SYNOPSIS OF THE CASE SUPERIOR INDUSTRIES, LTD. IS THE PRESENT OWNER OF A FACILITY LOCATED IN PHOENIXVILLE, PENNSYLVANIA. THE FACILI- TY WAS FORMERLY A PAINT AND COATING MANUFACTURING OPERATION OWNED AND OPERATED BY TURCO COATINGS, INCORPORATED ( TURCO ). ON JANUARY 3, 1980, TURCO COATINGS FILED UNDER CHAPTER 11 OF THE BANKRUPTCY CODE FOR REORGANIZATION. AS A RESULT OF TURCO'S FAILURE TO SUPPORT THE PETITION FOR RE- ORGANIZATION, THE LAND AND BUILDINGS WERE SOLD TO SUPERIOR INDUSTRIES, LTD. AT A SHERIFF'S SALE ON AUGUST 21, 1982. AT THE TIME OF THE SALE, A NUMBER OF DRUMS CONTAINING PAINT, SOLVENT, AND COATING WASTES WERE STORED AT THE FACILITY. TURCO HAD NOTIFIED EPA ON OCT. 20, 1980 AS A POTENTIAL HAZ- ARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITY UN- DER THE RESOURCE CONSERVATION AND RECOVERY ACT, 42 U.S.C. 6901 (RCRA). ON NOVEMBER 19, 1980, TURCO SUBMITTED A PART A RCRA APPLICATION LISTING THE ESTIMATED QUANTITIES OF HAZ- ARDOUS WASTE AT THE FACILITY. AT THE REQUEST OF THE PENNSYLVANIA DEPARTMENT OF ENVIRON- MENTAL RESOURCES ( DER'), THE PRESIDENT FO SUPERIOR INDUS- TRIES, LTD., MR. ANTHONY MIRABLE, AGREED TO PROPERLY DISPOSE OF ALL WASTES AT THE TURCO FACILITY. IN MAY OF 1982, DER ISSUED A TEMPORARY RCRA TRANSPORTATION IDENTIFICATION NUMBER TO BE USED FOR THE TRANSPORTATION OF HAZARDOUS WASTE FROM THE SITE. IN MAY AND JUNE OF 1982 EPA