THE CONDITIONS PRESENT AT THE SITE CONSTITUTE A THREAT TO PUBLIC HEALTH, WELFARE, OR THE ENVIRONMENT. THIS ORDER REQUIRES THE RESPONDENTS, STEVEN J. PEDI AND WILLIAM LERCH, TO CONDUCT REMOVAL ACTIVITIES. THE RESPONDENTS SHALL REIMBURSE U.S. EPA, UPON WRITTEN DEMAND, FOR ALL RESPONSE COSTS INCURRED BY THE UNITED STATES IN OVERSEEING RESPONDENT'S IMPLEMENTATION OF THE REQUIREMENTS OF THIS ORDER. VIOLATION OF ANY PROVISION OF THIS ORDER MAY SUBJECT RESPONDENTS TO CIVIL PENALTIES OF UP TO $27,500 PER VIOLATION PER DAY.