THE UAO WAS NECESSARY BECAUSE ATTEMPS BY BOTH HARFORD COUNTY (THE PERFORMING PRP AT THE SITE) AND EPA HAD FAILED TO RESULT IN CONSENSUAL ACCESS TO THE PROPERTY. SUCH ACCESS IS NECESSARY SO THAT A REMEDIAL ACTION CAN BE CONDUCTED, AND SO THAT EPA MAY OVERSEE RESPONSE ACTIONS AT THE SITE. IN ACCORDANCE WITH THE SEPTEMBER 30, 1998 MEMORANDUM OUTLINING REVISIONS TO OECA CONCURRENCE AND CONULSTATION REQUIREMENTS FOR CERCLA CASE AND POLICY AREAS, WELL AS THE EPA DELEGATION 14-6 (INSPECTIONS, SAMPLING, INFORMATION GATHERING, SUBPOENAS, AND ENTRY FOR RESPONSE) REGIONAL STAFF CONSULTED WITH EPA HEADQUARTERS ABOUT THE UAO PRIOR TO ISSUING IT.