This Settlement Agreement concerns the Trinity Superfiind Site ( Site ) located in Cleveland, Cuyahoga County, Ohio. EPA alleges that the Site is a facility as defined by Section 101(9) of CERCLA, 42 U.S.C. § 9601(9). In response to the release or threatened release of hazardous substances at or from the Site, EPA undertook response actions at the Site pursuant to Section 104 of CERCLA, 42 U.S.C. § 9604. These actions included but were not limited to securing piles of crushed concrete at the Site and removing materials containing elevated levels of PCBs from areas located along the western edge of the Site property (including off-site soils at the adjacent residential property). In performing response action, EPA has incurred response costs at or in connection with the Site. EPA alleges that the Settling Party is a responsible party pursuant to Section 107(a) of CERCLA, 42 U.S.C. § 9607(a), and is jointly and severally liable for response costs incurred or to be incurred at or in connection with the Site. EPA and the Settling Party recognize that this Settlement Agreement has been negotiated in good faith and that this Settlement Agreement is entered into without the admission or adjudication of any issue of fact or law.