ON JUNE 16, 2007, EPA REGION VII ISSUED AN ADMINISTRATIVE SETTLEMENT AGREEMENT AND ORDER ON CONSENT FOR REMOVAL ACTION (ÂAGREEMENTÂ) PURSUANT TO SECTIONS 104, 106(A), 107 AND 122 OF CERCLA. THE AGREEMENT REQUIRES THE RESPONDENT, THE UNIFIED GOVERNMENT OF WYANDOTTE/KANSAS CITY, KANSAS (ÂUGÂ) TO PERFORM A REMOVAL ACTION ON PROPERTY IT CURRENTLY OWNS TO ADDRESSES THE RELEASE OR THREAT OF RELEASE OF PCBS, ASBESTOS, PESTICIDES OR OTHER HAZARDOUS SUBSTANCES. BACKGROUND: THE FIVE-ACRE SITE IS LOCATED IN KANSAS CITY, KANSAS IN AN INDUSTRIAL ZONED AREA. HOWEVER, LOW-INCOME RESIDENTIAL HOUSING COMPLEXES ARE LOCATED NORTH AND WEST OF THE SITE. THE SITE PROPERTY IS CURRENTLY UNUSED. IN MAY OF 2006, THE UG LEASED THE PROPERTY FOR 3 YEARS TO A COMPANY KNOWN AS INDUSTRIAL LIQUIDATORS, WHO SUBSEQUENTLY ABANDONED THE PROPERTY BEFORE THE LEASE TERMINATED. PRIOR TO 2006, THE UG USED THE PROPERTY AS A MAINTENANCE AND STORAGE FACILITY FOR ITS STREETÂS AND PARKS AND RECREATION DEPARTMENTS. THE EPA CONDUCTED ITS INITIAL INVESTIGATION IN MARCH 2009 AND FOUND THAT THE SITE CONSISTED OF 2 MAIN ONE-STORY BRICK STRUCTURES, THE REMAINS OF A SHED, AND NUMEROUS ABANDONED DRUMS AND CONTAINERS, AN ELECTRICAL TRANSFORMER AND GENERAL REFUSE. THE 2 MAIN STRUCTURES WERE IN A DILAPIDATED CONDITION AND WERE UNSECURED (NO DOORS OR WINDOWS). THE CONCRETE FLOOR IN THE NORTH STRUCTURE IS PREDOMINATELY COVERED WITH ELECTRICAL COMPONENTS AND RELEASED PESTICIDE RESIDUE. A DRUM STORAGE AREA WAS LOCATED ON TH