THIS IS THE FIRST RD/RA CONSENT DECREE IN THE COUNTRY WHEREIN THE DEFENDANTS WILL FUND RATHER THAN PERFORM THE CLEANUP OF THE SITE. THE CONSENT DECREE WAS STRUCTURED SO THAT EPA WAS ASSURED OF 100% NON-INTERRUPTED FUNDING OF THE RA. TWO OF THE VEHICLES FOR ACCOMPLISHING THIS PURPOSE WERE A PRIVATE CUSTODY ACCOUNT SET UP AND FUNDED BY THE DEFEN- DANTS AND AN EPA SPECIAL ACCOUNT WHICH WILL BE FUNDED BY THE CUSTODY ACCOUNT. THE OVER ONE HUNDRED DEFENDANTS TO ELECT TO CASHOUT AS DE MINIMIS DEFENDANTS OR TO SHARE THE CONTINUED LIABILITIES AND OBLIGATIONS OF THE NON-DE-MIMIMIS DEFENDANTS. THE CITY INDUSTRIES SITE IS LOCATED ON APPROXIMATELY ONE ACRE OF LAND IN WINTER PARK, FLORIDA. IN 1977, CITY INDUSTRIES, INC. DEVELOPED INTO A RECYCLING AND TRANSFER FACILITY FOR HAZARDOUS WASTES. DUE TO INADEQUATE PLAN PRACTICES AND INTENTIONAL DUMPING, SOIL AND GROUNDWATER AT THE SITE BECAME CONTAMINATED. THE MAY 1984, EPA CONDUCTED A REMOVAL ACTION IN WHICH IT HEAT TREATED 1,670 TONS OF CONTAMINATED SOIL. ON MARCH 29, 1990, THE ROD WAS SIGNED. THE REMEDY SELECTED WAS PUMPING AND TREATING CONTAMINATED GROUNDWATER ON-SITE AND THEN DISCHARGING THE GROUNDWATER TO A PUBLICLY- OWNED TREATMENT WORKS (POTW). THE ROD ALSO SELECTED A CONTINGENCY ALTERNATIVE IN THE EVENT THE POTW DOES NOT AGREE TO ACCEPT THE DISCHARGE. THE ALTERNATIVE