1. W & R DRUM INC. WAS A DRUM RECYCLING BUSINESS OWNED AND OPERATED BY MR.JOHNNIE WILLIAMS FROM THE EARLY 1980'S UNTIL 1994. W & R DRUM WAS IN THE BUSINESS OF RECONDITIONING 55-GALLON DRUMS THAT WERE ORIGINALLY USED FOR VARIOUS PRODUCTS RANGING FROM PRINTING INKS, PAINTS, GLUES, AND SOLVENTS. MR.WILLIAMS OBTAINED DRUMS FROM OTHER FACILITIES IN THE MEMPHIS AREA, MANY OF WHICH CONTAINED VARIOUS AMOUNTS OF RESIDUAL WASTE WHICH WOULD BE CONSIDERED HAZARDOUS SUBSTANCES. ONCE THE DRUMS WERE RECEIVED AT THE FACILITY THEY WERE EITHER RECONDITIONED IMMEDIATELY, OR STORED FOR LATER RECONDITIONING. ATHOUGH DRUMS RECEIVED AT THE FACILITY MAY HAVE BEEN VISUALLY INSPECTED PRIOR TO RECONDITIONING, NO ANALYTICAL TESTING WAS DONE TO DETERMINE WHETHER THE REMAINING DRUM CONTENTS WERE HAZARDOUS SUBSTANCES AS DEFINED BY CERCLA, SECTION 101(14), 42 U.S.C SECTION 9601(14). THE DRUMS WERE RECONDITIONED BY REMOVING THE LIDS AND SCRAPING AND/OR RINSING THE CONTENTS OF THE DRUMS ONTO THE GROUND. THE CONTENTS OF THE DRUMS FLOWED ALONG A DRAINAGE TRENCH THAT LED TO TWO 500-GALLON UNDERGROUND HOLDING TANKS. THE DRUMS