SETTLEMENT RESOLVES THE GOVERNMENT'S CLAIMS FOR PAST AND FUTURE COST, NATURAL RESOURCE DAMAGES, AND PENALTIES FOR VIOLATION OF A UNILATERAL ADMINISTRATIVE ORDER. IN ADDITION, THIS SETTLEMENT REQUIRES THE SETTLING DEFENDANTS TO COMPLETE THE REMEDIAL ACTION, INCLUDING OPERATION AND MAINTENANCE, AT THE SITE. FINALLY, THIS SETTLEMENT RESOLVES OUTSTANDING DEFENSIVE LITIGATION RELATED TO THIS SITE.