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1 4. CONCLUSION. <br /> ,.� 2 In conclusion, the Health Department's Order and its <br /> 3 refusal to grant Petitioner's request; for case closure (1) are <br /> 4 not supported by the large quantities of competent Site data, <br /> 5 (2) conflict with established state standards for UST removal and <br /> 6 remediation under the local oversight program, and (3) constitute <br /> 7 an unconstitutional deprivation of Petitioner's fundamental. <br /> 8 property interest. For the reasons set forth above, Petitioner <br /> 9 respectfully requests that the Board rescind the Health. <br /> to Department's order and grant closure in this case. <br /> 11 DISTRIBUTION <br /> 12 A copy of this petition has been sent to Jogi Khanna & <br /> 23 Donna Heran of the Department of Public Health Services for San. <br /> 14 Joaquin County, and to Elizabeth Thayer of the Central. Valley <br /> 15 Regional water Quality Control Board. <br /> 16 INTERESTED PARTIES AND AGENCY RECORD <br /> 17 Attached as Exhibit C-1 is a copy of the request to Linda <br /> 18 Turkatte of the Health Department to prepare the local agency <br /> 19 record and submit a list of interested parties. Attached as <br /> 20 Exhibit C-2 is a copy of the Health Department's response to our <br /> 21 request. <br /> 22 <br /> DATE: October 15, 1993 WILSON, SONSINI, GOODRICH & ROSATI <br /> 23 <br /> 24 VivZa M "" <br /> Clausi , <br /> 25 Attorneys. For Petitioner, <br /> COLOR SPOT,INC <br /> 26 <br /> 27 <br /> s <br /> 28 <br /> 14- N\UNC\C0L0RSPT\APPEAL.PL4(5P2) <br />