THIS IS A REFERRAL FOR COST RECOVERY UNDER CERCLA AND FOR NONCOMPLIANCE WITH A 106 UNILATERAL ORDER. THE REFERRAL SEEKS 106(B) CIVIL PENALTIES AND 107(C)(3) PUNITIVE DAMAGES. THE COMPLAINT WILL LIKELY NOT BE FILED FOR 2-3 MONTHS. THERE WAS A PREVIOUS CASE FILED AGAINST THESE PARTIES THAT WAS DISMISSED ON 8/22/94.