THIS IS A COST RECOVERY CASE TO RECOVER COSTS OF A U.S. EPA FINANCED REMOVAL ACTION AT THE SITE. THE SITE IS LOCATED ACROSS THE STREET FROM A FORMER CERAMICS COMPANY KNOWN AS THE INGRAM-RICHARDSON ( ING-RICH ) COMPANY, WHICH OPERATED BETWEEN 1915 AND 1980. THE ING-RICH COMPANY BOUGHT THE AUGUSTUS HOOK PROPERTY IN 1963 AND IT (AND ITS SUCCESSORS WITH IDENTICAL OR SIMILAR NAMES) USED THE PROPERTY TO DIS- POSE OF ING-RICH'S WASTES, INCLUDING ITS HAZARDOUS WASTES, UNTIL 1981. THE PROPERTY WAS ACQUIRED BY CHESTER ASSOCIATES AN OHIO LIMITED PARTNERSHIP, IN 1981. CHESTER ASSOCIATES CHANGED ITS NAME TO AUGUSTUS & HOOK ASSOCIATES ( AHA ) ON DECEMBER 16, 1982. IN 1986, OWNERSHIP OF THE SITE WAS TRANSFERRED. IN 1986, OWNERSHIP OF THE SITE WAS TRANSFERRED TO 815 REALTY, INC. ( 815 REALTY ), A CLOSELY HELD INDIANA CORPORATION. THE PROPERTY IS UNIMPROVED AND HAS NOT BEEN USED BY ANY OF THE OWNERS FOR ANY PURPOSES EXCEPT DISPOSAL OF WASTE. U.S. EPA CONDUCTED A TIME CRITICAL REMOVAL ACTION AT THE SITE PURSUANT TO APRIL 3, 1995 AND AUGUST 22, 1996 ACTION MEMORANDA. ATTACHMENT 3 AND 4. U.S. EPA SECURED THE SITE AND STABILIZED 45,000 TONS OF HAZARDOUS WASTE. THE AGENCY THEN REMOVED STABILIZED WASTE CONTAINING LEAD LEVELS IN EXCESS OF 500 PPM AND DISPOSED OF IT OFF-SITE. THE REMOVAL WAS COMPLETED ON SEPTEMBER 13, 1997. ATTACHMENT 5. U.S. EPA INCURRED COSTS TOTALING $2,613,8