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On December 29, 1986, Housewares bought a facility located in Antrim, New Hampshire from Strombeck Manufacturing Company.  Strombeck had purchased the facility from the Goodell Company, which had owned the site from 1875 to 1982.   Housewares manufactured knives at the site, but ceased using the site in 1989.

On May 18, 1993, the United States Environmental Protection Agency (EPA) advised Housewares that, in response to a citizen complaint, the Antrim site had been placed on the EPA’s inventory of known or potential hazardous waste disposal areas.  On July 19, 1993, the EPA, pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), notified Housewares that it was a potentially responsible party (PRP) with regard to the Antrim site.  The letter read in pertinent part:

“Unless a potentially responsible party (“PRP”) or parties commit to properly performing or financing [cleanup actions], EPA may perform these actions pursuant to Section 104 of CERCLA, 42 U.S.C. § 9604.

* * *

EPA has evaluated evidence gathered during investigations of the Site.  Based on this evidence, EPA has information indicating that you are a potentially responsible party under Section 107(a) of CERCLA with respect to the Site.  Specifically, EPA has reason to believe that General Housewares is the owner/operator of the Site.  By this letter, EPA notifies you [of] your potential liability and urges you to voluntarily perform or finance those response activities that EPA determines are necessary at the Site.”

Record at 328-329 (original emphasis).

On July 27, 1993, Housewares sent a letter to the EPA agreeing to voluntarily remedy the situation as per the PRP notice.  The next day, on July 28, 1993, Housewares began sampling, analyzing, and disposing of the contents of containers at the site.  On

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