NATURE OF CASE THIS IS A CIVIL ACTION AGAINST THE CITY AND COUNTY OF DENVER, COLORADO, PURSUANT TO SECTION 106 OF THE COMPREHEN- SIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT (CERCLA), 42 U.S.C. SECTION 6906, FOR VIOLATION OF AN ADMIN- ISTRATIVE ORDER ON CONSENT. THE ORDER (ATTACHMENT A) REQUIRES DENVER TO INSTALL AND OPERATE A CONTAINMENT AND TREATMENT SYSTEM DESIGNED TO RE- STRICT THE MIGRATION OF CONTAMINATED GROUNDWATER TO THE NORTH OF THE LOWRY LANDFILL SITE. THE SYSTEM BASICALLY WILL CONSIST OF (1) A CLAY BARRIER THAT WILL INTERCEPT GROUND- WATER AS IT FLOWS OFF THE SITE TO THE NORTH; (2) A SUMP THAT WILL REMOVE THE CONTAMINATED WATER ONCE IT COLLECTS AT THE BARRIER; AND (3) A CARBON TREATMENT SYSTEM THAT WILL TREAT THE CONTAMINATED WATER PRIOR TO REINJECTION INTO THE ENVIR- ONMENT. AT TIME OF VIOLATION DENVER HAD COMPLETED THE BARRIER AND WAS IN THE PROCESS OF INSTALLING THE TREATMENT SYSTEM. THE ORDER, AT PAGES 8-9, CONTAINS THE FOLLOWING PROVISION ABOUT CONTAMINATED WATER COLLECTING AT THE BARRIER PRIOR TO COMPLETION OF THE TREATMENT SYSTEM: I. DENVER AGREES THAT FROM THE PERIOD BETWEEN CON- STRUCTION OF THE BARRIER SYSTEM AND COMPLETION OF THE TREATMENT AND REINJECTION SYSTEMS, CON- TAMINATED WATER COLLECTED