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11 <br />21 <br />3 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 1 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />Code of Regulations, title 22 section 66273.15; <br />i. Stored hazardous waste onsite for more than 180 days, in violation of California <br />Code of Regulations, title 22 section 66262.34(d); <br />SECOND CAUSE OF ACTION <br />VIOLATION OF HEALTH AND SAFETY CODE SECTION 25280 ET SEQ. <br />(UNDERGROUND STORAGE OF HAZARDOUS SUBSTANCES) <br />11. Paragraphs 1 through 10, above are incorporated herein by reference. Plaintiff is <br />informed and believes and based on such information and belief alleges that beginning at an exact <br />date that is unknown to Plaintiff, but within five (5) years prior to the filing of this Complaint (CCP <br />§338.1), Defendants engaged in acts in violation of Health and Safety Code, section 25280 et seq., <br />including but not limited to the following: <br />a. Failed to perform secondary containment testing in violation of California Code of <br />Regulations, title 23 section 2637; <br />b. Failed to maintain evidence of financial responsibility, in violation of Health and <br />Safety Code section 25292.2(a); <br />c. Failed to have onsite a monitoring and response program approved by local agency <br />in violation of California Code of Regulations, title 23 section 2712(i); <br />d. Failed to maintain a list of facility employees trained by the designated <br />underground storage tank operator on-site, in violation of California Code of Regulations, title 23 <br />section 2715(f)(3); <br />e. Failed to perform annual certification of monitoring equipment, in violation of <br />California Code of Regulations, title 23 section 2638(d); <br />f. Failed to perform annual line leak detector test, in violation of California Code of <br />Regulations, title 23 section 2638(a); <br />g. Failed to implement a current monitoring and response program approved by the <br />local agency, in violation of California Code of Regulations, title 23 section 2632(b); <br />h. Failed to keep primary containment product tight in violation of California Code of <br />Regulations, title 23 section 2631(a); <br />4 <br />VERIFIED COMPLAINT FOR INJUNCTION, CIVIL PENALTIES, AND OTHER RELIEF <br />