THE INDIANA PALLET SITE (IPS) IS LOCATED IN EAST CHICAGO, LAKE COUNTY, INDIANA, AND IS AN INDUSTRIAL, COMMERCIAL, RESIDENTIAL AREA. THE IPS BUILDING WAS ONCE USED FOR PROCESSION STEEL. THE DRUM STORAGE AREA WAS APPROXIMATELY, 120' BY 30'. TWENTY-SEVEN INVESTIGATIVE SAMPLES COLLECTED FROM POLY DRUMS. STEEL DRUMS, AND POLY BAGS ON JANUARY 21ST AND JANUARY 22ND, 2003, WERE ANALYZED FOR CHARACTERISTICS OF HAZARDOUS WASTE. THE SAMPLES EXCEEDED THE CRITERIA FOR CHARACTERISTICS OF HAZARDOUS WASTE. BASED UPON THE FOREGOING FINDINGS OF FACT, THE RESPONDENTS SHALL CONDUCT REMOVAL ACTIVITIES, AND REIMBURSE U.S. EPA, UPON WRITTEN DEMAND, FOR ALL RESPONSE COSTS INCURRED BY THE UNITED STATES IN OVERSEEING RESPONDENTS' IMPLEMENTATION OF THE REQUIREMENTS OF THIS ORDER. VIOLATION OF ANY PROVISION OF THIS ORDER MAY SUBJECT RESPONDENTS TO CIVIL PENALITIES OF UP TO $27,500 PER VIOLATION PER DAY.