CIVIL REFERRAL TO INITIATE A COST RECOVERY ACTION PURSUANT TO SECTION 107(A) OF CERCLA TO RECOVER RESPONSE COSTS. THE SITE WAS A FAMILY-OPERATED, CO-DISPOSAL LANDFILL THAT OPERA- TED FROM APPROXIMATELY 1934 UNTIL 1990. SINCE 1982, U.S. EPA HAS INCURRED COSTS IN CONDUCTING RESPONSE ACTIONS AT THE SITE. U.S. EPA'S RESPONSE ACTIVITIES HAVE INCLUDED SAMPLING AND INVESTIGATING THE SITE TO ASSESS THE EXTENT OF CONTAMINA TION, OVERSIGHT OF THE POTENTIALLY RESPONSIBLE PARTIES' (PRPS) IMPLEMENTATION OF A UNILATERAL ADMINISTRATIVE ORDER ISSUED IN DECEMBER OF 1992, FOR CERTAIN RESPONSE ACTIVITIES, OVERSIGHT OF AN ADMINISTRATIVE ORDER ON CONSENT DATED MARCH 29, 1994, FOR THE REMEDIAL DESIGN AT THE SITE, AND ENFORCE- MENT ACTIVITIES INCLUDING NEGOTIATION OF A REMEDIAL ACTION CONSENT DECREE (RA DECREE). U.S. EPA HAS INCURRED APPROXI- MATELY $4,343,479 IN UNREIMBURSED RESPONSE COSTS THROUGH MAY 31, 2000. THE RA DECREE INCLUDES PAYMENT TO THE UNITED STATES OF APPROXIMATELY $1,941, 181, THEREFORE, U.S. EPA'S HAS APPROXIMATELY $2,402,298, IN UNREIMBURSED RESPONSE COSTS AT THE SITE. THE U.S. EPA PROPOSES NAMING ELEVEN DEFENDANTS IN THIS CASE. PLEASE BE AWARE THAT TWO OF THE PROPOSED DEFENDANTS HAVE REFUSED TO SIGN AN EXTENSION TO THE TOLLING AGREEMENT THAT IS CURRENTLY IN PLACE AND WHICH EXPIRES ON SEPTEMBER 30 2000. FOR THIS REASON, U.S. EPA REQUESTS THAT THE DEPART- MENT IMMEDIATELY FILE A COMPLAINT FO