IN JANUARY OF 1986, EPA AND 9 RESPONDENTS, INCLUDING THE PROPOSED DEFENDANTS, ENTERED INTO AN ADMINISTRATIVE ORDER ON CONSENT TO PERFORM PHASE I OF THE REMOVAL ACTION. DURING PHASE I, HAZARDOUS SUBSTANCES WERE REMOVED TO A RCRA- APPROVED DISPOSAL FACILITY. THE SAME 9 DEFENDANTS PERFORMED PHASE II OF THE REMOVAL ACTION PURSUANT TO AN ADMINISTRATIVE ORDER. ON MARCH 23, 1994 EPA ISSUED A DEMAND LETTER TO THE RES- PONDENTS SEEKING REIMBURSEMENT OF $356,151.54 IN COSTS IN- CURRED IN CONNECTION WITH THE SITE. NO PAYMENT HAS BEEN RECEIVED.