THIS CASE CONCERNS A WOOD TREATMENT FACILITY LOCATED IN JEFFERSON DAVIS COUNTY, MS, APPROXIMATELY 2 MILES FROM PRENTISS, MS. WOOD TREATMENT REPORTEDLY BEGAN AT THIS LOCATION IN 1957 OR 1960, OR BY ANOTHER REPORT, AS EARLY AS THE 1940'S, AND CONTINUED THROUGH CHANGES IN OWNERSHIP UNTIL 1986. THE PROPOSED RCRA CLAIMS CONCERN THE FACILITY'S LOSS OF INTERIM STATUS ON NOVEMBER 8, 1985, VIOLATIONS ARISING FROM THE ABANDONMENT OF THE FACILITY IN 1986, AND CORRECTIVE ACTION NEEDED ONSITE. FOLLOWING THE ABANDONMENT OF THE FACILITY, A PHASED REMOVAL ACTION WAS BEGUN BY EPA IN 1987, GIVING RISE TO COST RECOVERY CLAIMS UNDER CERCLA IN EXCESS OF $3,500,000. WHILE IN OPERATION, THE FACILITY INCLUDED A THREE-CELLED SURFACE IMPOUNDMENT USED FOR THE TREATMENT OF PROCESS WASTEWATER AND CONTAINING EPA HAZARDOUS WASTE NUMBER K001. CONSEQUENTLY, THE FACILITY WAS SUBJECT TO REGULATION UNDER RCRA, AND A PART A APPLICATION WAS SUBMITTED, QUALIFYING THE FACILITY FOR INTERIM STATUS. HOWEVER, THE FACILITY LOST INTERIM STATUS ON NOVEMBER 8, 1985, AS A RESULT OF THE FAILURE TO SUBMIT A PART B APPLICATION AND GROUNDWATER MONITORING AND FINANCIAL RESPONSIBILITY CERTIFICATIONS. FROM 1972 UNTIL 1985, THE FACILITY WAS OWNED AND OPERATED BY PRENTISS CREOSOTE AND FOREST PRODUCTS, INC. IN AUGUST 1985, THE OFFICERS OF PRENTISS CREOSOT