THE COMPLAINT SEEKS PAST RESPONSE COSTS AND A DECLARATORY JUDGMENT FINDING CCA LIABLE FOR FUTURE RESPONSE COSTS INCUR RED BY THE USEPA AT THE MIAMI COUNTY INCINERATOR AND LAND- FILL LOCATED IN MIAMI COUNTY, OH. ( SITE ). THE MIAMI COUNTY SITE WAS PLACED ON THE NATIONAL PRIORI- TIES LIST IN 1984. EPA HAS INCURRED RESPONSE COSTS, THROUGH OCTOBER 29, 1990, OF APPROXIMATELY $2.8 MILLION IN UNREIMBURSED RESPONSE COSTS. FUTURE RESPONSE COSTS ARE EXPECTED TO BE IN EXCESS OF $800,000. PURSUANT TO SECT 113G OF CERCLA AN ACTION FOR RECOVERY OF COSTS REFERRED TO IN SECT 107A OF CERCLA MUST BE COMMENCED WITHIN THREE YEARS AFTER COMPLETION OF THE REMOVAL ACTION. USEPA THEREFORE REQUEST THAT A COST RECOVERY LAWSUIT SEEKING ALL OF USEPA'S UNREIMBURSED PAST COSTS BE FILED ON OR BEFORE FEBRUARY 22, 1992, IN ORDER TO AVOID A STATUTE OF LIMITA- TIONS BAR. THE CIVIL REFERRAL REQUESTS THAT A COMPLAINT BE FILED AGAI NST CONTAINER CORPORATION OF AMERICA, PURSUANT TO SECTION 10 4E OF THE CERCLA. THE COMPLAINT SEEKS TO COMPEL ANSWER TO A 1989 INFORMATION REQUEST AND SEEKS PENALTIES FOR CCA'S FAIL URE TO COMPLY WITH THE INFORMATION REQUEST, PURSUANT TO SECT ION 104E CERCLA. EPA SENT CCA THE INFORMATION REQUEST IN RE LATION TO ACTIVITY FOR THE MIAMI COUNTY INCINERATORS AND LAN DFILL SITE LOCATED IN MIAMI COUNTY, OH