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J <br />1 <br />1 <br />Everett, Washington. The Facility is more particularly described in Exhibit A of the Consent <br />2 <br />Decree that is being submitted to settle this action. <br />3 <br />3.2 Ecology has determined that there has been a release or threatened release of <br />4 <br />hazardous substances at the Facility. Ecology has further determined that this release or <br />to human health, welfare, the <br />5 <br />threatened release requires remedial action protect and environment; <br />6 <br />and that the Defendant is the potentially liable person with respect to this Facility. <br />7 <br />3.3 Ecology and Defendant has entered into a Consent Decree regarding remedial <br />8 <br />actions to be taken at the Facility. <br />9 <br />3.4 The Consent Decree has been the subject of public notice and comment under <br />10 <br />RCW 70.105D.040(4)(a). The Consent Decree is being submitted to the court along with this <br />11 <br />Complaint. <br />Consent Decree lead <br />12 <br />Ecology has determined that entry of the will to a more expeditious <br />13 <br />cleanup of the Facility. <br />14 <br />IV. CAUSE OF ACTION <br />15 <br />4.1 Plaintiff realleges all preceding paragraphs. <br />1.6 <br />4.2 Plaintiff alleges that the Defendant is responsible for remedial action at the Facility <br />17 <br />pursuant to the MICA, chapter 70.105D RCW. <br />18 <br />V. PRAYER FOR RELIEF <br />19 <br />5.1 Ecology and the City of Everett request that the court sign and enter the Consent <br />20 <br />Decree in this matter. <br />21 <br />5.2 Ecology and the City of Everett further request that the court retains jurisdiction <br />22 <br />to enforce the terms of the Consent Decree. <br />23 <br />24 <br />25 <br />26 <br />COMPLAINT 2 ATTORNEY GENERAL OF WASHNGTON <br />Ecology Division <br />PO Box 40117 <br />Olympia, WA 98504-0117 <br />FAX (360) 438-7743 <br />