THIS DOCUMENT PRESENTS REGION V'S ANALYSIS, UNDER THE INERIM CERCLA SETTLEMENT POLICY, OF THE PROPOSED RD/RA CONSENT DECREE AND SEPARATE ADMINISTRATIVE DE MINIMIS SETTLEMENT RESOLVING CLAIMS AGAINST A NUMBER OF PRPS AT THE SUMMIT NATIONAL NPL FACILITY IN DEERFIELD, OHIO. THE REMEDIAL WORK TO BE PERFORMED BY THE SETTLING DEFENDANTS UNDER THIS CON- SENT DECREE WILL COST APPROXIMATELY $32.4 MILLION, INCLUDING OPERATION AND MAINTENANCE. FOR THE REASONS SET FORTH IN THIS SETTLEMENT BE ADOPTED. WE BELIEVE THE RESOLUTION IN- CORPORATED IN THIS SETTLEMENT PACKAGE IS FAVORABLE TO THE U.S. EPA. THE OVERALL SETTLEMENT IS EMBODIED IN THE ACCOM- PANYING CONSENT DECREE AND ITS ATTACHMENTS, WHICH IS PROPOS- ED UNDER SECTION 122(F) OF CERCLA AND ARE INCLUDED AS APPEN- DIX A. ALSO FORWARDED FOR FINAL APPROVAL ARE THE TWO VER- SIONS OF THE DE MINIMIS ADMINISTRATIVE ORDER ON CONSENT. ON APPROVAL BY YOUR OFFICE OF THE DE MINIMIS SETTLEMENTS, THE REGIONAL ADMINISTRATOR WILL EXECUTE THE ORDERS WHICH WILL THEN BECOME EFFECTIVE. - BECAUSE THIS SETTLEMENT RAISES ISSUES WITH SOME POTENTIAL NATIONAL INTEREST, AND BECAUSE THE SCOPE OF THE COVENANT NOT TO SUE IN THE RD/RA CONSENT DECERR INCLUDES RELIEF BEYOND SECTIONS 104, 106 AND 107 OF CERCLA AND SECTION 7003 OF RCRA, HEADQUARTERS CONCURRENCE IS BEING SOUGHT. -