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evaluate the site conditions, to develop a conceptual remedy, and <br />to apportion the Debtor's financial liability. There is <br />currently no pending litigation with respect to any of the Four <br />Sites which might otherwise determine the Debtor's liability. <br />Contract With Remcor <br />11. To complete the necessary evaluation of the Four <br />Sites, the Debtor proposes to retain Remcor under the terms of <br />the agreement attached hereto as Exhibit A. <br />12. The following paragraphs in this section summarize <br />the agreement between the Debtor and Remcor (the "Agreement"). <br />The summary does not, of course, reflect all of the terms and <br />conditions of the Agreement but is only provided as an overview <br />for the convenience of parties in interest and the court. <br />13. The Agreement obligates Remcor to conduct <br />evaluations of the Four Sites described in the preceding section <br />with the basic objectives of (1) developing a comprehensive <br />understanding of the available data and site conditions, (2) <br />developing a remedial plan for each site which plan includes the <br />realistic activities already proposed by regulatory agencies as <br />well as Remcor's conceptual approach, and (3) calculating and <br />estimating an apportionment of costs for the Debtor at the Four <br />Sites. The scope of Remcor's obligations under the Agreement <br />with respect to site evaluation is set forth in the proposal (the <br />"Proposal") attached and made part of the Agreement. <br />9 <br />