SITE CONSISTS OF 3 PIECES OF ADJACENT PROPERTY. ALL 3 OF THE PROPOSED DEFENDANTS ARE LIABLE AS OWNERS. ONE IS THE CURRENT OWNER AND OPERATOR OF A PORTION OF THE SITE. THE OTHER 2 ARE PAST OWNERS AT THE TIME OF DISPOSAL. EPA SEEKS TO RECOVER PAST COSTS FOR A COOPERATIVE AGREEMENT FOR AN RI CONDUCTED IN 1987, SINCE TWO OF THE POTENTIAL PRPS REFUSED TO SETTLE WITH EPA FOR AN RD/RA, THIS CASE IS REFERRED AS PART OF THE NON-SETTLER/NON-COMPLIER INITIATIVE.