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SEP 0 4 1992 <br /> August 31 , 1992 ENVIRONMENTAL HEALTH <br /> HERMIT/SCRYIQF_5 <br /> Mary Meays , EHS <br /> Environmental Health Division <br /> Public Health Services <br /> San Joaquin County <br /> P.O. Box 24639 <br /> Stockton, CA 95241 <br /> RE: SITE CODE #1828 <br /> Dear Ms. Meays : <br /> Per your instructions , I am writing to request an <br /> extension of the September 1st drilling timetable for <br /> the subject site until such time as we are able to <br /> access the needed funds from the Underground Storage <br /> Tank Cleanup Fund (USTCF) . We have been involved <br /> since April in a series of ongoing appeals to the <br /> State Water Resources Control Board. We are strongly <br /> convinced that they have been seriously remiss in <br /> their procedures and determinations . Initially they <br /> placed us in Priority Class D, then moved us to <br /> Priority Class C upon appeal , but declined to move us <br /> into Priority Class B where we firmly believe we <br /> belong. This week we are completing our final appeal <br /> to the full Board at which time we hope to be able to <br /> present our appeal in person. The issues , while not <br /> complex, are subtle and require the USTCF to study and <br /> treat our application individually rather than . . . <br /> without fully grasping our reasoning. . , to shunt us <br /> into a pre-existing category. Hopefully, a face to <br /> face discussion will accomplish this individualized <br /> evaluation of our situation. So that you might be . <br /> fully apprised of the issues we are confronting and <br /> the specifics of our appeal as well as the USTCF' s <br /> responses to date, I have enclosed copies under <br /> separate cover of all related correspondence. Next <br /> week, I will also send you a copy of our final appeal . <br /> We are in need of a further extension of your request <br /> that we initiate clean-up efforts on our property, in <br /> that we do not have the funds available to undertake <br /> such an expensive and open-ended project. As our <br /> appeal outlines , we are a small business with <br /> declining revenues in this recession and cannot afford <br /> a project of this magnitude. As you know we have over <br /> a 25`/o vacancy rate at the Waterloo site with our lead <br /> buildings immediately adjacent to the clean up site <br /> having been vacant for over a year and a half. While <br /> our gross revenues may sound impressive, the reality <br /> of our business is that large mortgages , maintanence <br /> and repair costs coupled with extraordinary vacancy <br /> rates in the past few years have left us with little <br />