NATURE OF THE CASE: THE DREYFUS STREET SITE, LOCATED IN COLUMBIA, SOUTH CAROLINA, WAS OPERATED AS A DRUM STORAGE SITE BY SOUTH CAROLINA RECYCLING AND DISPOSAL, INC. (SCRDI) BETWEEN 1977 AND 1981. BETWEEN 400 AND 600 DRUMS IN VARYING STAGES OF DISREPAIR WERE STORED AT THE SITE DURING ITS PERIOD OF OPERATION. SINCE SCRDI OPERATED SEVERAL SITES IN THE COLUMBIA AREA AND MOVED DRUMS AMONG THE SITES, THE NUMBER OF DRUMS STORED AT THE DREYFUS STREET VARIED. THE SITE IS LOCATED IN AN AREA OF THE CITY WHERE THERE IS SIGNIFICANT AUTO AND PEDESTRIAN TRAFFIC, INCLUDING CHILDREN, AND THUS POSED A SERIOUS HEALTH THREAT IN ADDITION TO THE RISK OF ENVIRONMENTAL HARM. THE SOUTH CAROLINA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL (DHEC) INITIATED LITAGATION AGAINST SCRDI AND THE OWNER OF THE PROPERTY, COLUMBIA STEEL AND METAL COMPANY, INC. (CSMCI), BUT THE SUIT WAS UNSUCCESS- FUL, PRIMARILY BECAUSE SCRDI WAS PRACTICALLY IN SOLVENT, BUT ALSO BECAUSE CSMCI FOUGHT THE ISSUE OF LIABILITY ADAMANTLY. IN SEPTEMBER 1981, CERCLA FUNDS WERE AUTHORIZED FOR AN IMMEDIATE REMOVAL ACTION, WHICH WAS COMPLETED OCTOBER 30 AND COST OVER $300,000. THE CASE WAS REFERRED TO EPA HQ ON APRIL 26, 1982, AND TO THE DEPARTMENT OF JUSTICE ON SEPTEMBER 9, 1982, FOR FILING AS CERCLA COST RECOVERY ACTION. THE COMPLAINT AND DISCOVERY REQUESTS ARE CURRENTLY BEING REVISED BY DOJ.