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17. Thc terms of the EPA SeWement Agreement arc set forth in Ncir entirety in Exhibit 1 and should be reviewed in detail, however, the more salient pointy tie summarired u follows: a. Subject to cuuin wnditions precedent, Rtorganired CFAeI shall pay b the EPA the sum of Two Million Two Hundred Thousand Dollars (f2,200,000); b. Upon receipt by she EPA of Two Million Two Hundred Thousand Dollar (f2,200,000), the United States acknowledges full salisfaztion of, and releases and waives all claims wish respect lo, the United Su W' Allowed Roebling Claim Against CF8r1, releases and waives VI claims That the United Sates hss or may have to the remainder of the Insurance Settlement Proceeds, waives and releases any right m assert claims against txnain proceeds of sale of assert after the Effective Dam of the Confirmed Plan, and acknowledges That is hlcd no additional claims against the Debtors, except Ne United Stites' Allowed Roebling Claim Against CFdrI, which is being fully satisfied, and the 29th and Mad CLtim against Kansas Metals, which was disallowed and estimated at f0. c. The EPA wnxnn to settlements between CF&I and the Insurance Companies of the Coverage Action and will not object Io such settlements nor to a provision in certain of the underlying _y setUemenl agreements and in the Bankruptcy Coon's older approving me setdemenrs, baiting any and all claims brought or Thar could be brought by the PPA against certain of the Insurance Companies arising out of or based on Undulying Claims. In Ameri~n Emolpyers' Ins. Co. v. Kine Resources Co .556 F.2d 471, 475 (10th Cir. 1977) the Tenth Circuit Court of Appeals approved a sera factor test enumerated by the Uisl wort in wnnection wiN the settlement of litigation under the Bankruptcy Act. In Reiss v. Harms-"n, 881 FZd. 890, 891 (IOtlr Cir. 1989) a e-rse under the Bankruptcy Codt, the Twth Circuit acknowledged the ten factor lest of the Kine Resources Co. wse u wnuolling in wnnalion with the approval of a sUUemwt and wmpromise under the Bankruptcy Code, however, the Tenth Circuit in Reiss v. Naemann (waled particularly on the issue of the likelihood of suttess and the upected expense and delay eased by Iitiga0onr. Other of the ten facmn wuncialed in the Kine R N ~ ~• o ease Thal would arguable apply to the proposed EPA Setlement Agreement include the number of parties That object to the setlemenl, the wmpuency and experience of wunsel who support the sUllemenl and the extent to which Ue settlement is Wly the product of arms length bargaining. A bankruptcy wart's approval of a wmpromise may be disturbed only when it rBenuse the case wu a very large, wmplex rase involving a seWement that was put together over a period in ucess of two years and involved some forty (40) distinct represenntive groups or panirs holding sharp, antagonistic and wn0icting interests, several of the tw (10) factors enumerated tie not appliable to many settlemwn, including the proposed EPA Settlement Agreement. _g.