NATURE OF THE CASE THIS PROPOSED COST RECOVERY CASE CONCERNS THE UNION SCRAP SITE IN MINNEAPOLIS, MN. THE SITE IS LOCATED IN NORTH MIN- NEAPOLIS AND WAS OPERATING AS A BATTERY RECYCLING FACILITY UNTIL THE EARLY 1980S. LEAD CONTAMINATED BY-PRODUCTS FROM THE RECYCLING OPERATION ACCUMULATED ON THE SITE FOR ALMOST A DECADE. LEAD WAS CONTAMINATING THE SOILS ON THE SITE AND AIR AND WATER IN THE AREA SURROUNDING THE SITE. AFTER A DETERMINATION THAT THE LEAD CONTAMINATION POSED A SERIOUS THREAT TO HUMAN HEALTH AND THE ENVIRONMENT, THE U.S. EPA INITIATED A STABILIZATION ON DECEMBER 9, 1985. THE STA- BILIZATION ACTION CONTINUED UNTIL JANUARY 17, 1986. ONCE A PERMANENT REPOSITORY FOR THE LEAD CONTAMINATED WASTES WAS FOUND, A REMOVAL TO THE LEAD CONTAMINATED SOILS AND DEBRIS WAS INITIATED IN APRIL OF 1988. FURTHER SOIL REMOVAL OCCUR- RED IN NOVEMBER 1988. CAUSE OF ACTION USEPA SEEKS THE RECOVERY OF APPROXIMATELY $2.1 MIL EXPEND- ED AT THE SITE PURSUANT TO SECT 107 OF CERCLA, 42 USC SECT 9607. THE RECOMMENDED DEFENDANTS INCLUDE A FORMER OPERATOR OF THE FACILITY AND MANY OF THE GENERATORS OF THE LEAD TO THE SITE. PROPOSED REMEDY THE REMEDY SOUGHT IN THIS ACTION IS THE REIMBURSEMENT OF ALL RESPONSE COSTS EXPENDED BY THE USEP