CALLAND CLEMENTS ZOMNIR Linpsavr
CALLAND CLEMENTS ZOMNIR LINPSAVr. HOVC'ARP May 14, 1999 VIA FEDERAL EXPRESS Frank Klanchar (3HW22) United States Environmental Protection Agency Region III 841 Chestnut Building Philadelphia, PA 19107-4431 RE: Welsh Road/Bartaan Landfill Superfund Site Administrative Order for Remedial Action (Docket No. III-99-012-DC) Dear Mr. Klanchar: I. Introduction On or about March 19, 1999, the United States Environmental Protection Agency ("EPA" or the "Agency") issued an Administrative Order for Remedial Action (Docket No. III-99-012-DC) (the "Order") to fourteen (14) respondents (collectively, the "Respondents"), including Ecolaire Incorporated ("Ecolaire"), directing those parties to, inter .alia, implement certain remedial activities at the Welsh Road Superfund Site located in Chester and Lancaster Counties, Pennsylvania (the "Site"). Pursuant to Section XXV of the Order, EPA directed each Respondent to provide notice to EPA's Remedial Project Manager stating whether the Respondents would comply with the terms of the Order. Although the Order required such notice to be provided no later than two (2) days after the effective date of the Order, through mutual agreement among the parties, this deadline was extended to May 17, 1999. The purpose of this letter is to communicate Ecolaire's current intentions with respect to the Order, and, subject to the reservations below, to set forth a description of the "sufficient cause" defenses that are known to Ecolaire at the time of this letter. See Sections 106 and 107 of the Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA"), 42 U.S.C. §§9606;and 9607." """ Twu Gareviii\ Center ir-ih, P«nn*vK.mici 4i: «4o40C " Fax 41- ^4-6576' AROUI725 Frank Klanchar May 14, 1999 Page 2 II.
[Show full text]