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Operations principally included the temporary storage and reprocessing of waste oil . Current records indicate that more than 15 million gallons of waste oil were collected at the FPR Facility from many sources , including the Respondents listed in Appendix A and the City. 7 . This waste oil leaked from tanks and spilled onto the ground causing extensive soil and groundwater contamination during operations at the FPR Facility. The waste oil contained hazardous substances as defined by Section 101 ( 14) of CERCLA, 42 U .S .C. § 9601 ( 14) , including volatile organic compounds (VOCs) . 8 . In the Spring of 1996, EPA's Emergency Response and Removal program conducted an assessment of the FPR Facility. The FPR Facility was abandoned at that time. There were several above-ground tanks and drums in poor condition, containing waste oil and wastewater at the FPR Facility. The secondary containment structures around these tanks and drums had deteriorated. The contents of the tanks and drums were sampled, and the results indicated the presence of VOCs and other hazardous substances . EPA determined that an immediate response action was warranted to address the imminent threat posed by the tanks and drums and to stabilize the FPR Facility pending further evaluation. 9. As a result, removal activities were undertaken and all tanks and an estimated 13 ,000 gallons of waste oil and 26,000 gallons of wastewater were removed from the Site. This work was completed in 1997 pursuant to an Administrative Order on Consent with Florida Petroleum Reprocessors Steering Committee, whose member(s) are currently part of the major FPR potentially responsible party group ("major FPR PRP group") . 10. EPA' s contractor completed the field work for the remedial investigation (RI) for the FPR Site in April 1997 and issued a RI and feasibility study (FS) report in June 1998 . 11 . The Site was placed on the National Priorities List on March 6, 1998 . 12 . A second round of removal activities was conducted by the major FPR PRP group in 1999 , pursuant to a second Administrative Order on Consent, to address the highly contaminated soils ranging from ground surface to a depth of approximately 12 feet below ground surface. Contaminants removed included chlorinated VOCs and petroleum-related compounds. Approximately 69000 tons of soil were removed for off- Site disposal . The excavated areas were filled in with clean soil . 13 . A third round of removal activities is currently on-going, and was started by the major FPR PRP group in November 2000, pursuant to a third Administrative Order on Consent, to address deep soil contamination and a zone of residual dense nonaqueous-phase liquid (DNAPL) in the northwestern portion of the FPR Facility, at a depth from 34 to 43 feet below ground surface. This material was believed to represent a continual source of contamination to the Biscayne aquifer, the sole source of drinking water for Dade and 5