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Neumiller & BeardsleeJAN 1 0 1^91 <br /> A PROFESSIONAL CORPORATION IRUNMENTAL HEMI++G ADDRESS: <br /> COUNsR Z P.O. 80X 20 <br /> FOUNDED AS ATTORNEYS AND EpRMIT/SER ' N. CALIFORNIA 95201-3020 <br /> ASHLEY 6 NEUMILLER PHONE(209)949-8200 <br /> JANUARY 1903 FIFTH FLOOR WATERFRONT OFFICE TOW FAY.(209)948-4910 <br /> 509 WEST WEBER AVENUE <br /> STOCKTON, CALIFORNIA 95203 <br /> 75376-17093 <br /> January 9 , 1991 <br /> Ms. Diane Hinson <br /> Mr. Gordon Boggs <br /> San Joaquin Local California Regional Water Quality <br /> Health District Control Board - <br /> Post Office Box 2009 Central valley Region <br /> Stockton, CA 95201 3443 Routier Road <br /> Sacramento, CA 95827-3098 <br /> Re: 102 S Wilson Way, Stockton <br /> Dear Ms. Hinson and Mr. Boggs: <br /> Our office represents the Roek Bros. who own the property <br /> located at 102 S. Wilson Way, Stockton. We are writing this <br /> letter to your two agencies jointly because our client requires <br /> direction from at least one of your agencies to proceed on this <br /> matter. In essence, our client, the identified PRP, is in <br /> "regulatory limbo" without either of your agencies regulating <br /> this site. <br /> The basis for this problem is that each of your agencies <br /> has separate policies which, in our clients case when working <br /> together, causes our client to slip through the cracks <br /> without <br /> any regulation. Because San Joaquin County is participating g the <br /> local oversite program, the Regional Board will not take any <br /> action on underground storage tanks within this County. <br /> However, the program acceptance of new sites in the local <br /> oversite program is restricted to those sites which had tanks in <br /> place on or after January 11 1984. The tanks at 102 S. Wilson <br /> Way were removed in 1978 leaving residual contaminates. <br /> Therefore, neither of your agencies are available to assist our <br /> client by reviewing reports concerning the characterization and <br /> remediation Of this site. <br /> The Roeks purchased the property in 1985 after the tanks <br /> had been removed. Therefore the Roeks have several reasons why <br /> they need regulatory oversight. The Roeks need oversight to <br /> recover against other responsible parties for their contribution <br /> to the contamination. Insurance policies may cover some of the <br /> damages and thus expenditures must be pursuant to governmental <br /> regulation. Finally, in the event our clients attempt to sell <br /> the property they will need governmental assessment of the <br /> contamination problem on the property prior to any sale. <br /> BOGGS.LTR/TXTBKB/3 <br />