WHITE CHEMICAL CORP. HAS BEEN IN CHAPTER 11 BANKRUPTCY SINCE SEPTEMBER, 1988. WHITE CHEMICAL CORP. OPERATES A CHEMICAL MANUFACTURING BUSINESS IN NEWARK, N.J. OVER 9000 IMPROPERLY STORED, RUPTURED AND/OR LEAKING DRUMS OF HAZARDOUS SUBSTANCES ARE ON SITE. AMONG THESE ARE EXTREMELY DANGEROUS AND VOLATILE CHEMICALS. ASTDR CONCLUDED THAT THE SITE PRESENTS A SERIOUS RISK, AND THE REGION DETERMINED THAT THE SITE PRESENTS A THREAT TO HUMAN HEALTH, WELFARE AND THE ENVIRONMENT. EPA REGION II DETERMINED THAT A REMOVAL ACTION SHOULD BE CARRIED OUT TO SECURE THE SITE AND MINIMIZE THESE RISKS. ON 9/28/90, THE REGION ISSUED AN ADMINISTRATIVE ORDER TO THE PROPOSED DEFENDANTS REQUIRING THAT ALL CHEMICAL MANU- FACTURING WORK OR OTHER ACTIVITIES AT THE FACILITY BE STOPPED AND THAT ALL PERSONNEL BE COMPLETELY EVACUATED FROM THE FACILITY IMMEDIATELY. THE ORDER ALSO REQUIRES AP- PROPRIATE SITE ACCESS FOR EPA AND ITS CONTRACTORS. THE ORDER, BY ITS TERMS, BECAME EFFECTIVE ON 10/2/90. ON 9/28/90, WE HAD REASON TO BELIEVE THAT THE ORDER WOULD NOT BE COMPILED WITH, SO A TELEPHONE REFERRAL OF THIS MATTER WAS MADE TO THE DOJ AND THE U.S. ATTORNEY'S OFFICE; EPA HEADQUARTERS WAS ALSO NOTIFIED. ON 10/1/90 IT BECAME CLEAR THAT THERE WOULD, INDEED, BE NO COMPLIANCE WITH THE AD- MINISTRATIVE ORDER. THE REGION IS REQUESTING THAT A TEMP- ORARY RESTRAINING ORDER BE SOUGHT AS S