THIS IS AN ACTION TO RECOVER THE COSTS INCURRED BY EPA IN TAKING RESPONSE ACTIONS AT THE ROBINTECH, INC./NATIONAL PIPE CO. SITE (THE SITE ), AND ASSOCIATED ADMINISTRATIVE, EN- FORCEMENT AND INDIRECT COSTS. THE RESPONSE ACTIONS THAT HAVE BEEN TAKEN BY EPA AT THE SITE INCLUDE THE PREPARATION OF A WORKPLAN FOR A REMEDIAL INVESTIGATION AND FEASIBILITY STUDY ( RI/FS ) OF THE SITE, AND PRELIMINARY FIELD INVESTI- GATIONS AIMED AT FACILITATING THE PREPARATION OF THE RI/FS WORKPLAN. THE SITE IS ON THE NATIONAL PRIORITIES LIST. RE- IMBURSEMENT IS SOUGHT FROM FIVE POTENTIALLY RESPONSIBLE PARTIES WHO ARE PAST AND/OR PRESENT OWNERS AND/OR OPERATORS OF THE SITE, FOR PURPOSES OF SECTIONS 107(A)(1) & 107(A)(2) OF CERCLA, 42 U.S.C. 9607(A)(1), 9607(A)(2). RECOVERY IS SOUGHT OF ALL DIRECT AND INDIRECT COSTS IN- CURRED BY EPA IN CONNECTION WITH THE SITE AS OF OCTOBER 7, 1987, AS WELL AS PREJUDGEMENT INTEREST AND THE GOVERNMENT'S LITIGATION COSTS. A REQUEST FOR A DECLARATORY JUDGMENT AS TO FUTURE LIABILITY SHOULD ALSO BE CONSIDERED. A DEMAND LETTER WAS SENT TO THE DEFENDANTS ON AUGUST 29, '88. THE DEFENDANTS RESPONDED TO THIS LETTER BY INDICATING THAT THEY ARE NOT WILLING TO REIMBURSE EPA FOR THE COSTS IT HAD INCURRED WITH RESPECT TO THE SITE AS OF OCTOBER 7, 1987. * FACILITY NAME: NATIONAL PIPE COMPANY (