DURING THE THREE YEAR PERIOD OF 1962 TO 1964 JOHNSON CONTROLS SENT ABOUT 13,964,178 POUNDS OF NET METAL JUNK AND 1,463,948 POUNDS OF PLANT SCRAP TO THE SITE. JOHNSON CONTROLS IS POTENTIALLY LIABLE AS A GENERATOR OF HAZARDOUS SUBSTANCES DISPOSED OF AT THE SITE. IN AUGUST 1984 AND IN MAY 1986, A U.S. EPA CONTRACTOR PERFORMED A SITE INSPECTION AND REPORTED THE RESULTS: LEAD CONTAMINATION PRESENT AT LEVELS AS HIGH AS 3,247 PPM. IN AUGUST 1995, THE MARION COUNTY HEALTH DEPARTMENT COLLECTED SOIL SAMPLES FROM THE NORTH PERIMETER OF THE FACILITY AND REPORTED THE LEAD CONTAMINATION MORE THAN 7,000 PPM, AND LEAD CONTAMINATION RANGING FROM 128 PPM TO 17,200 PPM FROM THE COLLECTED 17 COMPOSITE SAMPLES OF SOIL WITHIN A 0.5 MILE RADIUS OF THE FACILITY. IN OCTOBER 1995, INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT CONDUCTED AN EXPANDED A SITE INSPECTION ON THE FACILITY AND SHOWED LEAD CONCENTRATIONS RANGED FROM 47 PPM TO 6,400 PPM. ON JANUARY 31, 2005, U.S. EPA SIGNED AN ADMINISTRATIVE ORDER ON CONSENT WITH NATIONAL LEAD INDUSTRIES (NL). PURSUANT TO THE TERMS OF THE AGREEMENT, NL CONDUCTED A TIME-CRITICAL REMOVAL ACTION FOR THE AREA. AS OF JANUARY 31, 2005, U.S. EPA HAD INCURRED $83,091.11 IN COSTS AT THE SITE. DOJ HAS INCURRED APPROXIMATELY $24,158.89 IN COSTS AT THE SITE. AS NOTED, THE REMOVAL WORK IS BEING CONDUCTED BY NL AND IS ESTIMATED TO COST BETWEEN $3 AND $5 MILLION. U.S. EPA'S RESPONSE COSTS, WHICH ARE DEFINED IN THE AOC WITH NL AS ALL COSTS INCURRED AFTER JANUARY 31, 2005, AR