The NWOD is a series of former and existing unlined canals located in northern Salt Lake County. Among the wastes discharged to the canals of the NWOD were oily and sewage sludges. Sample analyses of the sludge indicate elevated concentrations of organics, such as benzene and metals, especially lead, copper and arsenic. The non-time critical removal action being performed by parties other than the Respondent is necessary to protect the public health and welfare or the environment. It is hereby ordered and agreed that Respondent shall reimburse EPA for past response costs.