THIS IS A REFERRAL OF AN ACTION FOR THE FILING OF A PROOF OF CLAIM IN REGARDS TO CHEMICAL HANDLING CORPORATION FOR RESPONSE COSTS INCURRED BY EPA IN THE REMOVAL ACTION NECESSITATED BY RELEASES OF HAZARDOUS SUBSTANCES AT THE SITE AS WILL AS THE SUBSTANTIAL THREAT OF RELEASE CREATED BY CHEMICAL HANDLING'S WASTE HANDLING PRACTICES AND IT INSISTENCE ON CONTINUING TO OPERATE AT AN IMPROPERLY CONSTRUCTED FACILITY THAT WAS NOT ADEQUATELY PROTECTED FROM FIRE.