On or about December 8, 2005, the Region issued a CERCLA 106 unilateral administrative order for removal (Order) to Smurfit Stone Container Corporation, American Premier Underwriters Inc., and Wittstadt Hunting Club Inc. (Respondents) with respect to the Sauer Dump Site, located in Baltimore County Marlyland. Under the terms of this unilateral Order, Respondents are directed to, among other things, install fencing to prevent unauthorized access to the Site, protect the shoreline of the Site from erosion, and install a cover system to mitigate further erosion of the contaminated surficial soils and the subsequent migration of hazardous substances off-site. The Site is an inactive landfill and former dump. The above Order is necessary to address threats to human health, welfare and the environment posed by debris, soils and sediments contaminated with PCBs, lead and other hazardous subtances or contaminants.