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Ms . Wendy Wyels <br /> December 28 , 1994 <br /> Page 2 <br /> appreciate copies . If not, then the alleged NOVs do not <br /> exist, and we would appreciate correction of your records <br /> to remove this basis for requesting an investigation at <br /> the Koppel Stockton Terminal. We want to clarify that our <br /> client is not and has not been an offender of air <br /> regulations . <br /> Recently the Regional Water Quality Control Board <br /> approved a workplan submitted on November 1, 1994, for <br /> site investigation. After reviewing the information <br /> contained in the San Joaquin Valley Unified Air Pollution <br /> Control District files , it is apparent that the basis for <br /> requesting that the owner of the Koppel Stockton terminal <br /> conduct an investigation is erroneous ; therefore, there is <br /> absolutely no basis for the Regional Water Quality Control <br /> Board to request an investigation at our client' s expense. <br /> If the investigators at the PM Ag Site believe that the <br /> contamination originates on the Koppel Stockton Terminal <br /> Property, they should pay for the costs of investigating <br /> and proving their theory. The mere fact that fertilizers <br /> were loaded on this property is not enough to require the <br /> owner to spend thousands of dollars investigating problems <br /> relating to another site. Our client will continue to <br /> cooperate with the Regional Water Quality Control Board <br /> but requests retraction of the requested work in light of <br /> the corrected information obtained from the San Joaquin <br /> Valley Unified Air Pollution Control District. <br /> Should you have any questions or comments, please do <br /> not hesitate to call. <br /> Sincerely yours , <br /> ��a <br /> LEAH S . GOLDBERG <br /> - -L <br /> Attorney at aw <br /> LSG:ect <br /> Enclosure <br /> cc : Dan Munzer <br /> Paul Sundbera <br /> Diane Hinson <br /> 25134-1 <br />