THIS IS A CIVIL REFERRAL SEEKING REIMBURSEMENT OF COSTS INCURRED BY EPA BETWEEN 1986 AND 1989 IN CONDUCTING A REMOVAL ACTION AT THE GENERAL REFINING SITE, A SEDOIL RE- REFINERY WHICH CEASED DOING BUSINESS IN 1978. USED OIL FROM A VARIETY OF SOURCES WAS BROUGHT TO THE SITE IN GENERAL REFINING TRICKS AND PROCESSED. THE PROCESS RESULTED IN THE CREATION OF AN ACIDED OILY SLUDGE CONTAMINATED WITH LEAD, CHROMIUM, CADMIUM AND PCBS. THE SLUDGE WAS DISPOSED OF ON- SITE IN VALLINED LAPOONS. IN 1988 EPA DETERMINED THAT RE- LEASE OF HAZARDOUS SUBSTANCES HAD OCCURRED AND FURTHER RELEASES WERE POSSIBLE IF IMMEDIATE RESPONSES ACTION WAS NOT TAKEN. THE SITE WAS NOT FENCED AND WAY EASILY ACCESSIBLE. GROUNDWATER AND SOILS WERE THREATENED WITH CONTAMINATION. IN 1986 EPA INITIATED A REMOVAL ACTION WHICH CONSISTED OF REMOVING AND TREATING THE SLUDGES AND LIQUIDS FROM THE LAGOON, AND TREATING CONTAMINATED SOILS. THE RESULTING SOLIDS REMAINING AFTER THE TREATMENT PROCESS WERE SOLIDIFIED AND BURNED ON SITE. A SOIL COVER WAS PLACED OVER THE SOLIDIFIED MATERIAL. EPA HAS IDENTIFIED GENERATOR FROM SITE RECORDS AND HAS SENT DEMAND LETTERS TO 59 PRPS. THE LETTERS REQUEST THE PRPS TO REIMBURSE EPA FOR AT LEAST $2.75MILLION IN COSTS EPA INCURRED. IN OCTOBER 1988, EPA ISSUED AN UNILATERAL CERCLA SECTION 106 ADMINISTRATIVE ORDER TO 24 PRPS ORDERING THEM TO CONDUCT PHASE 2 OF THE REMOVAL