THE COMPLAINT SEEKS TO RECOVER COSTS INCURRED BY THE U.S. EPA IN RESPONDING TO AN ACTUAL OR THREATENED RELEASE OF HAZARDOUS SUBSTANCES AT SUMMIT EQUIPMENT & SUPPLY. U.S.EPA INCURRED THESE COSTS IN CONDUCTING A REMOVAL ACTION AT THE SITE PURSUANT TO SECTION 104 OF THE CERCLA. - THIS REFERRAL IS FOR RECOVERY OF APPROX. $588,807.14 IN PAST COSTS INCURRED BY THE U.S.EPA FORM 1987 TO PRESENT IN RE- SPONDING TO A RELEASE AND THREATENED RELEASE OF HAZARDOUS SUBSTANCES AT THE SITE. THE COSTS WERE INCURRED FOR THE PREPARTATION, PERFORMANCE AND FOLLOW-UP OF A REMOVAL ACTION FOR THE REMOVAL OF HAZARDOUS SUBSTANCES FROM THE SITE. THE REMOVAL WAS CONDUCTED FROM MARCH 10, 1987, UNTIL SEPTEMBER 29, 1987, AND THUS THE STATUTE OF LIMITATIONS RUNS ON SEPTEMBER 29, 1990. - THE SUMMIT EQUPIMENT AND SUPPLY SIT EAS A SCRAPYARD AND SALVAGE FACILITY FOR INDUSTRIAL MACHINERY AND MISC DISCARDED ITEMS. PCB CONTAINING ITEMS, INCLUDING TRANSFORMERS AND CAPACITORS, WERE GENERATED BY THE PROPOSED DEFENDANTS. (SEE DEFENDANT LIST; SCREEN 4.) - SUMMIT EQUIPMENT & SUPPLY PURCHASED THE ITEMS AT AUCTION AND TRANSPORTED THEM TO ITS AKRON FACILITY. PCB WASTES WERE RE- LEASED TO THE ENVIRONMENT DURING THE