The United States of America ( United States ), on behalf of the Administrator of the United States Environmental Protection Agency ( EPA ), filed a complaint in this matter pursuant to Sections 106, 107, and 1 13(g)(2) of the
Comprehensive Environmental Response, Compensation, and Liability Act ( CERCLA ), 42 U.S.C. §§ 9606,9607 and 9613(g)(2); and Section 7003 of the Resource Conservation and Recovery Act ( RCRA ), 42 U.S.C. § 6973. The State of California on behalf of the State Department of Toxic Substances Control ( DTSC ), joined the complaint in this matter with respect to the claims under Section 107 and 113(g)(2) ofCERCLA, 42 U.S.C. §§ 9607 and 9613(g)(2). The complaint seeks, inter alia: (1) reimbursement of costs incurred by EP A, the Department of Justice, and DTSC for response actions at the Puente Valley Operable Unit of the San Gabriel Valley Superfund Site, Area 4, in Los Angeles County, California, as more fully defined in Section iV below (the Site ), together with accrued interest; and (2) performance of response work by defendants at the Site consistent with the National Contingency Plan, 40 C.F.R. Part 300 (as amended) ( NCP ).