PERONA BROTHERS, INC. (PERONA) OPERATED A JUNK YARD WHICH COMTAINED APPROXIMATELY FIVE MILLION TIRES, AN UNDETERMINED NUMBER OF AUTOMOBILES, TRUCKS AND OTHER DISCARDED DEBRIS, AS WELL AS DRUMS AND CYLINDERS OF UNKNOWN ORIGIN. ON 12/06/86, A FIRE OCCURRED, WHICH LASTED FOR FIVE DAYS AND SPREAD HAZ- ARDOUS SUBSTANCES AND MATERIALS ONTO THE SITE AND INTO THE GROUNDWATER. EPA PERFORMED A RESPONSE ACTION IN PROVIDING ASSISTANCE IN PUTTING OUT THE FIRE AND INCURRED COSTS IN TAKING THIS RESPONSE ACTION AT THE SITE. ON 06/29/89, THE NJDEP REQUESTED THAT EPA PERFORM A CERCLA REMOVAL ACTION TO REMOVE THE HAZARDOUS SUBSTANCES AND MATERIALS AT THE SITE WHICH RESULTED FROM THE DECEMBER 1986 FIRE. THIS CONTING- ENCY MAY INCUR ADDITIONAL RESPONSE COSTS FOR EPA IN THE FUTURE. ON OCTOBER 31, 1986, PERONA BROTHERS, INC. FILED A PETIT- ION FOR PROTECTION UNDER CHAPTER 11 (REGORANIZATION) OF THE UNITED STATES BANKRUPTCY CODE. THE TRUSTEE IN BANKRUPTCY, MR. JAMES CAIN, PETITIONED THE COURT FOR A CONVERSION OF THE PETITION TO A CHAPTER 7 (LIQUIDATION) ACTION, WHICH WAS GRANTED BY THE COURT ON 06/14/89. IN ORDER TO PROTECT ITS ABILITY TO RECOVER RESPONSE COSTS FROM THE POTENTIALLY RESPONSIBLE PARTY (PRP), EPA MUST FILE A PROOF OF CLAIM WITH THE BANKRUPTCY COURT PRIOR TO OCTOBER 18, 1989, THE BAR DATE. THIS REFERRAL TO THE UNITED STATES DEPARTMENT OF JUSTICE (DOJ) IS SUBMITTED TO SUPPORT