SITE IS LOCATED AT 4135 ALGONQUIN PARKWAY IN AN INDUSTRIALIZED AREA OF LOUISVILLE, JEFFERSON COUNTY, KENTUCKY, LOCALLY KNOWN AS RUBBER TOWN. MOBILE TANK CAR SERVICES, INC. ( MTCS ) OPERATED A RAILROAD TANK CAR CLEANING FACILITY AT THE SITE. THE FACILITY WAS CONSTRUCTED IN 1970. APPROXIMATELY 700 RAILROAD TANK CARS WERE CLEANED BY MTCS EACH YEAR BETWEEN THE YEARS 1970 TO 1985. MTCS ALSO RECEIVED INDUSTRIAL WASTEWATERS FROM OFF-SITE FOR DISPOSAL. MTCS FILED BANKRUPTCY IN 1989. NORFOLK SOUTHERN RAILWAY COMPANY ( NSRC ) AND ASHLAND CHEMICAL CO ( ACC ) ARE THE CURRENT OWNERS AND OPERATORS OF THE SITE. MTCS LEASED THE SITE FROM A SUCCESSION OF RAILWAY COMPANIES, NSRC BEING THE FINAL SUCCESSOR AND SITE OWNER. ACC OWNS THE PROPERTY ON WHICH PART OF THE WASTEWATER TREATMENT LAGOON IN WHICH THE HAZARDOUS WASTES FROM THE MTSC OPERATIONS WERE LOCATED. RECORDS INDICATE THAT BOTH ACC AND NSRC HAD TANK CARS CLEANED AT THE FACILITY. THE KENTUCKY DIVISION OF WASTE MANAGEMENT ( KDWM ) BECAME ACTIVE ON THE SITE DURING MTCS'S FACILITY CLOSURE EFFORTS. EPA AND KDWM SAMPLING INVESTIGATIONS AT THE FACILITY REVEALED ORGANIC CONTAMINANTS IN THE GROUNDWATER, SOILS, AND SLUDGES; AND SEVERAL EXTRACTABLE ORGANIC COMPOUNDS, METALS AND TOXAPHENE IN THE SOIL SAMPLES. KDWM WAS UNSUCCESSFUL IN ITS EFFORTS AGAINST MTCS FOR FAILURE