THE SETTLEMENT AGREEMENT IN THIS BANKRUPTCY MATTER RELATES TO ENVIRONMENTAL LIABILITIES OF DEBTOR LYONDELL CHEMICAL COMPANY AND 93 OF ITS AFFILIATES (COLLECTIVELY, THE ``LYONDELL DEBTORS''). THE SETTLEMENT AGREEMENT RESOLVES CLAIMS OF THE ENVIRONMENTAL PROTECTION AGENCY (``EPA'') AGAINST CERTAIN LYONDELL DEBTORS FOR RESPONSE COSTS UNDER THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT (``CERCLA''), 42 U.S.C. 9601-9675, WITH RESPECT TO THE FOLLOWING REGION 5 SITES: (1) THE ALLIED PAPER/PORTAGE CREEK/KALAMAZOO RIVER SITE LOCATED IN MICHIGAN; AND (2) THE HEGELER ZINC SITE LOCATED IN ILLINOIS.