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~STATU-ALIIIIOftCTION AGampNCY

JOIIOIWIDtlll

DATI I April 19 1993

BUBJ I Toxicity Hazardous Etfecta and Volume o Hazardous Substances contributed to the Ottati Gou Superfund Site Kinqaton New Hampshire

1ROKJ Steven J Calde r Remedial Project Manaqer J j-~ TOI ottati Goaa Si t e Files

This memorandu111 summarizes the conclusions o the Environmental Protection Agency (EPA) after a careful review of the hazardous substances associated with the pot e nt ially napond b le parties (PRPa) at the ottati co Superfund d t e (Site) The Site actually consists of two d h t i nct but cont i guous areas - - the Otta t i Goaa (0 G) port i on and the Kinqst on Steel DrumGr eat Lakes containe r corpor at ior1 r GLCC) port ion Th h r eview was unde rtake n i n orde r t o docume nt the eligibility of var ious pe r s ona for a Ill ainJmia settlement baaed on the requi reaenta of section 12 2 (g) (1 ) (A) of the Comprehe naive Environaental Response Compe nsation and Liability Ac t (CERCLA) Moat of the pa rt ies are contribut i on ac tion defendants in a laws uit brought by IMCERA Group Inc the priaary defendant i n the lawsu i t brought by the United states

SOURCE OF HAZJROOUS SUBSTANCE TYPE IN FORMATI ON

Tr a ns act i ona l documents and othe r r elevant i n fo rmation were used in the a ssessbullent of the hazardous s ubs t ances present

a t the Site and the t ypes of hazardous s ubst ances bull contributed to the Sit e by the PRPs Documentation ot the

volume of hazardous subst ances sent to the Site by the pr oposed a ain1m1a parties is part of the document depository uintained by the law firm ot Nixon Hall Hess locat ed a t 80 Merrimack Street in Manchester New Hampshire

EPA used the above-referenced i nformation information in the Remedial Investigation Feasibility Study and the Record ot Decision to evaluate hazardous s ubstances present at the Site and the hazardous substances contributed to the Site by the PRPs EPA compared the hazardous substances descriptions associated with the parties expected to participate in the ~ minimii settlement with the hazardous

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substances descriptions of other PRPs who contributed hazardous substances to the Site and with the full range of contaminants found at the Site

PURPOSC or HAZAROOUS SUBSTANCE TXPE REVIEW

EPA used the available i nformation to assess volumes and any posdble ditterences i n the potential for toxic or other hazardous etfects of the hazardous subs tances of the J1l 11inia1J ttlinq parties compared to the total volume and cumulative toxicity of the hazardous substances at the Site EPA also compared the volume and toxicity to the hazardous subst ances of other PRPa It was EPAs intention as required by CERCLA Section 122(g) (1) (A) to establbh whether or not the volumes and the potential for toxic or other hazardous e f fec t s of hazardous subst ances contributed by the a llinia1a settling parties t o t he f acility are a inimal i n compar ison to t he volumes and the potential tor cumulat ive t oxic or other hazardous ettects ot all the haza rdous subs t ances associated wi th t he site

RESULTS OF HAZAROOUS SUBSTANCE T XPE REVIEW

I Voluae

The docuaentation ot hazardous s ubs tances sent to the Sit e h incoaplete because subs tantial gaps exist in the transactional docuaenta particularly tor the early yeara ot Site operation The Site was us ed as a drum reconditioning facility whe re drums we r e shipped to be cleaned and reconditioned s o they could be r e -used The OlG portion ot the Site also was ope r a t ed a s a hazardous s ubs tance s olidification business The contri bution defendants who will participate i n a settlement will certify that the drums they sent tor recondi t ioni ng were

bull bulleapty bull 1 Operations bega n at t he GLCC facility at the

Mobil Oil the company with the largest documented amount ot drua sent t o the GLCC port ion ot the Site has provided EPA with a copy ot a Mobil document that indicates that its d rums could not be sent tor reconditioning unless empty ie with less than 2 gallons or inches of rasidue remaining in the drum All parties who will participate in a settlement will certify that their drums were empty containing only a residue or less than two inches ot material

Although the settling parties will certify that their drums contained very little waste material until 1979 other) parties may have regularly sent drums containing tour to ten

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Site in the 1950 s and ceased in 1980 630 F Supp at 1374 1380 Operationbull were conducted at the m G facility at the Site from 1977 to 1979 630 r supp at 1369

The transactional documents collected by IMCERA show that at leas t 2643970 drums were aent to the GLCC portion of the site by the contribution defendante 1 However it appears that aigniticantly more drums and hazardous aubatancea were s h ipped to the GLCC facili t y a t the Site For e xample Kingston Steel Drum processed between 500 to 700 barr els daily i n 1966 630 F Supp at 137 4 Thh numbe r i ncreased to 1200 barrels per day prior t o when IMCERA purchased the facili ty i n 1973 IMCERA increased production to 2 00 0 barrels pe r day 630 r Supp a t 13 74 1 In add i t i on until s ometime in 1973 or e a rly 1974 1

the operaton ot the GLCC portion ot the Site util ized an unlined lagoon whe re liquid hazardous s ubs tanc e res idue troa reconditioning operations and drums waa dis posed The hazardoua substances sent to the lagoon ranqed troa 1 000 gallona day in the beginning to 5 000 gallons day The lagoon was tilled in by IMCERA in 1974 630 F supp at 1375 The production capacity and the capacity and use ot the lagoonbull indicataa that aigniticantly greater volumes ot hazardoua subatancea were likely diapoaed ot at the GLCC portion ot the Site than that tor which transactional

gallonbull ot uterial to GLCC 630 r supp at 1378

Since the Court tound IMCERA liable only tor activit at the GLCC facility IMCERA did not coapile transactional docuaenta concerning the activities conducted by OG

3 Using the courts tigurea the number of barrels s ent to the site from 1966 through 1976 could eaaily be in exc ess ot 4000000 Thia tigure is de rived by assuming a steadily

bull increaaing production capacity and production 365 days per year tor the following annual amounts

1966 - 600 day bull 219000 1967 - 700 day bull 255 500 1968 - 800 day bull 292 ooo 1969 - 900 day bull 328 500 1970 - 1 000day bull 365000 1971 - 1 100day bull 401500 1972 - 1 200day bull 43 8 000 1973 - 1 200day bull 438000 1974 - 1 500day bull 547500 1975- 1800day bull 657000) 1976 - 2 000day bulllJQ

J 4 2JJ500

r r

documents exist

The documentation of the volume of drums shipped to the 0G por tion of the Site b sparse The Court found that the following defendant PRPa shipped at leaat the lbted number of drums to the OG facility Lilly - fi70 General Electric - 458 SRS - 5962J Lewis Chemical - 732 to 900 Quinn 64 630 F Supp at 1396 1370 1405 Some or all of the drums were full primarily containing otf-specitication mat eria l s and spent solvents 630 F Supp at 1370 1371 overall at least 6900 drums of waste were sent to OG 630 F Supp a t 1371 1405 For an unknown period includ i ng a t least Januar y 1979 1 the OG operation was tak ing in 250 drums per month 630 F Supp a t 1370 In add i tion t o thb waste-in i n formation t here is i nformation that from Hay 1978 to May 1979 a company removed a t l e as t 69 dumps t e r s full of proces s ed drums from 0G 4 5 to 90 druaa would fill a dUlllpste r 630 r s upp at 1371

After the drum rec onditioning and hazardous subs tance solidification activitha conducted by OG were terainated in May 1979 additional hazardous aubatancaa were dispos ed of at the Site by Richard French beqinninq at l east by July 1979 French brought at least hundreds of druaa of hazardous aubatancea to the Site The Court found that French continued to bring on site aa many drums aa he could reqardlebullbull ot their condition tor monetary gain 630 F Supp at 1391

At the tibulle of an EPA inspection in late 1980 several thousand drua were stored in the area ot the OG hazardous substance solidification activities During its removal action PA removed over 4 000 drums and approximate ly J l 2 bullUlion pounds of hazardous substances and other materials from the Site

bull Therefore although EPA cannot de t en i ne wi th speciticity the voluae of hazardous subs tance s or number of drums disposed ot at the Site the available i nformation indicates that the totals are t ar grea t e r than the figure tor which transactional docume nts are available Even c ompared to the drum inventory log s tigure of 2 6 million empty drums the vast major i ty ot the PRPs lis t ed on the i nventory s e nt fewer than U A small number of t he potential settlera sent more than U of that figure but no more than about 5 All of t hese PRPs are sll minimJJ in terms of t he volume of hazardous substances at the Site This ia particularl y true when the known existence of the significant i n formational gaps is taken into account

4

) The largest documented contributor was Mobil Oil The

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tigure on the drum count inventory is incorrect And while Mobil agreed with I MCERA for purposes ot settlement only that ita contribution was 112 of the knolon number of drums at GLCC Mobil contends that the documents actually indicate it nt leas than 95 of the drums documented tor the GLCC acUity Taking into account the addit ional known volumea of hazardous auba tances sent to the obullG facility and the production capacity of the GLCC and obullc facilities the volume of hazardous s ubs tances sent by Mobil h probably no more than 6l of the druJDs and an even smaller percentage of the total volume of hazardous aubstances Therefore Mobil also qualities as a sH m1nia1l party

odaitrha~ar4oua e ffeota

The toxicityj hazardous effects of the hazardous subatancea contributed to the Site by the contribution action defendantbull ia comparatively low It appears that nona of the contribution action da f a ndanta druma contained PCBa the cleanup of which ia primarily driving the r emedy at the Site and ia the bulloat coatly aapect of the remedy PCBa are auapected carcinogenbull

The partiebull bullbullbullking to aettle abull a ain1aiJ contributors will certify that the conatituenta of the hazardoua aubatancbullbull contained in the dnma each party aant to tha Site vera not utarially different or diaproportionata in toxicity or hazardoua affacta frobull the hazardous aubatancaa f ound at the Site aa docUIIantad in the Remedial Invaatigationf Paadbility Study and Record of oaciaion for the Site Copiaa of the certificationbull will be 11ada part ot the adlliniatrativa record in s upport of a a ainia1a datanination The available documentation conta i nbull no intonation which ahova that the hazardoua aubatancea contributed by the a llinimia aettling parties would have the potential for greater toxic or other hazardous affects t han that of the c umulative hazardous substances contributed by the other parties Thus it appears the contribution defenda nts meet the toxicity components of the a m1D1W dateaination

In addition the available recorda indicate that the drums sent to the facility by Mobil Oil corp (the largest contributor of drums among the contribution action defendanta) contained lube oil with a small percentage of additives Mobil Oil has provided affidavits describing) the companys practice of reconditioning drums containing

Q 20 C)

= =-

r

Site in the 1950 s and ceased in 1980 630 F Supp at 1374 1380 Operationbull were conducted at the m G facility at the Site from 1977 to 1979 630 r supp at 1369

The transactional documents collected by IMCERA show that at leas t 2643970 drums were aent to the GLCC portion of the site by the contribution defendante 1 However it appears that aigniticantly more drums and hazardous aubatancea were s h ipped to the GLCC facili t y a t the Site For e xample Kingston Steel Drum processed between 500 to 700 barr els daily i n 1966 630 F Supp at 137 4 Thh numbe r i ncreased to 1200 barrels per day prior t o when IMCERA purchased the facili ty i n 1973 IMCERA increased production to 2 00 0 barrels pe r day 630 r Supp a t 13 74 1 In add i t i on until s ometime in 1973 or e a rly 1974 1

the operaton ot the GLCC portion ot the Site util ized an unlined lagoon whe re liquid hazardous s ubs tanc e res idue troa reconditioning operations and drums waa dis posed The hazardoua substances sent to the lagoon ranqed troa 1 000 gallona day in the beginning to 5 000 gallons day The lagoon was tilled in by IMCERA in 1974 630 F supp at 1375 The production capacity and the capacity and use ot the lagoonbull indicataa that aigniticantly greater volumes ot hazardoua subatancea were likely diapoaed ot at the GLCC portion ot the Site than that tor which transactional

gallonbull ot uterial to GLCC 630 r supp at 1378

Since the Court tound IMCERA liable only tor activit at the GLCC facility IMCERA did not coapile transactional docuaenta concerning the activities conducted by OG

3 Using the courts tigurea the number of barrels s ent to the site from 1966 through 1976 could eaaily be in exc ess ot 4000000 Thia tigure is de rived by assuming a steadily

bull increaaing production capacity and production 365 days per year tor the following annual amounts

1966 - 600 day bull 219000 1967 - 700 day bull 255 500 1968 - 800 day bull 292 ooo 1969 - 900 day bull 328 500 1970 - 1 000day bull 365000 1971 - 1 100day bull 401500 1972 - 1 200day bull 43 8 000 1973 - 1 200day bull 438000 1974 - 1 500day bull 547500 1975- 1800day bull 657000) 1976 - 2 000day bulllJQ

J 4 2JJ500

r r

documents exist

The documentation of the volume of drums shipped to the 0G por tion of the Site b sparse The Court found that the following defendant PRPa shipped at leaat the lbted number of drums to the OG facility Lilly - fi70 General Electric - 458 SRS - 5962J Lewis Chemical - 732 to 900 Quinn 64 630 F Supp at 1396 1370 1405 Some or all of the drums were full primarily containing otf-specitication mat eria l s and spent solvents 630 F Supp at 1370 1371 overall at least 6900 drums of waste were sent to OG 630 F Supp a t 1371 1405 For an unknown period includ i ng a t least Januar y 1979 1 the OG operation was tak ing in 250 drums per month 630 F Supp a t 1370 In add i tion t o thb waste-in i n formation t here is i nformation that from Hay 1978 to May 1979 a company removed a t l e as t 69 dumps t e r s full of proces s ed drums from 0G 4 5 to 90 druaa would fill a dUlllpste r 630 r s upp at 1371

After the drum rec onditioning and hazardous subs tance solidification activitha conducted by OG were terainated in May 1979 additional hazardous aubatancaa were dispos ed of at the Site by Richard French beqinninq at l east by July 1979 French brought at least hundreds of druaa of hazardous aubatancea to the Site The Court found that French continued to bring on site aa many drums aa he could reqardlebullbull ot their condition tor monetary gain 630 F Supp at 1391

At the tibulle of an EPA inspection in late 1980 several thousand drua were stored in the area ot the OG hazardous substance solidification activities During its removal action PA removed over 4 000 drums and approximate ly J l 2 bullUlion pounds of hazardous substances and other materials from the Site

bull Therefore although EPA cannot de t en i ne wi th speciticity the voluae of hazardous subs tance s or number of drums disposed ot at the Site the available i nformation indicates that the totals are t ar grea t e r than the figure tor which transactional docume nts are available Even c ompared to the drum inventory log s tigure of 2 6 million empty drums the vast major i ty ot the PRPs lis t ed on the i nventory s e nt fewer than U A small number of t he potential settlera sent more than U of that figure but no more than about 5 All of t hese PRPs are sll minimJJ in terms of t he volume of hazardous substances at the Site This ia particularl y true when the known existence of the significant i n formational gaps is taken into account

4

) The largest documented contributor was Mobil Oil The

r

tigure on the drum count inventory is incorrect And while Mobil agreed with I MCERA for purposes ot settlement only that ita contribution was 112 of the knolon number of drums at GLCC Mobil contends that the documents actually indicate it nt leas than 95 of the drums documented tor the GLCC acUity Taking into account the addit ional known volumea of hazardous auba tances sent to the obullG facility and the production capacity of the GLCC and obullc facilities the volume of hazardous s ubs tances sent by Mobil h probably no more than 6l of the druJDs and an even smaller percentage of the total volume of hazardous aubstances Therefore Mobil also qualities as a sH m1nia1l party

odaitrha~ar4oua e ffeota

The toxicityj hazardous effects of the hazardous subatancea contributed to the Site by the contribution action defendantbull ia comparatively low It appears that nona of the contribution action da f a ndanta druma contained PCBa the cleanup of which ia primarily driving the r emedy at the Site and ia the bulloat coatly aapect of the remedy PCBa are auapected carcinogenbull

The partiebull bullbullbullking to aettle abull a ain1aiJ contributors will certify that the conatituenta of the hazardoua aubatancbullbull contained in the dnma each party aant to tha Site vera not utarially different or diaproportionata in toxicity or hazardoua affacta frobull the hazardous aubatancaa f ound at the Site aa docUIIantad in the Remedial Invaatigationf Paadbility Study and Record of oaciaion for the Site Copiaa of the certificationbull will be 11ada part ot the adlliniatrativa record in s upport of a a ainia1a datanination The available documentation conta i nbull no intonation which ahova that the hazardoua aubatancea contributed by the a llinimia aettling parties would have the potential for greater toxic or other hazardous affects t han that of the c umulative hazardous substances contributed by the other parties Thus it appears the contribution defenda nts meet the toxicity components of the a m1D1W dateaination

In addition the available recorda indicate that the drums sent to the facility by Mobil Oil corp (the largest contributor of drums among the contribution action defendanta) contained lube oil with a small percentage of additives Mobil Oil has provided affidavits describing) the companys practice of reconditioning drums containing

Q 20 C)

= =-

r r

documents exist

The documentation of the volume of drums shipped to the 0G por tion of the Site b sparse The Court found that the following defendant PRPa shipped at leaat the lbted number of drums to the OG facility Lilly - fi70 General Electric - 458 SRS - 5962J Lewis Chemical - 732 to 900 Quinn 64 630 F Supp at 1396 1370 1405 Some or all of the drums were full primarily containing otf-specitication mat eria l s and spent solvents 630 F Supp at 1370 1371 overall at least 6900 drums of waste were sent to OG 630 F Supp a t 1371 1405 For an unknown period includ i ng a t least Januar y 1979 1 the OG operation was tak ing in 250 drums per month 630 F Supp a t 1370 In add i tion t o thb waste-in i n formation t here is i nformation that from Hay 1978 to May 1979 a company removed a t l e as t 69 dumps t e r s full of proces s ed drums from 0G 4 5 to 90 druaa would fill a dUlllpste r 630 r s upp at 1371

After the drum rec onditioning and hazardous subs tance solidification activitha conducted by OG were terainated in May 1979 additional hazardous aubatancaa were dispos ed of at the Site by Richard French beqinninq at l east by July 1979 French brought at least hundreds of druaa of hazardous aubatancea to the Site The Court found that French continued to bring on site aa many drums aa he could reqardlebullbull ot their condition tor monetary gain 630 F Supp at 1391

At the tibulle of an EPA inspection in late 1980 several thousand drua were stored in the area ot the OG hazardous substance solidification activities During its removal action PA removed over 4 000 drums and approximate ly J l 2 bullUlion pounds of hazardous substances and other materials from the Site

bull Therefore although EPA cannot de t en i ne wi th speciticity the voluae of hazardous subs tance s or number of drums disposed ot at the Site the available i nformation indicates that the totals are t ar grea t e r than the figure tor which transactional docume nts are available Even c ompared to the drum inventory log s tigure of 2 6 million empty drums the vast major i ty ot the PRPs lis t ed on the i nventory s e nt fewer than U A small number of t he potential settlera sent more than U of that figure but no more than about 5 All of t hese PRPs are sll minimJJ in terms of t he volume of hazardous substances at the Site This ia particularl y true when the known existence of the significant i n formational gaps is taken into account

4

) The largest documented contributor was Mobil Oil The

r

tigure on the drum count inventory is incorrect And while Mobil agreed with I MCERA for purposes ot settlement only that ita contribution was 112 of the knolon number of drums at GLCC Mobil contends that the documents actually indicate it nt leas than 95 of the drums documented tor the GLCC acUity Taking into account the addit ional known volumea of hazardous auba tances sent to the obullG facility and the production capacity of the GLCC and obullc facilities the volume of hazardous s ubs tances sent by Mobil h probably no more than 6l of the druJDs and an even smaller percentage of the total volume of hazardous aubstances Therefore Mobil also qualities as a sH m1nia1l party

odaitrha~ar4oua e ffeota

The toxicityj hazardous effects of the hazardous subatancea contributed to the Site by the contribution action defendantbull ia comparatively low It appears that nona of the contribution action da f a ndanta druma contained PCBa the cleanup of which ia primarily driving the r emedy at the Site and ia the bulloat coatly aapect of the remedy PCBa are auapected carcinogenbull

The partiebull bullbullbullking to aettle abull a ain1aiJ contributors will certify that the conatituenta of the hazardoua aubatancbullbull contained in the dnma each party aant to tha Site vera not utarially different or diaproportionata in toxicity or hazardoua affacta frobull the hazardous aubatancaa f ound at the Site aa docUIIantad in the Remedial Invaatigationf Paadbility Study and Record of oaciaion for the Site Copiaa of the certificationbull will be 11ada part ot the adlliniatrativa record in s upport of a a ainia1a datanination The available documentation conta i nbull no intonation which ahova that the hazardoua aubatancea contributed by the a llinimia aettling parties would have the potential for greater toxic or other hazardous affects t han that of the c umulative hazardous substances contributed by the other parties Thus it appears the contribution defenda nts meet the toxicity components of the a m1D1W dateaination

In addition the available recorda indicate that the drums sent to the facility by Mobil Oil corp (the largest contributor of drums among the contribution action defendanta) contained lube oil with a small percentage of additives Mobil Oil has provided affidavits describing) the companys practice of reconditioning drums containing

Q 20 C)

= =-

r

tigure on the drum count inventory is incorrect And while Mobil agreed with I MCERA for purposes ot settlement only that ita contribution was 112 of the knolon number of drums at GLCC Mobil contends that the documents actually indicate it nt leas than 95 of the drums documented tor the GLCC acUity Taking into account the addit ional known volumea of hazardous auba tances sent to the obullG facility and the production capacity of the GLCC and obullc facilities the volume of hazardous s ubs tances sent by Mobil h probably no more than 6l of the druJDs and an even smaller percentage of the total volume of hazardous aubstances Therefore Mobil also qualities as a sH m1nia1l party

odaitrha~ar4oua e ffeota

The toxicityj hazardous effects of the hazardous subatancea contributed to the Site by the contribution action defendantbull ia comparatively low It appears that nona of the contribution action da f a ndanta druma contained PCBa the cleanup of which ia primarily driving the r emedy at the Site and ia the bulloat coatly aapect of the remedy PCBa are auapected carcinogenbull

The partiebull bullbullbullking to aettle abull a ain1aiJ contributors will certify that the conatituenta of the hazardoua aubatancbullbull contained in the dnma each party aant to tha Site vera not utarially different or diaproportionata in toxicity or hazardoua affacta frobull the hazardous aubatancaa f ound at the Site aa docUIIantad in the Remedial Invaatigationf Paadbility Study and Record of oaciaion for the Site Copiaa of the certificationbull will be 11ada part ot the adlliniatrativa record in s upport of a a ainia1a datanination The available documentation conta i nbull no intonation which ahova that the hazardoua aubatancea contributed by the a llinimia aettling parties would have the potential for greater toxic or other hazardous affects t han that of the c umulative hazardous substances contributed by the other parties Thus it appears the contribution defenda nts meet the toxicity components of the a m1D1W dateaination

In addition the available recorda indicate that the drums sent to the facility by Mobil Oil corp (the largest contributor of drums among the contribution action defendanta) contained lube oil with a small percentage of additives Mobil Oil has provided affidavits describing) the companys practice of reconditioning drums containing

Q 20 C)

= =-

r

lube oil The affidavits also contain a toxicologists ment o f t he t oxicity of the lube oil and its additives Mobils lube oil is of low toxicity and bullability compared wi t h other hazardous substances found at t he d t e Moreover lube oil arguably falls within the petro leua excludon under Section 101(14) of CERCLA

Thus t he nature of the hazardous substances sent to the Site by t he contribution action dehndants renden their contribution to the aite J1s JR1nimia in terms of toxicity

In au- ary the volumes a nd t he pot ential fo r toxic or other hazardous e ffect s of hazardous subs t a nce s contributed by the a ainiaia settling paru to the facility are bulliniul in comparieon to the volumes and the potential fo r CWIUhtive toxic or other hazardous effects of all the hazardoua aubatancaa aaaociated with the Site It waa round that the huardoua aubatancea contributed by the sa ainiaia eettlinq partiebull were l a toxic than the PCBa contributed by the other parties were not JDaterially dirterent or disproportionate in toxicity or hazardous ertecta than the non-PCB hazardoua aubstancea present at the Site and that none or the substances contributed by the dl aJn1ai1 aettling parties were a major factor driving the raaedy aelected and ita costa The volumes or haaardoua aubetancea contributed by the s ettling Ill mJnim11 partiea are alao bullinibullal in cobullparison with the total voluae or hazardous substances aent to the Site Therefore the potential tor toxic or other hazardous errects or the hazardoua aubatancea disposed or by the dA a1nia1a settling parties would not contribute disproportionately to the environmental and public health ~ threat at the Site Ther e fore the cos t a o r the cleanup o r the hazardous substances or the dl llinirl1l settling parties at the Site ia only a bullinor portion or the response costs

The attidavita a nd the accompanying letter r r om Mobils counsel are included in the administrat ive record i n support or t he sa a1nJJD1I det ermination