BACKGROUND AND NATURE OF CASE THIS REFERRAL CONCERNS A PROPOSED COST RECOVERY ACTION UNDER SECTION 107 OF CERCLA. PEERLESS PLATING CO., LOCATED AT 2554 GETTY STREET, MUSKEGON, MICHIGAN, WAS CONSTRUCTED IN OR ABOUT 1937 AND ESTABLISHED AS A JOB SHOP PLATING OPERA- TION. THE FACILITY WAS OPERATED UNTIL JUNE 30, 1983, WHEN REGULATORY ACTION, LABOR RELATIONS PROBLEMS, AND FINANCIAL CONDITIONS FORCED IT TO CLOSE. PEERLESS DECLARED BANKRUPTCY IN AUGUST, 1983. THE FACILITY HAD BEEN LEFT IN OPERATIONAL CONDITION, THAT IS, ALL PLATING SOLUTIONS REMAINED IN THE PLATING LINES, RAW MATERIALS WERE STORED IN TANKS AND ORIGINAL CONTAINERS, AND DRUMS OF WASTE MATERIAL WERE STORED THROUGHOUT THE BUILDING. ACCESS WAS GENERALLY UNRESTRICTED. DURING THE WEEK OF AUGUST 22, 1983, LOCAL AND STATE AUTHORITIES DETECTED CYANIDE GASES IN THE FACILITY ATMOS- PHERE. THEY NOTIFIED U.S. EPA'S REGION V SPILL RESPONSE SECTION ON SEPTEMBER 1, 1983. ON SEPTEMBER 2, 1983, AN ON-SCENE COORDINATOR DETERMINE D THAT AN IMMEDIATE REMOVAL PURSUANT TO SECTION 104 OF CERCL A WAS NECESSARY TO ABATE THE HAZARDOUS CONDITIONS AT THE SITE (EXPOSURE TO CORROSIVE AND TOXIC MATERIALS AND POISON- OUS GASES). REMOVAL WORK WAS INITIATED ON SEPTEMBER 6, 1983 AND CONCLUDED ON OCTOBER 7, 1983. APPROXIMATELY 37,000 GALLONS OF HAZARDOUS LIQUIDS WERE REMO