THIS REFERRAL IS FOR DOJ TO FILE A PROOF OF CLAIM IN THE BANKRUPTCY ACTION PRIOR TO THE BAR DATE OF APRIL 8, 1991. EPA NEEDS TO PRESERVE ITS CLAIM FOR THE PENALTY AMOUNT. DOJ ALSO NEEDS TO ENFORCE THE CA/CO FOR COMPLETION OF THE RCRA CLOSURE ACTIVITIES. TRIGGS TRAILER CORPORATION ENTERED INTO A CONSENT AGREEMENT AND CONSENT ORDER (CA/CO) WITH EPA IN JUNE, 1989. THE CA/CO REQUIRED PAYMENT OF $15,000 IN PENALTY OVER FOUR YEARS. THE CA/CO ALSO REQUIRED RCRA CLOSURE OF HAZARDOUS WASTE MANAGMENT UNITS (HWMU) OPERATED BY TRIGGS TRAILER IN BELMOND AND KANAWHA, IOWA. THE CA/CO WAS ALSO SIGNED BY DENNIS TRIGGS, THE PRESIDENT OF TRIGGS TRAILER IN HIS INDIVIDUAL CAPACITY AS AN OWNER/OPERATOR OF THE RCRA FACILITIES. TRIGGS TRAILER FAILED TO MAKE TIMELY PENALTY PAYMENTS AND FAILED TO COMPLETE CLOSURE OF THE HWMUS. IN NOVEMBER 1990, TRIGGS TAILER FILED A BANKRUPTCY PETITION UNDER CHAPTER 11 FOR CORPORATE REORGANIZATION. THE REFERRAL IS TO DOJ TO PRESERVE OUR CLAIM FOR THE PENALTY AND TO SEEK COMPLETION OF THE RCRA CLOSURE ACTIVITIES.