IN THIS REFERRAL FOR A CIVIL ACTION UNDER SECTIONS 107(A) AND (C) AND 104(E) OF CERCLA, 42 U.S.C. SECTION 9607(A) AND (C) AND 9604(E), THE U.S. ENVIRONMENTAL PROTECTION AGENCY IS SEEKING THE RECOVERY OF $264,010.35 IN RESPONSE AND OVERSIGHT COSTS (PLUS INTEREST) INCURRED AT THE MISSION PLATING REMOVAL SITE AGAINST YOUSSEF MIKHAIL FARD, THE FORMER OWNER AND OPERATOR OF THE SITE. THESE COSTS WERE SPENT BY EPA IN CONNECTION WITH A TIME-CRITICAL REMOVAL ACTION. EPA IS ALSO SEEKING TREBLE DAMAGES FOR FARD'S FAILURE TO COMPLY WITH AN ORDER ISSUED PURSUANT TO CERCLA 106. IN ADDITION, EPA IS SEEKING PENALTIES FOR FARD'S NONCOMPLIANCE WITH A REQUEST FOR INFORMATION ISSUED PURSUANT TO CERCLA 104(E).