ON DECEMBER 23, 1997, WE REQUESTED DOJ FILE A REMEDIAL ACTION CD WITH THE DISTRICT COURT FOR THE DISTRICT OF OREGON. THE CONSENT DECREE WOULD REQUIRED SETTLING DEFENDANTS TO IMPLEMENT THE REMEDIAL ACTION SELECTED FOR THE GOULD SITE. THESE ACTIONS INCLUDE EXCAVATION OF CONTAMINATED SOILS, SEDIMENTS AND OTHER WASTES AND PLACEMENTS OF THE WATES IN A RCRA-TYPE LANDFILL THAT WILL BE CONSTRUCTED ON-SITE. IN ADDITION THE OWNER SETTLING DEFENDANTS WILL BE REQUIRED TO PROVIDE THE EPA WITH AN EASEMENT AND RESTRICTIVE COVENANTS THAT WILL ALLOW EPA CONTINUED ACCESS TO THE SITE AND ENSURE THAT FUTURE LAND USES WITHIN THE SITE ARE CONSISTENT WITH THE REMEDY. EPA ESTIMATES THAT IT WILL COST THE SETTLING DEFENDANTS $16 MILLION TO IMPLEMENT THE REMEDY. THE CONSENT DECREE WILL ALSO REQUIRE THE SETTLING DEFENDANTS TO REINBURSE EPA FOR FUTURE RESPONSE COSTS IN EXCESS OF $100,000. THE CONSENT DECREE REQUIRES EPA TO FORGIVE PAYMENT OF $355,301 IN PAST RESPONSE COSTS AND $100,000 IN FUTURE RESPONSE COSTS. EPA FORGAVE $272,000 BASED ON ITS EVALUATION OF THE SITE'S ORPHAN SHRE. THE REMAINDER OF THE COST RECOVERY COMPROMISE IF BASED ON LITIGATION RISK.