THIS ACTION IS BASED ON HAZARDOUS SUBSTANCES WHICH WERE SENT BY MOST OF THE PROPOSED GENERATOR DEFENDANTS TO THE PAS SITE FOR DISPOSAL. APPROXIMATELY 8,000 DRUMS (SOME, BUT NOT ALL OF WHICH MAY HAVE BEEN 'EMPTY') WERE SHIPPED FROM THE PAS SITE TO THE VOLNEY SITE. NO RECORDS WERE KEPT OF THESE SHIPMENTS. SUBSTANCES OF THE TYPE KNOWN TO HAVE BEEN SENT BY THE PROPOSED GENERATOR DEFENDANTS TO THE PAS SITE ARE KNOWN TO BE PRESENT AT THE VOLNEY SITE. EPA HAS IN CURRED COSTS IN CONDUCTING REMEDIAL ACTIONS, INCLUDING A REMEDIAL INVESTIGATION/FEASIBILITYSTUDY (RI/FS) AT THE VOLNEY SITE. EPA'S THEORY HOLDING THE PROPOSED GENERATOR DEFENDANTS LIABLE FOR THE CONDITIONS AT THE VOLNEY SITE HAS BEEN CONSIDERED & ACCEPTED BY SEVERAL COURTS. THE PROPOSED ACTION AGAINST THOSE GENERATORS WHO HAD NO ASSOCIATION WITH THE PAS SITE IS BASED UPON THEIR SHIPMENTS OF HAZARDOUS SUBSTANCES DIRECTLY TO THE VOLNEY SITE. THE PROPOSED ACTION AGAINST THE OWNERS AND OPERATORS OF THE VOLNEY SITE IS BASED UPON THE PAST AND CURRENT OWNERSHIP OF THE SITE BY THOSE PARTIES. THE PROPOSED RELIEF EPA SEEKS; 1) RECOVERY OF ALL COSTS WHICH HAVE BEEN INCURRED BY EPA IN CONNECTION WITH THE SITE, AS WELL AS INTEREST; AND 2) A DECLARATORY JUDGMENT AS TO THE PROPOSED DEFENDANTS' LIABILITY OF FUTURE EXPENSES TO BE INCURRED BY EPA AT THE SITE.