UNDER THE CONSENT DECREE, THE SETTLING DEFENDANTS HAVE AGREED TO PAY $400,000.00 TO SETTLE THE UNITED STATES' CLAIM UNDER SECTION 107(a) FOR PAST RESPONSE COSTS IN CONNECTION WITH THE INDUSTRIAL LANE SUPERFUND SITE (SITE). THE PERFORMING SETTLING DEFENDANTS (CHRIN BROTHERS, INC, AND CHRIN OF DELAWARE, INC) HAVE ALSO AGREED TO PAY 100% OF EPA FUTURE RESPONSE COSTS RELATING TO THE SITE. IN ADDITION, THE OWNER SETTLING DEFENDANT (CHRIN BROTHERS, INC) HAS AGREED TO IMPLEMENT ANY INSTITUTIONAL CONTROLS THAT EPA DETERMINES ARE NEEDED AT THE SITE.