EPA ALLEGES THAT THE SETTLING PARTIES, JOHN W. DADMUN AND HAROLD M. KNOWLTON, ARE RESPONSIBLE
PARTIES, AND ARE LIABLE FOR RESPONSE COSTS INCURRED OR TO BE INCURRED AT OR IN CONNECTION WITH THE SITE. EPA HAS DETERMINED THAT THE TOTAL PAST AND PROJECTED RESPONSE COSTS OF THE UNITED STATES AT OR IN CONNECTION WITH THE SITE WILL NOT EXCEED $500,000, EXCLUDING INTEREST. WITHIN 30 DAYS OF THE EFFECTIVE DATE, 10/24/2003, OF THIS AGREEMENT, SETTLING PARTIES SHALL PAY TO EPA $65,580.05. IF SETTLING PARTIES FAIL TO MAKE THE PAYMENT BY THE REQUIRED DUE DATE, INTEREST SHALL ACCRUE ON THE UNPAID BALANCE THROUGH THE DATE OF PAYMENT. SETTLING PARTIES SHALL BE IN VIOLATION OF THIS AGREEMENT AND SHALL PAY TO EPA, AS A STIPULATED PENALTY, IN ADDITION TO THE INTEREST, $1,000 PER DAY THAT SUCH PAYMENT IS LATE. IF SETTLING PARTIES FAIL OR REFUSE TO COMPLY WITH THE REQUIREMENTS OF THIS AGREEMENT, THEY SHALL BE SUBJECT TO ENFORCEMENT ACTION AND SHALL REIMBURSE THE UNITED STATES FOR ALL COSTS OF SUCH ACTION, INCLUDING BUT NOT LIMITED TO COSTS OF ATTORNEY TIME.