THE GRANT ROAD DRUM SITE IS LOCATED IN HOUSTON, TEXAS. THE TRACT OF LAND IS DIVIDED INTO THREE PARCELS. THERE WERE APPROXIMATELY 60 DRUMS CONTAINING HAZARDOUS SUBSTANCE SCATTERED THROUGHOUT THE SITE, SOME OF WHICH WERE MARKED WITH THE WORDS ANHYDROUS ALUMINUM CHLORIDE. EPA IDENTIFIED TWO PRPS: POWER PAK CO., INC. AND THE RAYMOND R. BETZ INTERES, INC. AN ADMINISTRATIVE ORDER ON CONSENT WAS ISSUED TO RAYMOND BETZ, TRUSTEE, ON OCTOBER 6, 1989. MR. BETZ CLEANED UP A PORTION OF THE SITE UNDER THE AOC AND EPA CLEANED UP THE REMAINING PORTION OF THE SITE. EPA WAS NEVER ABLE TO COME TO AN AGREEMENT WITH POWER PAK CO., INC. A TERMINATION ORDER WAS ISSUED IN AUGUST OF 1991 TERMINA- TING MR. BETZ'S GROUPS OBLIGATIONS UNDER THE ORDER.