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I e. Failed to install automatic line leak detectors on underground pressurized piping <br /> 2 capable of detecting 3-gallon per hour leak rate at 10 psi, in violation of California Code of <br /> 3 Regulations,title 23 section 2636(f)(2); <br /> 4 f. Failed to perform periodic testing of secondary containment system,in violation of <br /> 5 California Code of Regulations,title 23 section 2637(a); <br /> 6 g. Failed to submit a completed Monitoring System Certification form to the local <br /> 7 agency within thirty(30)days after completion of the inspection,in violation of California Code of <br /> 8 Regulations,title 23 section 2638(d); <br /> 9 h. Failed to maintain written monitoring and maintenance records on-site for a period <br /> 10 of at least three(3)years, in violation of California Code of Regulations,title 23 section 2712(b); <br /> 11 i. Failed to review the alarm history report or log for the previous month,and check <br /> 12 that each alaim condition was documented and responded to appropriately by the designated <br /> 13 underground storage tank operator,in violation of California Code of Regulations,title 23 section <br /> 14 2715(c)(1); <br /> 15 j. Failed to check that all required testing and maintenance for the underground <br /> 16 storage tank system have been completed,and document the dates these activities occurred,in <br /> 17 violation of California Code of Regulations,title 23 section 2715(c)(5);and <br /> 18 k. Failed to maintain a copy of the monthly inspection record and all attachments for <br /> 19 the previous twelve(12)months,in violation of California Code of Regulations,title 23 section <br /> 20 2715(e). <br /> SECOND CAUSE OF ACTION <br /> 21 <br /> VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 22 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 23 13. Paragraphs l through 12,above are incorporated herein by reference. Plaintiff is <br /> 24 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 25 date that is unknown to Plaintiff,but within four(4)years prior to the filing of this Complaint(B&P <br /> 26 17208),Defendants have engaged in acts unlawful and/or unfair competition prohibited by California <br /> 27 Business and Professions Code,section 17200 et seq. by virtue of the acts described herein,each of <br /> 28 which constitutes an unlawful and/or unfair business practice. <br /> -4- <br /> VERIFIED COMPLAINT FOR INJUNCTION,CIVIL PENALTIES,AND OTHER RELIEF <br />