november 11, 1992 assistant regional counselreference, i am enclosing a copy of that letter as well...

v.aste Management, Inc. " " UUU J (1003 Butterfield Road • Oan BrooK. Illinois cOi-'

November 11, 1992

Jeffrey A. CahnAssistant Regional CounselU.S. Environmental Protection Agency5CS - Region V77 West Jackson BoulevardChicago, IL 60604

Re: Hagen Farm SiteStoughton, Wisconsin

Dear Mr. Cahn:

On April 27, 1992, Waste Management of Wisconsin, Inc., (WMWI) supplemented itsinformation request response related to the above-referenced site. For your ease ofreference, I am enclosing a copy of that letter as well as color photographs of the GoodyearPliovic bags. As you recall, at that time WMWI provided information relating to Goodyeardry chemical bags with the label "Pliovic" which were discovered during the remedial actionactivities at the site. Since that time, WMWI has discovered that Pliovic is a PVC resin thatis transported in dry chemical bags. Further, Goodyear has a manufacturing plant in SunPrairie, Wisconsin at the following address: Goodyear Tire & Rubber Manufacturing Plant,143 Goodyear, Sun Prairie, Wisconsin 608/825-1800.

WMWI is providing this information consistent with the Agency's goals of identifyingresponsible parties as it prepares to initiate its enforcement action at the Hagen Farm Site.

Very truly yours,

Lisa S. SeglinEnvironmental Counsel

LSS:lc

Enclosures

708/572-5800 • T>'»-- ?--•

20. Augusts, 1991. "Goodyear PUovic" dry chemicalbag uneanhed during excavation of waste beneathBorrow Area 3.

21. August5, 1991. "Goodyear Pliovic" dry chemicalbags unearthed dur ing excava t ion of wastebeneath Borrow Area 3.

' North i - - : ca , '•. • 6 < ~> - f _ • S r;

April 27, 1992

Jeffrey A. CahnAssistant Regional CounselU.S. Environmental Protection Agency230 S. Dearborn StreetChicago, IL 60604

Re: Hagen Farm SiteStoughton, Wisconsin

Dear Mr. Cahn:

This letter is in response to your April 16, 1992 letter requesting Waste Management ofNorth America, Inc. (WMNA) supplement the Agency's July 5,1990 request for informationpursuant to Section 104(e) of CERCLA. This letter was received on April 20, 1992.

Please be advised that I represent Waste Management of Wisconsin, Inc. (WMWI) and notWMNA at the above site. Therefore, this supplemental response is being provided onbehalf of WMWI to information requested in Numbers 6, 7, 9, 13, 18 and 19.

6. Identify the acts or omissions of any person, other than your employees, contractorsor agents, that may have caused the release or threat of release of hazardoussubstances, pollutants, or contaminants and damages resulting therefrom.

During the Remedial Action activities at the Hagen Farm site, Goodyear drychemical bags with the label "Pliovic" were unearthed beneath Borrow Area 3 onAugust 5, 1991. (See Attachment A.) Pictures of this material are provided in theDraft Remedial Action Implementation Report-Source Control Operable Unit,Hagen Farm site. The pictures in Attachment A are contained in Appendix C of theReport, photographs 20 and 21. This document was submitted to Mr. Jae Lee of theU.S. Environmental Protection Agency for review in March 1992.

For your convenience, a March 30, 1992 Dun & Bradstreet, Inc. report is alsoenclosed as Attachment B.

7. Identify all persons, including Respondent's employees, who have knowledge orinformation about the generation, use, treatment, storage, disposal or other handlingof hazardous material at, or transportation of hazardous materials to the site.

Apart from the individual(s) who discovered and photographed the item in No. 6

above, WMWI knows of no additional persons.

9. Identify all persons or business who are or may be responsible for the liabilities ofthe Respondent arising from or relating to the release or threatened release ofhazardous materials at the site, including but not limited to successors andindividuals.

See WMWI's July 19, 1990 response. (See Attachment C.)

13. Did you ever use, purchase, store, treat, dispose, transport or otherwise handle anyhazardous materials at the Site? If the answer to the preceding questions isanything but an unqualified "no", identify: a) ... 0-


18. Have you or any other person working with you, for you, or on your behalf everaccepted hazardous materials of hazardous substances for transportation to theSite? If the answer to this question is anything but an unequivocal no identify: a). . . m).


19. Identify all persons, including yourself, who may have arranged for disposal ortreatment or arranged for transportation for disposal or treatment of hazardousmaterials at the Site. In addition, identify the following: a) ... p).

See WMWTs July 19, 1990 response. (See Attachment C.)

If you have any questions regarding the above supplemental response, please do not hesitateto contact me.

Respectfully,

Brett D. HeinrichEnvironmental Counsel forWaste Management of Wisconsin, Inc.

BDH:lc

Enclosures

1t

i

ii

iaioieiii

20. Augusts, 1991. "Goodyear Pliovic" dry chemicalbag unearthed during excavation of waste beneathBorrow Area 3.

21. Augusts, 1991. "GoodyearPliovic" dry chemicalbags unearthed dur ing excavation of wastebeneath Borrow Area 3.

f.l i

.3

p.COPYRIGHT 1992 DUN & ViADSTREET INC, - PROVIDED 'f?DER CONTRACT

FOR THE EXCLUSIVE USE OF SUBSCRIBER 002-004143L.ATTN: WASTE MANAGEMENT

*IN DATE* Statement Date: DEC 31 1991

DUNS: 00-446-7924ODYEAR TIRE & RUBBERMPANY, THE (INC)

14 E MARKET STREET5 BRANCH(ES) OR DIVISION(S)iON OH 44316TEL: 216 796-2121

DATE PRINTEDMAR 30 1992

MFC TIRES &RELATED PRDTS &SVCS, VEHICLECOMPONENTS,INDUSTRIAL RUBBER,CHEMICAL,POLYESTER & FILMPRDTS & CRUDE OILPIPELINESIC NOS.30 11 75 38 50 1355 31 08 31 45 81

SUMMARYRATING 5A2STARTEDPAYMENTSSALES FWORTH FEMPLOYSHISTORYFINANCIALCONDITION GOODTREND UP

1893SEE BELOW$10,906,800,000$2,731/100;00099,952(5,708 HERE)CLEAR

:F EXECUTIVE: STANLEY C. GAULT, CHB-CEO

IAL EVENTS7/92 According to published reports. Shell Chemical Company has signed

a letter of intent with the Goodyear Tire & Rubber Company to buyGoodyear's polyester resins business. The business7 main product ispolyethylene terephthalate (PET) which is used to make beveragebottles, food containers and other thermoformed packaging. About 700employees are associated with the Goodyear business which includes a.nanufacturing plant in Point Pleasant, WV, a technical center inAkron, OH, and related sales activities. The acquisition is subjectto the satisfactory negotiation of a definitive sales agreement,approvals by both companies and appropriate governmental agencies.

'92 According to published reports, Goodyear Tire and Rubber Coagreed to offer the shareholders of Goodyear Canada Inc, $48 a sharein cash, in a deal that would make Goodyear Canada a wholly ownedsubsidiary of Goodyear.

92 EARNINGS UPDATE: According to published reports, comparativeoperating result* for the year ended December 31, 1991 are as follows:sales of $10,900,000,000 and net income (loss) of $96,600,000 comparedto sales of $11,272,500,000 and net income (loss) of $(38,300,000) forthe comparable period in the prior year.

92 According to published reports, John G Breen, chairman and chiefexecutive officer of The Sherwin-Williams Company of Cleveland, waselected to the board of directors. He joined Sherwin-Williams in 1979as president and chief executive officer and became chairman in 1980.

55OS

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32 P.4

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4-5 Mos2-3 Mos2-3 Mos6-12 Mos6-12 Mos1 Mo6-12 Mos1 Mo1 Mo2-3 Mos1 MO4-5 Mos6-12 Mos1 Mo1 Mo6-126-121 MO1 MO1 MO2-3 MOS2-3 Mos6-12 Mos1 Mo1 Mo1 Mo2-3 Mos2-3 Mos6-12 Mos1 Mo1 Mo1 Mo1 Mo4-5 Mos1 Mo4-5 Mos1 Mo6-12 Mos4-5 Mos1 Mo2-3 Mos1 Mo4-5 Mos6-12 Mos

* Payment experiences reflect how bills are met in relation to theterms granted. In some instances payment beyond terms can be theresult of disputes over merchandise, skipped invoices etc.

* Each experience shown represents a separate account reported by asupplier. Updated trade experiences replace those previouslyreported.

STATEMENT UPDATE03/19/92 Fiscal Consolidated statement dated DEC 31 1991:

Cash $ 163,400,000 Accts Pay $Accts Rec 1,315,000,000 Notes Pay

839,500,000511,600,000

MftR 30 '32 16:52

InventoryHktbl* SecuritiesPrepaid

Curr AssetsFixt & EquipInvestments-otherLong TermAccounts & NotesRecDef Charges &Other Misc Assets

312,700,00071,700,000255,900,000

3,118,700,0004,636,900,000123,100,000

234,000,000

397,800,000

AccrualsTaxesL,T. Liab-(lyr)Other Curr Liabs

Curr LiabsLong Term Debt &Capital LeasesMinority EquityIn SubsidiariesL.T. Liab-otherDef. Credits/IncomeCOMMON STOCKADDIT. PD.-IN CAPRETAINED EARNINGS 2CURR TRANS ADJ (

352,800,000245,000,00091,500,000352,200,000

2,392,600,000

2,038,100,000

119,700,000629,900,000599,100,00070,700,000639,100,000,208,500,000187,200,000)

Total Assets 8,510,500,000 TotalFrom JAN 01 1991 to DEC 31 1991 sales $10,

goods sold $8,405,300,000. Gross profit $2,501expenses $1,911,700,000. Other income $83,200,$402,300,000; net income before taxes $270,700,$196,200,000. Extraordinary gain $22,100,000.$2,097,900,000. Net income $96,600,000; otherdividends $23,500,000; other deductions $26,100$2,731,100,000.

8,510,500,000906,800,000; cost of,500,000; operating000; other expenses000; income taxesNet worth at startadditions $586,200,000;,000; net worth at end

Statement received by mail MAR 19 1992. Prepared fromstatement(s) by Accountant: Price Waterhouse, Cleveland, OH.

ACCOUNTANTS OPINION: "A review of the accountant's opinionindicates the financial statements meet generally accepted accountingprinciples and that the audit contains no qualifications".

—0--Accounts receivable shown net less $51,500,000 allowance. Fixed

assets shown net less $4,042,300,000 depreciation.

FINANCEA CONSULTING SERVICE IS AVAILABLE TO ASSIST YOU IN REVIEWING THIS ACCOUNTF THER. PLEASE CALL (800) 223 - 0141 TO SPEAK WITH A DUNS ACCOUNT

10/28/91

Curr AssetsCurr LiabsCurrent RatioWorking CapitalOther AssetsNoncurrent LiabsWorthsalesNet Income (loss)DepreciationInterest ExpenseCapital Additions

FiscalConsolidatedDec 31 1988

3,557,900,0002,458,500,000

1.441,099,400,0005,060,400,0004,132,700,0002,027,100,00010,810,400,000

350,100,000357,100,000231,800,000743,700,000


3,271,900,0002,200,200,000

1.481,071,700,0005,188,400,0004,116,300,0002,143,800,00010,869,300,000

206,800,000383,500,000255,300,000775,700,000


3,324,200,0002,293,600,000

1.441,030,600,0005,639,400,0004,572,100,0002,097,900,00011,272,500,000

(38,300,000)415,000,000328,200,000574,500,000

fiR 52 '33 16:53

Funds Prov Oper 799,400,000Cash Dividends 97,300,000

Fiscal Consolidated statementCash $ 220,300,000Accts RecInventoryMXtble SecuritiesPrepaid

1,495,200,0001,346,000,000

56,400,000206,300,000

Curr AssetsFixt & EquipInvestments-OtherLong Term Accts& Notes RecDef Charges &Other Hisc Assets

3,324,200,0004,808,400,000127,600,000

292,500,000

410,900,000

817,800 30103,800,000

dated DEC 31 1990:Accts PayNotes PayAccrualsTaxesL.T. Liab-(iyr)Other Curr Liabs

Curr LiabsLong Term Debt &Capital LeasesMinority EquityIn SubsidiariesL.T. Liab-OtherDef. Credits/IncomeCOMMON STOCKADDIT. PD.-IN CAPRETAINED EARNINGSCURR TRANS ADJ

p.6574,300,000104,700,000

986,800,000247,600,000442,700,000248,600,00085,400,000232,500,000

2,293,600,000

3,286,400,000

112,800,000550,000,000622,900,00058,500,00065,100,000

2,135,400,000(161,100,000)

Total Assets 8,963,600,000 Total 8,963,600,000From JAN 01 1990 to DEC 31 1990 sales $11,272,500,000; cost of

goods sold $8,805,100,000. Gross profit $2,467,400,000; operatingexpenses $1,999,600,000. Other income $180,600,000; other expenses$592,500,000; net income before taxes $55,900,000. (net loss)$(38,300,000). Income taxes $94,200,000. Net worth at start$2,143,800,000. Other additions $97,100,000; net loss(38,300,000); dividends $104,700,000; net worth at end$2,097,900,000.

Statement received by mail MAR 06 1991. Prepared fromstatement(s) by Accountant: Price Waterhouse.

ACCOUNTANTS OPINION: "A review of the accountant's opinionindicates the financial statements meet generally accepted accountingprinciples and that the audit contains no qualifications".

—0—Accounts receivable shown n«t less $38,900,000 allowance. Fixed

assets shown net l*ss $3,809,600,000 depreciation.

*A———.-———FINANCIAL STATEMENT EXPLANATIONS————.ACCOUNTS RECEIVABLE: Include notes receivable of an undisclosed

amount.INVENTORY: Stated at the lower of cost or market. Cost is

determined using the LXFO method for a significant portion of domesticinventories and the FIFO method or average cost method for otherinventories.

INVESTMENTS-OTHER: Represents the company's investments in 20% to50% owned affiliates accounted for on the equity method.

NOTES PAYABLE: Consists of bank loans and overdrafts. At Dec 311990, the company had short term credit lines and overdraftarrangements totaling $1,930.6 million, of which $470.7 million wereunused.

LONG TERM DEBT & CAPITAL LEASES (IN MILLIONS):.

riftR 30 '92 16:53 P.?

Sinking fund c entures $57.5.Promissory notes 1/68.4.Swiss franc bonds 341.4.Yen bonds 336.0.Y«n bank term loan due 1994 37.0.6.875% convertible debentures due 2003 150.0.Bank term loans due 1991-2000 544.6.Revolving credit agreements 160.0.Euro-commercial paper 16.0.Other domestic debt 958.8.Foreign subsidiary debt 507.3.Capital lease obligations 94.8.Less current portion (85.4).TOTAL LONG TERM DEBT 4 CAPITAL LEASES $3,286.4.At Dec 31 1990, the company had available long term credit

sources totaling $4,258.2 million, of which $2,098.7 million wereunused. Subsequent to year-end, the company renegotiated its $2.24billion revolving credit facility with a group of more than 40 banks.Under the facility, Goodyear now has commitments totaling $2.575billion, of which $2.31 billion is committed through Jun 1994, andothers through Jun 1995. The commitments were set to expire in thefourth quarter of 1992.

Sinking fund debentures (7.35%-8.60%) are due 1992-1997.Promissory notes (10.261-12.15%) are due 1991*2000. Swiss franc bonds(5.375%) are due 2000-2006. Yen bonds (6,625%-7.125%) are due1994-1996.

The annual aggregate maturities of long term debt for the fiveyears subsequent to 1990 are (in millions): 1991 $89.2; 1992 $74.3;1993 $1,442.0; 1994 $186.4; and 1995 $446.3. Maturities of debtincurred under or supported by revolving credit agreements have beenreported on the basis that the commitments to lend under theseagreements will be terminated effective at the end of their initialterms.

DEF. CREDITS/INCOME: Represents deferred income taxes.CONTINGENT LIABILITIES: None material.OTHER INCOME: Includes interest income of $86.8 million.OTHER EXPENSES: Consist of interest expense $328.2 million,

unusual items $103.6 million, other expenses $74.5 million, foreigncurrency exchange $72.1 million and minority interest in net income ofsubsidiaries $14.1 million.

Unusual charges consist of restructuring costs $66.4 million,plant closure and sale of facilities $15.0 million and discontinuedsegment-environmental cleanup costs $22.2 million. The principalcomponent of other expenses are costs associated with the company'scontinuous accounts receivable sale programs.

OTHER ADDITIONS: Consist of foreign currency translationadjustment $77.8 million and common stock issued $19.3 million.

FUNDS FLOW ANALYSIS: Sources of funds totaled $2,727.5 million atDec 31 1990, consisting primarily of short term debt incurred $1,519.9million, cash flow from operations $574.3 million, long term debtincurred $485.2 million and short term securities redeemed $110.3million. Uses of funds totaled $2,629.7 million at Dec 31 1990,consisting primarily of short term debt paid $1,707.5 million andcapital expenditures $574.5 million.

As sources exceeded uses of funds, cash increased by $97.8million at Dec 31 1990.

P1RR 30 '92 16:54 P. 3

RECENT TRENDS; et sales for the nine mon 5 ended Sep 30 1991ware $8,126,6 million versus $8,462.2 million tor the same period theprior year, down $335.6 million or 4.0%, reflecting continued weakdemand for tires and other automotive products worldwide in both theoriginal equipment and replacement markets and a further shift inconsumer preference to lower priced tires.

For the first nine months of 1991, Goodyear lost $8.5 millioncompared with a loss of $49.9 million a year earlier. Included inthese results were after-tax charges of $59.7 million in 1991 and$73.1 million in 1990. The charges in 1991 were for work force cutsand restructuring.

However, the company earned $59,1 million in the 1991 thirdquarter compared with a loss of $61.4 million in the same period ayear ago, despite lower sales. Management said the improved earningsreflect lower raw material costs, efficiencies due to recentrestructurings and lower selling, administrative and general expenses.Trend is up.

SELECTED OPERATING INFORMATION: 1989 1990.Sales - % increase 0.5 3.7.Cross profit margin - % of sales 24.2 21.9.Operating expenses - % of sales 17.i 17.7.Met income (loss) - % of sales 1.9 (0.3).FISCAL 1990 OPERATING RESULTS: The company recorded a net loss

for 1990 of $38.3 million compared to net income of $206.8 million in1989. Sales for 1990 of $11.3 billion increased 3.7 percent from the$10.9 billion recorded in 1989, reflecting primarily the impact ofcurrency translation on foreign results. Also contributing to thesales gain was a 2 percent increase in worldwide tire unit sales, theeffect of which was limited by a lower value mix compared to lastyear.

The loss in fiscal 1990 was largely attributable to after-taxcharges of $73.1 million for restructuring and plant consolidationsand for environmental cleanup costs related to previously sold assets.It also was the first full year that results included all expenses of

the All American Pipeline, which had been capitalized until the fourthquarter of 1989.

SELECTED FINANCIAL RATIOS: 1989 1990.Quick ratio (times) .66 .77.Inventory turnover (times) . 5,01 6.54.Inventory/net working capital (*) 153 131.Sales/net working capital (tines) 10.14 10.94.Total liabs/shareholders' equity (%) 295 327.On OCT 28 1991 Judith A Kosmo, director, invest rel, referred to

the above figures.The company submitted the following interim figures dated

JUN 30 1991:Cash $ 211,500,000 Short Term Debt $ 554,100,000Accts Rec 1,394,000,000Mdse 1,409,600,000

Sales for Jan 1 1991 to Sep 30 1991 were $8,126,600,000.Profits for the same period were $(8,500,000).

————ANALYST COMMENTS————.The tire industry is in a down cycle, with the major effect being

felt in the United States and Europe. Due to consolidation, the tireindustry now has six major companies that produce nearly 80 percent ofthe world's tires, which has intensified industry competition. As a

30 32result of current < nomic conditions, parties rly in th* automobileand truck industries, the company has experienced lower tire sales andint«n»« price competition among tire makers. Goodyear also ishampered by about $3.6 billion in debt stemming from its acquisitionof th« All American Pipeline and from defending itself against ahostile takeover in 1986.

In Jun 1991, Stanley c Gault was elected Chairman of the Boardand Chief Executive Officer of the company, replacing Tom H Barrett,who retired. Subsequent to this management change, the company setsignificant debt reduction as its first priority. The company'sactions include various cost containment measures, the sale of sharesof common stock and the proposed sale of certain assets not essentialto the company's core tire business.

Goodyear Tire has a strong stable of products, a strongmanufacturing base and a strong distribution network. In 1990,Goodyear had a 20% share of the world market for auto, truck and farmtires.

———— SUBSEQUENT EVENT ———— .In Oct 1991, th* company announced plans to sell 10 million

shares of its common stock to raise an estimated $400 million toretir* a piece of its debt. The company currently has 58 millionshares outstanding.

PUBLIC FILINGS

The following data is for information purposes only and is not theofficial record. Certified copies can only be obtained from theofficial source.

* * * JUDGMENT(S) * * *

DOCKET NO.: 23420 NOV 90JDGMT AWARD:JDGMT TYPE:AGAINST:

$510JudgmentGOODYEAR TIRE « RUBBER CO,PHILADELPHIA, PA

IN FAVOR OF: ANN MALONEY, PHILADELPHIA, PAW'-RE FILED: PHILADELPHIA MUNICIPAL COURT,_ PHILADELPHIA, PA

STATUS: UnsatisfiedDATE STATUS ATTAINED;DATE ENTERED:COLLECTED BY D&B:

01/25/199101/25/199102/08/1992

DOCKET NO.: 88908JDGMT AWARD:JDGMT TYPE:AGAINST:

$744JudgmentGOODYEAR TIRE & RUBBER COMPANY,THE (INC)

IN FAVOR OF: FRENCH CREEK MARINAWHERE FILED: KINGS COUNTY SUPREME COURT,

BROOKLYN, NY

STATUS: SatisfiedDATE STATUS ATTAINEDDATE ENTERED:RECEIVED BY D&B:

06/20/199006/04/199009/14/1990

BOOK/PAGE: 06879/0393JDGMT AWARD: $428JDGMT TYPE: JudgmentAGAINST: GOODYEAR TIRE & RUBBER COMPANY,

THE (INC), JACKSONVILLE, FLIN FAVOR OF: ABBEY, WANETTA KABEH

STATUS: UnsatisfiedDATE ENTERED:RECEIVED BY D&B:

04/06/199009/18/1990

HfiP 30 '92 16^55

WHERE FILED: DUVAL COUNTY RI ,RDERS OFFICE,JACKSONVILLE, FL

DOCKET NO.: SC 1188/89JDGMT AWARD: $341JDGMT TYPE: JudgmentAGAINST:

IN FAVOR OFWHERE FILED

GOODYEAR TIRE & RUBBER COMPANY,THE (INC)GRANDE, ANTHONY M, BELMONT, MAMIDDLESEX COUNTY DISTRICT COURTOF CAMBRIDGE, CAMBRIDGE, MA

STATUS: UnsatisfiedDATE STATUS ATTAINEDDATE ENTERED:RECEIVED BY D&B:

04/20/198904/20/193901/04/1551

* * * SUIT(S)

DOCKET NO.: W 22168SUIT AMOUNT: $8,993PLAINTIFF: ALEXANDER, LANCEDEFENDANT: GOODYEAR TIRE & RUBBER COMPANY,

THE (INC)WHERE FILED: BUFFALO CITY COURT, BUFFALO, NY

STATUS: PendingDATE STATUS ATTAINEDDATE FILED:RECEIVED BY D&B:

01/23/199201/23/199201/24/1992

E :<ET NO.:PLAINTIFF:

915519$153,000-DENVER'S TIRE & AUTOSERV.

DEFENDANT: THE GOODYEAR TIRE & RUBBER CO.WHERE FILED: MONTGOMERY COUNTY COMMON PLEAS

COURT, DAYTON, OH

STATUS: PendingDATE STATUS ATTAINEDDATE FILED:RECEIVED BY D&B:

12/20/199112/20/199102/03/1992

DOCKET NO.:SUIT AMOUNTPLAINTIFF:

91-3379$55,000,000MARY JENKINS FOR ESTATE OFRICHARD TOLL JENKINS INC,FROSTBURG, MDTEN OTHERS

DEFENDANT: GOODYEAR TIRE & RUBBER COMPANY,THE (INC)

CAUSE: FraudMisrepresentationNegligenceBreach of warranty(ies)

WHERE FILED: BALTIMORE CITY DISTRICT COURT,BALTIMORE, MD

STATUS: PendingDATE STATUS ATTAINED;DATE FILED:RECEIVED BY D&B:

11/27/199111/27/199112/04/1991

DOCKET NO.: 91-3378SUIT AMOUNTPLAINTIFF:DEFENDANT:

$55,000,000ANNA M COLE, CUMBERLAND, MDGOODYEAR TIRE & RUBBER COMPANY,THE (INC)

CAUSE: Breach of contractFraudMisrepresentationNegligenceBreach of warranty(ies)


STATUS: PendingDATE STATUS ATTAINED: 11/27/1991DATE FILED: 11/27/1991RECEIVED BY D&B: 12/04/1991

MPR 30


91-3377$55,000,000YOLAND T FACCINO, LA VALE, MDTEN OTHERSGOODYEAR TIRE & RUBBER COMPANY,THE (INC)FraudMisrepresentationNegligenceBreach of warranty(ies)


DEFENDANT:

CAUSE:

STATUS: PendingDATE STATUS ATTAINED:DATE FILED:RECEIVED BY DiB:

11/27/199111/27/199112/04/1991

DOCKET NO.: 91-3376SUIT AMOUNT:PLAINTIFF:DEFENDANT:CAUSE:

WHERE FILED;

$55,000,000VIOLET G GRAY, FROSTBURG, MDTEN OTHERSGOODYEAR TIRE & RUBBER COMPANY,THE (INC)FraudMisrepresentationNegligenceBreach of warranty(ies)BALTIMORE CITY DISTRICT COURT,BALTIMORE, MD

STATUS: PendingDATE STATUS ATTAINED:DATE FILED:RECEIVED BY D&B:

11/27/199111/27/199112/04/1991

DOCKET NO.: 91-3375SUIT AMOUNT: $55,000,000PLAINTIFF: EVELYN V BUSER, RIDGELEY, WV

TEN OTHERSDEFENDANT: GOODYEAR TIRE & RUBBER COMPANY,

THE (INC)CAUSE: Fraud

MisrepresentationNegligenceBreach of warranty(ies)



,KET NO. : 91-3372SUIT AMOUNTPLAINTIFF:

DEFENDANT:

CAUSE:

WHERE FILED;

$55,000,000ALBERT D STEWART, CUMBERLAND, MDTEN OTHERSGOODYEAR TIRE & RUBBER COMPANY,THE (INC)FraudMisrepresentationNegligenceBreach of warranty(ies)BALTIMORE CITY DISTRICT COURT,BALTIMORE, MD


DOCKET NO.: 91-3373SUIT AMOUNT: $55,000,000PLAINTIFF: LOUIS E SCHADT, CUMBERLAND, MD

TEN OTHERS

STATUS: PendingDATE STATUS ATTAINED:DATE FILED:

11/27/199111/27/1991

DEFENDANT

CAUSE:

WHERE FILED:

30 '92 16=56

GOODYEAR TIRE I .UBBER COMPANY, RECEIVED I D&B:THE (INC)FraudMisrepresentationNegligenceBreach of warranty(its)BALTIMORE CITY DISTRICT COURT,BALTIMORE, MD

P. 12

12/04/1991


91-3374$55,000,000MILFORD G & DOROTHY M WILSON,CUMBERLAND, MDTEN OTHERS

DEFENDANT: GOODYEAR TIRE & RUBBER COMPANY,THE (INC)

CAUSE: FraudMisrepresentationNegligenceBreach of warranty(ies)


STATUS: PendingDATE STATUS ATTAINED:DATE FILED:RECEIVED BY D&B:

11/27/199111/27/199112/04/1991

* * LIEN(S) * * *

A lienholder can file the same lien in more than one filinglocation. The appearance of multiple liens filed by thesane lienholder against a debtor may be indicative of suchan occurrence.

.,______.__.__.__•__«______.•__.__«__.____•——____•__«__ MM*,B«W ——•••——•• WW__»W__V<»»»__~»W ——wx

FILING NO.: 707731925 /91-6150AMOUNT: $3,275 cprp. declaration taxTYPE: State TaxFILED BY: S C TAXAGAINST: GOODYEAR TIRE & RUBBER CO THE

CORPWHERE FILED: GREENVILLE COUNTY CIRCUIT

COURT, GREENVILLE, SC

STATUS: OpenDATE STATUS ATTAINED:DATE FILED:RECEIVED BY D&B:

10/17/199110/17/199112/17/1991

NO.: 91*6150 /707731925AMOUNT: $3,275 CORP. DECLARATION TAXTYPE: State TaxFILED BY: S C TAXAGAINST: GOODYEAR TIRE & RUBBER CO INC

CORPWHERE FILED: GREENVILLE COUNTY CIRCUIT

COURT, GREENVILLE, SC

STATUS: OpenDATE STATUS ATTAINED:DATE FILED:RECEIVED BY D&B:

10/17/199110/17/199101/02/1992

00562456$599State TaxSTATE OF INDIANAGOODYEAR TIRE & RUBBER,INDIANAPOLIS, IN

WHERE FILED: MARION COUNTY CIRCUIT COURT,INDIANAPOLIS, IN

DOCKET NO. :AMOUNT:TYPE:FILED BY:AGAINST:

STATUS: OpenDATE STATUS ATTAINED: 05/03/1991DATE FILED: 05/03/1991RECEIVED BY D&B: 10/07/1991

* * * UCC PILING(S) * * *

COLLATERAL: Leased Inventory and proceeds - Leased Equipment and proceedsFILING NO: 1219032 DATE FILED: 07/24/1991TYPE:SEC. PARTY

ASSIGNEE

DEBTOR:

OriginalMERIDIAN LEASING CORP,DEERFIELD, ILUS PORTFOLIO LEASING INC, SANFRANCISCO, CAGOODYEAR TIRE & RUBBER CO, THE

RECEIVED BY D&B: 09/19/1991FILED WITH: SECRETARY OF

STATE/UCC DIVISION,WI

COLLATERAL;

FILING NO:TYPE:SEC. PARTY:

DEBTOR:

Leased Inventory and proceeds - Leased Computer equipment andproceeds * Leased Equipment and proceedsAE0004645 DATE FILED: 07/10/1990Original RECEIVED BY D&B:FINALCO INCORPORATED, BOCA FILED WITH:RATON, FLGOODYEAR TIRE & RUBBER COMPANY,THE (INC) , AKRON, OH

08/22/1990SECRETARY OFSTATE/UCC DIVISION,OH

C" \ATERAL:

FILING NO:TYPE:SEC. PARTY

DEBTOR:

Leased inventory - Business machinery/equipment and proceeds -Equipment89029914 DATE FILED: 02/13/1989Original FILED WITH: Secretary of State,MERIDIAN LEASING CORPORATION, TXDEERFIELD, ILLONG MILE RUBBER COMPANY,GREENVILLE, TX

COLLATERAL: Leased Account(s) including proceeds and products - LeasedEquipment including proceeds and products

FILING NO: B 92-00402 FS DATE FILED: 01/06/1992Original RECEIVED BY D&B: 01/16/1992AT & T CREDIT CORP, PARSIPPANY, FILED WITH: SECRETARY OFNJ STATE/UCC DIVISION,GOODYEAR TIRE & RUBBER CO, THE AL

TYPE:SEC. PARTY

DEBTOR:

LATERAL: Leased Proceeds - Leased Computer equipmentNO: 91091381 DATE FILED:

TYPE:SEC. PARTY

DEBTOR:

OriginalMERIDIAN LEASING CORP,DEERFIELD, ILTHE GOODYEAR TIRE & RUBBER CO

05/13/1991RECEIVED BY D&B: 05/31/1991FILED WITH: SECRETARY OF

STATE/UCC DIVISION,TX

COLLATERAL:FILING NO!TYPE:SEC. PARTY:

DEBTOR:.

Leased Proceeds - Leased Computer equipmentAE0058174 DATE FILED: 03/26/1991Original RECEIVED BY D&B: 06/18/1991MERIDIAN LEASING CORP, FIIJID WITH: SECRETARY OFDEERFIELD, IL STATE/UCC DIVISION,THE GOODYEAR TIRE & RUBBER CO OH

COLLATERAL;FILING NO:TYPE:SEC. PARTY;

Leased Proceeds - Leased Computer equipmentAE0058175 DATE FILED: 03/26/1991Original RECEIVED BY D&B: 06/18/1991MERIDIAN LEASING CORP, FILED WITH: SECRETARY OF

DEBTOR:

30 '92 16:5?

DEERFIELD, ILTHE GOODYEAR TIRE & RUBBER CO

D. 14

STATE/UCC DIVISION,OH

FILING NO:TYPE:SEC. PARTY

ASSIGNEE:

DEBTOR:

01049177AssignmentUNILEASE COMPUTER CORP,DEERFIELD, ILCIT GROUP/EQUIPMENT FINANCINGINC, THE, PARK RIDGE, ILGOODYEAR TIRE & RUBBER CO, THE

DATE FILED: 12/31/1991RECEIVED BY DiB: 03/09/1992ORIG. UCC FILED: 03/26/1991ORIG. FILING NO: AE0058175FILED WITH: SECRETARY OF


COLLATERAL: Leased Proceeds - Leased Computer equipmentFILING NO: AE0056696TYPE: OriginalSEC. PARTY: HERIDIAN LEASING CORP,

DEERFIELD, ILDEBTOR: THE GOODYEAR TIRE & RUBBER

COMPANY

DATE FILED: 03/17/1991RECEIVED BY D4B: 06/18/1991FILED WITH: SECRETARY OF


COLLATERAL: Leased Proceeds * Leased Computer equipmentF ING NO: AE0054042 DATE FILED: 03/05/1991Tt^E: Original RECEIVED BY DiB: 06/13/1991SEC. PARTY: MERIDIAN LEASING CORP, FILED WITH: SECRETARY OF

DEERFIELD, IL STATE/UCC DIVISION,DEBTOR: THE GOODYEAR TIRE & RUBBER CO OH

COLLATERAL;FILING NO:TYPE:SEC. PARTY;

DEBTOR:

Leased Proceeds - Leased Computer equipmentAE0054043 DATE FILED: 03/05/1991Original RECEIVED BY D&B: 06/18/1991MERIDIAN LEASING CORPORATION, FILED WITH: SECRETARY OFDEERFIELD, IL STATE/UCC DIVISION,THE GOODYEAR TIRE fc RUBBER CO OH

There are additional suits, liens, or judgments in D&B'sfile on this company available by contacting 1-800-DNB-DIAL.

There are additional UCC's in D&B's file on this companyavailable by contacting 1-800-DNB-DIAL.

The public record items contained in this report may have beenpaid, terminated, vacated or released prior to the date thisreport was printed.

BANKING03/9202/92

Account open over 5 years.en 1-3 years.Account open over

Account (s) averages low 4 figures. Account open oveAc count (s) averages high 3 figures. Account open 1-(Same bank) Account (s) averages low 4 figures. Accou

10 years.(Same bank) Account (s) averages medium 3 figures. Ac

over 10 years.(Same bank) Account (s) averages low 4 figures. Account open over

10 years.(Same bank) Account (s) averages low 4 figures. Account open 1-3

years .

Account open

r-lPR 30 '3£ 16:58 =. 15

Account(s) av* ges moderate 3 figures. . ;ount open over 10years.

Account(s) averages medium 3 figures. Account open 1-3 years.(Same bank)Account(s) averages high 3 figures. Account open over

10 years.Account(s) averages high 4 figures. Account open 1-3 years.Account(s) averages high 5 figures. Account maintained.(Same bank)Account(s) averages moderate 4 figures. Account

maintained.Account open under 1 year.

HISTORY03/19/92

STANLEY C. GAULT, CHB-CEO+ HOYT M. WELLS, PRES+FRANK R. TULLY, EX V PRES OREN G. SHAFFER, EX V PRES+EUGENE R. CULLER JR, EX V PRES WILLIAM J. SHARP, EXEC V PRESJAMES BOYAZIS, V PRES-SEC JOHN M. ROSS, V PRZS-GEN COUNSELCHARLES E, EDMISTEN, V PRES-COMPTROLLERDIRECTOR(S) : The officers identified by ( + ) and Thomas H. cruikshank,Gertrude G. Michelson, William C. Turner, Steven A. Minter, Charles W.Parry, Agnar Pytte and Russell E. Palmer.

BUSINESS TYPE: Corporation - DATE INCORPORATED: 08/29/1898Profit STATE OF INCORP: Ohio

AUTK SHARES-COMMON: 150,000,000PAR VALUE-COMMON: No Par ValueAUTH SHARES-PREF: 50,000,000PAR VALUE-PREF: No Par Value

OUTSTANDING CAPITAL STOCK: At Dec 31 1990, there were 58,477,890common shares outstanding. No preferred shares have been issued.

There were 48,780 shareholders of record at Feb 19 1991. This isa publicly held corporation whose common stock is listed on the NewYork, Midwest and Pacific Stock Exchanges under the ticker symbolHGT". Overseas listings include the Tokyo, Paris, Frankfurt andBrussels Stock Exchanges. At Feb 15 1991, no director or officerbeneficially owned more than 0.12%, and all directors and officers asa group beneficially owned approximately 0.76% of the shares of commonstock then outstanding. Beneficial owners of more than 5% of thecommon stock outstanding included two operating subsidiaries of TheCapital Group Inc, Los Angeles, CA, which owned approximately 6.4% ofoutstanding shares as of Feb 11 1991, and Sanford C Bernstein & CoInc, New York, NY, who owned approximately 8.2% of outstanding sharesas of Feb 6 1991.

Business started 1898.ACQUISITION:.In Dec 1989, Goodyear acquired Co-Ex Plastics Inc, a blown

wrapping films manufacturing company located in Levisburg, TN. Apurchase price was not disclosed.

DISCONTINUED OPERATIONS:.On Dec 30 1986 the company sold the capital stock of Motor Wheel

Corporation and on Apr 1 1987, sold the capital stock of Motor Wheel

HP.R 38 '32 1&:55 =. 16

Canada and certain her assets, including thr manufacturing plantsowned by the company, to MWC, inc for an aggregate selling price ofS175 million. On Mar 13 1987 the company sold substantially all ofthe assets of Goodyear Aerospace Corporation and certain relatedassets to Loral Corporation for $588 million.

On Jul 24 1987 the company sold approximately 6 1/2 percent ofits oil and gas reserves to a subsidiary of International Paper for$70 million. On Dec 4 1987 the company sold substantially all of itsremaining oil and gas reserves in the sale of all of the shares ofCeleron Oil and Gas Company to an Exxon subsidiary for $615.0 million.

In the 1989 second quarter, the company's oil transportationsubsidiary, All American Pipeline Company, sold about 435 miles ofunused 30-inch pipe to Coastal Corporation for $70 million.

In Aug 1989, the company sold its South African tire and generalproducts manufacturing subsidiary to Consol Limited, subsidiary ofAnglovaal Ltd, a South African financial, industrial and mining group,for $41 million.

————MANAGEMENT BACKGROUND————.STANLEY C. GAULT, born 1926. 1948 College of Wooster (Ohio),

B.A. 1944-46 USAAC. 1948-80 employed General Electric Co, seniorvice president-industrial products and components sector. 1980-91employed Rubbermaid Incorporated, Wooster, OH, CHB and CEO. Jun1991-present CHB and CEO, The Goodyear Tire & Rubber Company.

HOYT M. WELLS, born 1926 married. 1949 University of Nebraska,ME; 1951 MME. 1951 to present employed Goodyear Tire & RubberCompany. 1951 engineer. 1956 engineering manager North Chicagoplant. 1967 engineering manager St Marys Molded & Extruded Productsplant. 1969 plant manager. 1972 vice president general productsGoodyear Canada Inc. 1980 vice president general products GoodyearTire & Rubber Company. 1987 executive vice president; 1988 director;1991 president.

FRANK R. TULLY, born 1928 married. 1951-present The GoodyearTire & Rubber Company. 1980 elected vice president-human resources.Dec 1989 elected executive vice president-human resources and totalquality systems.

OREN G. SHAFFER, born 1943. 1968 to present employed by TheGoodyear Tire & Rubber Company. Held various financial posts until1981. 1981 elected president and managing director of Goodyear FranceSA, a subsidiary. 1983 assistant controller of The Goodyear Tire &Rubber Company. 1985 elected vice president and treasurer. 1987executive vice president and director.

EUGENE R. CULLER JR, born 1938. 1961-present The Goodyear Tire &Rubber Company; 1986 vice president; 1988 executive vicepresident-North American Tire Operations.

WILLIAM J. SHARP, born 1941. Graduated from the University ofAkron with a bachelor's degree in industrial relations. Joined TheGoodyear Tire & Rubber Co in 1964. Elected vice president, tiremanufacturing 1987. Became responsible for the wire and textileplants in 1989. 1991 elected executive vice president, productsupply.

JAMES BOYAZIS, born 1936 married. 1958 BE Youngstown StateUniversity, 1966 JD University of Akron, 1959-62 employed RepublicSteel Corp, industrial engineer. 1963 to present employed TheGoodyear Tire & Rubber Company, 1979 director, secretary's office.1983 secretary and counsel Goodyear Aerospace Corp subsidiary. 1987vice president and secretary The Goodyear Tire & Rubber Company.

30 '92 16=59 =. 17

JOHN M. ROSS, rn 1931 married. 1953 BA lie University. 1956LLB, Temple University Law School. 1956-65 employed Duane Morris &Heckscher, law firm. 1965 to present The Goodyear Tire i RubberCompany. 1965 legal staff, 1973 assistant general counsel andassistant secretary, 1987 vice president and general counsel.

CHARLES E. EDHISTEN, born 1929. Graduated from VirginiaCommonwealth University. 1951-present The Goodyear Tire & RubberCompany. 1973 general auditor. May 1990 appointed vice president andcomptroller.

————OTHER OFFICERS————JOHN P. PERDUYN, vice president.FREDERICK J. KOVAC, vice president.ROBERT M. HEHIR, vice president.EARL W. DAHL, vice president.DENNIS E. DICK, vice president.JAMES W, BARNETT, vice president.NISSIK CALDERON, vice president.WELTON BIRDWELL, vice president.GEORGE R. HARGREAVES JR, vice president & treasurer.JESSE T. WILLIAMS SR, vice president.J. DAVID WOLF, vice president.R. P. ADANTE, vice president.W. B. HIRSCH, vice president.————OTHER DIRECTORS————THOMAS H. CRUIKSHANK, CHB and CEO, Halliburton Company.GERTRUDE G. MICHELSON, senior vice president-external affairs, R,

H. Macy & Company, Incorporated.WILLIAM C. TURNER, CHB and CEO, Argyle Atlantic Corporation.STEVEN A. MINTER, director, The Cleveland Foundation.CHARLES W. PARRY, retired, formerly CHB, Aluminum Company of

America (ALCOA).AGNAR PYTTE, president, Case Western Reserve University.RUSSELL E. PALMER, CHB and CEO, The Palmer Group.Affiliates: The following are related through common ownership

and/or financial interest.Goodyear participates in several joint ventures in various

foreign countries. In 1987, Goodyear and Pacific Dunlop Limitedestablished South Pacific Tyres, an Australian partnership, and SouthPacific Tyres N.Z. Limited, a New Zealand company, in each of which

.. Goodyear and Pacific Dunlop Limited each have a 50% equity interest,which entities operate five tire manufacturing plants, 27 retreadplants and a chain of approximately 425 retail outlets in Australia,New Zealand and Papua - New Guinea.

In 1989, Goodyear and Pacific Dunlop Limited established TecbeltPacific, an Australian partnership in which Goodyear and PacificDunlop each have a 50% equity interest, which manufactures steelreinforced conveyor belting in Australia. Other joint ventureinterests of the company include a 50% interest in Nippon Giant TireCo., Ltd., which manufactures earthmover tires in Japan, and a 30%interest in a synthetic rubber and specialty polymers facility inBrazil.

OPERATION03/19/92 On a consolidated basis, the company manufactures (through its

tires and related products and services segment, 81.8% of 1990 sales]

ae '^^ i?^e p. iga broad line of til ,, tubes and retreads (sal of tires wereapproximately 72.6% of Goodyear's net salts in 1990), engages inautomotive repair services through its retail outlets, the sale todealers (wholesale) and consumers (retail) of automotive equipment andsupplies, the operation of seven rubber plantations and engages inaircraft wheel and brake maintenance; the general product* segment(18.0% of 1990 sales) manufactures vehicle components including a videvariety of automotive belts and hoses, industrial rubber products,rubber treads for tank tracks, a broad line of synthetic rubber,rubber latices and organic chemicals used in rubber and plasticprocessing and vinyl resins and latices, polyester resins, PVC films,and markets shoe products and roofing products; and through its oiltransportation segment (0.2% of 1990 sales), consists primarily of theAll American Pipeline system, a common carrier crude oil pipelineextending from California to Texas.

Terms are 30 days, dating and extended terms on some foreignsales. Has 65,000 accounts. Sells to original equipmentmanufacturers, dealers, wholesalers, service stations, distributors,the general public & retail chain stores. Territory : International.Foreign sales represented approximately 43% of total sales in 1990.Nonseasonal. Competition intense.

EMPLOYEES: 99,952. 5,708 employed here.FACILITIES: owns 1,800,000 sq. ft. in multi story brick building

in good condition. Premises neat. Corporate headquarters complex.LOCATION: Industrial section on main street.BRANCHES: On a consolidated basis, Goodyear manufactures its

products in 85 manufacturing facilities located around the world.There are 42 plants at 40 locations in 20 states of the United Statesand 43 plants in 25 foreign countries. There are approximately 1,363retail outlets in the United States and approximately 442 retailoutlets in foreign countries. The company also operates 86 retreadplants and approximately 277 warehouse and distribution facilities.There are also research and development facilities and technicalcenters in Akron, OH, Colmar-Berg, Luxembourg, and orsay, France. Thecompany also owns and operates tire proving grounds in Akron, OH,Colmar-Berg, Luxembourg, Mireval, France, and San Angelo, TX.The company owns and operates rubber plantations in the Philippines,Indonesia, Brazil and Guatemala and operates two rubber plantations inthe Philippines.

SUBSIDIARIES: At Mar 20 1991, the company listed 68 direct andindirect subsidiaries, 56 of which were wholly-owned. They areengaged in manufacturing or marketing of the company's productsthroughout the world. There are intercompany merchandise transactionson regular terms. A list of subsidiaries is available and on file atthe Cleveland, OH office of Dun & Bradstreet. Certain significantsubsidiaries are listed below.

The Kelly-Springfield Tire Company, Cumberland, MD, chartered MD1935, manufactures replacement passenger and truck tires.

Air Treads Inc, Forest Park, GA, chartered GA 1966, sells newaircraft tires, produces and sells retreaded aircraft tires andrepairs aircraft wheels and brakes in the U.S., Canada and Europe.

All American Pipeline Company, Houston, TX, chartered TX 1983,operates crude oil pipeline.

Brad Ragan Inc, Charlotte, NC, chartered NC 1962, 74.5% owned,tire retailing and commercial tire sales, retreading and servicechain.

Banking: Chemical I k, Continental Bank N.A.,Trust Company, Citibank N.A., Bank of America.03-30(9ZN /H6) 00000

inufacturers Hanover

012114114 H

FULL DISPLAY COMPLETE(EOR)

Attachment C

Waste Management of North America. Inc.Midwest RegionTwo Westbrook Corporate Center • Suite 1000P.O. Box 7070Westchester. Illinois 60154708/409-0700

July 19, 1990

Jeffrey A. Cahn, Esq.Assistant Regional CounselOffice of Regional CounselU.S. Environmental Protection Agency5CS-TUB-3230 South Dearborn StreetChicago, Illinois 60604

Re: Request for Information Pursuant to Section 104(e)of CERCLA addressed to Waste Management of North America,Inc., and Waste Management of Wisconsin, Inc., for theHaaen Farm Site in Stoughton. Wisconsin______________

Dear Mr. Cahn:

On July 10, 1990, Waste Management of North America, Inc., andWaste Management of Wisconsin, Inc., received Section 104(e)Requests for Information concerning the Hagen Farm Site inStoughton, Wisconsin. Waste Management of North America, Inc.,is not the parent corporation of Waste Management of Wisconsin,Inc., and has no involvement at the Hagen Farm Site in Stoughton,Wisconsin. Waste Management of Wisconsin, Inc., is the ultimatesuccessor to City Disposal Corporation which did have involvementas an operator and transporter to the Hagen Farm Site. WasteManagement, Inc., is the parent corporation of Waste Managementof Wisconsin, Inc., as noted in response to Question 12 of yourRequest for Information. In addition to the specific responsesand documents provided herein, outside counsel for WasteManagement at the law firms of DeWitt, Sundby, Hugett, Schumacher& Morgan In Madison, Wisconsin, and Sidley & Austin in Chicago,Illinois, handled related litigation arising out of the HagenFarm Site, and both firms maintain some files concerning thelitigation which they handled. As you are aware from discussionswith our Environmental Counsel, Ann Straw, these documents areavailable upon request for review and copying by USEPA. Thefollowing specific responses to Questions 1 through 21 of yourRequest for Information are provided:

1. For a complete listing of all persons consulted in thepreparation of this Response, see Attachment 1.

2. For a complete listing of documents consulted, examined andreferred to in this Response, please refer to Attachment 2.

Jeffrey A. Cahn, Esq.July 19, 1990Page 2

3. (a) Peter AbelesP. 0. Box 219Kenosha, WisconsinFormerly employed by City Disposal Corp.

(b) Richard Sundby2279 County Truck Highway AStoughton, WisconsinArea Resident, Owner of Sundby Sand & Gravel

(c) Ruth Sundby1212 HamiltonStoughton, WisconsinArea resident

(d) Oscar Forton604 Grant StreetStoughton, WisconsinFire chief, City of Stoughton

(e) Roger Olson587 Manerville RoadStoughton, WisconsinChairman, Town of Dunkirk

(f) William Chritton113 East MainStoughton, WisconsinCity Attorney for Stoughton

(g) Gerald Onsrud561 Peachwood DriveGrand Junction, ColoradoFormer City Disposal Employee

(h) Tom Every6102 S. HighlandMadison, WisconsinFormer Stoughton resident

(i) Liniel CooperAddress unknownFormer Mayor - City of Stoughton

Stoughton Trailer, Inc.Stoughton, Wisconsin


(k) The following EPA or Wisconsin DNR employees wereinvolved in investigation with the above site. (SeeAttachment 3, Re: State v. Waste Management, et al.,83 CV 1115, Plaintiff's Answers to Interrogatories.)Debra Newman Horn (WDNR), Hazardous Waste Specialist;William Rock (WDNR), Hazardous Waste Management SectionChief;David Stensby (WDNR), Chemist;Richard O'Hara (WDNR), Bureau of SW Management;Joseph Brusca (WDNR), Solid Waste Investigator;Wendell J. Wojner (WDNR), Hazardous Waste Specialist;Niles Ostenso (WDNR), Hydrogeologist;Floyd Stautz (WDNR), Assistant District Director;Joseph G. Brehm (WDNR), Natural Resources Technician.

(1) U.S. Rubber, now known as Uniroyal Plastics, Inc.,Employees:Robert NilesFrank KrawcekW. C. Brodhagen

(m) Susan Shumway, Esq.Shuroway & Merle2425 Post Road, Suite 205Southport, Connecticut 06490Attorney for Uniroyal Plastics, Inc., as successorcorporation to U.S. Rubber, at Hagen Farm Site.

4. Copy of 104(e) Response to EPA's February 23, 1987, requesthas not been located.

5. Entity E?A or Wisconsin I.D. Number

Hagen Farm Site WID 980610059 (no EPA I.D.number assigned)

Waste Management of None assignedWisconsin, Inc.

Waste Management of None assignedNorth America, Inc.

6. Pursuant to conversation memorialized in State of WisconsinAnswers to Interrogatories included in Answer to No. 7,State v. Waste Management, et al., 83 CV 1115, Attachment 3,between Debra Horn (investigator for State of Wisconsin) and


Ms. Ruth Sundby on July 16, 1981, Mrs. Sundby recalled CityDisposal, Uniroyal and Milprint using the site.

Pursuant to conversation between Debra Horn and Oscar Fortonon July 21, 1981, memorialized in State of Wisconsin Answerto Interrogatory No.7, State v. Waste Management, et al.. 83CV 1115, Attachment 3, Mr. Forton recalled City Disposal,Milprint and Uniroyal using the site.

Pursuant to a letter from Robert Miles (Uniroyal) to TomLoftus (Wisconsin DNR), dated January 13, 1983, disclosed inPlaintiff's Answer to Interrogatory No. 7 in State v. WasteManagement, et al.. 83 CV 1115, (letter is not in ourpossession), it states Uniroyal was one of many users of thesite.

Pursuant to a letter from Stoughton Trailer, Inc., to DougMorrissette (DNR), dated February 11, 1983, contained inWisconsin DNR files (not in possession of Waste Management),the letter stated Stoughton Trailers transported cardboardboxes, wood cutting materials, and general office type wastepaper.

Also, see companies identified in Question No. 20 and seeResponse No. 20.

7. For a complete listing of all persons having knowledge orinformation about the generation, use, treatment, storage,disposal or other handling of hazardous materials at thesite, see the Response to Question No. 3 above.

8. (a) See Attachment 4, Warranty Deed transferring title toHagen Farm Site from Orrin N. Hagen to Waste Management ofWisconsin, Inc., dated February 24, 1987.

(b) Respondents object to the use of the term "hazardousmaterials" as being vague and overbroad so as to renderimpossible any meaningful response. Without waiving saidobjection, Respondents state that they have never generatedwastes determined to be "hazardous," which were potentiallyor ultimately disposed of at the Site to the best of ourknowledge.

(c) Respondents object to the use of the term "hazardousmaterials" as being vague and overbroad so as to renderimpossible any meaningful response. Without waiving saidobjection, Respondents state that they never accepted for

Jeffrey A. Cahn, EsqJuly 19, 1990Page 5

transportation to the Site wastes determined to be"hazardous" at the time of acceptance.

(d) See Attachment 5, "Lease Agreement" for conduct ofdisposal operations between Nora E. Sundby and City DisposalService, Inc., dated December 10, 1962. The lease wasterminated in August of 1966. Respondents have been unableto locate document entitled "Termination of Lease'* but willforward same to you when document is located.

9. Waste Management of Wisconsin, Inc., as successor-in-interest to City Disposal Corporation, is responsible forthe liability, if any, of City Disposal Corporation arisingout of disposal operations at or transportation to the Site.

10. See Attachments 6-11 for Articles of Incorporation and By-Laws.

11. Acme Disposal Service Corporation registered as acorporation on December 17, 1959. See Attachment 6,Articles of Incorporation attached.

City Disposal Service, Inc., registered as a corporation onJanuary 5, 1963. See Attachment 7, Articles ofIncorporation attached.

Amendment to Articles of Incorporation of City DisposalService, Inc., changing name to City Disposal Corporation,dated February 22, 1963. See Attachment 8.

Articles of Merger of City Disposal Corporation into AcmeDisposal Service Corporation, dated September 12, 1967. SeeAttachment 9.

Amendment to Articles of Incorporation, changing the name ofAcme Disposal Service Corporation to Waste Management ofWisconsin, Inc., dated December 30, 1971. See Attachment10.

By-Laws of Waste Management of Wisconsin, Inc. SeeAttachment 11.

12. The parent corporation of Waste Management of Wisconsin,Inc., is Waste Management, Inc.

13. (a-f) Respondents object to the use of the term "hazardousmaterial" as being vague and overbroad so as to render

Jeffrey A. Cahn, EsqJuly 19, 1990Page 6

impossible any meaningful response. Without waiving saidobjection, Respondents state that they have nevertransported to the Site or disposed of at the Site wastesdetermined to be "hazardous" at the time of transportationor disposal and that the landfill was operated insubstantial compliance with all statutes, rules andregulations governing the types of wastes permitted to belandfilled at the time such wastes were accepted at theSite,

14. See Response Nos. 8(b) and 10 above.

15. Henry and Nora Sundby(a) Approximately 1948 to March 2 1969.

(b) See Response No. 8(a) above and Attachment No. 5.

(c) This information is unknown to Respondents.

Orrin and Ida Hagen(a) March 3, 1969, to May 11 1987

(b). See Attachment 4 and Response No. 8 (a) above andAttachment No. 5.

(c) This information is unknown to Respondents.

16. (a-d) Pursuant to an interview with Peter Abeles, cityDisposal was first to lease the Site for disposaloperations. According to the interview, prior to the CityDisposal lease, the Site was an exhausted gravel pit.

17. Respondents are in possession of Application for Garbage andRefuse Disposers License for Town of Dunkirk and Permit toTransport and Pick Up Garbage and Rubbish. See Attachment12. Respondents are not in possession of State of Wisconsinpermits as State did not begin permitting until 1968.

18. (a-m) See Respondents1 Response to No. 13 above. Withoutwaiving said objection, please refer to Attachments 13 and14 which include contracts and invoices which, to the bestof our knowledge, pertain to this facility.

19. Without waiving Respondents' objection stated in ResponseNo. 13, Respondents provide the following informationregarding transactions relating to the Site:


(a) Disposal arrangements for materials were arranged withPeter Abeles of City Disposal and W.C. Brodham of U.S.Rubber Company, now known as Uniroyal Plastics Company.

(b) Pursuant to records in Respondents' possession (seeAttachment 14) which are incomplete, Respondents executedcontracts with U.S. Rubber, now known as Uniroyal PlasticsCompany, on November 26, 1962, and March 1, 1966.

(c) Material transported by City Disposal was generated byU.S. Rubber, now known as Uniroyal Plastics Company, andaccording to the contracts consisted mainly of paper,synthetic resin films, scrap coating materials andmiscellaneous waste.

(d) U.S. Rubber Company, now known as Uniroyal Plastics Co.,Inc.

(e) This information is unknown to Respondents.

(f) Please refer to Attachment 3. Wisconsin DNR performedtesting on the Site. Please refer to Answer toInterrogatory No. 8.

(g) This information is unknown to Respondents. However,pursuant to an interview with Peter Abeles in 1983, heindicated that City Disposal chose the disposal location.

(h) Respondents have no information.

(i) To the best of our knowledge, wastes were transporteddirectly to the Site.

(j) Pursuant to an interview with Peter Abeles in 1983, heindicated that one method of handling Uniroyal's wastematerial at the Site was to attempt to solidify material onthe ground, through evaporation, leaving a solid plasticresidue.

(k) Respondents have no information as to disposition of thewaste material.

(1) Respondents' outside counsel investigating on behalf ofState of Wisconsin v. Waste Management, et al.. 83 CV 1115,conducted interviews and telephone interviews of pastemployees and people familiar with the Site; however, this


information is not formally documented and is therecollection of interviewed persons.

(m) [There is no subsection (m).]

(n) Information unknown to Respondents

(o) Copies attached. See Attachment 13.

(p) Refer to Response No. 19(o) and Response No. 3.

20. To the best of Respondents1 recollection, the list ofcompanies identified in this question was compiled byWisconsin DNR.

21. The meaning of this question is unclear to Respondents,however, the issue seems to be addressed in Response No. 13above.

The foregoing information provided in response to USEPA's Requestfor Information is true and correct to the.best of WasteManagement's current knowledge and belief, however, we reservethe right to supplement this Response if additional informationrelevant to the Hagen Farm Site in the Town of Dunkirk, DaneCounty, becomes available.

Please feel free to contact our Environmental Counsel, Ann Straw,at 708/409*3523, if questions arise concerning this Response.

Very truly yours,

William SchubertRegional Environmental ManagerOn behalf of Waste Management of Wisconsin, Inc

pt

cc: Carl FrankPeter Kelly

november 11, 1992 assistant regional counselreference, i am enclosing a copy of that letter as well...

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