THE SITE IS AN ABANDONED FORMER MANUFACTURING FACILITY FOR UNIVERSAL JOINTS, DRIVE SHAFTS, DRIVE LINE COMPONENTS AND SPARK PLUGS. ON JANUARY 3, 2005, AN ON-SITE TRANSFORMER CAUGHT ON FIRE AFTER CONTRACTORS, HIRED BY THE RESPONDENTS DRAINED THE OIL FROM THE TRANSFORMER AND WORKED TO DISMANTLE AND SCRAP IT. AT THE TIME OF THE INITIAL RESPONSE TO THE FIRE BY OEPA AND THE RESPONDENTS, WORKERS DISCOVERED THAT THE OIL RELEASED FROM THE TRANSFORMER INTO THE SECONDARY CONTAINMENT AROUND THE TRANSFORMER PAD HAD MIGRATED OUT OF CONTAINMENT, INTO AN ADJACENT AREA OF GRAVEL FILL, THE ADJACENT RAILROAD PROPERTY, A STORM SEWER ON THE PROPERTY, AND THE CITY OF DEFIANCE'S WASTEWATER TREATMENT PLANT VIA THE CITY'S COMBINED SEWER SYSTEM. ON AND AFTER JANUARY 6, 2005, THE RESPONDENTS REPORTED THE FOLLOWING LABORATORY RESULTS FOR SAMPLES COLLECTED FROM THE SITE AFTER THE SPILL: THE CONCENTRATION OF PCBS IN OIL RECOVERED FROM THE SPILL WAS AS HIGH AS 1161 PPM; THE CONCENTRATION OF PCBS IN OILY WATER RECOVERED FROM THE SITE WAS 8000 UG/L; THE CONCENTRATION OF PCBS IN OILY WATER RECOVERED FROM THE FLOODED BASEMENT OF AN ON-SITE BUILDING WAS 370 MG/KG; AND THE CONCENTRATION OF PCBS IN SOIL IMPACTED BY THE SPILL WAS AS HIGH AS 33 PPM. APPROXIMATELY 17 DRUMS OF SOLVENTS, OILS, CORROSIVES, AND UNKNOWN LIQUIDS AND POWDERS WERE IDENTIFIED THROUGHOUT THE SITE. A LABORATORY INSIDE THE MAIN SITE BUILDING CONTAINS APPROXIMATELY 200 JARS AND BOTTLES OF LAB-GRADE CHEMICALS. MANY OF THE TRANSFORMERS AND CAPACIT