A. NATURE OF THE CASE BETTER BRITE PLATING, INC., ALSO KNOWN AS WISCONSIN CHROMIUM-DIVISION OF BETTER BRITE PLATING, OWNED AND OPERA- TED A CHROMIUM ELECTROPLATING FACILITY LOCATED AT 519 LANDE STREET IN DE PERE, WISCONSIN. ON APRIL 30 AND JUNE 23, 1986, THE U.S. EPA TECHNICAL ASSISTANCE TEAM PERFORMED SITE ASSESSMENTS AT THIS FACILITY. THESE ASSESSMENTS DOCUMENTED THE PRESENCE OF HAZARDOUS SUBSTANCES IN THE SOIL, SURFACE WATER, AND GROUNDWATER AT THE SITE. THE PREDOMINANT CONTAM- INANT WAS IDENTIFIED AS HEXAVALENT CHROMIUM, THE MOST TOXIC FORM OF CHROMIUM. THE FACILITY IS NOT SECURED AND IS LOCA- TED IN A RESIDENTIAL NEIGHBORHOOD, WITH THE NEAREST RESI- DENCE APPROXIMATELY TWENTY-FIVE (25) YARDS AWAY. PURSUANT TO AN ACTION MEMO DATED SEPTEMBER 24, 1986, U.S. EPA IS CONDUCTING AN IMMEDIATE REMOVAL RESPONSE AC- TION AT THE BETTER BRITE FACILITY. (ATTACHMENT A). SPE- CIFIC RESPONSE ACTIVITIES TAKEN AT THE SITE INCLUDE: EX- TENSIVE SAMPLING, EXCAVATING CONTAMINATED SOIL, DRAINING AND DISPOSING OF DETERIORATED DRUMS AND TANKS, AND PUMPING AND DISPOSING OF HAZARDOUS CHROMIC ACID FROM UNLINED PITS. AS OF NOVEMBER 13, 1986, U.S. EPA EXPENDED $90,955.70 TO MITIGATE BY CLEANUP THE IMMEDIATE THREAT TO HUMAN HEALTH AND THE ENVIRONMENT POSED BY CONDITIONS AT BETTER BRITE'S FACIL- ITY. THESE COSTS ARE SET FORTH IN THE AFFIDAVIT OF STEVEN FARYAN WHICH SUPPORTS THE PROOF OF CLAIM.