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1 <br />2 <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 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />a. Failed to annually test the spill containment structure, in violation of Health and <br />I Safety Code section 25284.2; <br />b. Failed to maintain evidence of financial responsibility, in violation of Health and <br />Safety Code section 25292.2(x); <br />c. Failed to implement a monitoring program approved by the local agency and <br />specified in the underground storage tank operating permit, in violation of California Code of <br />Regulations, title 23 section 2632(b); <br />d. Failed to perform periodic testing of secondary containment system, in violation of <br />California Code of Regulations, title 23 section 2637(x); <br />e. Failed to perform annual monitoring certification and leak detector testing, in <br />violation of California Code of Regulations, title 23 section 2638(a); <br />f. Failed to submit a completed Monitoring System Certification form to the local <br />agency, in violation of California Code of Regulations, title 23 section 2638(d); <br />g. Failed to record or report any unauthorized release from the underground storage <br />tank, and any spill or overfill, in violation of California Code of Regulations, title 23 section <br />2650(b); <br />h. Failed to maintain written monitoring and maintenance records on-site, in <br />violation of California Code of Regulations, title 23 section 2712(b); <br />i. Failed to identify and submit a signed statement to the local agency indicating the <br />designated underground storage tank operator for each facility, in violation of California Code of <br />Regulations, title 23 section 2715(x); <br />J. Failed to maintain a copy of the monthly inspection record and all attachments for <br />the previous twelve months, in violation of California Code of Regulations, title 23 section 2715(e). <br />THIRD CAUSE OF ACTION <br />VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTIONS 17200 ET SEQ. <br />(UNLAWFUL AND/OR UNFAIR COMPETITION) <br />11. Paragraphs 1 through 10, above are incorporated herein by reference. Plaintiff is <br />S <br />VERIFIED COMPLAINT <br />