THIS IS A REFERRAL (LITIGATION REPORT) UNDER SECTIONS 106 AND 107 OF THE COMPREHENSIVE ENVIRONMENTAL, RESPONSE AND LIABILITY ACT OF 1980, AS AMMENDED BY THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986, PUB. L. NO. 99-499, ( CERCLA ), 42 U.S.C. SECTIONS 9606 AND 9607 FOR RECOUPMENT OF COSTS INCURRED IN CONNECTION WITH RESPONSE MEASURES UNDERTAKEN AT THE A.I.W. FRANK SUPERFUND SITE ( SITE ) IN EXTON, WEST WHITELAND TOWNSHIP, CHESTER COUNTY, PENSYLVANIA AND CERTAIN INJUNCTIVE RELIEF. THE U.S. ENVIRONMENTAL PROTECTION AGENCY ( EPA ) ADDITIONALLY SEEKS A DECLARATORY JUDGMENT UNDER SECTION 113(G)(2) OF CERCLA, 41 U.S.C. SECTION 9613(G)(2), AND 28 U.S.C. SECTION 2201 FOR LIABILITY FOR FUTURE COSTS TO BE INCURRED AT THE SITE AND FOR INJUNCTIVE RELIEF TO IMPLEMENT PROTIONS OF THE RECORD OF DECISION WHICH WAS ISSUED ON SEPTEMBER 29, 1995, A PROPOSED REMEDIAL ACTION PLAN ( PROPOSED PLAN ) WAS RELEASED FOR PUBLIC COMMENT ON JUNE 16, 1995. THE PUBLIC COMMENT PERIOD OPENED ON JUNE 16, 1995 AND CLOSED ON AUGUST 15, 1995.