THIS IS A CERCLA SECTION 122(H)(A) ADMINISTRATIVE PAST COST RECOVERY SETTLEMENT ( AGREEMENT ) FOR THE STANDARD SCRAP CERCLA REMOVAL ACTION SITE ( SITE ). THE SITE IS A SCRAP METAL RECLAMATION AND SHREDDING FACILITY LOCATED AT 4004- 4020 S. WENTWORTH AND 4000-4027 S. WELLS, CHICAGO, COOK COUNTY, ILLINOIS. IT WAS THE SUBJECT OF A FEDERALLY FUNDED REMOVAL ACTION COMMENCED ON SEPTEMBER 22, 1994 AND COMPLETED ON JANUARY 30, 1996. EPA'S OUTSTANDING RESPONSE COSTS, IN- CLUDING PREJUDGEMENT INTEREST, ARE $3,895,926.94 (THROUGH JUNE 30, 1998). EPA HAS IDENTIFIED APPROXIMATELY 305 PRPS IN CONNECTION WITH THE SITE, INCLUDING THE 3 OWNERS/OPERA- TORS OF THE SITE. EPA REFERRED, AND DOJ FILED IN THE NORTH- ERN DISTRICT OF ILLINOIS, A CERCLA COST RECOVERY AND CERCLA AND CAA CIVIL PENALTY ACTION AGAINST THE 3 OWNERS/OPERATORS OF THE SITE. SEE U.S. V STEVEN COHEN ET AL., CIV. NO. 96C 7801. THAT ACTION IS ONGOING. HOWEVER, BASED ON EXTENSIVE INFORMATION OBTAINED DURING DISCOVERY, IT IS APPARENT THAT THE OWNERS/OPERATORS DO NOT HAVE THE FINANCIAL RESOURCES TO SATISFY EPA'S OUTSTANDING RESPONSE COST CLAIMS OR EPA'S PUNITIVE CLAIMS. THE OWNERS/OPERATORS ARE NOT PARTICIPANTS IN THIS AGREEMENT. THE REMAINING 302 PRPS WHO HAVE BEEN IDENTIFIED ARE POTENTIALLY LIABLE AS ARRANGERS UNDER SECTION 107(A)(3) OF CERCLA. OF THESE PRPS, AT LEAST 34 ARE EITHER NO LONGER IN EXISTENCE OR NOT FINANCIALLY VIABLE. IN ADDITION, IT APPEARS THAT A SUBSTANT