THE LAWRENCE TODTZ FARM SITE IS LOCATED ON THE LAWRENCE TODTZ PROPERTY NEAR COMMANCHE, IOWA. THE SITE OCCUPIES A FORMER GRAVEL PIT APPROXIMATELY 12 ACRES IN AREA. THE SITE WAS OPERATED AS A MUNICIPAL LANDFILL BETWEEN 1969 AND 1975. E.I. DUPONT DE NEMOURS AND COMPANY, INC. (DUPONT), OPERATED A CELLOPHANE MANUFACTURING PLANT IN NEARBY CLINTON, IOWA. BETWEEN THE YEARS 1971 AND 1975, CELLOPHANE PROCESS WASTES FROM THE CLINTON PLANT WERE DISPOSED IN A SPECIALLY CONSTRUCTED IMPOUNDMENT OCCUPYING ABOUT 2.7 ACRES ON THE NORTHWEST CORNER OF THE SITE. THE SITE WAS IDENTIFIED AS A POTENTALLY UNCONTROLLED HAZARDOUS WASTE SITE AND WAS ADDED TO THE NPL IN 1986. EPA INFORMED DUPONT THAT IT HAD BEEN IDENTIFIED AS A PRP BECAUSE OF ITS PAST WASTE DISPOSAL ACTIVITIES AT THE SITE. PURSUANT TO A CERCLA 104/122 CONSENT ORDER BETWEEN EPA AND DUPONT, DUPONT HAS CONDEUCTED A REMEDIAL INVESTIGATION/ FEASIBILITY STUDY (RI/FS) FOCUSED ON THE IMPOUNDMENT INTO WHICH THE CELLOPHANE PROCESS WASTES FROM ITS CLINTON PLANT WERE DISPOSED. A ROD WAS SIGNED ON NOVEMBER 4, 1988. DUPONT'S CONTRACTOR SUBMITTED A FIRST DRAFT WORK PLAN FOR THE RD/RA ON DECEMBER 19, 1988.