RAYTECH PLACED ITSELF IN VOLUNTARY CHAPTER 11 BANKRUPTCY IN MARCH 1989. IN 1990, THE UNITED STATES FILED A PROOF OF CLAIM IN THE RAYTECH BANKRUPTCY ON BEHALF OF EPA IN THE AMOUNT OF $12.5 MILLION. THE PROOF OF CLAIM ASSERTS THAT THE UNITED STATES IS ENTITLED TO RECOVER FROM RAYTECH, AS SUCCESSOR-IN-INTEREST TO RAYMARK, RCRA CIVIL PENALTIES FOR VIOLATIONS AT THE RAYMARK INDUSTRIES, INC. FACILITY IN STRATFORD, CT. THE PURPOSE OF THE PROPOSED AMENDED CLAIM IS TO FULLY SET FORTH THE UNITED STATES CLAIMS WHICH NOW INCLUDE RESPONSE COSTS THAT THE EPA AND THE DEPARTMENT OF JUSTICE HAVE INCURRED PURSUANT TO THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT ( CERCLA ), RCRA PENALTIES FROM A 1991 CIVIL ACTION AND NATURAL RESOURCE DAMAGES UNDER THE TRUSTEESIP OF THE U.S. DEPARTMENT OF INTERIOR ( DOI ), THE NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION ( NOAA ). THE PROPOSED AMENDED PROOF OF CLAIM WILL INCLUDE RCRA CIVIL PENALTIES AT THE RAYMARK INDUSTRIES SUPERFUND SITE IN STRATFORD, CT ( THE STRATFORD SITE ), PAST AND FUTURE RESPONSE COSTS INCURRED BY EPA-NEW ENGLAND AND DOJ AT THE STRATFORD SITE, DAMAGES FOR ALL INJURY TO, DESTRUCTION OF, OR LOSS OF NATURAL RESOURCES UNDER THE TRUSTEESHIP OF DOI AND NOAA RESULTING FROM THE RELEASE OF HAZARDOUS SUBSTANCES AT THE STRATFORD SITE, PAST AND FUTURE RESPONSE COSTS INCURRED BY EPA-NEW ENGLAND IN RESPONDING TO OTHER RAYMARK CONTAMINATED SUPERF