NATURE OF THE CASE: IN MARCH 1983 EPA REGION IV WAS CON- TACTED BY THE KENTUCKY DEPARTMENT OF NATURAL RESOURCES (KY- DNR) REGARDING POTENTIAL CONTAMINATION OF THE LOST RIVER CAVE SYSTEM IN BOWLING GREEN, KENTUCKY. THE SUSPECTED CON- TAMINANTS WERE VOLATILE ORGANIC COMPOUNDS. ON MARCH 30, 1983 IN RESPONSE TO A REQUEST FROM KY-DNR, THE EPA TECHNICAL AS- SISTANCE TEAM (TAT) ARRIVED IN BOWLING GREEN TO INVESTIGATE AND SAMPLE THE CAVE CONTAMINATION. AT THE SAME TIME, TAT AND KY-DNR REPRESENATIVES INVESTIGATED THE J.L. KEITH FARM POND IN BOWLING GREEN. A DUCK KILL ON THE POND HAD OCCURRED IN MAY 1982 AND CONTAMINANTS WERE BELIEVED TO BE PRESENT SIMU- LAR TO THOSE FOUND IN THE LOST RIVER CAVE SYSTEM. IN THE COURSE OF INVESTIGATING THE POND, THREE INDUSTRIAL ACTIVITIES WERE FOUND IN THE VICINITY: MULTI-CHEM, INC., A CHEMICAL REPACKAGING PLANT, FMC CORP., A HEAVY EQUIPMENT MANUFACTURER, AND WARNCO, AN AGRICULTURAL PRODUCTS COMPANY. DUE TO THE SIMILARITY BETWEEN THE MATERIALS HANDLED BY MULTI-CHEM AND THE CONTAMINANTS FOUND IN THE POND, IN SEP- TEMBER 1982 THE STATE OF KENTUCKY REQUESTED MULTI-CHEM TO PRESSURE-TEST ITS UNDERGROUND TANKS. NONE OF THE 18 UNDER- GROUND TANKS WERE FOUND TO BE LEAKING. FOLLOWING CONTINUED ODOR COMPLAINTS BY THE KEITHS IN FEB- RUARY 1983, THE KY-DNR SAMPLED THE POND AGAIN AND FOUND HIGH LEVELS OF VARIOUS VOLATILE CHLORINATED HYDROCARBONS. BASED UPON THE CONTINUED EXISTENCE OF CONTAM