THE LANDFILL COMPRISES UNIT TWO OF THE IRON HORSE PART SUPER FUND SITE ( THE IHP SITE ). THE IHP SITE CONSISTS OF APPROX- IMATELY 553 ACRES OF LAND IN NORTH BILLERICA, MASSACHUSETTS, NEAR THE TEWKSBURY TOWN LINE. THE IHP SITE, AN ACTIVE INDUSTRIAL COMPLEX AND RAIL YARD IN USE SINCE 1913, HAS A LONG HISTORY OF ACTIVITIES THAT HAVE RESULTED IN CONTAMINA- TION OF SOILS, GROUNDWATER AND SURFACE WATER. THE IHP SITE INCLUDES OPEN STORAGE AREAS, LANDFILLS, AND LAGOONS. THIS ACTION IS FOR COST RECOVERY UNDER CERCLA SECTION 107(A) 42 U.S.C. SECTION 9670(A), FOR RECOVERY OF COSTS INCURRED BY THE UNITED STATES. THE CLAIMS FOR PENALTIES FOR THE VIOLATION OF THE UAO ARE UNDER CERCLA SECTION 106(B), AND THE CLAIMS FOR PUNITIVE DAMAGES ARE UNDER CERCLA SECTION 107(C)(3). THE PROPOSED SUIT SEEKS RECOVERY OF $2.9 MILLION FOR PAST COSTS ASSOCIATED WITH THE SHAFFER LANDFILL OPERABLE UNIT OF THE IRON HORSE PARK SUPERFUND SITE. THE UNITED STATES MUST FILE A COST RECOVERY SUIT FOR THESE COSTS BY NOV. 21, 1994 OR BE FACED WITH POSSIBLE STATUTE OF LIMITATIONS PROBLEMS IN RECOVERING PART OF THESE COSTS. FURTHERMORE, SOME OF THE PRPS DID NOT SIGN RELATED ROLLING AGREEMENTS AND THEREFORE MAY NOT BE LIABLE FOR COSTS INCURRED PRIOR TO JANUARY 15, 19 91. HOWEVER, ALL PRPS ARE ELIGIBLE FOR COST RECOVERY OF COSTS INCURRED AFTER JANUARY 15, 1991.