On March 21, 2011, EPA and a group of PRPs for the Swope Site entered into an Administrative Order on Consent (AOC) for Remedial Design (RD) for the first operable unit (OU) at the Site. The RD work includes, but is not limited to, the collection of data necessary to design a RCRA cap; the design of RCRA cap and a plan for establishing institutional controls. Under the terms of AOC, the Settling Parties will also pay oversight costs, incurred by EPA with respect to the OU1 RD. The Settling Parties are PRPs at the Site, because they were arrangers, who by contract or agreement, arranged for the disposal of hazardous substances at the Site, and accordingly are liable for response costs pursuant to Section 107(a)(3) of CERCLA.