THE RESPONDENT, LETT INDUSTRIES, INC., TO CONDUCT REMOVAL ACTIONS TO ABATE AN IMMINENT AND SUBSTANTIAL ENDANGERMENT TO THE PUBLIC HEALTH, WELFARE OR THE ENVIRONMENT THAT MAY BE PRESENTED BY THE ACTUAL OR THREATENED RELEASE OF HAZARDOUS SUBSTANCES AT OR FROM THE SITE. THE RESPONDENT SHALL PAY ALL PAST RESPONSE COSTS AND OVERSIGHT COSTS. THE RESPONDENT FIALS TO FULLY PERFORM ANY REQUIREMENT OF THIS ORDER IN ACCORDANCE WITH THE SCHEDULE ESTABLISHED PURSUANT TO THIS ORDER, RESPONDENT SHALL BE LIABLE.