THIS REFERRAL IS A REQUEST TO FILE A CROSS-CLAIM AGAINST NACELLE LAND & MANAGEMENT CORP. ( NACELLE ) AND LAKE UNDERGROUND STORAGE CORP. ( LAKE ) IN THE CAPTIONED LAKE COUNTY TREASURER V. PARCELS OF LAND, CASE NUMBER 1:97CV1894, ND OHIO. AN IN REM ACTION WAS FILED IN STATE CO URT ON 1/8/97 BY THE LAKE COUNTY TREASURER AGAINST PARCELS OF LAND IN PAINESVILLE, OHIO, TO FORECLOSE LIENS AND SEIZE PROPERTY FOR DELINQUENT LAND TAXES. ON 6/20/97 THE LAKE COUNTY TREASURER ADDED EPA AS A DEFENDANT IN THE CASE DUE TO THE NOTICE OF FEDERAL LIEN UNDER CERCLA THAT REGION 5 FILED WITH THE LAKE COUNTY RECORDER OF DEEDS 4/28/97. DOJ REMOVED THIS CASE TO THE US DISTRICT COURT FOR THE NORTHERN DIS- TRICT OF OHIO ON 7/21/97 ON BEHALF OF USEPA. THE CROSS- CLAIM INCLUDES 2 COUNTS: 1) A COST RECOVERY CLAIM AGAINST LAKE AND NACELLE, AND 2) AN ALLEGATION THAT LAKE AND NACELLE ARE ALTER EGOS FOR EACH OTHER AND OF JOSEPH G. BERICK, AND A REQUEST THAT THE COURT DECLARE NACELLE'S LIEN ON THE PROPERTY NULL AND VOID AND THAT THE CERCLA LIEN BE FIRST PRIORITY AFTER THE COUNTY'S TAX LIEN. IN MAY, 1996, USEPA COMPLETED A PHASED REMOVAL ACTION PURSUANT TO CERCLA AT THE LAKE SITE. THE REMOVAL INCLUDED AMONG OTHER THINGS, CHARACTERIZING AND DISPOSING OF HAZARDOUS SUBSTANCES INCLUDING MERCAPTAN, AN INDICATOR CHEMICAL WHICH PROVIDES THE SMELL TYPICAL OF COMMERCIAL GAS, AND PCBS. USEPA HAS INCURRED A