1. SECTION 122(H)(1) OF THE COMPREHENSIVE ENVIRONMENTAL RE- SPONSE, COMPENSATION AND LIABILITY ACT OF 1980, AS AMEND- ED ( CERCLA ), 42 U.S.C. SECTION 6922(H)(1). 2. ANTIFREEZE INC. SUPERFUND SITE 702 STANSBURY LANE AND 600 HENRY STREET ABBEVILLE, VERMILION PARISH, LOUISIANA 70510 RESPONDENTS: MICHAEL KENNETH STANSBURY AND ANDRE C. STANSBURY 3. IN RESPONSE TO THE RLEASE OR THREATENED RELEASE OF HAZ- ARDOUS SUBSTANCES AT OR FROM THE SITE, EPA UNDERTOOK RE- SPONSE ACTIONS AT THE SITE. IN PERFORMING THIS RESPONSE ACTION, EPA INCURRED RESPONSE COSTS AT OR IN CONNECTION WITH THE SITE. EPA ALLEGES THAT THE SETTLING PARTIES ARE RESPONSIBLE PARTIES AND ARE JOINTLY AND SEVERALLY LIABLE FOR RESPONSE COSTS INCURRED AT OR IN CONNECTION WITH THE SITE. 4. RELIEF SOUGHT PURSUANT TO SECTION 122(H)(1) OF CERCLA, EPA AND THE SETTLING PARTIES AGREE THAT THE PARTIES SHALL AN AMOUNT OF $21,000 IN REIMBURSEMENT OF PAST RESPONSE COSTS, 755 OF THE NET SALES PROCEEDS OF THE TRANSFER OF THE PROPERTY, AND 90% OF THE NET INSURANCE PROCEEDS.