or damages, or (B) the date of an administrative order under section 9622(g) of this title (relating to de minimis settlements) or 9622(h) of this title (relating to cost recovery settlements) or entry of a judicially approved settlement with respect to such costs or damages. 42 U.S.C. § 9613(g)(3); see Bedford Affiliates, 156 F.3d at 424. 79. None of the triggering events in CERCLA § 113(g)(3) has occurred. 80. Defendants maintain that where none of the triggering events has occurred, the Court should apply the limitations periods in CERCLA § 113(g)(2) applicable to removal and/or remedial cost recovery action under CERCLA § 107. See Sun Company, Inc. v. Browning-Ferris, Inc., 124 F.3d 1187, 1192 (10th Cir.1997), cert. denied, 522 U.S. 1113, 118 S.Ct. 1045, 140 L.Ed.2d 110 (1998) (<HOLDING>). 81. Relying on W.R. Grace & Co. v. Zotos
holding that  107 continues to offer a distinct cause of action for direct recovery and additionally an implied right to contribution for prps holding that the government prp may bring a costrecovery action pursuant to cercla  107 thereby imposing joint and several liability on the defendant prp holding that where the defendants  107 claim was based on remediation costs they incurred and may incur in the future as the result of a lawsuit instituted under  107a they did not demonstrate that they incurred necessary costs of response within the meaning of  107a holding that plaintiffs entering into a consent agreement with the epa did not trigger the running of the statute of limitations under  113g3 for purposes of a  113f1 contribution action and further distinguishing a  113f1 contribution action from a cost recovery action to which the limitations periods of  113g2 would apply holding that where none of the events for accrual of a  113f1 contribution claim can arise because a prp has incurred response costs based on its agreement to remediate in accordance with a state agencys administrative order the relevant period of limitations and accrual is provided in  113g2 the court found that under such circumstances the contribution action becomes the initial action for cost recovery under cercla  107 thus bringing such action within  113g2 applicable to initial actions for recovery of the costs referred to in  107