THE PROPOSED DEFENDANTS INCLUDE GENERATORS WHOSE HAZARDOUS SUBSTANCES CAME TO BE LOCATED AT THE CLOTHIER DISPOSAL SITE, THE OWNER AND/OR OPERATOR OF THE SITE, AND AN OWNER AND/OR OPERATOR OF THE POLLUTION ABATEMENT SERVICES OF OSWEGO, INC. ( PAS ) SITE TO WHICH THE CLOTHIER HAZARDOUS SUBSTANCES WERE ORIGINALLY SHIPPED FOR DISPOSAL AND FROM WHICH THEY WERE SENT FOR REDISPOSAL AT THE CLOTHIER SITE. HAZARDOUS SUBSTANCES WERE SENT BY THE PROPOSED GENERATOR DEFENDANTS TO THE PAS SITE FOR DISPOSAL. APPROXIMATELY 2,200 DRUMS OF HAZARDOUS SUBSTANCES WERE SHIPPED FROM THE PAS SITE TO THE CLOTHIER SITE. HAZARDOUS SUBSTANCES OF THE TYPES KNOWN TO HAVE BEEN SENT BY THE PROPOSED GENERATOR DEFENDANTS, IN DRUMS, TO THE PAS SITE ARE ALSO KNOWN TO HAVE BEEN PRESENT AT THE CLOTHIER SITE. EACH SUCH PAS GENERATOR IS THERFORE ALSO A GENERATOR AT THE CLOTHIER SITE. EPA HAS INCURRED COSTS IN CONDUCTING REMOVAL AND REMEDIAL ACTIONS AT THE CLOTHIER SITE. EPA'S THEORY HOLDING THE PROPOSED GENER- ATOR DEFENDANTS LIABLE FOR THE CONDITIONS AT THE CLOTHIER SITE HAS BEEN ACCEPTED BY SEVERAL COURTS. THE PROPOSED ACTION AGAINST THE OWNER AND/OR OPERATOR OF THE CLOTHIER SITE IS BASED UPON THAT PARTY'S OWNERSHIP OF THE SITE. EPA SEEKS PROPOSED RELIEF OF: 1) RECOVERY OF ALL COSTS WHICH HAVE BEEN INCURRED BY EPA IN CONNECTION WITH THE SITE, AS WELL AS PRE-JUGEMENT INTEREST; 2) CIVIL PENALTIES AND PUNITIVE DAMAGES FOR NON-COMPLIANCE WI