1) Solutia has filed for bankruptcy and there are three sites at which Solutia, or its corporate predecessor Monsanto Company, may be liable for costs or may share in cleanup obligations. The first two sites (Bayonne Barrel and Drum Superfund Site and Diamond Alkali Superfund Site -- Lower Passaic River Study Area) are CERCLA sites, and the third site is a RCRA corrective action site (Solutia Delaware River Plant). 2) EPA seeks to file a proof of claim in Solutia's bankruptcy proceeding to protect its potential claims against Solutia at these three sites. The violation type shown above (closure and post-closure requirements) is related to the RCRA claims. EPA Region 2 included claims for two CERCLA sites, and one RCRA site, in a referral to HQ to be added to a national referral from HQ to DOJ. 2) DOJ filed a proof of claim for EPA that included claims for multiple regions, including, for Region 2, the two CERCLA sites (Bayonne Barrel and Drum Superfund Site and Diamond Alkali Superfund Site -- Lower Passaic River Study Area) and a protective contingent claim for the RCRA corrective action site (Solutia Delaware River Plant). 3) Solutia entered into a settlement agreement with Monsanto Company, which is not one of the debtors in the bankruptcy, whereby Monsanto affirmed its responsibility for the CERCLA sites, instead of Solutia, and Solutia affirmed its continuing responsibility for the RCRA site. The US was not a party to this settlement agreement. The bankruptcy