PRE-REFERRAL LITIGATION INVOLVES THE FILING OF A CIVIL ACTION TO SEEK RESPONSE COSTS AND INJUNCTIVE RELIEF PURSUANT TO SECTION 106, 107 AND 122 OR CERCLA. THE SUBJECT OF THIS ACTION IS THE NORTHSIDE LANDFILL IN SPOKANE, WA WHICH IS ON THE NATIONAL PRIORITY LIST. THE CITY OF SPOKANE HAS OWNED AND OPERATED NORTHSIDE LANDFILL FOR OVER FIFTY YEARS. THE CITY, AS A POTENTIALLY RESPONSIBLE PARTY, CONDUCTED A REMEDIAL INVESTIGATION AND FEASIBILITY STUDY OF THE NORTHSIDE LANDFILL SITE IN 11/88. EPA ISSUED A ROD ON 9/10/89, WHICH SET FORTH THE SELECTED REMEDIAL ACTION FOR THE SITE. THE CITY, STATE OF WASHINGTON DEPARTMENT OF ECOLOGY AND EPA EXECUTED A CONSENT DECREE, WHICH WAS LODGED AND ENTERED BY THE DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON.