LITIGATION PLAN: 11/18/82: HQ IS NOT ACTIVELY PARTICIPATING IN ON-GOING STATE/GENERATOR NEG'S. QUESTIONS ABOUT SITE ARE BEING RE- FERRED FROM HQ TO REGN. HQ WILL BECOME INVOLVED ONLY UPON RE QUEST OF STATE IF STTLMNT PROCEEDS AS AT PRESENT. RE: JUNE 8, 1989 REFERRAL THIS EXPEDITED REFERRAL REQUESTS THAT A COMPLIANT BE FILED AGAINST ADDITIONAL GENERATORS AT THE ENVIRONMENTAL CON SERVATION & CHEMICAL CORP SITE (ENVIROCHEM) PURSUANT TO SECT 107 OF CERCLA. THE ENVIROCHEM SUPERFUND SITE IS LOCATED NEAR ZIONSVILLE, INDIANA, AND IS LISTED ON THE NAT'L PRIORITIES LIST. IN 19 83, THE USEPA WORKED WITH YOUR OFFICE TO FILE SUIT, THEN EN- TER A PARTIAL CONSENT DECREE, UNDER CERCLA WITH APPROXIMATE LY 250 DEFENDANTS. USEPA IS CURRENTLY NEGOTIATING A FINAL CONSENT DECREE IN THE CASE. A NUMBER OF ADDITIONAL DEFENDANTS WERE SUBSEQUENTLY IDENTI FIED. IN 1988, THE USEPA WORKED WITH YOUR OFFICE TO FILE IT AGAINST A NUMBER OF THESE NEWLY DISCOVERED, POTENTIALLY RESPONSIBLE PARTIES (PRPS) WHO WERE UNWILLING TO SIGN A TOL- LING AGREEMENT, IN ORDER TO AVOID ANY STATUTE OF LIMITATIONS ARGUMENT THAT MIGHT HAVE ARISEN AFTER JULY 18, 1988. BY THEIR TERMS, HOWEVER, THE TOLLING AGREEMENTS (WHICH HAVE AL- READY BEEN EXTENDED ONCE) EXPIRE ON JUNE 30, 1989. USEPA, THEREFORE, SEEKS TO FILE AGAINST CERTA