1 - STATUTES AND REGULATIONS: 42 USC SECT 9607. 3 - CERCLA VIOLATIONS: A) FAILURE TO COMPLY WITH A SECT 106 ORDER; B) FAILURE TO REIMBURSE THE U.S. FOR RESPONSE COST INCURRED AT THE PBM ENTERPRISES FACILITY. 4 - PROPOSED RELIEF: A) DIST COURT ORDER ASSESSING PENAL- TIES FOR NON-COMPLIANCE WITH A 106 ORDER; B) REIMBURSEMENT OF OVER $8 HUNDRED THOUSAND IN RESPONSE COST TO THE U.S. 5 - ADMINISTRATIVE HISTORY AND RECENT CONTACTS: ON APRIL 11, 1985, USEPA COMMENCED A REMOVAL ACTION AT THE PBM ENTER- PRISES FACILITY. USEPA ISSUED A DEMAND LETTER TO THE DEFEN- DANTS ON OR ABOUT DECEMBER 28, 1985. 6 - SIGNIFICANT ISSUES: STATUTE OF LIMITATIONS MAY APPLY, IF THE COMPLAINT IS NOT FILED BY OCTOBER 8, 1988. 7 _ DATE OF ACTION WHICH LED TO REFERRAL: DEFENDANTS RE- FUSED TO COMPLY WITH THE SECT 106 ORDER - APRIL 11, 1985. DEFENDANTS REFUSED TO COMPLY WITH THE DEMAND LETTER ISSUED ON OR ABOUR DECEMBER 28, 1985. 8 - SIGNIFICANT ASPECTS OF THIS CASE: STRONG EQUITABLE AR GUMENTS CAN BE BROUGHT TO BEAR BY MR. MATAKAS, MR. MATAKAS IS A CONSTITUENT OF CONGRESSMAN DINGLE. THE DATA SHEET AND LITIGATION REPORTS, REFER A RECOMMENDA- TION FOR FILING OF A CIVIL ACTION UNDER SECT 107 OF CERCLA AS AMENDED BY THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986, AGAINST WILLIAM & PHILLIPA MATAKAS AS OWNER OF THE PBM FACILITY, AND PBM ENTERPRISES