=> BETWEEN 1961 & 1971 ROBERT BROWN OPERATED A FACILITY FOR BREAKING BATTERIES & RECOVERY OF LEAD. INITIALLY PRICE BATTERY CORP. WAS BROWN'S EXCLUSIVE CUSTOMER. BROWN WOULD PICK UP THE BATTERIES FROM PRICE, BREAK THEM IN GROUPS, RECOVER THE LEAD PARTS, WASH & CRUSH THE CASINGS, & DISPOSE OF LIQUIDS IN THE BATTERIES & CASINGS ON SITE. BROWN WAS PAID PER BATTERY WHEN THE LEAD WAS RETURNED TO PRICE. THE CASINGS WAS USED AS FILL MATERIAL & AS A BASE FOR DRIVEWAYS ON THE PROPERTY. => ROBERT BROWN DIED IN 1971, AT WHICH TIME OPERATIONS CEASED. HIS WIFE, BARBARA BROWN, INHERITED THE PROPERTY. SHE SOLD IT TO TERRY & SUSAN SHANER IN 1977. IT WAS TRANSFERRED TO TERRY SHANER INDIVIDUALLY IN 1980. THREE RESIDENCES & A GARAGE ARE PRESENTLY LOCATED ON THE PROPERTY. => DURING THE SUMMER OF 1983, IT WAS DISCOVERED THAT CHILDREN LIVING ON THE PROPERTY HAD BLOOD LEAD LEVELS IN EXCESS OF LEVELS CONSIDERED BY THE CENTER FOR DISEASE TO POSE A POTENTIAL RISK OF ADVERSE HEALTH EFFECTS. => AN EXTENT OF CONTAMINATION STUDY REVEALED THAT AN ESTIMATED 24,700 CU YRDS. OF LEAD CONTAMINATED BATTERY CASINGS WERE PRESENT AT THE FACILITY. IN THE PRIMARY DISPOSA L AREA THE SOIL CONTAINED UP TO 70% LEAD. => AN IMMEDIATE REMOVAL ACTION WAS COMMENCED IN OCT, 1983 TO ELIMINATE THE THREAT OF DIRECT CONTACT TO LEAD, AN ACUTELY TOXIC SUBSTANCE, & THE RELEASE OF