THE SONDEY PAINT AND SUPPLY COMPANY, OWNED BY STANLEY SONDEY, CONSISTS OF A ONE AND ONE-HALF ACRE TRACT OF LAND LOCATED AT 2 MIDLAND AVE, WALLINGTON, NEW JERSEY. THE SITE IS UNFENCED AND IMMEDIATELY ADJACENT TO AN ACTIVE LUMBER BUSINESS AND IT IS WITHIN 300 FEET OF RESIDENCES. THE PROPERTY IS LOCATED AT THE CONFLUENCE OF THE PASSAIC RIVER AND THE SADDLE BROOK RIVER. DEF SONDEY MANUFACTURED PAINT PRODUCTS AND PAINT SUPPLIES AT THE SITE UNTIL APPROXIMATELY 1970. NO MANUFACTURING HAS TAKEN PLACE AT THE SITE FOR NEARLY TWENTY YEARS. THE MATERIALS USED IN THE MANUFACTUR- ING PROCESS WERE LEFT IN THREE BUILDINGS ON THE SITE. IN MAY 1986 THE NJDEP ENTERED THE SITE AND SAMPLED THE CONTENTS OF NUMEROUS CONTAINERS. ANALYSES OF THE SAMPLES INDICATED THE PRESENCE OF THE FOLLOWING CERCLA HAZ SUB'S: ACETONE, METHYLENE CHLORIDE, TOLUENE, ETHYLBENZENE, XYLENE, ARSENIC AND LEAD. IN JULY 1986, AND AGAIN IN SEPT 1986, NJDEP ISSUED A DIRECTIVE TO DEF PURSUANT TO THE NEW JERSEY SPILL COMPENSATION AND CONTROL ACT, N.J.S.A. 58: 10-23.11 ET SEQ. THE DIRECTIVE REQUIRED SONDEY TO INVESTIGATE THE SITE AND REMOVE ALL HAZ SUB'S. SONDEY FAILED TO COMPLY WITH DIRECTIVE. AT THE REQUEST OF NJDEP, EPA ATTEMPTED TO BEGIN A SITE INVESTIGATION IN SPRING, 1987. SONDEY DENIED EPA OFFICIALS ACCESS TO THE SITE IN APRIL AND MAY 1987. EPA OBTAINED A 30 DAY WARRANT FOR ENTRY, INSPECTION A