The referral requests that DOJ file a civil judicial complaint under the authority contained in Sections 107(a) and 113(g)(2) of the Comprehensive Environmental Response, Compensation and Liability Act, as amended ( CERCLA ) 42 U.S.C. 9607(a) and 9613(g)(2), against the CleanCare Corporation, and against Mr. David Bromley, president of CleanCare, Mr. Russell Bulman, former president and owner of CleanCare, Lilyblad Petroleum, a company owned by Glenn Tegen which conducted operations in the late 1980s and early 1990s at the CleanCare facility, and Mr. Glenn Tegen, former owner/operator of CleanCare and its predecessors at the current 1510 Taylor Way address of CleanCare. This referral seeks recovery of EPA's $ 5,888,907.07 of unreimbursed past costs associated with the removal assessment and removal actions at the Site, as well as EPA's and DOJ's enforcement costs incurred at the Site from November 1999 to the present time, plus interest on all these costs. Specifically, the referral requests DOJ's assistance in filing a civil complaint alleging that CleanCare, and its various individual owners and operators, Messrs. Bromley, Bulman and Tegen, and Lilyblad, are liable to the United States under Section 107 of CERCLA for the response costs the United States has incurred at the CleanCare Site.