EPA IS FORWARDING THIS PRE-REFERRAL NEGOTIATION CIVIL LITIGATION REPORT TO INITIATE/CONTINUE NEGOTIATIONS BETWEEN BETHLEHEM STEEL CORPORATION ( BSC ), THE STATE OF MARYLAND, AND THE UNITED STATES TO RESOLVE A PROPOSED CIVIL ACTION PURSUANT TO SECTIONS 3008(H) AND 7003 OF THE RESOURCE CONSERVATION AND RECOVERY ACT, AS AMENDED ( RCRA ), 42 U.S.C. SECTION 6928(H) AND 6973, TO ADDRESS RELEASES OF SOLID AND/OR HAZARDOUS WASTE AT BSC'S MAJOR INTEGRATED STEEL FACILITY IN SPARROWS POINT, MARYLAND ON THE PATAPSCO RIVER FACILITY ). THE ACTION PROPOSED IS FOR INJUNCTIVE RELIEF UNDER SECTIONS 3008(H) AND 7003 OF RCRA, 42 U.S.C. SECTION 6928(H) AND 6973, AGAINST BETHLEHEM STEEL CORPORATION. UNDER THE TERMS OF THE CONSENT DECREE TO RESOLVE THE PROPOSED ACTION, BSC WOULD BE REQUIRED TO 1) CONDUCT A RCRA FACILITY INVESTIGATION TO DETERMINE THE NATURE AND EXTENT OF HAZARDOUS WASTE RELEASES/CONTAMINATION AT THE FACILITY; 2) PERFORM A CORRECTIVE MEASURE STUDY TO EVALUATE REMEDIAL ALTERNATIVES TO ADDRESS/REMEDIATE SUCH RELEASES/ CONTAMINATION; 3) IMPLEMENT INTERIM MEASURES TO ABATE, MITIGATE, OR STABILIZE RELEASES/CONTAMINATION AT THE FACILITY; 4) IMPLEMENT THE CORRECTIVE MEASURES SELECTED TO REMEDY THE CONTAMINATION AT THE FACILITY; AND 5) IMPLEMENT ACTIVITIES TO MINIMIZE OR PREVENT THE AMOUNT OF HAZARDOUS WASTE GENERATED AT THE FACILITY. THE STATE OF MARYLAND WILL ALSO BE IMPOSING CORRECTIVE ACTION REQUIREMENTS ON BSC FOR NUMEROUS AREAS AT THE FACILITY. THE CONSE