THIS CIVIL ACTION IS FILED FOR COST RECOVERY AND IMPOSITION OF CIVIL PENALTIES AND TREBLE DAMAGES FOR FAILURE TO COMPLY WITH A SECTION 106 UNILATERAL ADMINISTRATIVE ORDER AGAINST IBM CORPORATION. IBM ARRANGED FOR THE TREATMENT OF HAZARDOUS SUBSTANCES AT THE ROCKY FLATS INDUSTRIAL PARK SITE. THE AMOUNT OF COST RECOVERY SOUGHT IS $1,633,383. CIVIL PENALTIES ARE PROPOSED IN THE AMOUNT OF $495,505.