AN ACCESS ORDER WAS ISSUED TO THE RESPONDENT COMPANIES IN ORDER TO ASSURE ACCESS BY EPA TO DO REMEDIAL ACTION WORK UNDER RODS FOR OU1 AND OU2. EPA TOOK THIS ACTION AFTER INFORMAL WRITTEN REQUESTS AND AFTER THE COMPANIES BEGAN TO DO REMEDIAL ACTION WORK AT THE SITE WITHOUT EPA APPROVAL. THE COMPANIES BEGAN THE WORK CLAIMING AUTHORITY UNDER 2 UAOS WHICH HAD BEEN ISSUED TO THEM ON MARCH 20, 1990 AND FEBRUARY 4, 1991. SEE DOCKET NO. V-W-90-C-049 AND V-W-91-C-086 TO DO REMEDIAL DESIGN AND REMEDIAL ACTION WORK. EPA HAD TAKEN THE POSITION THE AUTHORITY TO DO WORK UNDER THOSE ORDERS WHEN THEY REFUSED TO PERFORM THE WORK SHORTLY AFTER THEY WERE ISSUED. SIMULTANEOUSLY WITH THIS ACCESS ORDER, EPA ISSUED 2 106 UAOS WHICH TERMINATED ANY AUTHORITY CLAIMED UNDER THE 2 PREVIOUS UAOS. THE COMPANIES SUBSEQUENTLY AGREED TO COMPLY AND CEASED REMEDIAL ACTION WORK AT THE SITE AND HAVE AGREED TO PROVIDE ACCESS.