1. SECTION 107(A) OF THE COMPREHENSIVE ENVIRONMENTAL RE- SPONSE, COMPENSATION, AND LIABILITY ACT ( CERCLA ), 42 U.S.C. SECTION 9607(A). 2. J.C. ELLIOTT LANDFILL TIRE FIRE SUPERFUND SITE 7001 AYERS CORPUS CHRISTI, NUECES COUNTY, TEXAS 78350 RESPONDENT: CITY OF CORPUS CHRISTI 3. AN ACCUMULATION OF TIRE CHIPS AT THE LANDFILL SPONTAN- EOUSLY IGINITED AND CAUSED THE FIRE THAT REQUIRED THE COMMENCEMENT OF AN EMERGENCY REMOVAL ACTION. THE CITY OF CORPUS CHRISTI, AS OWNER/OPERATOR OF THE LANDFILL, IS THE ONLY VIABLE PRP FOR RECOVERY OF THE RESPONSE ACTION. 4. RELIEF SOUGHT PURSUANT TO SECTION 107(A) OF CERCLA, EPA FORWARDED REFERRAL TO DOJ REQUESTING ASSISTANCE IN THE RECOVERY OF COSTS INCURRED BY EPA IN IMPLEMENTING RE- SPONSE MEASURES AT THE SITE. EPA SEEKS TO RECOVER THE COSTS OF REMOVAL AND REMEDIAL ACTIONS THAT TOTALLED, EX- CLUSIVE OF INTEREST, APPROXIMATELY $738,486.31.