NATURE OF CASE ON JULY 5, 1983, US.S EPA COMMENCED AN IMMEDIATE REMOVAL ACTION AT THE NORTHERNAIRE PLATING COMPANY FACILITY IN CADILLAC, MICHIGAN, TO REMOVE HAZARDOUS PLATING WASTES. THE WASTES WERE ABANDONED BY NORTHERNAIRE PLATING COMPANY AND/OR TOP LOCKER ENTERPRISES, INC., FOLLOWING THE LIQUIDA- TION OF NORTHERNAIRE'S ASSETS TO SATISFY A LOAN TO THE FIRST BANK OF CADILLAC. EMERGENCY ACTION WAS TAKEN TO PREVENT DRUMS AND VATS OF CYANIDE WASTE FROM MIXING WITH ACIDS LEFT AT THE SITE. MIX- TURE OF THE CYANIDE AND ACID WASTE WOULD RESULT IN THE FORMATION OF DEADLY HYDROGEN CYANIDE GAS. IN ADDITION, EMERGENCY ACTION WAS UNDERTAKEN TO REMOVE GROSSLY CONTAMI- ATED SLUDGES FROM A SEWER LINE TO PREVENT FURTHER GROUND- WATER CONTAMINATION. R. W. MEYER, INC., OWNS THE LAND ON WHICH THE NORTHERNAIRE PLATING FACILITY IS LOCATED. MEYER CONSTRUCTION COMPANY, CONSTRUCTED A SEWER LINE WHICH EXTENDS BETWEEN THE FACILITY AND THE CITY SEWER SYSTEM. THE SEWER LINE WAS CONSTRUCTED IN A MANNER WHICH ALLOWED HAZARDOUS WASTE TO ESCAPE INTO THE SURROUNDING SOILS AND GROUNDWATER. NORTHERNAIRE PLATING COMPANY OWNED AND OPERATED THE PLATING FACILITY BETWEEN THE YEARS 1971 AND 1981. THE FACILITY WAS ABANDONED IN MAY OR JUNE,