MCI, INC., LOCATED IN DETROIT, MI OPERATED A PAINT AND RUST STRIPPING BUSINESS BETWEEN 1970 AND APRIL 21, 1989, WHEN THE CORPORATION FILED FOR BANKRUPTCY UNDER CHAPTER 7 OF THE BANKRUPTCY CODE. AS A SECONDARY PART OF ITS BUSINESS, MCI ALSO OPERATED A PLATING BUSINESS AT THE SAME LOCATION. PAINT AND RUST STRIPPING OPERATIONS RESULTED IN THE ACCUMULATION OF PAINT WASTE AND STRIPPING SLUDGE, INCLUDING HAZARDOUS SUBSTANCES SUCH AS LEAD, CADMIUM, AND CHROMIUM. ON 10/11/89, THE USEPA TECHNICAL ASSISTANCE TEAM CONDUCTED A SITE ASSESSMENT OF THE SITE. APPROX 250 DRUMS WERE OBSERVED OUTSIDE THE FENCE LINE AND APPEARED TO CONTAIN PAINT SLUDGE. AN ADDITIONAL 300 DRUMS OF MATERIAL WERE FOUND INSIDE THE BUILDING. OTHER CONTAINERS ON THE PREMISES INCLUDED 10 ABOVE GROUND STORAGE TANKS AND 20 OPEN VATS, ALL OF WHICH WERE FOUND TO CONTAIN HAZ SUBSTANCES. BETWEEN JUNE AND DECEMBER 1990, USEPA CONDUCTED REMOVAL ACTIVITIES PURSUANT TO SECTION 104 OF CERCLA. ON 9/19/91, THE USEPA REFERRED THE MATTER OF MCI, INC. TO DOJ FOR PROSECUTION OF USEPA'S COST RECOVERY CLAIM UNDER SECTION 107 OF CERCLA, AGAINST SEVERAL OF THE POTENTIALLY RESPONSIBLE PARTIES TO THE SITE. ON 11/4/91, USEPA HELD A MEETING WITH THE PRPS WHO RECEIVED A DEMAND FOR PAYMENT FROM EPA DATED 8/16/91, IN AN ATTEMPT TO RESOLVE THEIR LIABILITY FOR APPROX $1 MILLION IN RESPONSE COSTS INCURRED BY THE AGENCY AT