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4723 -1999 9 :07AM <br />FROM SWEENEY LAW FIRM 2235289 P.9 <br />9. Industrial activities at the Schnitzer Site included salvaging lead- containing <br />products, including lead -acid batteries, "plumber's lead," "printer's lead," solder; piping and wire. <br />Salvaging lead -acid batteries involved "cracking" the outer battery casting and removing the Lead <br />grids contained within the battery for resale. Transformers and other electrical equipment were <br />also recycled at the Schnitzer Site. These transformers and electrical equipment contained <br />polychlorinated biphenols ("PCBs ") and were cut up on-site and sold as scrap metal. <br />10. Salvage operations at the Site resulted in releases and threatened releases to the <br />environment of hazardous substancL including lead and PCBs. <br />11. The Schnitzer Site was added to the Minnesota Permanent List of Priorities <br />("PLP ") in November, 1986. <br />12. In 1987, the Liquidating Trust for Schnitzer Iron & Metal Company ( "Liquidating <br />Trust ") entered into a Response Order by Consent with the MPCA ( "1987 Order"). Under the <br />1987 Order, the Liquidating Trust was required to complete an Investigation of the Schnitzer Site <br />to determine the extent and magnitude of Site contamination, conduct a Feasibility Study to <br />evaluate options which could be used in responding to the Site contamination, propose a <br />Response Action Plan for the selected response action(s) and implement the Response Action <br />Plan. <br />13. On August 31, 1987, the University of Minnesota and the Schnitzer Liquidating <br />Trust entered into a Purchase Agreement for the Schnitzer Site. The Liquidating Trust was <br />obligated under the Purchase Agreement to fully implement the requirements of the 1987 Order. <br />14. On September 24, 1991, the Schnitzer Site was added by the MPCA Board to the <br />MERLA Project List, enabling State Superfund monies to be expended at the Site: This action <br />Page 159 <br />