ON 12/4/86, EPA REG. II SENT A MEMO TO HQ REQUESTING THE FILING OF A PROOF OF CLAIM BY 12/12/86 TO PRESERVE THE GOV- ERNMENT'S RIGHT TO SEEK RECOVERY OF COSTS FROM THE AMERICAN THERMOSTAT CORP. OF APPROXIMATELY $20,000 WHICH HAVE BEEN INCURRED, ADD'L COSTS WHICH HAVE BEEN INCURRED BUT HAVE NOT BEEN DOCUMENTED, & ADD'L COSTS WHICH ARE INCURRED. THESE COSTS HAVE BEEN OR WILL BE INCURRED BY THE GOV'T AS PART OF A REMOVAL ACTION AUTHORIZED ON 8/19/85 OR THE EXTENSION OF Q THE REMOVAL ACTION WHICH AUTHORIZED THE EXPENDITURE OF $141,000 ON 8/25/86. PURSUANT TO SECT. 104 OF CERCLA, THE EPA, THROUGH THE HAZARDOUS SUBSTANCES TRUST FUND, UNDERTOOK & WILL UNDERTAKE INVESTIGATIVE, REMOVAL AND REMEDIAL WORK AT THE FACILITY WHICH WAS OWNED AND OPERATED BY THE DEBTOR, AMERICAN THERMOSTAT CORP. SECT. 107 OF CERCLA & OTHER AUTHORITIES PROVIDE THAT THE DEBTOR, AS THE OWNER OR OPERATOR AT THE TIME OF DISPOSAL OF CONTAMINANTS, INCLUDING HAZARDOUS SUB- STANCES, AT THE SITE IS LIABLE TO THE U.S. FOR THE COSTS OF THE INVESTIGATIVE, REMOVAL AND REMEDIAL WORK. THIS CLAIM MAY BE FILED AS A PRIORITY CLAIM ON THE BASIS THAT THE MONIES EXPENDED ARE ADMINISTRATIVE COSTS PRESERVING THE ESTATE. ALTERNATIVELY, THE CLAIM MAY BE FILED AS A GENERAL UNSECURED CLAIM. AMERICAN THERMOSTAT IS LIABLE UNDER CERCLA BASED UPON THE FOLLOWING. IN 1965 THE OFFICERS OF AM