NATURE OF THE CASE: THIS PROPOSED COST RECOVERY CASE CONCERNS THE GREINER'S LAGOONS SITE LOCATED OUTSIDE OF THE CITY OF FREMONT IN SAN- DUSKY COUNTY, OHIO. THE SITE OPERATED AS AN INDUSTRIAL CHEM ICAL WASTE RECEIVER BETWEEN 1954 AND 1970. DURING THIS PERI OD, THE OPERATORS TOOK LIQUID WASTES FROM SEVERAL LOCAL IN- DUSTRIES AND PUT THEM INTO A SERIES OF LAGOONS CONSTRUCTED ON THE SITE. THE OPERATION CEASED IN 1970, AFTER WILD ANI- MAL KILLS AND COMPLAINTS OF NEIGHBORS BROUGHT THE OPERATION TO THE ATTENTION OF THE LOCAL AUTHORITIES. AFTER HEAVY RAINS, HAZARDOUS SUBSTANCES, INCLUDING PCBS, LEAKED INTO A DRAINAGE DITCH CONNECTING EVENTUALLY TO THE RIVER THAT SERVES AS THE LOCAL DRINKING WATER SUPPLY. IN MAY OF 1986, EPA INITIATED A TWO-DAY REMOVAL ACTION TO RE- PAIR THE LAGOON DIKE AT THE SITE. IN AUGUST 1987, EPA FOUND THAT THE NEAR OVERFLOW OF CONTAMINATION FROM THE SITE POSED A SERIOUS THREAT TO HUMAN HEALTH AND THE ENVIRONMENT. THE USEPA INITIATED A REMOVAL ACTION TO DEWATER, CAP AND GRADE THE LAGOON AREA WHICH WAS COMPLETED ON JUNE 10, 1988. CAUSE OF ACTION: USEPA SEEKS THE RECOVERY OF APPROXIMATELY $750,000 EXPEND ED AT THE SITE PURSUANT TO SECT 107 OF CERCLA, 42 USC SECT 9607. THE RECOMMENDED DEFENDANTS INCLUDE THE FOUR GENERA- TORS OF HAZARDOUS SUBSTANCES TO THE SITE. THE STATUTE OF LI MITATIONS FOR REMOVAL ACTIONS COULD EX