ON MAY 16, 1994, THE WASTE MANAGEMENT DIVISION DIRECTOR FOR EPAREGION V EXECUTED A PROPOSED REMOVAL ADMINISTRATIVE ORDER ON CONSENT( AOC ) REQUIRING, INTER ALIA, TWO POTENTIALLY RESPONSIBE PARTIES TOREMOVE SEVERAL THOUSAND DRUMS OF HAZARDOUS SUBSTANCES AND CONTAMINANTSFROM THE JACKSON DROP FORGE SITE ( THE SITE ) AND REIMBURSE EPA FOR ALLOF ITS OVERSIGHT COSTS. THE SITE IS LOCATED AT WELLWORTH AVENUE, JACKSON, MICHIGAN. THESITE IS SITUATED IN MIXED INDUSTRIAL AND RESIDENTIAL AREA AND IS ADJACENT TO THE GRAND RIVER. FOR SEVERAL YEARS, A PORTION OF THE SITE WAS OPERATED AS A DROP FORGE FACILITY WHILE OTHER PORTIONS OF HTE SITE WERE UTILIZED AS A DUMP. ON DECEMBER 2, 1993, EPA ISSUED A REMOVAL ACTION MEMORANDUM DOCUMENTING, INTER ALIA, THE PRESENCE OF SEVERALTHOUSAND DRUMS OF INDUSTRIAL WASTES, INCLUDING HAZARDOUS SUBSTANCES AND CONTAMINANTS, AT THE SITE (AND WITHIN THE FLOOD PLAIN OF THE GRANDRIVER) AND APPROVING THE EXPENDITURE OF APPOXIMATELY $2 MILLION TO BEGIN TO ADDRESS THE CONDITIONS AT THE SITE. SUBSEQUENTLY, ON JANUARY 21, 1994, EPA ENTERED INTO THE FIRST AOC WITH JACKSON/ INNOVA CORPORATION AND MERCER FORGE CORPORATION PURSUANT TO WHICH THOSE CORPORATIONS WOULDUNDERTAKE REIMBURSE EPA FOR ALL ITS PAST AND OVERSIGHT COSTS. ON MAY16, 1994, ENTERED INTO THIS SECOND AOC WITH MARTIN MARIETTA AND BASF