HomeMy WebLinkAbout2008-09-08 08-294 ORDERCOUNCIL AMON
Ud 294
Item No,
Date: September 8, 2008
]tem/Subject ORDER, Authoring the City Manager to Execute the West Site/Hows Comer
Superfund Tolling Agreement and Plymouth Site Tolling Escrow Memorandum
Responsible Deparb M: Legal
The City of Bangor u a potentially Responsible Parry (PRP) for a suWrfund site in Plymouth,
Maine and has been part of the Joint Defense Group that has been negotiating with the EPA and
Maine DEP since 1898.
The EPA and DEP have a claim for $1,000,000 In Past costs. In 2007, the City and other PRFs
executed a Tolling Agreement extending the time by which the EPA and DEP might bring suit to
attempt to collect those costs. The EPA is now requesting, and the PRP Group Executive
Committee recommends, execution of another Tolling Agreement edending the statute of
limitations for bringing a suit to June 30, 2009. It Is in the City's and other PRFs best interest to
avoid the EPA formally filing suit as continuing negotiations give the Joint Defense Group the
opportunity W continue m have Input in the final settlement.
The Tolling Agreement will only be accepted by EPA if at least 36 PRFs representing 37,000
Sollars of waste participate. The PRP group has, therefore, drafted an escrow agreement W
allow the PRP group W retain each PRFs signature page until this threshold has been met. If R
Is not met, the signature pages will be returned and no PRP will toll the sbhte of limitations.
This ensures that the oversight casts are shared by a substarldal group of PRK
This Order will authorize the execution of both documents.
Department Head
This has been reviewed and Is recommended by the Finance Committee. %Li//en_ / LY
_. f/
City Manager
France Director
Solidtor
Introduced for
_Y Passage
_ Firth Reading
Referral
Assigned ro Councilor palmi aepte er 8, 2008
CITY OF BANGOR
(TREE.) ORDER Authorizing the City Manager to Execute the West Ste/Homs Corner
Superfund Tolling Agreement and Plymouth Site Tolling Escrow Memorandum
Sy the oty cwmt of the Cty ofRengo,:
ORDERED,
That the City Manager Is hereby authorized, on behalf of the City of Bangor, to execute a West
Site/Howl Caner Superfund Site Tolling Agreement with the United States Environmental
Proteddon Agency and the Plymouth Site Tolling Escrow Agreement in relation to the Lbws
Comer, Plymouth superfund site negotiations. These documents shall be in a form substantially
as attached hereto and in a final form as approved by the City Solicitor or Assistant City
SOIKItor.
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Septeutie= 8, 2008
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WMI SITELDO WS CORNER SUPERFLIND
LINO AgREafta -
This Tolling Agreement is added into on this 12th day of August, 2008 between the
United Stmea of America ("United States') on behalf of the United Steles Erwhopm anal
Protection Agency CEPA"), and the Suee of Maine C'Maine') on behalf of the Maine
Department of Environmental Production ("DEn, and the potemiedly responsible party that has
signed this agreement ("Cooperating Party').
WHEREAS, EPA and DEP anduded response activities and thereby incurred response
costs related 10 the release or direst of release of hazardous substmoas at the West SitelHows
Cmnm Supatund Site ("Site"), located at Plymouth, Maim.
WHEREAS, the United States addends that it has claims; against Cooperating Perry
purswas to Sections 107 and 113 of the Comprebevdve EvviromnenW Response,
Compensation, and UBKUY Act C'CERCLA'), as amended 42 U.S.C. §§ 96('1 and 9613 for the
recovery ofrnpmise asti and for mount resource damages ("To0ed Claims').
WHEREAS, Maine contends that it bas claims against Cooperating Parry Pursuant w
Sections 107 and 113 of the Comprehensive Environmental Response, Compensation, and
Uahitity Ad C'CERCLA'), as amendnd, 42 U.S.C. §§ 960 and %13, 38 MRSA § 1367 and
OUT Sesta laws for the recovery Ofresponsa ends mal for natural reaurce damages ('"Tollod
Claims"). -
WHEREAS, the United Stores, Allain¢, and Cooperating Party enter into this Tolling
Agreement to facilitate sentiment negdutioms betwean the Parties within the time period
Provided by this Agreement without Unity altering the claims or defenses available to any party
hereto, except as specifically Provided been.
NOW, THEREFORE, the parties hereto, in consideration of the eovennnts ad out hard ,
afire as follows:
I. The period commencing on September 30, 2008 will ending on Ane 30,2009
inclusive (the "Tolling Period'), shall not be included in computing the running of my statute of
Iimimtions Wain allY applicable w my intim brought by the Usual States or Maim on the
muco Claims. - -
2. Any defenses of laches, estoppel, or waiver, or other Nationals defenses based
upon flan morning or estimation of any time period shag not include the Talking Period for the
Tallest Claims.
3. Cooperating Party shall not stow, plead, or sure annual the United Stales or
Maine in any fashion, whether by wervven motion or otherwise, my affirmative defense,
including, but not limited to, laches, estappel, waiver or other equitable defense based on the
running of my dadde Oflimitdions or the passage of time during the Tolling Period in any
action brought on Om Tolled Claims. -
4. This Tolling Agreement does not constitute an admission m ackmwhedgment of
my fwd, conclusion of law, or liability by any party to this Tolling Agreement, Not does this
Tolling Agreement contribute an admission or acknowledgment on the pard of the United Stites
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br Mame met any mmme Of limitations. or defense couceming the timeliness of commencing a
civil action, is applicable W rhe TollNClaims. The Vmled Surma and Mauve rcamve the rightfo
eased thatncstatuteoflimitnommenciga my ofthe Tolled Claims andthathi othetdefere
bused upon the timeliness of commencing a civil action is applicable. Cing Agi a ens,Party0 serves
allrightsoanddefenseswhichdmryhave,exceptaeset toedinthis Tolling A®eetatea to
contest or defvd ant claim or action the United States or Menne may asset[ or. initiate age" the
CaaPmating Party.
S. Tads Tolling Agreement my" be modified except is a writing signed by all the
Parties. This Tolling Agr¢ tmybeoxtmdedforsuchp iadoftimeastMPanies agsaw
in writing.
6. This Toiling Agreemeat does not limit in any way the nature or scope army
claims that could he brought by me VNted Slates orM thoom a complaintogra se Caopnafiug
Party.
Parties. 7. This Tolling Agreemcat is not intended W affect any claims by of against mad
S. C Pcarfing Party shall Preserve and maintain, during the Pandenry ofthe Tolling
Period, and fur amwmum Mone year oder termination of din Tolling Period, at least one legible
copy of all documents and other mmerials subject to discovery ander t e Federal Rules of Civil
Procedure and rel noting m the Toiled Claims, regardleu of any corporate or document retortion
PolicY to me contrary or potenfial clean of privilege regarding any docmnent
9. Thu Tolling Agaemeng coname the create Unicameral between the Pardes,and an
sstemevS promise, or inducement made by any Party m this Tolling Agreement that is rot set
form in this Tolling Agrcmned And be valid or binding, swr said it be used in constraint the
toms of this Tolling Agmemem as set forts herein
10. Tice midersigned representative ofeach Mthe parties certifies that he or she is
fidty aadawi a to enter mm the lines and conditions of man Tolling Agreement and to legally,
bindng ndeOnieewsmW acting an a MrhisdwvmmL.TNs To llingAmentalrtstrollha
binding upon the United Stage,ehalffbehalfe De United Of EovimwtalPlmrica,n
Agency, the Stam Of Maine en babaVofthe MaireD ymmuem of EnvironeenWl Pmtatio4 and
upon Cooperating party and its succzsors.
11. This Tolling Agreement is efkctivespan execution by the Parties, and without
the requirement of filing caul she C.Omt, and may he signed to ooedema s.
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For the United Shtes on behalf of the
For
U.S. Environmental Protection Agency:
CoopereUng Petty
DatNNis_dayaf ,2008
Sigpaum
RONALD G. GLUM
Assistant Section Chief
Name
Enron menml &Sorcement Section
Emlromvent and Natural Resoev=
-
Division
TiU<
U.S. Depmtmmt of Janice
Cooperetmg Petry.
DatM tbis_daY o£ 2008
MADSA.GALucssDt
Senior AUomey
Eovvomnental Enforcement Section
Eovimnment and Natural Resources
Division
U.S. Department offus0ce
P.O. Sax 7611
Washinemo, DC 200447611
FORTRESrAT60FMAME:
Dated this_ day of 20M
Many M. Sauer
Aalslbnt Attorney Genual
Office of the Auomey Genal
State of Maine
6 State House Smtion
Augusta, ME 04333
3
Datta Us_dayof 2005
08 294
Plymouth Site Tolling Agreement Escrow Memoranda
This ESCROW MEMORANDUM (the "Escrow Agrxme d`� is made as of this 12th day
ofAugust, 2008 by and among the parries who sign this Escrow Agreement (individually, m it a
"Parry ' collectively, the "Parries") and Pierce Atwood LLP, a law Jim having a place of
business at One Monument Square, Portland, Maine (the "Escrow Ageat").
WHEREAS, the Parlim intend an he signatories to aU.S. Enviromnental Protection
Agency ("EPA') Toiling Agremnmt, In the Matter of West Snev'Rows Corner Superposed Site
(die'Tolling Agement"), with respect to Ne West Site at Bows Comer Suprfest Site (the
"Site") located in Plymouth, Maine and ate signamries to this Escrow Agreement.
NOW, THEREFORE, for good mW valuable consideration, the delivery and oweipt of
which is hereby ackrmwledged, the parties =it the Escrow Agent hereby agree as follows:
1. Appointment of Escrow Agent and Delivery of Signature Pages to the Escrow
Agent.
The Paries hereby appoint Pierce Arwood LLP to act as the Escrow Agent order the
tons and provisions of this Escrow Agreement and the Escrow Agent hereby accepts such
appointment Each Party shall deliver to the Escrow Agent by August 27,2008 an exmuted
original signature page of this Escrow Agreement and an executed original sigramm page to the
Tolling Agcemmt.
2. Distribution of Signature Pages and Copies Thereof.
After the Escrow Agent receives execution pages of this Ere row Agnomen and the
Toiling Agcemmt from at least thirty-six (36) Parties representing an allocated volume of at
Imo 31,0008ailons, Ne Escrow Agent shall
(a) provide the original of the signed Party's signature page for the Tolling Agement to
EPA, and
(b) provide copies of the signature pages for the Tolfug Agreement and this Escrow
Agreement to the Party upon request.
If the enMitions in the preceding sentence are not entitled by August 21, 2008, the Escrow
Agent shall rmum the signaWre pages to the Escrow Agement and rolling Agreement to curb
Party that delivered signature pages to the Escrow Agent in accordance with this Agreement.
3. Deliveries.
Any docaments, notices, demands and requests given or requird to b<given hereondr
shall be in writing, shall be sent to the address for notice listed banner for such individual or
entity, and shell be given by hand, by overnight wort", or shall be mailed by first claw
OR 294
registered or certifiedmail, postage prepaid, return receipt requested, and shall he given as
follows:
To the PRP Group Executive Commitee:
Plymouth PRP Group do Joanna Tournngeeu, Esq,
Pince Atwood LLP
One Monument Square
Portland; ME 04101
To the Parties
at the addresses set forth in the Pamos'respwhve sipmmre Pages
To the EPA:
Gretchen Mmund, Esq.
U.S. Environmental Protection Agency
One Congress Street
Boston, MA 021142023
To the U.S.:
Apomey Assigned to West Site/Hows Cama,
Plymouth, Maine CERCLA Site
Environmental Defense Section, U.S. Dept. of Justice
601 D. Strut, N.W., Room 8140
Washington, D.C. 20004
To the Escrow Agent
Piave Atwood LLP
One Monument Square
Portland, ME 04101
Apt: Joanna Touroneeau.&a.
4. Disputes.
(a) Any dispute which may mine under this Escrow Agreement shall be settled either by
mutual agreement of the patties to such dispute or by a final order of corn of prom
jurisdiction.
(b) In the event of my dispute under this Escrow Agreement. the Escrow Agent may,W
shall have no duty to, institute an im erpleader proceeding in a mud of proper jurisdiction to
determine Me rights of the parties. TheEscrow Aacetshall notberequird todefend any legal
prowalings which maybe instituted against it with respect to this Es smw Agreement unless
O8 294
requested to do win writing by any of the parties heem, and unless and will it is indemnified
by the rerpowinglearty to the =ankle satisfaction of the Escrow Agent against the cost and
expense of such defense, including without limitation the reasonable fees and expenses of its
legal counsel. Should a interyleader proceeding be instituted, or should the Escrow Agent
became involved in litigation in my manner whatsoever on account of this Escrow Agreement or
my fends paid to the Escraw Agent by the Parties, the other patties beeto shall pay the Escrow
Agent, in addition to any charge made hereunder for acting as the Escrow Agent, reasonable
attomeys' fres incurrN by the Escrow Agent, and any other disbursements, expenses, losses,
costs and damages actually and reasonably insured in wmection with and resulting from such
litigation,
S. Responsibilities of Escrow Agent
(a) Other than the exercise of reasonable care in the custody of documents delivered or
any funds paid to the Escrow Agent by fire Patties, the Escrow Agem.shall have no
responsibilities, obligations or duties with respect m such documents or funds except as
wponifically set forth harem, and there shall be no implied duties. In the event of any disputcor
question concerning the Agent's rights or duties hereunder, the Escrow Agent shall be entitled to
advice of counsel concerning its duties herwnder and may pay reasonable wmpemation to all
such attorneys, agars, revivers, employees and transit as may be reasonably employed and the
cast of such compensations shall Ie home by the Parties hereto jointly and severally.
(b) The Escrow Agent shall run by meson ofirs execution of this Escrow Agreement,
assume any responsibility in liability for any transactions between the other parties hereto, other
than the perfomance of its obligations, ns Escrow Agent, with respect to the documents or fiends
held by it in accordance with this Escrow Agreement, and it is agreed Naz its duties are purely
ministerial in name and that the Eacrow Agent shall incur no liability whatsmver to the other
paniwhrtcmdm except for willful misconduct ormgiigmce. The Escrow Agentshallbe
authorized to net upon my document quest or notion believed by it to good With to be lmaine
executed by a duly mtlmdzed representative of my party hereto, nod shall he fully protected in
enacting The Escrow Agent wall not bebound by my modification, amendment, lamination,
cumulation or rescission of this Escrow Agreementmilesa the same shall be in writing and
signed by all of the other parties berem and, if its duties as Escrow Agent herconder are Wetted
thereby, unless it shall have given Inner written consent thereto.
6. indemnification and First Lien
The Probes jointly and severally, agree to indemnify, defend and hold the Escrow Agent
and its p mxvrrs, employees and agents (each an "Indemnitee') homeless from caul against any
end all liabilities, obligations, losses, dmmges, penalties, actions, tames of action, judgments,
suits, claims, casts, expenses and disbursements of any kith or nature whatsoever (including,
without limim6on, the reasonable fees and disbursements of wmsel) in connection with any
investigetim, administrative or -judicial proceeding, which may be imposed on, incurred or
rumored against any mesh hdermitee in my mama relating to or miaing out of the notions or in
sorions of the Escrow Agent with remain this Nam Agreement or the performance of its
duties hareunder, except those caused by Escrow Agar's own negligence or misconduct. The
nR 2qq
Escrow Agent shall have a first lion on any funds paid to the Escrow Agent by the Parties to pay
f any and all fees, costs, expenses and indemnification for which the Escrow Agent is entitled
be hereunder.
7. Resignefioq Removal, and Successor
The Escrow Agent in its salediscretion mayresign at anytime and be discharged of its
duties hereunder by giving fifteen (15) days prior written names w the parties hereto (such notice
b specify the date of such resignation). Escrow Agreement may be removal at any time by
delivery in writingofm instrument signed by all the Parties, to the evenuhepmiss fail to
appoint a successor escrow agent and notify the Escrow Agent in writing of such appointment
within such fifieen-day period, the Escrow Agent shall be deemed to be solely a custodian of the
Escrow Account without further duties hereunder except to deposit any funds received into its
Attorney Trost Pond Account, and shall be entitled to petition a court ofmmp sumajumsdiction
m appoint asrmeasor. eseow agent Upon the appoiahnentofe euemsmr escrow ¢gent by the
parties hereunder or by such aware, the Escrow Agent shall commit any funds paid or documents
delivered to the Escrow Agent by the Pasties Osm any and all fors, costs, aspen s and
madminification for which the Escrow Agent is emitted to hemmker) to the new narrow agent as
well as all camera and documents relating thereto, whereupon the Escrow Agent's duties and
liabilities under this Agreement shall terminate.
S. Binding Effect; Successors and Assigns.
This Escrow Agreement shall be binding own, and insure to the benefit of, the respective
parties hams and their casements and assigns, and shall be construed and enhanced! according to
the laws of Maine,
9. Counterpand; Authority
This Escrow Agreement may be executed in separate munterymts, each of which shall be
deemed an original,burall of which together shall constitute one and theiame lnshmnent. Each
party to this Escrow Agreement represents to the other parties that the signatory to this document
bar each party has full authority to ascente this document on its behalf and a thereby bind that
party
10. Modificaues, Termination
Has Agreeunent may be modified only in a writing signed by all Parties. This Agreement
shall terminate upon perfomanas by Escrow Agent of its duties hereunder, except for the
provisions of section fi which shall survive.
IN WITNESS WHEREOF, the parties hereto have caused this Escrow Agreement to be
==led m an agreement under seal as of the day and you first written above
mm
Pierce Atwood LLP, ESCROW AGENT
By:
(Signature)
Joanna Tourangear, Eq.
(Nome of Party)
By: Dam:
(Signaturt)
ADDRESS FOR NOTICE
(PrinW Name)
wm".o