THIS IS A CERCLA SECTION 122(H)(1) 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 JAUNARY 30, 1996. EPA'S OUTSTANDING RESPONSE COSTS, IN- CLUDING PREJUDGEMENT INTEREST, ARE $3,895,926.94 (THROUGH JUNE 30, 1008). EPA HAS IDENTIFIED APPROXIMATELY 305 PEPRS IN CONNECTION WITH THE SITE, INCLUDING THE 3 OWNERS/OPERA- TORS OF THE SITE. SEE U.S. V STEVEN COHEN ET AL., CIV. NO. 96C 7801. THAT ACTION IS ONGOING. HOWEVER BASED ON EXTEN- SIVE INFORMATION OBTAINED DURING DISCOVERY, IT IS APPARENT THAT THE OWNERS/OPERATORS DO NOT HAVE THE FINANCIAL RESOURCE S 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 ADDI- TION, IT APPEARS THAT A SUBSTANTIAL NUMBER OF THE REMAINING 268 PRPS MAY BE OF QUESTIONABLE OR LIMITED FINANCIAL VIABI- LITY. UNDER THE AGREEMENT, EPA WILL RECOVER $74,771.45 FROM SAMUALS RECYCLING COMPANY.