MARTHA C. ROSE CHEMICALS, INC. CONSISTS OF A FACILITY LOCATED AT 500 W. MCKISSOCK IN HOLDEN, MO, WHERE PCBS HAVE BEEN RELEASED AS A RESULT OF ACTIVITIES OF ROSE, INC. BEGINNING IN EARLY 1983 TRHOUGH 1986, ROSE, INC. WAS ENGAGED IN THE BUSINESS OF BROKERAGE OF PCBS AND PCB ITEMS, PROCESS- OF PCB CAPACITORS AND TRANSFORMERS FOR DISPOSAL, AND DECON- TAMINATION OF MINERAL OIL DIELECTRIC FLUIDS CONTAINING PCBS. BETWEEN 1983 AND 1986, THE GERERATOR RESPONDENTS AND OTHER ENTITIES CAUSED MATERIALS CONTAINING PCBS TO BE SHIPPED TO THE HOLDEN FACILITY FOR PROPER DISPOSAL UNDER TSCA. ROSE, INC. DID NOT PROPERLY MANAGE, HANDLE, AND ARRANGE FOR THE LAWFUL DISPOSAL OF PCBS & PCB ITEMS SHIPPED TO ITS FACILITY. THE GENERATOR RESPONDENTS ASSERT THAT ROSE, INC. WAS ALSO IN VIOLATION OF ITS CONTRACTUAL OBLIGATION TO EACH GENERATOR RESPONDENT FOR FAILING TO PROPERLY MANAGE, HANDLE & ARRANGE FOR THE LAWFUL DISPOSAL OF PCBS AND PCB ITEMS. ROSE, INC. FAILED TO MANAGE, HANDLE AND DISPOSE OF PCBS AND PCB ITEMS IN ACCORDANE WITH THE APPLICABLE FEDERAL PCB REGU- LATIONS CONTAINED AT 40 C.F.R. PART 761. INVESTIGATIONS CONDUCTED BY EPA AND/OR MDNR HAVE DETECTED PCBS IN FAUNA SAMPLES DOWNSTREAM FROM THE HOLDEN FACILITY, IN SLUDGE DRYING BEDS AT THE HOLDEN CITY SEWAGE TREATMENT PLANT DOWNSTREAM APPROXIMATELY 1000 FEET FROM THE HOLDEN FACILITY, AND IN BRANCH AND CREEK SEDIMENTS DOWNSTREAM FROM THE HOLDEN FACILITY. EPA BELIEVES T