THE CITY OF DETROIT THROUGH ITS COMMUNITY AND ECONOMIC DEV ELOPMENT(CEDD) OWNS THE OLD MACK AVENUE STAMPING PLANT (OLD MACK) LOCATED AT 11631 MACK AVE., DETROIT, MI., AND HAS VIO- LATED POLYCHLORINATED BIPHENYLS (PCBS) MANUFACTURING, PROCES SING, DISTRIBUTION IN COMMERCE, AND USE PROHIBITIONS PROMUL- GATED AND ENFORCEABLE UNDER THE TOXIC SUBSTANCES CONTROL ACT (TSCA), 15 U.S.C. 2601 ET SEQ. IN DECEMBER 1982, DETROIT BOUGHT OLD MACK FROM ITS ORIGIN- AL OWNER, CHRYSLER CORPORATION. DETROIT, HOWEVER, DID NOT TAKE PHYSICAL POSSESSION OF THE FACILITY UNTIL 1984. IN FEB RUARY 1983, THE MICHIGAN DEPARTMENT OF NATURAL RESOURCES (MDNR) INSPECTED OLD MACK; ADN FOUND NUMEROUS VIOLATIONS OF THE PCB REGULATIONS AND TSCA. AS A RESULT OF THIS INSPEC- TION, THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY(U.S EPA), REGION V FILED A CIVIL ADMINISTRATIVE COMPLAINT AGAINST DETROIT AND CHRYSLER IN NOVEMBER 1983. THE PARTIES SETTLED THE MATTER THROUGH A CONSENT AGREEMENT AND FINAL OR- DER IN APRIL 1985. ON OCTOBER 30, 1986, DECEMBER 3, 1986, AND DECEMBER 9, 1986, U.S. EPA AND MDNR AGAIN INSPECTED OLD MACK. THESE IN- SPECTIONS REVEALED NEW VIOLATIONS OF THE PCB REGULATIONS AND TSCA. A SECOND ADMINISTRATIVE COMPLAINT WAS FILED AGAINST DETROIT ON APRIL 14, 1987. IN JUNE 1987, DETROIT CONTRACTED TO HAVE PCB SCREENING PERFORMED AT OLD MACK. THIS SCREENING REVEALED WIDE-SPREAD CONTAMINATION, WI