1. SECTION 122(H) OF THE COMPREHENSIVE ENVIRONMENTAL RESPON- SE, COMPENSATION, AND LIABILITY ACT OF 1980 ( CERCLA ), 42 U.S.C. SEC. 9622(H). 2. LITHIUM OF LUBBOCK SITE 2301 AVENUE C LUBBOCK, TEXAS 3. THE SITE CONSISTS OF A WAREHOUSE STRUCTURE IN WHICH BAT- TERIES AND WASTE WERE ABANDONED. THE ABANDONED BATTERIES AND WASTE CONTAINED HAZARDOUS SUBSTANCES. EPA FOUND THAT THERE HAD BEEN A RELEASE OR THREAT OF RELEASE OF HAZARD- OUS SUBSTANCES INTO THE ENVIRONMENT FROM THE SITE. EPA CONDUCTED A RESPONSE ACTION FROM JUNE UNTIL NOV. OF 1992, WHICH CONSISTED OF SITE STABILIZATION, PACKING LITHIUM BATTERIES IN OIL, SAMPLING OF WASTE MATERIALS, REMOVAL AND DISPOSAL OF HAZARDOUS SUBSTANCES, AND DECON- TAMINATION OF THE SITE. THE RESPONSE ACTION COST EPA $636,177.72. 4. RELIEF SOUGHT PURSUANT TO SECTION 107(A) OF CERCLA, EPA IS AUTHORIZED TO RECOVER, FROM POTENTIALLY RESPONSIBLE PARTIES, THE COSTS IT HAS INCURRED IN CONDUCTING A RE- SPONSE ACTION. THE EPA, SETTLING FEDERAL AGENCIES (SFAS) AND THE POTENTIALLY RESPONSIBLE PARTIES (PRPS) HAVE A- GREED TO SETTLE CLAIMS ARISING FROM THE SFAS PRPS IN- VOLVEMENT WITH THE SITE WITHOUT LITIGATION AND WITHOUT THE ADMISSION OR ADJUDICATION OF