1. SECTION 122(H)(1) OF THE COMPREHENSIVE ENVIRONMENTAL RE- SPONSE, COMPENSATION, AND LIABILITY ACT OF 1980, AS A- MENDED ( CERCLA ), 42 U.S.C. SECTION 9622(H)(1). 2. LUTHER SMITH SUPERFUND SITE APPROXIMATELY 4 MILES SOUTH EAST OF NEW BERLIN, TX. ON FM 539, ON THE EAST SIDE OF HARTSVILLE ROAD OPPOSITE THE POST OAK CEMETARY NEW BERLIN, GUADALUPE COUNTY, TEXAS 78121 3. THE SITE CONSISTS OF TWO LARGE PITS WITH WATE OIL, 46 55- GALLON DRUMS, A SHED CONTAINING SEVERAL HUNDRED LAB PACKS, TWO PILES OF UNKNOWN GRANULAR/CRYSTALLINE SUB- STANCES, AND TWO 5,000 GALLON STORAGE TANKS. VARIOUS DRUMS HAD LABELS FOR CONTENTS SUCH AS TOLUENE, TRICHLORO- ETHYLENE, CLEANING COMPOUNDS, AIRCRAFT SERVICE SOLVENTS, AND 1,1,1-TRICHLOROETHANE. PRELIMINARY HAZARD CATEGORIZA- TION INDICATED HIGH CONCENTRATIONS OF LEAD AND CHROMIUM IN THE SOIL AROUND THE PILES, BENZENE IN THE WASTE OIL PITS, AND STRONGLY ACIDIC DRUM CONTENTS. RELEASE OF MATERIALS INTO THE ENVIRONMENTAL WAS PLAINLY VISIBLE. SOME DRUMS HAD NO TOPS AND/OR WERE TURNED ON THEIR SIDES. THE SOIL AROUND MANY OF THE DRUMS WAS STAIN- ED AND ALL DRUMS WERE IN POOR CONDITION. IN RESPONSE TO THE RELEASE OR THREATENED RELEASE OF HAZ- ARDOUS SUBSTANCES FROM THE SITE, EPA CONDUCTED A TIME- CRITICAL REMOVAL ACTION AT THE SI