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I California Code of Regulations,title 23 section 2638(a); <br /> 2 d. Failed to perform annual line leak detector test, in violation of California Code of <br /> 3 Regulations, title 23 section 2638(a); <br /> 4 e. Failed to perform annual spill containment testing, in violation of Health and Safety <br /> 5 Code Section 25284.2; <br /> 6 f. Failed to maintain onsite the monthly reports of the designated operator for the <br /> 7 previous twelve(12)months in violation of California Code of Regulations, title 23 section 2715; <br /> 8 g. Failed to implement a current monitoring and response program approved by the <br /> 9 local agency,in violation of California Code of Regulations, title 23 section 2632(b); <br /> 10 h. Failed to have onsite a monitoring and response program approved by local agency <br /> 11 in violation of California Code of Regulations,title 23 section 2712(i); <br /> 12 i. Failed to maintain onsite the written monitoring and maintenance records for the <br /> 13 previous twelve(12)months in violation of California Code of Regulations, title 23 section 2712(b); <br /> 14 j. Failed to obtain an operating permit from the local agency in violation of Health <br /> 15 and Safety Code Section 25284 <br /> 16 <br /> 17 THIRD CAUSE OF ACTION <br /> 18 VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br /> 19 (UNLAWFUL AND/OR UNFAIR COMPETITION) <br /> 20 24. Paragraphs 1 through 21, above are incorporated herein by reference. Plaintiff is <br /> 21 informed and believes and based on such information and belief alleges that beginning at an exact <br /> 22 date that is unknown to Plaintiff,but within four(4)years prior to the filing of this Complaint(CCP <br /> 23 §338.1), Defendants have engaged in acts unlawful and/or unfair competition <br /> 24 prohibited by California Business and Professions Code, section 17200 et seq. by virtue of the acts <br /> 25 described herein, each of which constitutes an unlawful and/or unfair business practice. <br /> 26 25. The use of such unlawful and or unfair business practices constitutes unfair competition <br /> 27 within the meaning of California Business and Professions Code, section 17200 et seq. The <br /> 28 unlawful and/or unfair business practices committed by the Defendants include, but are not limited <br /> 6 <br />