THIS REFERRAL RECOMMENDS LITIGATION TO RECOVER APPROX. $360,000 SPENT BY EPA IN CONNECTION WITH A REMOVAL ACTION AT THE AEROLITE PLATING SITE IN RENO, NEVADA (THE SITE ). ON FEBRUARY 24, 1988, LOCAL AUTHORITIES RAIDED THE SITE SUSPECTING AEROLITE PLATING OF IMPROPER WASTEWATER DISCHARGES. THE METALS PLATING OPERATION HAD A LENGTHY HISTORY OF DISCHARGE VIOLATIONS. THE AUTHORITIES NOT ONLY CONFIRMED THEIR SUSPICIONS, BUT DISCOVERED OPERATING PRACTICES THAT POSED A CLEAR AND IMMINENT DANGER TO LIFE AND PROPERTY. THE CITY, THROUGH THE NEVADA DIVISION OF EMERGENCY MANAGEMENT, REQUESTED EPA'S ASSISTANCE IN POSSIBLE REMOVAL AND ENFORCEMENT ACTIONS. EPA FINALLY ASSUMED CONTROL OF SITE STABILIZATION AND COMPLETED CLEANUP WHEN THE SITE OWNERS/OPERATORS WERE UNABLE TO RESPOND ADEQUATELY. WE ARE REQUESTING THE DEPARTMENT OF JUSTICE (DOJ) TO FILE A COST RECOVERY ACTION AGAINST THESE OWNERS/OPERATORS PURSUANT TO SECTION 107(A) OF CERCLA, 42 U.S.C. 9607(A). CERTAIN OF THE PROPOSED DEFENDANTS IN SUCH AN ACTION ARE FACING FEDERAL CRIMINAL CHARGES RELATING TO THE OPERATION OF THE FACILITY. AS DISCUSSED MORE FULLY IN THE SECTION BELOW, WE REQUEST THAT DOJ REFRAIN FROM COMMENCING THE CIVIL ACTION OR CONTACTING THE PROPOSED DEFENDANTS PENDING FINAL RESOLUTION OF THE CRIMINAL MATTER.