THE SITE HAD SEVERAL OPERATORS PRIOR TO 1978, NONE OF WHICH WAS INVOLVED IN THE HAZARDOUS WASTE CONTAMINATION WHICH WAS THE SUBJECT OF THE U.S. EPA REMOVAL. SUBSEQUENT TO 1978, MAURICE AND DANIEL GREEN, UNDER VARIOUS BUSINESS NAMES, CON- DUCTED ELECTROPLATING OPERATIONS AT THE SITE. IN 1988, THEIR COMPANY SOLD THE SITE TO HRW INDUSTRIES, WHO, UNDER THAT OR DIFFERENT NAMES, CONTINUED THE SAME BUSINESS. U.S. EPA INITIATED REMOVAL ACTION AT THE SITE IN MARCH 1996, ANDC COMPLETED IT IN AUGUST 1997. TOTAL COSTS INCURRED ARE APPROXIMATELY $3 MILLION. THOUGH NO PRP, BASED UPON WHAT EACH HAS PROVIDED, WOULD APPEAR TO HAVE MUCH IN ASSETS FROM WHICH TO RECOVER COSTS, INVESTIGATIONS CONDUCTED BY NEIC AND INDUSTRIAL ECONOMICS REVEAL THAT THERE ARE SOLID GROUNDS FOR HOLDING MAURICE AND DANIEL GREEN INDIVIDUALLY LIABLE, THERE IS A STRONG LIKELIHOOD THAT THEY HAVE MADE TRANSFERS OF THEIR PROPERTY WHICH COULD BE SET ASIDE UNDER THE OHIO UNIFORM FRAUDULENT TRANSFER ACT, AND THOSE ASSETS MADE AVAILABLE FOR COST RECOVERY.