EDWARDS, Judge.
On June 4, 1984, defendant/appellant, Witco Corporation (Witco), was issued an Order by the Department of Environmental Quality (DEQ) which placed it in an assessment mode, requiring it to submit a groundwater assessment plan. The Order was issued following a statistical triggering in contamination indicators for shallow groundwater at the facility, which was reported by Witco to DEQ. Witco responded to the Order on November 6, 1984 by submitting a...
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