PRIOR TO 1941, THE SITE HAD BEEN OPERATED AS A LEATHER TREATMENT/TANNING FACILITY BY THE PFISTER & VOGEL LEATHER COMPANY. THE NORTHWESTERN BARREL COMPANY OPERATED ON THE APPROXIMATELY 18 ACRES OF THE PROPERTY FROM APPROXIMATELY 1941 TO THE MID 1960S. ITS OPERATIONS INCLUDED THE ON-SITE HANDLING, WASHING, AND REFURBISHING OF STEEL DRUMS AND WOODEN BARRELS. IN 1988, THE U .S. EPA CONDUCTED A SITE INSPECTION, AND FOUND THAT PCBS, CHROMIUM, VOCS, AND LEAD WERE PRESENT IN SOIL SAMPLES OF THIS SITE. DURING 1998, CONESTOGA-ROVERS & ASSOCIATES, ENVIRONMENTAL CONSULTANT FOR THE PRPS PERFORMING WORK AT THE SITE, CONDUCTED TWO ROUNDS OF SOIL SAMPLING AND FOUND THAT THE HIGHEST LEAD CONCENTRATION WAS 1,150 MG/KG, VOCS' 190 MG/KG. ON JULY 5, 2002, U.S. EPA AND RESPONDENTS ENTERED AN ADMINISTRATIVE ORDER ON CONSENT IN WHICH THE RESPONDENTS AGREED TO CONDUCT AN EE/CA INVESTIGATION FOR ANY AREAS OF THIS SITE, AND FOUND THAT HAZARDOUS SUBSTANCES HAVE BEEN OR ARE THREATENED TO BE RELEASED AT OR FROM THE SITE. THIS ORDER PROVIDES FOR PERFORMANCE OF CERTAIN REMOVAL ACTIONS AND FOR REIMBURSEMENT OF CERTAIN RESPONSE COSTS. RESPONDENTS SHALL PAY OVERSIGHT COSTS TO BE INCURRED AND PAID BY UNITED STATES RELATED TO THE FACILITY THAT ARE NOT INCONSISTENT WITH THE NCP. FOR EACH DAY, OR PORTION THEREOF, THAT RESPONDENTS FAIL TO FULLY PERFORM THEIR OBLIGATIONS WITH THE SCHEDULE ESTABLISHED PURSUANT TO THIS ORDER, AND SUBJECT TO THE DISPUTE RESOLUTION PROVISIONS OF THIS ORDER, RESPONDENTS SHALL BE LIABLE A