THIS IS A PROPOSED ACTION AGAINST CORNELL-DUBILIER ELECTRONICS (CDE), JEFFERSON-PILOT INVESTMENTS, INC., AND THE CITY OF SANFORD, N.C. UNDER SECTION 107 OF CERCLA TO RECOVER PAST COST INCURRED UNDER SECTION 104. THIS CASE INVOLVES THE CDE SITE, LOCATED IN SANFORD, N.C. THE SITE WAS OPERATED BY CDE FROM 1953 UNTIL 1983 AS A MANUFACTURING FACILITY. PILOT LIFE INSURANCE, JEFFERSON- PILOT INVESTMENT'S PARENT CORP, OWNED THE SITE FROM 1954 UNTIL 1986. IN 1986 TITLE TRANSFERRED TO JEFFERSON-PILOT. IN 1987, JEFFERSON-PILOT GAVE THE PROPERTY TO THE CITY OF SANFORD, THE CURRENT OWNER. THE SITE WAS INVESTIGATED IN OCTOBER 1987. ADMINISTRA- TIVE ORDERS WERE ISSUED TO CORNELL-DUBILIER AND JEFFERSON- PILOT ON MARCH 4, 1988; A NOTICE LETTER WAS SENT TO THE CITY THE SAME DATE. THE REMOVAL ACTION TOOK PLACE BETWEEN JULY 18 AND AUGUST 2, 1988. SOILS CONTAMINATED W/VOLATILE AND SEMI- VOLATILE ORGANICS, INCLUDING TRICHLOROETHYLENE AND ACETONE, WERE EXCAVATED AND DISPOSED OF AT A RCRA-APPROVED FACILITY. TOTAL FEDERAL GOVERNMENT COSTS AS OF 3/21/89 ARE APPROXI- MATELY $428,000.00. A DEMAND LETTER WAS SENT ALL THREE PRPS ON 03/08/89. THE STATUTE OF LIMITATIONS MAY RUN ON 08/02/91.