THIS REFERRAL REQUESTS THAT THE DEPARTMENT OF JUSTICE FILE A PROOF OF CLAIM ( POC ) ON BEHALF OF THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ( EPA ) IN A CONSOLIDATED BANKRUPTCY MATTER PENDING IN THE NORTHERN DISTRICT OF CALIFORNIA. EPA IS SEEKING TO RECOVER RESPONSE COSTS INCURRED BY EPA AT THE SONOMA GEOTHERMAL WELL SUPERFUND SITE ( SGW SITE ), LOCATED IN A REMOTE LOCATION IN NORTHERN SONOMA AND SOUTHERN MENDOCINE COUNTIES, CALIFORNIA. ON OR ABOUT MAY 23, 1997, THE TRUSTEE FILED A NOTICE OF TRUSTEE'S INTENT TO ABANDON REAL PROPERTY, ( NOTICE ) SEEKING THE PERMISSION OF THE BANKRUPTCY COURT TO ABANDON ALL OF THE BANKRUPTCY ESTATE'S RIGHT, TITLE, AND INTEREST IN THE APPROXIMATELY 1100 ACRES OF REAL PROPERTY THAT COMPRISE THE SGW SITE. TO AVOID POTENTIALLY COMPLICATED LITIGATION, THE UNITED STATES, THE STATE OF CALIFORNIA, AND THE TRUSTEE REACHED AN AGREEMENT IN PRINCPLE WHEREBY THE TRUSTEE WILL PERMIT THE UNITED STATES (AND IN ALL LIKELIHOOD THE STATE OF CALIFORNIA) TO FILE A LATE POC FOR AN ADMINISTRATIVE CLAIM WITHOUT OBJECTION AND THEREAFTER PAY TO TH E UNITED STATES AND THE STATE OF CALIFORNIA, IN EQUAL SHARES, ALL FUNDS REMAINING IN THE ESTATE AFTER PAYMENT OF THE TRUSTEE'S FEES AND EXPENSES (ESTIMATED TO BE APPROXIMATELY $100,000 - $120,000). THE DEBTOR WAS A FORMER GEOTHERMAL