SUBJECT OF PRESENT CASE IS AN OPERABLE UNIT WHERE A CON- SENT DECREE IS CURRENTLY BEING NEGOTIATED FOR THE CLEANUP OF PAINT SLUDGE. ADDITIONALLY, IS A LARGER CASE ENCOMPANING THE SPIEGELBERG LANDFILL AND THE ADJACENT RASMUSSEN DUMP SITE. A DRAFT RI WAS JUST COMPLETED 3/15/88. THE SPIEGELBERG SITE IS LOCATED IN GREEN OAK TWNSHP IN LIVINGSTON COUNTY, MICHIGAN. THE OPERABLE UNIT OCCUPIES APPROX. 1/2 ACRE OF THE SITE AND CONSISTS OF A GRAVEL PIT IN WHICH A VARIETY OF WASTES WERE DISPOSED OF FROM APPROX 1966 UNTIL. SOME OF THIS WASTE CONSISTED OF WASTE PAINT MATE- RIALS FROM FORD'S WAYNE TRUCK PLANT. FOLLOWING THE LISTING OF THE SITE ON NATIONAL PRIORITIES IST IN DECEMBER 1982 AND BASED ON INFORMATION COLLECTED DURING A PHASED FEASIBILITY STUDY, A SOURCE CONTROL REMEDIAL ACTION WAS SELECTED FOR THE SPIEGELBERG OPERABLE UNIT IN A RECORD OF DECISION SIGNED BY THE REGIONAL ADMINISTRATOR ON SEPTEMBER 30, 1986. FOLLOWING AN EXTENDED PERIOD OF NEGOTIA TIONS, AN AGREEMENT WAS REACHED TO CONDUCT A REMEDIAL ACTION WHICH WAS CONSIDERED ACCEPTABLE TO FORD, THE STATE OF MICHIGAN AND THE UNITED STATES. THE CONSENT DECREE ALSO CALLS FOR FORD TO REIMBURSE U.S. EPA FOR ALL COSTS INCURRED AT THE SITE PRIOR TO JANUARY 1, 1987, WHICH ARE NOT INCON- SISTENT WITH THE NATIONAL CONTINGENCY PLAN. THE AUTHORITY FOR FILING A COMPLAINT