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Benjamin E. Quayle [bquayle@hhqventures.com] 8/2/2017 4:21:17 PM Kelly, Albert [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=08576e43795149e5a3f9669726dd044c-Kelly, Albe] Re: Superfund Task Force Report--Troy Corp
Yes. Please let me know what time works for you. Thanks.
Sent from my iPhone
On Aug 2, 2017, at 10:00 AM, Kelly, Albert < keiiy.8lbert@epa.gov> wrote:
Thank you Congressman, would you have time for a call later this afternoon?
Albert Kelly Senior Advisor to the Administrator 1200 Pennsylvania Avenue, NW Washington, DC 20460 ! Ex! 6 I
From: Benjamin E. Quayle [mailto:bquayle@hhqventures.com1 Sent: Wednesday, August 2, 2017 11:44 AM To: Kelly, Albert <kelly.albert@epa.gov>; Falvo, Nicholas <falvo.nicholas@epa.gov> Cc: Rashid G. Hallaway <rhanaway@hhqvenfures.com>; Dewey, Amy <Dewey.Amy@epa.gov> Subject: Superfund Task Force Report--Troy Corp
Albert/Nick,
Congratulations on completing the Superfund Task Report. I am eager to see the report's recommendations implemented soon.
In that regard, we reviewed the Report and noticed that several recommendations in the Task Force Report support allowing Troy to proceed quickly to final remedy selection. Some of the recommendations and how it fits into Troy's plan are noted below.
< I--[if !supportLists]--x!--[en d if]-->Recommendation 1: Establish metrics on all sites to track progress, including PRP lead, length of time to estimated partial or complete deletion, costs anticipated, etc.; Develop project timelines and exit strategies; and, track and report progress on achieving/meeting timelines.
o < I--[if supportLists]-->< !--[endif]-->7roy has requested that Region 2 agree to an expedited schedule to achieve remedy selection and implementation.
< I--[if IsupportLists]--><!--[endif]-->Recommendation 5: Clarify Priorities for RI/FS Resources.
o < I--[if IsupportLists]--> < !--[endif]-->7roy believes sufficient information exists to develop a complete RI/FS without significant additional work. Additional data requested by USEPA Region 2 is not likely to change the outcome.
Sierra Club v. EPA 18cv3472 NDCA
Tier 7
ED 002061 00115785-00001
<!--[if !supportLists]--x!--[endif]-->Recommendation 16: Develop a plan to provide financial incentives in the form of reduced oversight to PRPs who perform timely, quality work under an agreement by reducing the costs associated with EPA's oversight, including adjustments to indirect costs. Establish and promote strict adherence to project deadlines.
o <!--[if supportLists]-->< !--[endif]-->7roy has proposed a schedule to Region 2 that includes deadlines applicable to all parties.
<!--[if IsupportLists]--><!--[endif]-->Recommendation 21: Facilitate site redevelopment during cleanup by encouraging PRPs to fully integrate and implement reuse opportunities into investigations and cleanups of NPL sites.
o <!--[if supportLists]-->< --[endif]-^Troy's approach to the investigation and remediation of its Newark site will allow for the continuation and expansion of chemical manufacturing operations. Other approaches, even if possible, would jeopardize these operations.
Troy is prepared to address contamination pursuant to the cost-effective approach contemplated by the Task Force Report. We appreciate your work on these matters and look forward to working with the EPA to remedy the issues at Troy's site. Please let me or Rashid know if you have any questions or comments.
Best,
Ben Quayle
Hon. Ben Quayle Partner HHQ Ventures, LLC M: Ex. 6
Sierra Club v. EPA 18cv3472 NDCA
Tier 7
ED 002061 00115785-00002