THIS CONSENT AGREEMENT SHALL CONSTITUTE FULL SETTLEMENT OF THE VIOLATIONS ALLEGED IN THE SIX NOVS ISSUED TO THE BUREAU OF INDIAN AFFAIRS - ABERDEEN AREA OFFICE ON 8/13/1992, 9/4/1992, 9/19/1994, 7/31/1995, 9/14/1995, AND 1/23/1996. THIS CONSENT AGREEMENT APPLIES ONLY TO THE NOVS CITED AND DOES NOT PERTAIN TO ANY OTHER COMPLIANCE ISSUES. THIS ORDER IS SUBJECT TO THE 22 RULE WHICH IS ENTERED INTO BY THE PARTIES FOR THE PURPOSE OF SIMULTANEOUSLY COMMENCING AND CONCLUDING THIS MATTER. THE RESPONDENT SHALL PAY A CIVIL PENALTY IN THE AMOUNT OF $93,383 DUE 90 DAYS AFTER THE EFFECTIVE DATE OF THE CONSENT ORDER. RESPONDENT SHALL ALSO PERFORM A SEP WHICH THE PARTIES AGREE ARE INTENDED TO SECURE AND PROMOTE ENVIRONMENTAL OR PUBLIC HEALTH PROTECTION AND IMPROVEMENTS IN INDIAN COUNTRY WITHIN THE BIA GREAT PLAINS REGION (FORMERLY KNOWN AS THE ABERDEEN AREA). THE TOTAL EXPENDITURE OF THE SEP SHALL BE NOT LESS THAN $425,410. YEARS FROM THE EFFECTIVE DATE OF THE CONSENT ORDER.