THIS SITE IS LOCATED IN KANSAS CITY, KANSAS AND IS COMPOSED OF 27 ACRES OF LAND UPON WHICH A SMELTER WAS OPERATED IN THE LATE 1800S - EARLY 1900S. THE SMELTER WAS OWNED AND OPERATED BY THE CONSOLIDATED KANSAS CITY SMELTING AND REFINING COMPANY (CKCS&R), WHICH WAS ONE OF SEVERAL SMELTERS THAT JOINED TO FORM THE TRUST KNOWN AS THE AMERICAN SMELTING AND REFINING COMPANY (ASARCO) IN 1899. THE SITE WAS PURCHASED IN 1907 BY THE KANSAS CITY STRUCTURAL STEEL COMPANY, WHO USED THE PROPERTY AS A STEEL FABRICATION PLANT UNTIL 1987, WHEN BANCAMERICA ACQUIRED THE PROPERTY BY WAY OF TAKING DEED IN LIEU OF FORECLOSURE. SHORTLY THEREAFTER, IT WAS DISCOVERED THAT THE SOILS ON SITE CONTAIN LEVELS OF LEAD UP TO 43,000 PPM. EPA CONDUCTED NEGOTIATIONS WITH THREE POTENTIALLY RESPONSIBLE PARTIES (BANCAMERICA, ASARCO AND TRINITY INDUSTRIES); HOWEVER, ONLY BANCAMERICA AGREED TO SIGN AN ADMINISTRATIVE ORDER ON CONSENT REQUIRING STABILIZATION/SOLIDIFICATION OF THE LEAD-CONTAMINATED SOILS ON-SITE. IN AUGUST, 1990, EPA SENT A REQUEST FOR INFORMATION PURSUANT TO SECTION 104(E) TO ASARCO, SEEKING, INTER ALIA, ALL DOCUMENTS PERTAINING TO THE CONSOLIDATION OF CKCS&R AND ASARCO. ASARCO RESPONDED THAT IT HAD NEVER HAD AN INTEREST IN THE SITE AND THAT IT HAS NO DOCUMENTS DATING FROM THE TURN OF THE CENTURY THAT RELATE TO HAZARDOUS SUBSTANCES AT THE SITE. THE COMPANY SENT EPA A C