06/15/94: DURING SETTLEMENT NEGOTIATIONS, DEFENDANTS HAVE CLAIMED AN INABILITY TO PAY THE $45,000 RCRA PENALTY. WHILE ANALYZING THE SMITH'S CLAIM, THE REGION HAD DISCOVERED THAT THE DEFENDANTS HAD TRANSFERRED CERTAIN PROPERTIES TO FAMILY MEMBERS. THE REGION HAS DEVELOPED EVIDENCE THAT THESE TRANSFERS WERE MADE TO AVOID PAYING ANY PENALTY. THIS REFERRAL IS FOR FRAUDULENT CONVEYANCE.