THIS CASE IS A CERCLA SECTION 107 COST RECOVERY ACTION AGAINST THE CITY OF DERBY, CT, FOR 2 IMMEDIATED REMOVAL ACT- IONS UNDERTAKEN BY EPA IN WHICH APPROX 900 DRUMS CONTAINING HAZARDOUS SUBSTANCES WERE REMOVED FROM PROPERTY OWNED BY THE CITY. IN THE 1ST REMOVAL ACTION (MAR-APR 1983) ABOUT 200 DRUMS WERE REMOVED IN ORDER TO STABILIZE THE AREA IN PREPARA TION FOR LONGER-TERM REMEDIAL ACTION. SUBSEQUENTLY, SIGNI- FICANT EROSION IN AREA CONTAINING THE REMAINING DRUMS OC- CURRED & EPA HAD TO UNDERTAKE A 2ND IMMEDIATE REMOVAL ACTION (SEPT 1984-JAN 1985) IN WHICH THE REMAINING APPROX 700 DRUMS WERE REMOVED FROM THE SITE. ON FEB 25, 1983, THE BURIED DRUMS WERE DISCOVERED AT O'SULLIVAN'S ISLAND, A PENINSULA AT THE CONFLUENCE OF 2 MA- JOR CONNECTICUT RIVERS, THE HOUSATONIC & THE NAUGATUCK IN DERBY, CT, BY A CONTRACTOR WORKING AT THE SITE FOR THE CITY. WILLIAM KOROLYSHUM WAS DREDGING FOR CLEAN COVER MATERIAL TO BE USED AT THE CITY LANDFILL WHEN THE BANK OF THE LAGOON COLLAPSED, EXPOSING APPROX 20 DRUMS & CAUSING ABOUT 10 DRUMS TO FALL INTO THE WATER. KOROLYSHUM OBSERVED THAT A FISH KILL HAD OCCURRED WHERE THE DRUMS HAD BEEN IN THE WATER. SAMPLES WERE TAKEN FROM CONTAMINATED LAGOON WATER, THE SOIL NEAR LEAKING DRUMS ON SHORE, & A DRUM CONTAINING LI- QUID. ANALYSES INDICATED THE PRESENCE OF METHYL ISOBUTYL KETONE, TOLUENE, & 1,1,1,-TRICHLOROETHYLENE, ALL HAZARDOUS SUBSTANCES AS DEFINED IN CERCLA SECT 101(