THIS IS A COST RECOVERY ACTION UNDER SECTION 107 OF CERCLA FOR RECOVERY OF REMOVAL COSTS INCURRED BY EPA IN THE SUMMERS OF 1988 AND 1989. THE CASE INVOLVES AN INDUSTRIAL WASTE DISPOSAL DUMP/LANDFILL LOCATED IN BROOKS, KY, A RURAL AREA OF BULLITT COUNTY LOCATED ABOUT 15 MILES SE OF LOUISVILLE. THE SITE WAS OPERATED AS AN INDUSTRIAL WASTE DUMP FROM APPROXIMATELY LATE 1964 THROUGH THE FIRST HALF OF 1967. DURING AT LEAST A PORTION OF THIS TIME, THE SITE WAS LEASED AND OPERATED BY TRI-CITYINDUSTRIAL SERVICES, INC., WHICH OVER THE YEARS HAS UNDERGONE A SERIES OF MERGERS INTO WHAT IS NOW WASTE MANAGEMENT OF KENTUCKY, INC. TRI-CITY NOT ONLY OPERATED THE SITE, BUT ALSO ACTED AS THE TRANS- PORTER OF WASTES TO THE SITE. IT HAS BEEN REPORTED THAT TRI-CITY'S GENERATOR CUSTOMERS INCLUDED FORD MOTOR CO., INC. AND GENERAL ELECTRIC COMPANY, INC. AND THE WASTES HAULED AND DISPOSED OF FOR THESE COMPANIES INCLUDED PAINT SLUDGES, PAINT THINNERS, SOLVENTS AND HYDRAULIC FLUIDS. TRI-CITY'S PRESIDENT, HARRY KLETTER, IS BELIEVED TO HAVE BEEN DIRECTLY INVOLVED IN BOTH THE OPERATION OF THE SITE AND IN ARRANGING FOR THE TRANSPORTATION OF GENERATOR WASTES TO THE SITE. SAMPLING ACTIVITIES CONDUCTED BY THE STATE OF KENTUCKY AND BY EPA REVEALED THE PRESENCE OF VARIOUS HAZARDOUS SUB- STANCES IN SOILS, GROUNDWATER AND DRUMS, INCLUDING TOLUENE, TETRACHLOROETHANE, TRICHLOROETHENE, PCBS, XYLENES, PHTHALATES, ETHYL BENZENE, CYANIDE, COP