STATUTES WHICH ARE THE BASIS FOR THE PROPOSED ACTION: SECT 104A1, A2, C1 AND SECT 107 OF CERCLA, 42 USC SECTS 9601 ET SEQ. PROPOSED RELIEF: THE RELIEF SOUGHT IS THE ENTRY OF JUDGMENT AGAINST THE DE- FENDANTS IN FAVOR OF THE UNITED FOR ALL RESPONSE COSTS INCUR RED AT AND IN CONJUNCTION WITH THE RESPONSE ACTIVITIES AT THE ACME SOLVENT RECLAIMING, INC. SITE ALONG WITH INTEREST. ALSO, WE SEEK ATTORNEY'S FEES AND COSTS AND A DECLARATORY JUDGMENT ON LIABILITY FOR RESPONSE COSTS OR DAMAGES WHICH THE U.S. MAY INCUR IN THE FUTURE. RECENT CONTACTS WITH DEFENDANTS: LETTERS DEMANDING REIMBURSEMENT FOR FUNDS EXPENDED BY U.S. EPA IN RESPONSE TO THE RELEASE AT THE ACME SITE WERE SENT TO THE DEFENDANTS ON JUNE, 1989. THEY WERE GIVEN THIRTY (30) DAYS IN WHICH TO NOTIFY USE WHETHER THEY INTENDED TO REIM- BURSE THE USEPA. TO DATE WE HAVE NOT HEARD FROM ANY OF THE RECIPIENTS. SIGNIFICANT NAT'L OR PRECEDENTIAL LEGAL/FACTUAL ISSUES: UNIQUE TO THOIS CASE IS THE AGENCY'S EFFORT TO RECOVER COSTS FOR OVERSIGHT OF A SUPPLEMENTAL SITE ASSESSMENT NECES- SITATED BY THE PRP GROUP'S UNAUTHORIZED REMOVAL OF CONTAMI- NATED SOIL. AN ARGUMENT MAY BE FASHIONED THAT BECAUSE USEPA DID NOTHING TO STOP THE UNAUTHORIZED REMOVAL, ALL COSTS WHICH ARISE DIRECTLY FROM THE REMOVAL A