You have been cited with a deficiency. You do not understand why it is being handled the way you are being told to handle the problem.
You wonder if you have the grounds for an appeal.
You have a short length of time to find out and research and process the Appeal and send it to licensing.
Do not waste time wondering. Call RCFC, Inc. immediately. Arrange for a consultation to determine the availability of sending an appeal and getting it completed and sent to CCLD during the 10 day window of time you have to process for the Appeal.