and Safety Code §25284(a)(1). <br /> 11 b. Operating facility without a current certification of financial responsibility, <br /> 12 in violation of Health and Safety Code § 25292.2(a). <br /> 13 c. Failure to complete secondary containment testing by January 1, 2003, in <br /> 14 violation of 22CCR §2637(a). <br /> 15 d. Failure to have current owner information in the facility file, in violation <br /> 16 of 22CCR §271 l(b). <br /> 17 e. Failure to submit monitoring and response plan to local agency for <br /> 18 approval, in violation of 22CCR §2632(b). <br /> 19 f. Failure to have monitoring and response plan at the facility on July 1, <br /> 20 2002, during routine inspection, in violation of 22CCR §2712(i). <br /> 21 g. Failure to have EPA Identification Number for the facility, in violation of <br /> 22 22CCR§66262.12(a). <br /> 23 h. Failure to have spill control equipment at the facility, in violation of <br /> 24 22CCR §66265.32(c). <br /> 25 i. Failure to have hazardous waste emergency information posted by the <br /> 26 telephones at the facility, in violation of 22CCR §66262.34(d)(2). <br /> 27 <br /> 28 <br /> H:\IOMBEANTOLINIUST,QU[CKU(L.WPD 3 <br />