REFERENCE A91-0589-CIV, REFERRAL REQUESTS DOJ SIMULTANEOUSLY FILE AN AMENDED COMPLAINT IN THIS MATTER, ADD A SECTION 106 CLAIM AND LODGE RD/RA CONSENT DECREE NEGOTIATED WITH ALL DEFENDANTS, EXCEPT MONTGOMERY WARD. UNDER THE CD, THE SETTLING DEFENDANTS AGREE TO PERFORM CLEANUP WORK VALUED AT APPROXIMATELY $6 MILLION REQUIRED BY THE RECORD OF DECISION, PERFORM LONG-TERM O & M , AND REIMBURSE THE U.S. ALL OF ITS FUTURE RESPONSE COSTS. MONTGOMERY WARD DID NOT ENTER INTO THE SETTLEMENT DUE TO ITS RECENT BANKRUPTCY. EPA AGREED TO COMPROMISE APPROXIMATELY $53,000 OF ITS FUTURE OVERSIGHT COSTS TO OFFSET A PORTION OF THE SHORTFALL CAUSED BY MONTGOMERY WARD'S BANKRUPTCY. A PREVIOUS PAST COST CONSENT DECREE WAS ENTERED BY THE U.S. DISTRICT COURT FOR THE DISTRICT OF ALASKA UNDER WHICH THE U.S. RECOVERED PAST RESPONSE COSTS INCURRED AT THE SITE. (SEE DOCKET N