THIS IS A REFERRAL UNDER SECTION 107 OF THE COMPREHEN- SIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF 1980, AS AMENDED BY THE SUPERFUND AMENDMENTS AND REAUTH- ORIZATION ACT OF 1986, PUB. L. NO. 99-499 ( CERCLA ), 42 U.S.C. SECTION 9607, FOR RECOUPMENT OF APPROXIMATELY $325,913.83 IN COSTS INCURRED IN THE REMOVAL ACTION UNDER- TAKEN AT THE PAGAN ROAD DRUM DUMP SITE IN SUMMIT TOWNSHIP, ERIE COUNTY, PENNSYLVANIA ( PAGAN ROAD SITE OR SITE ). THE ENVIRONMENTAL PROTECTION AGENCY ( EPA ) ADDITIONALLY SEEKS A DECLARATORY JUDGEMENT UNDER SECTION 113(G)(2) OF CERCLA, 42 U.S.C. 9613(G)(2), AND 28 U.S.C. SECTION 2201 FOR LIABILITY FOR FURTHER COSTS INCURRED AT THE PAGAN ROAD SITE