THIS IS AN ACTION TO RECOVER PAST COSTS INCURRED BY EPA IN UNDERTAKING RESPONSE ACTIONS AT THE HELEN KRAMER LANDFILL SUPERFUND SITE LOCATED IN MANTUA TOWNSHIP, GLOUCESTER COUNTY NEW JERSEY. THE RESPONSE ACTIONS WHICH HAVE BEEN FUNDED BY EPA AT THE SITE INCLUDE THE REMEDIAL INVESTIGATION AND FEASIBILITY STUDY ( RI/FS ), THE REMEDIAL DESIGN ( RD ) AND THE REMEDIAL ACTION. THE SITE RANKS FOURTH ON THE NATIONAL PRIORITIES LIST. A RECORD OF DECISION ( ROD ) FOR THE SITE WAS ISSUED ON SEPTEMBER 27, 1985. THE REMEDIAL ACTION IS SCHEDULED TO COMMENCE IN THE FALL OF 1989. EPA SEEKS: RECOVERY OF ALL COSTS WHICH HAVE BEEN INCURRED BY EPA IN CONNECTION WITH THE SITE; AND A DECLARATORY JUDGMENT AS TO THE DEFENDANTS' LIABILITY FOR FUTURE EXPENSES TO BE INCURRED BY EPA IN CONNECTION WITH THE SITE. SINCE THE RI/FS IS A PRE-SARA RESPONSE ACTION, THE OCTOBER 17, 1986 DATE IS THE KEY MILESTONE FROM WHICH TO MEASURE THE EFFECT OF SECTION 113(G)(2) OF CERCLA, THREE YEARS STATUTE OF LIMITATIONS.