The Agreement provides for recovery of response costs incurred by EPA in conducting removal activities at the Michelin Powerhouse and Building 3 Vat Superfund Site, located in Milltown, New Jersey. On January 18, 2013, DOJ filed CERCLA Sections 107(a) and (l) claims against numerous parties, some of which later filed for bankruptcy, for EPA's response costs related to the Site. Pursuant to the Agreement, a Plan of Reorganization which contains the terms of the Settlement Agreement will be filed in Bankruptcy Court and a Consent Decree will be filed in the District Court settling all remaining CERCLA claims against the non-Debtor entities in that matter. In addition, a separate District Court judgment against the non-Debtors and related entities for failure to provide access to the Site will be dismissed once all of the terms of the Settlement Agreement are met. The Settlement Agreement requires the Debtors to extend EPA's CERCLA lien across six other properties adjacent to the Site, which are owned by related entities.