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notified the company of existing and potential environmental <br />problems at the Roeblinq Steel Company site. The Debtor is a <br />past owner and operator at the Roeblinq site and sold the <br />property in 1974. The United States Environmental Protection <br />Agency ("EPA") has taken over the lead agency role in this <br />matter. On October 29, 1987, the EPA notified the Company that <br />the EPA intended to conduct removal action. In December, 1987, <br />EPA officials authorized such initial cleanup activities for up <br />to $1,000,000. The Company understands that the EPA completed <br />its initial cleanup activities in November, 1988 at a cost of <br />approximately $2,000,000. Additional site remedial cleanup was <br />approved by EPA in 1990 at an estimated cost of approximately <br />$5 million, including fencing, excavation of certain areas, and <br />the removal and off-site treatment of remaining drums, tanks, <br />transformers, chemical piles and tires. After undertaking <br />further studies of the site, including groundwater monitoring <br />studies, EPA issued a Proposed Plan in July, 1991 to cover the <br />slag disposal area at an estimated cost of $12 million. The <br />Company is presently unable to determine the full extent of <br />remedial requirements or to what extent it will be required to <br />participate. The claims made against the Debtor on account of <br />the Roeblinq Site are as follows: <br />a. United States Environmental Protection Agency <br />filed a claim against the Debtor in the amount of $23,177,800 <br />representing costs relating to response actions at the Roeblinq <br />3 <br />