IN PART ONE, THE ENVIRONMENTAL PROTECTION AGENCY ( EPA OR THE THE AGENCY ) REQUESTS THAT THE UNITED STATES DEPARTMENT OF JUSTICE ( DOJ ) ASSIST THE AGENCY WITH A COST RECOVERY ACTION IN CONNECTION WITH THE ALLIED-PULASKI SUPERFUND SITE ( SITE ), PURSUANT TO SECTIONS 107 AND 113 OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF 1980 ( CERCLA ), AS AMENDED, 42 U.S.C. SECTION 9607 AND 9613. THE SIT EIS LOCATED IN THE TOWN OF PULASKI, PULASKI COUNTY, VIRGINIA. EPA HAS INCURRED AT LEAST $507,521.90 IN RESPONSE COSTS THROUGH JUNE 11, 2005, INCONNECTION WITH THE SITE. THE AGENCY REQUESTS TAHT DOJ FILE A COMPLAINT AGAINST OR REACH A SETTLEMENT OF EPA'S COST CLAIM WITH SIX (6) POTENTIALLY RESPONSIBLE PARTIES ( PRPS ) AT THE SITE - HONEYWELL INTERNATIONAL INC (FORMER OWNER/OPERATOR), DOWNTOWN EAST LIMITED PARTNERSHIP (CURRENT OWNER/OPERATOR AT THE TIME OF DISPOSAL), H.W.HUFF (FORMER OWNER/OPERATOR), DOWNTOWN EAST, INC. (CURRENT OWNER), DELP-2, L.L.C (CURRENT OWNER), AND AAA, L.L.C. (CURRENT OWNER).
IN PART TWO, EPA REQUESTS THAT DOJ SEEK PENALTIES, PURSUANT TO SECTIO 106 OF CERCLA, AGAINST DOWNTOWN EAST LIMITED PARTNERSHIP, DOWNTOWN EAST, INC., AND DELP-2, L.L.C., FOR FAILURE TO COMPLY WITH AND/OR FOR WILLFUL VIOLATIONS OF AN ADMINISTRATIVE ORDER FOR REMOVAL RESPONSE ACTION ( ORDER ), DOCKET NO. III-2000-0027DC. EPA REQUESTS THAT DOJ FILE A COMPLAINT AGAINST THE PENALTY DEFENDANTS FOR PENATLIES AND APPROPRIATE INJUNCTIVE RELIEF.
THE SITE IS