THE SITE CONSISTS OF THE VINELAND CHEMICAL CO. PLANT SITE; THE RIVER AREAS, INCLUDING THE BLACKWATER BRANCH, THE MAURICE RIVER BETWEEN THE BLACKWATER BRANCH AND UNION LAKE; AN 870-ACRE IMPOUNDMENT ON THE MAURICE RIVER, OWNED BY THE NJDEP. SIGNIFICANT ARSENIC CONTAMINATION OF THE GROUNDWATER, SOILS AND SEDIMENT AT THE SITE HAS BEEN DETECTED. THE CONTAMINATION POSES A SERIOUS ENVIRONMENTAL PROBLEM AND A HUMAN HEALTH RISK. EXTENSIVE INFORMATION HAS BEEN GATHERED REGARDING THE CONTAMINATION IN ALL THREE AREAS OF THE SITE IN THE REMEDIAL INVESTIGATION AND FEASIBILITY STUDY. A RECORD OF DECISION WAS SIGNED ON SEPTEMBER 28, 1989 BY EPA. THE PROPOSED DEFENDANTS IN THIS LITIGATION ARE MR. AND MRS. SCHWERDTLE, THE OWNERS AND OPERATORS, AND VINELAND CHEMICAL COMPANY, INC. EPA WILL SEND DEMAND LETTERS FOR RE- IMBURSEMENT OF PAST COSTS TO THE ABOVE LISTED PARTIES AFTER SEPTEMBER 29, 1989. MOREOVER, THE SCHWERDTLES HAVE FAILED TO CLOSE TWO IMPOUNDMENTS REGULATED UNDER RCRA WHICH ARE THE SUBJECT OF TWO FEDERAL COURT DECISIONS. THIS ACTION SEEKS RECOVERY OF ALL PAST COSTS INCURRED BY EPA IN CONNECTION WITH THE SITE, AS WELL AS INTEREST AND ALL COLLECTION COSTS. THE ACTION ALSO SEEKS A DECLARATORY JUDGMENT ESTABLISHING THE LIABILITY OF THE PROPOSED DEFENDANTS FOR ALL FUTURE COSTS WHICH EPA MAY INCUR WITH RESPECT TO THE SITE. THE CASE FOR PAST COSTS AND A DECLARATORY JUDGMENT IS BEING REFERRED FOR EXPEDITIOUS FILING SO THAT THE UNITED STATES WILL BE ABLE TO COLLECT SOME SMALL PORTION