THE RESPONDENT, EQ RESOURCE RECOVERY INC., AMONG OTHER ACTIVITIES, CONDUCTS FUEL BLENDING AND SOLVENT RECYCLING AT ROMULUS WHICH IS A SUBURB OF DETROIT ABOUT TWO MILES NORTH OF DETROIT METROPOLITAN AIRPORT. ON AUGUST 9, 2005, THE FACILITY HAD APPROXIMATELY 50 ABOVE-GROUND STORAGE TANKS RANGING IN SIZES UP TO 20,000 GALLONS CONTAINING VARIOUS PRODUCTS, INCLUDING HAZARDOUS SUBSTANCES, AND APPROXIMATELY 400 DRUMS OF VARIOUS PRODUCTS, INCLUDING HAZARDOUS SUBSTANCES. ON AUGUST 9, 2005, A FIRE AND EXPLOSION OCCURRED AT THE SITE. MARY OF THE ABOVE-GROUND STORAGE TANKS WERE IMPACTED BY THE FIRE/EXPLOSION. IN ADDITION, A DRUM PAD WITH OVERHEAD CANOPY AND MANY OF THE DRUMS WERE DESTROYED DURING THIS FIRE. SMOKE FROM THE FIRE REACHED NEARBY RESIDENTIAL AREAS. ON AUGUST 11, 2005, RESPONDENT MOBILIZED EQUIPMENT TO EXTINGUISH REMAINING FIRES AND INITIATE CLEAN UP ACTIVITIES. RESPONDENT DEPLOYED COFFER DAMS UPSTREAM AND DOWNSTREAM OF THE SITE TO CONTAIN ANY POTENTIAL RUN OFF. ON AUGUST 23, 2005, U.S. EPA ISSUED A VERBAL CERCLA GENERAL NOTICE OF POTENTIAL LIABILITY UNDER CERCLA, WITH WRITTEN CONFIRMATION, TO RESPONDENT. THE GENERAL NOTICE SOUGHT RESPONDENT'S COMMITMENT TO PERFORM THE REMOVAL AND REIMBURSE U.S. EPA ITS COSTS INCURRED IN CONNECTION WITH THE SITE. ON AUGUST 25, 2005, RESPONDENT RESPONDED, INDICATING THAT IT DID WISH TO PERFORM OR FUND THE NECESSARY REMOVAL ACTION AT THE FACILITY. THE REGIONAL ADMINISTRATOR OF U.S. EPA REGION 5, OR HIS DELEGATEE, HAS DETERMINED THAT THE TOTAL PA