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The Site property covers approximately 7 acres and the facility primarily consists of a building that was constructed in 1954, with expansions to the building in 1967 and 1970, and two former wastewater lagoons located in the western portion of the property.  GLCC owned and operated the Facility from 1954 to October 2000, when Dow Chemical acquired GLCC.  Dow has entered into a Voluntary Corrective Action Agreement with EPA to finish corrective action at the Site under RCRA authority.  Dismantling of the facility by Dow began in 2001 and concluded in 2002.  GLCC operated latex and polyurethane plants that included storage tanks, agitators, mixers and vulcanizers for the production of liquid latex and polyurethane products.  The key raw chemicals included natural latex, neoprene, isoprene GRS 2000 type latex, trichlorofluoromethane (Freon) toluene diisocyanate (TDI), which was replaced in the mid-1980’s with methyl diphenyl diisocyanate (MDI) and polymeric diphenyl methane diisocyanate.  When operations ceased in 2001, unused raw materials and products were shipped to retailers and to other GLCC facilities.  The equipment was removed from the property by February 2002.  Currently, the property is vacant.  During operations the lagoons were used for the disposal of facility wastewater.  From 1954 to 1975, the lagoons received untreated wastewater and from 1975 to 1981, the lagoons received only treated wastewater while coagulated solid waste was sent offsite to a sanitary landfill.  From February 1981 to operational shutdown (2001), the City of Ashland sanitary sewer system received all treated wastewater.  After wastewater discharge to the lagoons ceased, the northern lagoon and a portion of the southern lagoon were backfilled and leveled over an extended period of time.  During operations seven accidental releases of raw chemicals occurred.  The chemicals released include TDI, natural latex, Freon, ammonia latex, and polymeric MDI.  The cleanup activities began immediately and releases were reported to the proper authorities within the Ohio EPA. Accidental discharge reports were prepared and submitted to the Ohio EPA, as necessary.  The cleanup activities included cleaning up the remaining chemicals on the ground surface and excavation of contaminated soil, as needed.  Dow has been conducting investigations at the facility since 2001.  GLCC was regulated under RCRA as a generator of hazardous waste, and investigations and reports were completed in accordance with the Ohio EPA Voluntary Action Program (VAP).  Activities conducted included investigations to support the preparation of a phase II property investigation report (including a phase I property investigation report); soil and groundwater fate and transport modeling; remedial action planning and remediation (soil); and quarterly groundwater monitoring from December 2004 to December 2006.