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1 controlling load rack spills (the sump pump) has been periodi- <br /> 2 cally inoperable from April 1982 until the date of filing the <br /> 3 complaint . <br /> 4 3 ) Violation of §79 .807(a ) ( 8 ) in that defendants <br /> 5 failede to provide means to prevent overfill in that the ground <br /> 6 plug which is designed to measure the liquid level has been ino- <br /> 7 perable as of July 2, 1986 until the date of filing the <br /> 8 complaint . <br /> 9 iii . Defendants, and each of them, violated the provi- <br /> 10 sions of §4-008 . 5 of the Stockton Municipal Code; said acts <br /> 11 include but are not limited to the following violations of said <br /> 12 provisions : <br /> 13 1 ) Violation of §4-008 . 5 in that defendants have <br /> 14 transferred fuel without having alarms capable of alerting per- <br /> 15 sonnel of hazardous fill conditions , in that defendants have <br /> 16 intentionally attached weights to the high level alarms on the <br /> 17 tanks rendering them inoperable . <br /> 18 i ) Violation of §67140 in that defendants have no con- <br /> 19 tingency plan designed to minimize hazards to human health or the <br /> 20 environment from release of hazardous waste or hazardous waste <br /> 21 constituents to air, soil, or surface water; <br /> 22 j ) Violation of §67142 in that no copy of a contingency <br /> 23 plan as required by §67140 has been submitted to local police <br /> 24 departments, fire departments, hospitals , and state and local <br /> 25 emergency response teams that may be called upon to provide <br /> 26 emergency services . <br /> 27 k ) Violation of 567163 in that defendants failed to main- <br /> 28 tain a written operating record and a map or diagrams describing <br /> 9 . <br />