The United States in its complaint seeks, inter alia: (1) reimbursement of costs
incurred by EPA and the Department of Justice (?DOJ?) for response actions at the Ballard Mine
Superfund Site in Caribou County, Idaho (?Site?), together with accrued interest; and
(2) performance of response actions by Defendant P4 Production, L.L.C. (?Settling Defendant?)
at the Site consistent with the National Contingency Plan, 40 C.F.R. Part 300 (?NCP?).