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. MR. KENT MCNAIR THE CREWS PLATING SITE 2530 MERRELL ROAD DALLAS, DALLAS COUNTY, TEXAS 75229 3. ON SEPT. 24, 1993, EPA BEGAN A REMOVAL ACTION AT THE SITE CONSISTING OF REMOVING AND PLACING INTO DRUMS APPROXI- MATELY 75 GALLONS OF PLATING WASTES THAT HAD BEEN OB- SERVED BEING DISCHARGED INTO A DITCH ON THE EAST SIDE OF THE FACILITY. THAT REMOVAL ACTION WAS A PREVENTATIVE AC- TION AND WAS PERFORMED TO STABILIZE THE SITE UNTIL EN- FORCEMENT ACTIVITIES COULD BE COMPLETED. EPA BEGAN A SECOND EMERGENCY REMOVAL ACTION AT THE SITE ON APR. 21, 1995, TO REPAIR THE BERMS AND RESTORE SITE SECURITY. AS OF FEB. 28, 1999, TOTAL EPA EXPENDITURES FOR ITS RE- ACTIONS INCURRED AT OR IN CONNECTION WITH THE SITE WERE ESTIMATED AT $105,862.70. EPA HAS NOT YET RECOVERED ANY OF THESE RESPONSE COSTS. 4. RELIEF SOUGHT PURSUANT TO SECTION 122(H)(1) OF CERCLA, EPA ISSUED AN ADMINISTRATIVE ORDER ON CONSENT TO, AND A- GREED TO BY, MR. KENT MCNAIR. MR. MCNAIR WILL PAY THE SUM OF $27,301.44 IN REIMBURSEMEN