EMERGENCY REMOVAL OF LEAD SOILS IN NOV-DEC OF 1985. RI COM- PLETED FS BEING DRAFTED ROD SIGNATURE DUE 9/30/88. PROPOSED RELIEF: THE REMEDY SOUGHT IS RECOVERY OF FUNDS EXPENDED PURSUANT TO SECT 104 OF CERCLA. RESOURSE REQUIREMENTS: THE REGION ANTICIPATES THAT EXTENSIVE NEGOTIATIONS, OR, IN THE ALTERNATIVE, A CIVIL TRIAL WILL BE NECESSARY TO RECOVER THE COSTS EXPENDED BY THE GOVERNMENT IN THIS MATTER. RECENT CONTACTS WITH PROPOSED DEFENDANTS: DEFENDANTS WHO RECEIVED SPECIAL NOTICE OF AN OPPORTUNITY TO CONDUCT OR FINANCE THE REMEDIAL ACTION SUBMITTED AN OFFER ON JANUARY 19, 1989. USEPA REJECTED THAT OFFER ON FEBRUARY 16, 1989. SINCE THEN, THE STEERING COMMITTEE AND A DE MINI- MIS COMMITTEE HAVE KEPT IN CONSTANT CONTACT WITH THE AGENCY; A DE MINIMIS OFFER WAS RECEIVED IN JUNE, 1989. LETTERS DE- MANDING REPAYMENT OF FUNDS EXPENDED BY U.S. EPA WERE ALSO SENT IN JUNE 1989. A SECOND DEMINIMUS OFFER, FOR ONE PRP LANCASTER METAL, WHOSE ASSETS ARE NOW PART OF THE ESTATE OF THE PRP'S DECEASED OWNER WAS RECEIVED IN 1989. BOTH DE MINIMUS PROPOSALS ARE CURRENTLY BEING EVALUATED BY EPA AND DOJ, 5/31/90. SIGNIFICANT NAT'L OR PRECEDENTIAL LEGAL OR FACTUAL ISSUES: SIGINFICANT ISSUES THAT MAY SET LEGAL PRECEDENT ARE: 1) WHETHER A USED BATTERY SOLD TO A BRO