DECEMBER 20, 2021 - CERCLA SECTION 122(h)(1) SETTLEMENT AGREEMENT FOR RECOVERY OF PAST RESPONSE COSTS This Settlement Agreement concerns the LL Harwell Road Private Well Contamination Site (?Site?) located in Gastonia, Gaston County, North Carolina. 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. Beginning in 2017, EPA performed a removal action at the Site, which included inspecting the Site, sampling private wells, installing a water filtration system, and connecting residences to municipal water. In performing its response actions, EPA has incurred response costs at or in connection with the Site. EPA alleges that Settling Party is a responsible party pursuant to Section 107(a) of CERCLA. EPA and 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. The actions undertaken by Settling Party in accordance with this Settlement Agreement do not constitute an admission of any liability by Settling Party. Settling Party does not admit, and retains the right to controvert in any subsequent proceedings other than proceedings to implement or enforce this Settlement Agreement, the validity