L.A. CLARKE & SON, INC. IS THE OWNER & OPERATOR OF A WOOD TREATING FACILITY IN FREDERICKSBURG, VA. DEF'S WHOLLY-OWNED SUBSIDIARY, SOUTHERN MARYLAND WOOD TREATING CORP., OWNS AND OPERATES A WOOD TREATING FACILITY IN HOLLYWOOD, MD. ON 12/12/82, EPA INITIATED A PRELIMINARY ASSESSMENT & SITE INSPECTION AT THAT SITE. THE SITE INSPECTION REVEALED THAT SEVERAL HAZARDOUS SUBSTANCES, POLLUTANTS & CONTAMINANTS ASSOCIATED W/WOOD TREATMENT OPERATION HAD BEEN RELEASED INTO THE SOIL, GROUNDWATER & SURFACE WATERS FROM THAT SITE. ON 3/11/83, DURING THE CONDUCT OF THE PRELIMINARY ASSESS- MENT & SITE INSPECTION AT THE SOUTHERN MD SITE, DEF FILED A, PETITION FOR REORGANIZATION UNDER CHAP 11. ON 3/23/83, EPA INITIATED A PRELIM. ASSESSMENT & SITE IN- SPECTION AT THE L.A. CLARKE SITE. THIS INSPECTION ALSO RE- VEALED THAT HIGH CONCENTRATION OF HAZARDOUS SUBSTANCES, POL- LUTANTS OR CONTAMINANTS COMMONLY ASSOCIATED W/WOOD TREATMENT HAD BEEN RELEASED FROM THE SITE INTO GROUNDWATER, SURFACE WATERS & SOILS. BOTH SITES HAVE BEEN INCLUDED ON THE NATIONAL PRIORITIES LIST. ON 10/25/84, EPA RECEIVED NOTIFICATION FROM L.A. CLARKE THAT EPA HAD BEEN ADDED TO THE SCHEDULE OF UNSECURED CREDI- TORS HAVING CLAIMS AGAINST L.A. CLARKE IN ITS REORGANIZATION PROCEEDING. BECAUSE THE SCHEDULE LISTED EPA'S CLAIM AS CONTINGENT & DISPUTED, IT WAS NECESSA