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i • <br /> III. The Date the Regional Board Acted <br /> The date of the Regional Board's action subject to review is July 24, 2006. <br /> IV. Statement of the Reasons the Action is Inappropriate and Improper <br /> The issues raised in this petition were presented to the Regional Board before its <br /> issuance of the Order. The issuance of the Order was beyond the authority of the <br /> Regional Board, inappropriate, improper, or not supported by the record, for the <br /> following reasons: <br /> A. The Order includes findings of fact that are not supported by substantial <br /> evidence in the record. <br /> B. The Order fails to identify additional potentially responsible parties for the <br /> groundwater plume subject to cleanup and abatement. <br /> C. The Order improperly specifies the design, location, type of construction, <br /> and particular manner in which compliance may be achieved, in violation of Water Code <br /> § 13360. <br /> D. The Order imposes water quality objectives, cleanup standards and/or <br /> triggers or goals for remedial action that are not supported by fact or law or supporting <br /> analysis and have not been adopted in accordance with applicable law. <br /> E. The Order imposes discharge limits for treated groundwater discharged <br /> into the City of Ripon's non-potable water system that are more stringent than maximum <br /> contaminant levels and public health goals for drinking water, not supported by fact or <br /> law or supporting analysis, have not been adopted in accordance with applicable law, and <br /> are inconsistent with the Monitoring and Reporting Program ("MRP") with which <br /> Petitioner is required to comply. <br /> F. The Order requires Petitioner to provide replacement water for a Caltrans <br /> irrigation well that is not"affected"because it consistently meets California maximum <br /> contaminant levels, in violation of Water Code § 13304(a) and the California <br /> Constitution, Article X, Section 2. <br /> G. The Order requires Petitioner to submit technical reports and perform <br /> investigations and corrective action under arbitrary and unreasonable timeframes. <br /> H. The Order fails to bridge the analytic gap, explaining the rationale for <br /> required actions by the Regional Board. <br /> V. Petitioner is Aggrieved <br /> Petitioner is aggrieved for the reasons set forth in paragraph IV above. <br /> 2 <br />