THIS PRE-REFERRAL LITIGATION REPORT PREPARED IN ANTICIPATION OF THECOMMENCEMENT OF RD/RA NEGOTIATIONS RELATED TO THE REILLY TAR & CHEMICALSUPERFUND SITE, WHICH IS LOCATED IN INDIANAPOLIS, IN. THE REPORT INCLUDES A SUMMARY OF THE SITE HISTORU AND DISCUSSES ANTICIPATED LITIGATION ISSUES. THE REPORT WAS JOINTLY PREPARED BY THE REGION 5 ORC OF THE USEPA AND THE WASTE MANAGEMENT DIVISION. SUPPORTINGDOCUMENTATION ENCLOSED WITH THE REPORT INCLUDES: THE ROD FOR OPERABLE UNIT ONE, A FACT SHEET PRESENTING EPA'S PROPOSED PLAN FOR OPERABLE UNIT ONE, THE RI/FS CONSENT ORDER, COMMENTS FROM REILLY TAR ON EPA'S PROPOSED PLAN FOR OPERABLE UNIT ONE, TABLES FROM THE FFS SUMMARIZING REMEDIAL TECHNOLOGIES, AN UPDATED, ITEMIZED COST DOCUMENTATION SUMMARY, THE DRAFTRD/RA CONSENT DECREE AND THE DRAFT RD/RA SCOPE OF WORK.