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1 contamination is detected, assessment and removal of such <br /> 2 contaminated soil is required. Such assessment and removal of <br /> 3 contaminated soil can be very costly. <br /> 4 Defendants, as licensed contractors, excavated and removed <br /> 5 underground tanks. Defendants would submit plans to the County <br /> 6 Health Department indicating how the tank removal and soil <br /> 7 testing were to be performed. The Health Department required <br /> 8 notice be given prior to any soil sampling so that such sampling <br /> 9 could be observed by Health Department personnel. <br /> 10 In violation of several laws, as detailed herein, <br /> 11 defendants would, prior to the arrival of the Health Department, <br /> 12 apply a product called "Simple Green" on the soil where sampling <br /> 13 was to take place. The purpose of the application of Simple <br /> 14 Green was to mask or move petroleum contamination so that such <br /> 15 contamination would not be found by the tests. In soliciting <br /> 16 for tank removal contracts, defendants would guarantee "clean <br /> 17 tests" . <br /> 18 These illegal applications of "Simple Green" occurred at <br /> 19 various sites in San Joaquin County where underground gasoline <br /> 20 tanks were removed, including Canepa' s Car Wash, Hunter and Park <br /> 21 Streets, Stockton; Valley Motors, Main and Grant Streets, <br /> 22 Stockton; Major Mart, West Lane and Alpine, Stockton; Klud+ <br /> 23 Petroleum, Lodi; Siebold Corporation, 820 South American, <br /> 24 Stockton; 3422 South B1 Dorado Street, Stockton; Brysons Heat <br /> 25 and Air Conditioning, 907 South Wilson, Stockton. <br /> 26 <br /> 27 <br /> 28 <br /> 4 <br />