THIS IS A COLLECTION ACTION FOR FAILURE OF THE DEFENDANT TO MAKE ANY OF THE PAYMENTS REQUIRED UNDER THE TERMS OF AN ADMINISTRATIVE SETTLEMENT AGREEMENT FOR COST RECOVERY ISSUED UNDER THE AUTHORITY OF SECTION 122(H)(1) OF CERCLA. NON-PAYMENT UNDER THE TERMS OF A SECTION 122 SETTLEMENT IS A VIOLATION OF SECTION 122(H)(3) OF CERCLA.