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Ms. Laurie Casias <br /> September 3, 1993 <br /> Page 10 <br /> the following: <br /> (A) Name the Adjacent Landowners as additional responsible <br /> parties for groundwater contamination; <br /> (B) Authorize the implementation of a workplan to <br /> investigate and confirm the relationship between the soil and <br /> groundwater contamination at the Site, and direct PHS/EHD to <br /> respond to that workplan and terminate requests for groundwater <br /> investigation upon establishment of a lack of connection; <br /> (C) Confirm that the Petitioner is secondarily liable for <br /> contamination at the Site and require the primary responsible <br /> parties to undertake investigation and remediation at the Site. <br /> In the alternative, if the State Board denies our requests, <br /> Petitioner requests that the State Board remove the Petitioner <br /> from the LOP and begin proceedings for issuance of a Cleanup and <br /> Abatement Order pursuant to Section 13304 of the Water Code. <br /> (7 ) POINTS AND AUTHORITIES IN SUPPORT OF PETITIONER'S REQUEST <br /> See Attachment 1. <br /> ( 8) LIST OF INTERESTED PERSONS <br /> On August 30, 1993, Petitioner requested PHS/EHD to supply <br /> Petitioner with a list of those persons known by it to have an <br /> interest in the subject matter of the petition. As soon as <br /> Petitioner receives the list, we will forward it to the State <br /> Board. <br /> (9) PETITION SENT TO OTHER INTERESTED PARTIES <br /> This petition has been sent to the following parties: <br /> 1. Donna Heran, REHS, Program Manager <br /> San Joaquin County Public Health Services, <br /> Environmental Health Division <br /> Post Office Box 2009 <br /> Stockton, CA 95201 <br /> 2 . Beth Thayer, Esq. <br /> Regional Water Quality Control Board, <br /> Central Valley Region <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3089 <br /> F:\TM\17093\D\ROHR3.RHH <br /> 75376-17093/®/09/03/93/4 <br />