THE ROLFITE SITE IS A MANUFACTURING PLANT LOCATED IN SHELTON, CONNECTICUT THAT HAS BEEN IN COMMERCIAL USE SINCE 1963, THE ROLFITE COMPANY PRESENTLY OWNS THE PLANT AND USES IT TO MANUFACTURE INDUSTRIAL FUEL ADDITIONS AND ANTI-ODOR CHEMICALS. IN EARLY 1986 THE STATE OF CT DEPARTMENT OF EN- VIRONMENTAL PROTECTION RECEIVED A COMPLAINT THAT THE COM- PANY WAS ILLEGALLY STORING DRUMS CONTAINING HAZARDOUS CHEM- ICALS. ON 04/02/86, A REPRESENTATIVE OF THE DEP INSPECTED THE SITE AND FOUND APPROXIMATELY 700 DRUMS CONTAINING HAZ- ARDOUS SUBSTANCES STORED IN A CONCRETE CONTAINMENT AREA. SEVERAL OF THE DRUMS WERE LEAKING, HAD OPEN TOPS, OR WERE SEVERELY DETERIORATED. ON 05/15/86, THE COMMISSIONER OF THE CT DEP ISSUED ORDER #335 TO ROLFITE MANDATING THAT IT REMOVE AND PROPERLY DISPOSE OF ALL TOXIC, HAZARDOUS AND OTHER IN- DUSTRIAL WASTES STORED ON-SITE. ROLFITE FAILED TO COMPLY WITH THE ORDER AND ON 11/21/86, CT ATTORNEY GENERAL BROUGHT A LAWSUIT AGAINST THE COMPANY SEEKING A PERMANENT INJUNCTION REQUIRING ROLFITE TO COMPLY WITH THE ORDER AND A COURT ORDER REQUIRING ROLFITE TO FORFEIT $25,000 PER DAY FOR EACH VIOLA- TION OF CT'S HAZARDOUS WASTE MANAGEMENT REGULATIONS. AT PRE- SENT ROLFITE HAS ACCUMULATED OVER $3 MILLION IN PENALTIES. THE STATE HAS PLACED A LIEN ON THE PROPERTY AND WILL PARTI- CIPATE IN THE BANKRUPTCY PROCEEDINGS. FROM 06/29/87 UNTIL 03/17/88, EPA CONDUCTED A REMOVAL ACTION AT THE SITE WHICH CONSISTED OF