On April 12, 2013, Region 2 signed an Administrative Settlement Agreement under CERCLA § 122(h) in which the Respondent agreed to pay into the Alcoa Study Area Special Account. The payment will reimburse 100% of EPAÂs site-related past response costs from January 1, 2006 through August 31, 2011, which EPA sought from the Respondent in a September 28, 2012, demand letter. The Agreement includes a covenant not to sue the Respondent pursuant to CERCLA Section 107(a) for EPAÂs past response costs that were paid during that period. The site, which is not on the National Priorities List, includes approximately seven miles of the Grasse River that is contaminated with PCBs discharged by the Respondent. On April 4, 2013, Region 2 signed a Record of Decision in which it selected a remedial action for the site with an estimated present-worth cost of $243 million. The Respondent performed the investigation of the Grasse River contamination, and is required to design and implement EPAÂs selected remedy, pursuant to a September 1989 unilateral administrative order issued under CERCLA § 106(a).