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- a <br /> d . <br /> 1 MORGAN, LEWIS & BOCKIUS LLP <br /> 2 ANTHONY O. GARVIN (STATE BAR NO. 80953) <br /> One Market, Spear Street Tower <br /> 3 San Francisco, CA 94105 <br /> Telephone: (415) 442-1620 <br /> 4 Facsimile: (415)442-1001 <br /> 5 Attorneys for Appellants <br /> 6 Tandy Corporation and RadioShack Corporation <br /> 7 <br /> 8 BEFORE <br /> THE SAN JOAQUIN COUNTY <br /> 9 SOLID WASTE INDEPENDENT HEARING PANEL <br /> 10 <br /> 11 In the Matter of- ) Order No. 04-01 <br /> 12 WORLD ENTERPRISES SITE, ) NOTICE OF APPEAL,REQUEST <br /> SWIS #39-CR-0033 ) FOR ADMINISTRATIVE HEARING <br /> 13 ) AND INITIAL STATEMENT OF <br /> 14 ) ISSUES <br /> 15 <br /> This administrative appeal and request for hearing is submitted by and on behalf of Tandy <br /> 16 <br /> 17 Corporation and RadioShack Corporation(hereafter referred to as "RadioShack") from (1)the <br /> 18 Notice and Order No. 04-01 issued by the San Joaquin County Environmental Health Department <br /> 19 ("hereafter referred to as "Department') dated October 25, 2004 (Attached hereto as Exhibit A) <br /> 20 and(2)the Department's letter dated November 15, 2004 rejecting the URS Remediation Plan for <br /> 21 the site. (Attached hereto as Exhibit B). Although the Order is dated October 25, 2004 it was not <br /> 22 received by RadioShack until November 8, 2004. <br /> 23 <br /> The contested Order alleges that RadioShack has violated sections 20919 and 20919.5 of <br /> 24 <br /> 25 Title 17 of the California Code of Regulations. 17 CCR §20919 and § 20919.5. In particular, the <br /> 26 Order alleges that RadioShack has, inter alia, failed to submit an adequate Remediation Work <br /> 27 Plan which meets the requirements of the sections 20919—20937 of Title 17 of the California <br /> 28 Code of Regulations with respect to methane gas concentrations at the closed World Enterprises <br /> -1-SF/7170386.1 <br /> Notice of Appeal,Request for Administrative Hearing& Initial Statement of Issues <br />