Proposed Cost Recovery Settlement Agreement Between the United States of America and Paramount Global Pursuant to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as Amended; In Re: Wells G&H Superfund Site, Operable Unit 4, in Woburn, Massachusetts

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The U.S. Environmental Protection Agency ("EPA"), Region 1, hereby provides notice of a proposed settlement agreement ("Agreement"), under section 122(h)(1) of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended ("CERCLA"), between EPA and Paramount Global ("Settling Party"), regarding Operable Unit 4 ("OU4") of the Wells G&H Superfund Site, in Woburn, Massachusetts. The proposed Agreement resolves the matter at EPA Region 1 CERCLA Docket No. 01-2024-0051, pursuant to CERCLA section 122(h)(1) and the authority of the Attorney General of the United States to compromise and settle claims of the United States. The proposed Agreement requires Settling Party to make a $120,000 payment to EPA in partial reimbursement of response costs incurred in connection with an ongoing remedial action at OU4, in accordance with the Record of Decision issued by EPA on September 29, 2017. In return for this payment, the Agreement provides Settling Party with a covenant by EPA not to sue or take administrative action, pursuant to sections 106 or 107(a) of CERCLA, for performance of remedial work or recovery of response costs relating to OU4, subject to standard reservat