THIS AGREEMENT AND COVENANT NOT TO SUE IS MADE AND ENTERED INTO BY AND BETWEEN THE EPA, DOI, DOJ ON BEHALF OF EPA AND DOI, THE STATE OF UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY AND L. CLAIR WILLIAMSEN, LARRY D. WILLIAMSEN, SHIRLEY WILLIAMSEN, SOUTHWEST INVESTMENT, AND WILTEC, L.C. IN CONSIDERATION OF AND IN EXCHANGE FOR THE UNITED STATES' AND THE STATE'S COVENANTS NOT TO SUE, THE SETTLING RESPONDENTS SHALL PAY TO EPA THE SUM OF $30,000 AND TO DOI THE SUM OF $4,000 WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THIS AGREEMENT.