THIS LITIGATION REFERRAL SEEKS TO RECOVER APPROXIMATELY THREE HUNDRED AND NINETY FOUR THOUSAND DOLLARS (394,000) FOR A REMOVAL ACTION INVOLVING PHENOLIC CAUSTIC (CONTAINING PHENOLS AND CRESOLS) ABANDONED IN TANKS AND CONTAINED IN SOILS ON A TWO-ACRE SITE IN WELLS, NEVADA. THE POTENTIALLY RESPONSIBLE PARTIES IDENTIFIED TO DATE INCLUDE THE OPERATORS AND THE GENERATOR AND VARIOUS PARENT AND RELATED CORPS. C. MICHAEL WILWERDING, ONE OF THE OPERATORS OF THE FACILITY SET UP A SHAM RECYCLING OPERATION IN A SMALL TOWN IN NEVADA. AS PART OF THIS SCHEME, ON BEHALF OF ONE OF HIS COMPANIES, WILWERDING ACQUIRED THOUSANDS OF GALLONS OF HIGHLY TOXIC SPENT PHENOLIC CAUSTIC FROM A REFINERY IN MONTANA, AND STORED IT IN SEVERAL HOLDING TANKS AT THE COMPANY'S NEVADA SITE. A SPILL OCCURRED AND, AFTER INEFFECTUAL ATTEMPTS TO CLEAN UP THE SPILL, POLY-CARB INC. ABANDONED THE SITE. THE GENERATOR, MONTANA REFINING COMPANY, HAD SENT TRUCK LOADS OF SPENT PHENOLIC CAUSTIC FROM ITS REFINERY TO WILWERDING'S COMPANY. THE GENERATO'S ACTIVITIES ARE A THINLY DISGUISED DISPOSAL OF THESE HIGHLY TOXIC SUBSTANCES. MOREOVER, THE GENERATOR HAS BEEN OPENLY DEFIANT OF ENVIRONMENTAL LAWS AND AUTHORITIES, REFUSING TO COMPLY WITH EPA'S SECTION 106 ORDER, REFUSING TO FULLY AND TRUTHFULLY RESPOND TO SECTION 104(E) REQUESTS, AND REFUSING TO EVEN DISCUSS EPA'S DEMAND LETTER.