THE SETTLING PARTIES ARE JOHNS MANVILLE ( JM ) AND COMMONWEALTH EDISON ( COM ED )
HEREINAFTER REFERRED TO AS RESPONDENTS. UNDER THE TERMS OF THE AOC, THE RESPONDENTS
HAVE AGREED TO: A) CONDUCT AN ENGINEERING EVALUATION COST ANALYSIS STUDY ( EECA ) OF
THE SOUTHWESTERN SITE AREA; B) CONDUCT EPA'S SELECTED REMOVAL ACTION IN AN ACTION
MEMORANDUM OR OTHER DECISION DOCUMENT AFTER PUBLIC COMMENT ON THE EECA; C)
REIMBURSE 100% OF EPA'S PAST COSTS AT THE SOUTHWESTERN SITE AREA INCLUDING SITES 3, 4, 5
AND 6; AND D) REIMBURSE FUTURE RESPONSE COSTS INCLUDING THE COSTS OF OVERSEEING THE WORK
AT THE SOUTHWESTERN SITE AREA. THE AOC WILL BECOME EFFECTIVE THREE DAYS AFTER U.S. EPA
SIGNS THE AOC.