This is a civil action referral package recommending initiation of a civil action against three potentially responsible parties ( PRPs ), pursuant to Section 107 of CERCLA, for recovery of costs incurred by EPA. This referral package also recommends the filing of civil penalty claims against two of the PRPs under CERCLA Section 106(b) for their noncompliance with a UAO issued in 1992. EPA?s unreimbursed costs incurred prior to March 2003 are $1,781,545. Pursuant to CERCLA Section 107(a), 42 U.S.C. Section 9607(a), relief is requested in that amount plus interest.