NATURE OF THE CASE: THIS REFERRAL REQUESTS THAT A CIVIL ACTION BE FILED PURSUANT TO SECTION 107 OF CERCLA AND SEC- TION 7003(A) OR RCRA FOR REIMBURSEMENT OF IMMEDIATE REMOVAL COSTS INCURRED IN TWICE RESPONDING TO THE RELEASE OF HAZAR- DOUS SUBSTANCES AT THE SWAINSBORO PRINT WORKS SITE IN SWAINSBORO, GA. IN 1984. THE POTENTIAL DEFENDANTS INCLUDE THE COMPANY WHICH LENT MONEY TO SWAINSBORO PRINT WORKS AND ALLEGEDLY PARTICIPATED IN ITS MANAGEMENT; THIS COMPANY IS FLEET FACTORS (AND HEREAFTER REFERRED TO AS AMBASSADOR). A SECOND CORPORATE DEFENDANT IS NIX RIGGING AND MILLWRIGHT CO. A RIGGER HIRED TO HELP CLEAN OUT THE SPW PLANT. ALSO, FOUR INDIVIDUALS HAVE BEEN NAMED - CLIFFORD GREENSIDE, EXECUTIVE VICE PRESIDENT OF AMBASSADOR; CARL NIX, OF NIX RIGGING; CLIFFORD HOROWITZ, FORMER OWNER AND PRESIDENT OF SPW; AND MURRAY NEWTON, FORMER OWNER AND VICE PRESIDENT OF SPW. THE SWAINSBORO PRINT WORKS (SPW> SITE IS AN INACTIVE, BANKRUPT CLOTH PRINTING FACILITY LOCATED ON APPROXIMATELY 10 ACRES IN SWAINSBORO, GA. WHEN OPERATED, THE PLANT BLEACHED UNFINISHED CLOTH, AND THEN FINISHED, WASHED AND PRINTED APPROXIMATELY 80,000 LBS OF CLOTH PER DAY. IMPORTANT ISSUES OF NATIONAL OR PRECEDENTIAL IMPACT: THE CASE INVOLVES TWO ISSUES OF IMPORTANCE. THE FIRST IS THE SCOPE OF THE OWNER OR OPERATOR EXCLUSION IN THE DEFINITION OF OWNER OF OPERATOR. THE ISSUE IS WHETHER AMBASSADOR SO PARTICIPATED IN THE MANAGEMENT OF SPW