THE INT'L DISC CORP. SITE OCCUPIES APPROX. 27 ACRES ALONG THE NW PART OF ELLSWORTH LAKE IN ELLSWORTH, ANTRIM COUNTY, MI. FROM THE LATE 1950'S TO THE MID-1980'S, THE SITE WAS USED FOR MANUFACTURING A VARIETY OF PRODUCTS RANGING FROM FARM DISCS TO 105 MM PROJECTILES THAT REQUIRED THE USED OF HAZARDOUS MATERIALS. OPERATIONS INCLUDED METAL PLATING, PAINTING, AND METAL HEAT-TREATING. THE MICHIGAN DEPARTMENT OF NATURAL RESOURCES (MDNR) CON- DUCTED A SITE INSPECTION IN NOVEMBER 1985. THE MDNR FOUND ELEVATED LEVELS OF HEAVY METALS IN SOILS AND SEDIMENTS AND DISCOVERED IGNITABLE, CORROSIVE AND TOXIC MATERIALS STORED ON THE PREMISED, INCLUDING IMPROPERLY STORED CYANIDES AND ACIDS. IN MARCH 1986, THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (U.S. EPA) CONDUCTED PHASE I OF A REMOVAL ACTION TO STABILIZE CONDITIONS AT THE SITE. AFTER THE SITE WAS STA- BILIZED, THE PRP'S WERE GIVEN AN OPPORTUNITY TO COMPLETE THE CLEAN-UP ACTIVITIES, BUT THEIR EFFORTS WERE INADEQUATE, IN- EFFECTIVE, AND NOT TIMELY. IN APRIL 1987, U.S. EPA ISSUED A UNILATERAL ADMINISTRATIVE ORDER UNDER CERCLA SECTION 106 TO COMPLETE SITE CLEAN-UP. RESPONDENTS DID NOT COMPLY WITH THE ORDER. ON JULY 21, 1987, U.S. EPA INITIATED PHASE II OF THE RE- MOVAL ACTION. THE REMOVAL WAS COMPLETED ON OCTOBER 10, 1987 U.S. EPA'S UNRECOVERED COSTS TOTALLED