INITIATION OF A CIVIL ACTION PURSUANT OT SECTION 107(A) OF CERCLA, TO RECOVER RESPONSE COSTS INCURRED BY THE U.S. RELATED TO THE RESPONSE ACTIONS AT THE ROYAL RECOVERY SYSTEMS SUPERFUND SITE AND A DECLARATORY JUDGMENT FOR FUTURE COSTS THAT MAY BE INCURRED AT THE SITE. EPA SEEKS TO RECOVER THE ENTIRE PAST COSTS FROM ELLIOTT PACKER WHO WAS THE OWNER/OPERATOR OF THE FACILITY AT THE TIME OF DISPOSAL AND THE ROYAL RECOVERY SYSTEMS, INC. WHICH WAS THE OPERATOR OF THE FACILITY AT THE TIME OF DISPOSAL.