UNDER THE PROPOSED CONSENT DECREE, TWO PRPS, SOL AND BETTY YOUNG, AGREE TO REIMBURSE THE UNITED STATES $625,000 IN PAST COSTS RELATING TO THE FIRST AND SECOND OPERABLE UNITS AT THE KELLOGG DEERING SUPERFUND SITE IN NORWALK, CT. IN RETURN, THE YOUNGS WILL RECEIVE A COVENANT NOT TO SUE FROM THE UNITED STATES WITH RESPECT TO PAST RESPONSE COSTS, AS DEFINED IN THE DECREE. THE YOUNGS ARE NOT RELEASED FOR THE PERFORMANCE OF THE SECOND OPERABLE UNIT REMEDY, WHICH IS CURRENTLY BEING PERFORMED BY PARTIES TO A PRIOR SEPARATE CONSENT DECREE.1 THIS LIMITATION OF THE COVENANT IS SIGNIFICANT BECAUSE THE PARTIES TO THE PRIOR SEPARATE CONSENT DECREE HAVE FILED A CONTRIBUTION ACTION AGAINST SOL AND BETTY YOUNG, AS WELL AS OTHER PARTIES. THE UNITED STATES TOOK CARE TO ENSURE THAT THIS SETTLEMENT WILL NOT TRAMMEL THE PRIOR SETTLER'S RIGHTS IN THAT ACTION. AS OF NOVEMBER, 1992, EPA'S TOTAL PAST COSTS AT THE SITE ARE $3,446,498. ADDITIONALLY, THE VALUE OF THE SECOND OPERABLE