The Defendant filed for bankruptcy under Chapter 11 and is a potentially responsible party under CERCLA Section 107 for costs incurred and to be incurred by EPA with regard to the Diamond Alkali Site, Lower Passaic River Study Area (Site), and with respect to the Berry Creek Study Area (BCSA) operable unit of the Ventron/Velsicol Superfund Site. EPA handled this matter as a national case, filing a proof of claim for numerous sites including these two Region 2 sites, alleging that the Defendant is a responsible party under Sections 107(a)2) and (a)(3) of CERCLA. The settlement agreement resolves the United States' claims for the Diamond Alkali Site and Ventron Site.