THE SITE CONSISTS OF A SINGLE STORY, APPROXIMATELY 80' BY 100' STEEL STRUCTURE LOCATED ON 1.7 ACRES OF LAND. THE REAL PROPERTY IS OWNED BY NORFOLK SOUTHERN RAILWAY COMPANY AND IS LEASED TO TRI-STATE CHEMICAL COMPANY. IN 1988, THE TRI-STATE CHEMICAL COMPANY MOVED TO THE SITE WITH AN INVENTORY OF APPROXIMATELY 700 DRUMS OF CONCRETE CURING COMPOUND. THE CURING COMPOUND CONTAINS A HYDROCARBON RESIN WITH A MINERAL SPIRITS CARRIER, A PIGMENT (TITANIUM DIOXIDE), SOY BEAN LECITHIN, ADDITIONAL MINERAL SPIRITS, AND WATER. THE METAL BUILDING AT THE SITE HAS BEEN USED TO STORE NUMEROUS 55-GALLON DRUMS AND SMALLER CONTAINERS SUCH AS BUCKETS, CANS, ETC. THERE ARE ALSO SEVERAL LARGE TANKS ON-SITE RANGING FROM APPROXIMATELY 1,000 TO 10,000 GALLONS IN SIZE. ON NOVEMBER 10, 2004, OHIO ENVIRONMENTAL PROTECTION AGENCY (OEPA) OBSERVED THAT SEVERAL OF DRUMS LEAKING AND BULGING AND THAT A PAINT WASTE TYPE ODOR WAS NOTED INSIDE THE BUILDING. ON NOVEMBER 12, 2004, AN OEPA OSC VISITED THE SITE AND CONDUCTED AN EMERGENCY RESPONSE ASSESSMENT. ON DECEMBER 16, 2004, THE OEPA COLLECTED SAMPLES FROM 15 DRUMS AT THE SITE. EIGHT SAMPLES EXHIBITED FLASH POINTS BELOW THE REGULATORY LIMIT OF 1400F FOR HAZARDOUS WASTE. IN A LETTER DATED JANUARY 26, 2005, TO THE U.S. EPA, THE OEPA REQUESTED ASSISTANCE IN CONDUCTING A POTENTIAL TIME-CRITICAL REMOVAL ACTION AT THE SITE. THE OEPA NOTED THAT THERE WERE HUNDREDS OF DRUMS (NUMEROUS LEAKING) IN WHAT APPEARED TO BE AN ABANDONED BUILDING. THE U.S. EPA COMPLETED AN INVENT