THIS PROPOSED CIVIL ACTION INVOLVES THE CROSS BROTHER'S PAIL RECYCLING FACILITY LOCATED IN PEMBROKE TOWNSHIP, KANKAKEE COUNTY, ILLINOIS. THE FACILITY WAS OPERATED BY JAMES AND ABNER CROSS FROM APPROX. 1961 THROUGH 1980 AS A BARREL AND PAIL RECLAMATION FACILITY. THE FACILITY IS LOCATED ON AP- PROX. 20 ACRES IN RURAL KANKAKEE OWNED BY THE CROSS BROTHERS AND USED FOR THEIR RECLAMATION OPERATION. - THE OPERATION ITSELF WAS EXTREMELY HAPHAZARD, RESULTING IN THE RELEASE OF GREAT QUANTITIES OF HAZARDOUS SUBSTANCES TO THE ENVIRONMENT. IT WAS THE PRACTICE OF THE CROSS BROTHERS TO BRING BARRELS AND OTHER CONTAINERS CONTAINING HAZARDOUS SUBSTANCES TO THE FACILITY WHERE THEY WOULD BE OVERTURNED TO EMPTY THE CONTENTS ONTO THE GROUND. THE CONTAINERS WOULD THEN BE PARTIALLY FILLED WITH SOLVENTS FOR THE PURPOSE OF DI SSOLVING ANY REMAINING RESIDUE. THIS MIXTURE WOULD THEN BE DUMPED ON THE GROUND OR WOULD BE IGNITED AND ALLOWED TO BURN OUT ANY REMAINING RESIDUE. FOLLOWING THE DUMPING AND BURN- ING PROCESS THE BARRELS AND CONTAINERS WOULD BE SANDBLASTED, REPAINTED AND SOLD. OVER THE YEARS OF OPERATION, THIS PRO- CESS RESULTED IN THE INDISCRIMINATE RELEASE OF A GREAT A- MOUNT OF HAZARDOUS SUBSTANCES TO THE ENVIRONMENT. - MANY BARRELS AND CONTAINERS WHICH WERE NOT CAPABLE OF RECON- DITIONING WERE BURIED ON SITE IN ANY