ON AUGUST 24, 1993, OTIS LAMB T/A CULPEPER RECYCLING COMPANY FILED FOR A VOLUNTRAY PETITION FOR RELIEF UNDER CHAPTER 13 OF THE BANKRUPTCY CODE. BY ORDER OF THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF VIRGINIA DATED AUGUST 25, 1991, THE COURT SET A BAR DATE OF DECEMBER 22, 1993 FOR FILING PROOFS OF CLAIM. THE EPA INCURRED PRE-PETITION CERCLA RESPONSE COSTS FOR RESPONSE ACTIVITIES CONDUCTED, AND TO BE CONDUCTED AT THE C&R BATTERY CO INC SITE ( C&R ) IN CHESTERFIELD COUNTY, VIRGINIA IN THE AMOUNT OF APPROXIMATELY $2,370,298.37 (THROUGH JULY 6, 1993). THE RESPONSE COSTS RELATING TO ACTIVITIES CONDUCTED, AND TO BE CONDUCTED AT C&R INCLUDE ACTIVITIES UNDERTAKEN PURSUANT TO A 1986 REMOVAL ACTION, THE REMEDIAL INVESTIGATION AND FEASIBILITY SUTDY ( RI/FS ) REPORT ISSUED MARCH 30, 1990; THE CERCLA SECTION 106 UNILATERAL ADMINISTRATIVE ORDER AND REMEDIAL ACTION ( UAO ) ISSUED MARCH 27, 1992; AND OVERSIGHT OF THE CONDUCT OF THE REMEDIAL ACTION. THE AMENDED CIVIL LITIGATION REPORT BEING SENT TO DOJ FOR THE C&R BATTERY CO., INC. SITE IS REQUIRED BECAUSE 1) EPA NEEDS TO FORMALLY REFER THE DE MINIMIS PORTION OF THE CASE TO DOJ WHICH WE DIDN'T DO IN THE 9/30/93 REFERRAL; 2) ADDITIONAL INFORMATION ON SOME OF THOSE DE MINIMIS PARTIES NEEDS TO BE PROVIDED TO DOJ; A