United States v. Union Corp.

MEMORANDUM

GILES, Chief Judge.

TABLE OF CONTENTS

I. INTRODUCTION.364

II. FINDINGS OF FACT AND CONCLUSIONS OF LAW

A. Location and Description of the Site.

1. The Courtyard Area.

2. The Southern Area.

3. The River Sediments Area.

B. Ownership and Early Use of the Property.

C. Summary of Investigative and Enforcement History

D. Unsuccessful Remediation Attempt.

E. Nature of the Contamination.

1. PCBs. fc-CO

2. PAHS. to t-CO

3. Other Contaminants . ÍO t~ CO

F. Migration of Contaminants. t-t-CO

G. Health and Environmental Risks oi t-CO

1. Risks to the Ecosystem. Oi t-CO

2. Risks to Human Health _ w oo CO

III. ANALYSIS