THIS CASE IS AGAINST THE RESPONDENT UNDER SECT 106(A) OF CERCLA TO UNDERTAKE ACTION TO PROTECT THE PUBLIC AND THE ENVIRONMENT FROM ENDANGERMENT. EPA HAS DETERMINED THAT THE RELEASE AND THREATENED RELEASE INTO THE ENVIRONMENT OF THE HAZARDOUS SUBSTANCES, POLLUTANTS, OR CONTAMINANTS IN THE KN ENERGY FACILITY MAY PRESENT AN IMMINENT AND SUBSTANTIAL ENDANGERMENT TO THE PUBLIC HEALTH, WELFARE, AND THE ENVIRONMENT.