ON JANUARY 21, 1994, THE WASTE MANAGEMENT DIVISION FOR EPA REGION VEXECUTED A PROPOSED REMOVAL ADMINISTRATIVE ORDERON CONSENT ( AOC )REQUIRING, INTER ALIA, TWO POTENTIALLY RESPONSIBLE PARTIES TO REMOVESEVERAL THOUSAND DRUMS OF HAZARDOUS SUBSTANCES AND CONTAMINANTS FROM THEJACKSON DROP FORGE SITE AND REIMBURSE EPA FOR ALL OF ITS PAST ANDOVERSIGHT COSTS. THE JACKSON DROP FORGE SITE (THE SITE ) IS LOCATED AT WELLWORTHAVENUE, JACKSON, MICHIGAN. THE SITE IS SITUATED IN A MIXED INDUSTRIALAND RESIDENTIAL AREA AND IS ADJACENT TO THE GRAND RIVER. FOR SEVERALYEARS, PORTION OF THE SITE WAS OPERATED AS DROP FORGE FACILITY WHILEOTHER PORTIONS OF THE SITE WERE UTILIZED AS A DUMP. ON DECEMBER 2, 1993, EPA ISSUED A REMOVAL ACTION MEMORANDUM DOCUMENTING, INTER ALIA,THE PRESENCE OF SEVERAL THOUSAND DRUMS OF INDUSTRIAL WASTES, INCLUDING HAZARDOUS SUBSTANCES AND CONTAMINANTS, AT THE SITE (AND WITHIN THE FLOODPLAIN OF THE GRAND RIVER) AND APPROVING THE EXPENDITURE OF APPROXIMATELY $2 MILLION TO ADDRESS THE CONDITIONS AT THE SITE. SUBSEQUENTLY, EPAENTERED INTO THE AOC WITH JACKSON . INNOVA CORPORATION AND MERCER FORGECORPORATION PURSUANT TO WHICH THOSE CORPORATIONS WOULD UNDERTAKE REMOVALCLEANUP ACTIVITIES AT THE SITE AND REIMBURSE EPA FOR ALL ITS PAST ANDOVERSIGHT COSTS.