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Telephone LAW OFFICES OF FAX <br /> (916)972-1791 DARYL B. KATCHER (916)972-1856 <br /> ATTORNEY AT LAW <br /> 3415 American River Drive P.O.Box 661704 <br /> Suite D <br /> Sacramento,CA 95864 Sacramento,CA 95866.1704 <br /> August 24 , 1990 <br /> Mr. Val F. Siebal <br /> Regional Administrator <br /> Toxic Substances Control Program . V,11, zu <br /> Department of Health Services <br /> 10151 Croydon Waykm <br /> . <br /> Sacramento, California 95827 AUG 98 <br /> Mr. Ronald L. Valinoti, Director EN'J�ROf�ME!� ;,�,L HEAL <br /> Public Health Services PERIMM'SE:RVICE� <br /> San Joaquin County Environmental Health Division <br /> P.O. Box 2009 <br /> Stockton, California 95201 <br /> Re: RESPONSE TO NOTICE OF REMEDIAL <br /> ACTION ORDER FOR LODI AIRPORT <br /> Dear Gentlemen: <br /> The following is submitted in partial response to the <br /> Notice of Remedial Action Order (RAO) for Lodi Airport, dated 7 <br /> June 1990. <br /> The above-referenced RAO alleges Robert E. Kupka as owner <br /> of Lodi Airport a responsible party (TSP) as defined by Health and <br /> Safety Code Section 253235 and 25385. 1(8) . <br /> Robert E. Kupka denies that he is a responsible party as <br /> that term is defined in 42 U.S. Code Section 9607 (a) for any <br /> claimed hazardous waste storage and/or disposal as more fully <br /> described in the RAO. Based upon such denial, this alleged RP <br /> disclaims that he is subject to the RAO. <br /> Respondent bases his disclaimer of the liability ascribed <br /> to him by the RAO in whole or in part, on the following <br /> defenses, and without prejudice to assert other and further <br /> defenses that may be subsequently determined to be applicable: <br /> (1) That pursuant to Comprehensive Environmental <br /> Response, Compensation and Liability Act of 1980 (CERCLA) , as <br /> amended by the Superfund Amendments and Reauthorization Act of <br />