THE PROPOSED ACTION IS THE FILING OF A PROOF OF CLAIM IN THE CHAPTER 11 BANKRUPTCY PROCEEDINGS FOR QUEBECOR WORLD (USA) INC. AND 53 RELATED ENTITIES( QUEBECOR ). HALLIDAY ITHOGRAPH CORPORATION IS ONE OF THE QUEBECOR ENTITES AND IS A POTENTIALLY RESPONSIBLE PARTY AT OPERABLE UNIT TWO OF THE PETERSON PURITAN SITE.