EPA ALLEGES THAT IT HAS A CLAIM AGAINST THE RESPONDENT FOR RECOVERY OF PAST AND FUTURE RESPONSE COSTS PERTAINING TO THE BAXTER/UNION PACIFIC TIE TREATING SITE, LOCATED IN LARAMIE, WYOMING PURSUANT TO SECTION 107A OF CERCLA, 42 USC SECTION 9607A. WITHIN 30 DAYS AFTER THE EFFECTIVE DATE OF THIS AGREEMENT AS DEFINED, THE RESPONDENT SHALL PAY TO THE HAZARDOUS SUBSTANCES SUPERFUND PAST RESPONSE COSTS IN THE AMOUNT OF $237,996.12.