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FIRST CAUSE OF ACTION <br /> 1 <br /> VIOLATIONS OF HEALTH AND SAFETY <br /> 2 <br /> CODE SECTIONS 25100 et seq. <br /> 3 <br /> 4 (Hazardous Waste Control Act) <br /> 5 8 . The rules and regulations issued under and pursuant to <br /> the California Hazardous Waste Control Act are set forth in <br /> 6 <br /> Title 22 of the California Code of Regulations (CCR) Section <br /> 7 <br /> 8 66001 et seq. Petroleum products referred to herein meet the <br /> 9 definition of hazardous waste as defined in said regulations <br /> 10 and/or Health and Safety Code §§ 25117 and 25250. 4 . <br /> 11 9 . Defendants, beginning ata date unknown to Plaintiff, <br /> 12 but within five years from the date of filing of this complaint <br /> 13 (CCP § 338 . 1) , and continuing through this date have operated in <br /> 14 violation and aided and abbetted the violation of the laws of <br /> 15 the State of California as set forth more fully herein. <br /> 16 10. Defendants violated the provisions of Section 25189 (b) , <br /> 17 c) and/or (d) of the California Health and Safety Code by <br /> 18 violating the Hazardous Waste Control Act. Said violations <br /> 19 include, but are not limited to, the following: <br /> 20 a. Violations of Health and Safety Code § 25201: Treatment <br /> 21 of hazardous wastes without a permit by application of "Simple <br /> 22 Green" onto soil for the purpose of treating petroleum <br /> 23 contamination. <br /> 24 b. Violations of Health and Safety Code § 25189 . 2 : <br /> 25 Disposing or causing the disposal of a hazardous waste as a <br /> 26 point not authorized for said disposal, to-wit: causing the <br /> 27 movement of petroleum waste in soil and/or fraudulent <br /> 28 concealment of the presence of hazardous waste. <br /> 5 <br />