IN 1993, EPA FILED AN ADMINISTRATIVE COMPLAINT AGAINST SALINA INVESTMENT CO., INC. IN SALT LAKE CITY, UTAH, UNDER SUBTITLE I OF RCRA. WHILE THIS LITIGATION WAS PENDING, EPA LEARNED THAT SALINA AND SEVERAL RELATED ENTITIES, ALL OWNED AND OPERATED BY THE RICCI FAMILY, HAD FILED FOR BANKRUPTCY PROTECTION UNDER CHAPTER 11 OF THE BANKRUPTCY CODE. EPA IS CONCERNED THAT INSUFFICIENT MONEY WILL BE SET ASIDE IN THE BANKRUPTCY REORGANIZATION TO PERFORM NECESSARY EN- VIRONMENTAL CLEANUP AND COMPLY WITH REGULATORY REQUIREMENTS FOR USTS. IN THE EVENT THAT THE STATES IN WHICH THE FACILI- TIES ARE LOCATED ARE UNABLE TO PERFORM NECESSARY ENVIRON- MENTAL CLEANUP, THIS RESPONSIBILITY WILL DEVOLVE TO EPA. THEREFORE, EPA HAS REQUESTED THAT DOJ PURSUE A PROTECTIVE PROOF OF CLAIM TO ASSURE ADEQUATE FUNDS ARE AVAILABLE IN THE BANKRUPTCY FOR ENVIRONMENTAL COMPLIANCE.