2014 DUTY TO DEFEND SETTLEMENT AGREEMENT AND PARTIAL RELEASE
This Duty to Defend Settlement Agreement And Partial Release (the "Defense 
Agreement") is entered into by and between the Port of Seattle ("the Port of Seattle") and Great 
American Insurance Company and Great American Insurance Company of New York, formerly 
known as American National Fire Insurance Company (collectively "the Great American 
Companies") as of the Effective Date (as defined in Section II.D. of this Defense Agreement).
I.      RECITALS
A.   Numerous Environmental Actions (as defined in Section II.A. of this Defense 
Agreement)  have been asserted  against  the Port of Seattle  arising  out of the alleged 
contamination  of  land,  groundwater,  and  sediments  at  or  adjacent  to  certain  sites  in 
Washington.
B.   The Port of Seattle alleges that the Great American Companies issued certain 
insurance policies to the Port providing general liability coverage. The Port contends that the 
Great American Companies owe a duty to defend the Port of Seattle under these policies.
The list of the Great American Companies' insurance policies, upon which the Port of Seattle 
currently claims a duty to defend the Environmental Actions (hereafter, the "Policies"), is 
attached hereto as Exhibit A and incorporated by this reference.
C.   The Port of Seattle and the Great American Companies entered into a Duty to 
Defend Settlement Agreement and Partial Release on or about February 12, 1997 (hereafter, the 
"1997 Agreement"), resolving certain alleged defense obligations. In the 1997 Agreement, the 
Great American Companies agreed to defend the Port of Seattle with respect to environmental 
actions identified in that agreement, subject to a reservation of rights to challenge their ultimate 
obligation to indemnify the Port of Seattle.
D.   In the 1997 Agreement, the Great American Companies agreed to pay certain past 
incurred defense costs incurred by the Port of Seattle before the 1997 Agreement was reached.
In the 1997 Agreement, the Great American Companies also agreed to pay certain defense costs 
to be incurred after February 12, 1997, with respect to environmental actions listed in that

agreement, subject to a reservation of the right to challenge the reasonableness, necessity, 
characterization as defense or indemnity costs and relationship to the defense of the 
environmental actions of all claimed defense costs incurred by the Port.
E.   After the 1997 Agreement was reached, the Port of Seattle submitted claims for 
defense and indemnity with respect to certain of the Environmental Actions that did not exist at 
the time of the 1997 Agreement, involving claims concerning investigation and potential cleanup 
relating to the Lower Duwamish Waterway, including Terminal 117. The Great American 
Companies agreed to defend the Port with respect to such Environmental Actions, subject to a 
reservation of the right to challenge the reasonableness, necessity, characterization as defense or 
indemnity costs and relationship to the defense of the Environmental Actions of all claimed 
defense costs incurred by the Port, and subject to a reservation of rights to challenge their 
ultimate obligation to indemnify the Port of Seattle.
F.    The Port of Seattle has subsequently tendered costs to the Great American 
Companies, incurred after February 12, 1997, which the Port of Seattle contends were incurred 
for the defense of the Environmental Actions. The Great American Companies have 
acknowledged certain defense costs have been incurred and have paid certain of the defense 
costs claimed by the Port of Seattle with respect to the Environmental Actions, and have disputed 
or reserved their right to dispute the reasonableness, necessity, characterization as defense or 
indemnity costs, and relationship to the defense of the Environmental Actions of certain other 
costs claimed by the Port of Seattle.
G.   The Port of Seattle and the Great American Companies desire to amicably resolve 
and to discontinue their dispute concerning the Great American Companies' duty to defend the 
Port of Seattle, with respect to certain costs the Port of Seattle claims to have incurred for work 
performed on or before December 31, 2012 for the defense of the Environmental Actions, 
defined herein to be "Certain Past Incurred Defense Costs."
H.   The Port of Seattle and the Great American Companies by this Defense 
Agreement are resolving only the claims relating to Certain Past Incurred Defense Costs. The 
2

Parties reserve all their respective rights concerning (i) the Great American Companies' duty to 
defend the Port of Seattle with respect to certain costs that are not Certain Past Incurred Defense 
Costs which the Port of Seattle claims to have incurred for work performed before January 1, 
2013 for the defense of the Environmental Actions, or (ii) the Great American Companies' duty 
to defend the Port of Seattle with respect to costs the Port of Seattle claims or will claim to have 
incurred for work performed after December 31, 2012 for the defense of the Environmental 
Actions, or (iii) the Port of Seattle's claims for indemnity.
NOW, THEREFORE, in consideration of the mutual covenants contained herein and 
intending to be legally bound, the Port of Seattle and the Great American Companies agree as 
follows:
II.     DEFINITIONS
A.   "Environmental Actions" shall mean those claims or demands already tendered by 
the Port of Seattle to the Great American Companies concerning the claims identified in Exhibit 
B to this Defense Agreement. As to these claims or demands tendered to the Great American 
Companies, "Environmental Actions" shall further mean any demand, claim, suit, request for 
relief, action or forbearance of any kind, proceeding, notice of partial or total responsibility 
made, asserted, or filed against the Port of Seattle by the United States Environmental Protection 
Agency, any other federal, state, local or other governmental or quasi-governmental agencies 
and/or private persons, organizations or entities for alleged property damage, cleanup, 
remediation or any other harm, injury, damage, or violation or need for remedy of any kind, 
and/or any other claim, demand, or cause of action arising out of the Port of Seattle's alleged, 
actual, threatened, potential or vicarious acts, omissions, liability or responsibility, including but 
not limited to alleged liability or responsibility as a generator, disposer, manufacturer, 
distributor, transporter, or operator, or as a present or former lessee, lessor or owner of real 
property, whether at law or in equity, and whether sounding in tort, in contract, equity, nuisance, 
trespass, negligence or strict liability or any statutory, regulatory, equitable or legal theory.

3

B.   The "Port of Seattle" or "the Port" shall mean the Port of Seattle, its agents, 
servants, employees, attorneys, elected officials, representatives, predecessors, successors, and 
assigns, but does not include any third parties such as tenants.
C.   The "Great American Companies" shall mean Great American Insurance 
Company and Great American Insurance Company of New York, formerly known as American 
National Fire Insurance Co., all other Great American affiliates, their parents, affiliates and 
subsidiaries, and their agents, servants, employees, attorneys, representatives, predecessors, 
successors and assigns.
D.   "Effective Date" shall mean the last date on which this Defense Agreement is 
executed by any of the parties as reflected on the signature pages of this Defense Agreement.
E.   "Certain Past Incurred Defense Costs" shall mean only costs claimed as defense 
costs by the Port of Seattle and incurred by or on behalf of the Port of Seattle for work performed 
on or before December 31, 2012 for the defense of the Environmental Actions, which are set 
forth in detail in Attachments 1(GAIC indeterminate), 2 (Port employees), 3 (Port overhead), 4 
(legal(overage)), 5 (other sites), 6 (past due/dupe billing), 7 (Interest), 8 (paid vendor charges), 
and 9 (Gradient indeterminate), with the categories set out in those attachments being referred to 
by the Parties generally as GAIC indeterminate, Port employees, overhead, legal(overage), other 
sites, past due/dupe billings, interest, paid vendor charges, and Gradient indeterminate. Certain 
Past Defense Costs shall not include any cost which is not set forth in Attachments 1-9 hereto.
III.    PAYMENT BY THE GREAT AMERICAN COMPANIES OF PAST INCURRED 
DEFENSE COSTS AND OTHER COSTS CLAIMED BY THE PORT OF SEATTLE
Within 45 days after the Effective Date, the Great American Companies shall deliver to 
the Port of Seattle at the address of its counsel, Graham & Dunn PC, a check payable to the Port 
of Seattle in the amount of one million five hundred thousand dollars ($1,500,000.00.)
IV.   NOTICE TO OTHER INSURERS AND RIGHT OF CONTRIBUTION
The Great American Companies assert that certain other insurers may be obligated to 
defend the Port of Seattle in the Environmental Actions. The Port of Seattle has previously 

4

given notice to successors of United Pacific Insurance Co., American Employers Insurance Co., 
and Industrial Indemnity Company. In addition, the Port of Seattle shall promptly provide notice 
and tender, including a notice of lost policy claim under WAC 284-30-920 when applicable, to 
other insurers or their successors that the Great American Companies assert have a potential 
obligation to defend the Port of Seattle with respect to the Environmental Actions, which include 
but are not limited to the following, which may provide coverage to the Port as an additional 
insured:
A.   American Home Insurance Company, certain Underwriters at Lloyd's, London, 
and Stuyvesant Insurance Company, under policies issued to Wilbur-Ellis Company; 
B.   General Insurance Company of America, under a policy issued to Olympic 
Steamship Co.;
C.   certain Underwriters at Lloyd's, London and certain London Market insurance 
companies, under policies issued to American Mail Line, Ltd.; 
D.   certain Underwriters at Lloyd's, London and certain London Market insurance 
companies, under policies issued to Lockheed Shipbuilding Corp.; and
E.   Travelers Indemnity Company, Aetna Casualty and Surety Company, and 
Insurance Company of North America, under policies issued to Shell Oil Corp.
Upon request by the Great American Companies, the Port of Seattle agrees to cooperate 
and use reasonable, good faith efforts to provide notice, including notice of lost policy claim, to 
any other insurers that are later discovered to have a potential obligation to defend the Port of 
Seattle with respect to the Environmental Actions. The Great American Companies reserve their 
right to seek contribution from other insurers for payment of any of the Port of Seattle's defense 
costs. The Port of Seattle agrees to cooperate with the Great American Companies in their 
attempt to seek contribution from other insurers to the extent consistent with applicable law and 
as required under the Policies. The Port of Seattle reserves the right to seek recovery from the 
Great American Companies under policy provisions for costs incurred in cooperation with the 
Great American Companies' effort to seek contribution from other insurers for payment of the 
5

Port of Seattle's defense costs, with the exception of costs incurred by the Port of Seattle to 
provide notice and notice of the lost policy claims to such other insurers. The Great American 
Companies also reserve the right to pay such costs as required by policy provisions, or to decline 
payment of such costs based upon the policy provisions.
V.   THE GREAT AMERICAN COMPANIES' CONTINUED ACCEPTANCE OF THE 
DUTY TO DEFEND THE PORT OF SEATTLE IN THE ENVIRONMENTAL 
ACTIONS
The Great American Companies shall continue to provide a defense to the Port of Seattle 
with respect to the Environmental Actions under the general liability coverages of the Great 
American Policies at issue, under a reservation of rights. The defense provided pursuant to this 
Paragraph V is made without reservation of any right to recoup such defense costs from the Port 
of Seattle. The Great American Companies' acceptance of their duty to defend is made with all 
previously asserted reservations of rights to challenge their ultimate obligation to indemnify the 
Port of Seattle. The Port of Seattle's appointed defense counsel shall continue to defend the Port 
of Seattle in the Environmental Actions. The Great American Companies reserve the right to 
challenge the reasonableness, necessity, characterization as defense or indemnity costs and 
relationship to the defense of the Environmental Actions of all defense costs not resolved by this 
Defense Agreement, including those incurred by or on behalf of the Port of Seattle for work 
performed after December 31, 2012 and those incurred by or on behalf of the Port of Seattle for 
work performed before January 1, 2013 which are for other than Certain Past Incurred Defense 
Costs. The Great American Companies shall also be provided with reasonable documentation of 
future claimed defense costs, including a listing of future defense costs, proof of payment, 
unredacted legal fee invoices, invoices from consultants and other reasonable documentation 
requested by the Great American Companies.
The Port of Seattle has posted materials on a website accessible to the Great American 
Companies (hereafter, the "Website") in support of its claims for defense costs incurred for work 
performed during 2013. Subject to its reservation of rights and other rights specified in this 

6

Defense Agreement, the Great American Companies shall complete their review of the Port's 
claim for costs incurred for work performed during 2013, and shall make appropriate payments 
directly to the vendors or the Port of Seattle, by July 31, 2014.
As long as the Port of Seattle continues to claim defense costs from the Great American 
Companies with respect to the Environmental Actions, the Port shall post on the Website 
(whether it is on Livelink or some other software program) summaries of claimed costs, and 
invoices and other documentation supporting its claimed defense costs. The Port of Seattle shall 
promptly advise the Great American Companies when it has completed the posting of such costs 
for each six month calendar period (i.e., January through June and July through December).
Following such notification by the Port, and subject to its reservation of rights and other rights 
specified in this Defense Agreement, the Great American Companies shall commence an initial 
review of the Port of Seattle's claim for costs incurred for work performed during each such sixmonth
period. The Great American Companies shall complete an initial review within three 
months after receiving notification from the Port that the Port has completed the posting of such 
costs for a six month period and shall make appropriate payment directly to the vendors or the 
Port of Seattle, within that three month period.
If, at any time subsequent to notifying the Great American Companies that it has 
completed the posting of claimed defense costs for each six month calendar period on the 
Website, the Port of Seattle modifies, adds, or subtracts information or sums relative to the 
claimed costs, it must promptly notify the Great American Companies that it has made a change 
and provide details regarding each such change.
VI.   RELEASE
A.   In consideration of the payment by the Great American Companies of 
$1,500,000.00 for Certain Past Incurred Defense Costs and the Great American Companies' 
agreement to provide the Port of Seattle with a defense of the Environmental Actions, the Port of 


7

Seattle hereby fully and forever releases and discharges the Great American Companies and their 
employees, officers, directors, agents, and attorneys from the following:
1.    All claims under the Policies and any other insurance policies issued to the 
Port by the Great American Insurance Companies, known or unknown, including policies 
providing property coverages, for Certain Past Incurred Defense Costs and any claims arising out 
of the Great American Companies' previous alleged refusal to accept and to pay for Certain Past 
Incurred Defense Costs, including all such claims for:
a.    breach of contract;
b.    declaratory relief pursuant to the Declaratory Judgment Act;
c.    breach of fiduciary duty;
d.    bad faith;
e.    violations of the Consumer Protection Act, Insurance Fair Conduct
Act, or of any regulations or statutes pertaining to insurance and 
handling of claims under insurance contracts;
f.      negligence, compensatory, punitive, or statutory 
damages and claims for attorney fees pursuant to Olympic 
Steamship Co. v. Centennial Ins. Co., under policy provisions or 
otherwise, which concern exclusively Great American Companies' 
previous refusal to accept and to pay for Certain Past Incurred 
Defense Costs; and
g.    prejudgment interest on the Certain Past Incurred Defense Costs.
B.   In furtherance of the Port's release in this Defense Agreement of the Great 
American Companies relating to Certain Past Incurred Defense Costs, and notwithstanding the 
Port's reservation to make certain claims in the future to the Great American Companies for costs 
other than Certain Past Incurred Defense Costs, the Port agrees not to submit any item which is 
identified in Attachments 1-9 as an indemnity claim to the Great American Companies.

8

C.   This release extends only to the Great American Companies' conduct prior to the 
Effective Date of this Defense Agreement, and only to claims arising from the Great American 
Companies' alleged duty to defend with respect to Certain Past Incurred Defense Costs. The 
Port of Seattle is not hereby releasing any possible claims, including possible claims for costs 
other than Certain Past Incurred Defense Costs, possible claims for indemnity under the policies, 
breach of contract, declaratory relief, breach of fiduciary duty, bad faith, violations of the 
Consumer Protection Act, prejudgment interest, or attorney fees that may arise after the Effective 
Date of this Defense Agreement.
D.   The parties specifically agree that nothing in this Defense Agreement shall impair, 
release, or effect in any way the claims that the Port of Seattle has asserted against the Great 
American Companies for costs other than Certain Past Incurred Defense Costs, indemnity with 
respect to the Environmental Actions, including claims for associated relief such as claims for 
attorneys' fees. However, in its indemnity claims, the Port of Seattle releases and agrees not to 
assert claims for attorneys' fees incurred in claiming a defense from the Great American 
Companies, and agrees to permit court review of legal fee invoices for apportionment of legal 
fees incurred solely in connection with its defense cost claims and with this Agreement, which 
have been waived and released hereunder. Nothing in this Defense Agreement shall impair the 
Port of Seattle's right to claim any and all attorneys' fees in connection with its pursuit of 
indemnification claims or otherwise, except as provided herein.
E.   The parties specifically agree that nothing in this Defense Agreement shall impair, 
release, or affect in any way:
1.    the 1997 Agreement, except as modified by Sections III, IV, V, and VI of 
this Agreement and the February 27, 1998 Confidential Settlement, Release, and Hold Harmless 
Agreement; 
9

2.    the Port of Seattle's right to claim any and all costs incurred for work 
performed after December 31, 2012 for the defense of Environmental Actions or for costs which 
are not Certain Past Incurred Defense Costs before January 1, 2013 for the defense of 
Environmental Actions;
3.    with respect to the Port of Seattle's claims for costs incurred for work 
performed after December 31, 2012 for the defense of Environmental Actions or before January 
1, 2013 for costs other than Certain Past Incurred Defense Costs, the interim agreement between 
the Port of Seattle and the Great American Companies regarding offsets for certain 
reimbursements from other potentially responses parties, dated October 1, 2012;
4.    the agreement between the Port of Seattle and the Great American 
Companies regarding funding of fees, costs, and expenses (hereafter, "PRP Recovery Costs")
incurred by or on behalf of the Port of Seattle in seeking recovery from potentially responsible 
parties ("PRPs") for investigation and remediation costs with respect to Terminal 91, dated 
December 14, 2012, and the Great American Companies' reservation of the right to contend that 
it and the Port of Seattle entered into a prior, longstanding agreement with respect to the Great 
American Companies' payment of PRP Recovery Costs and the benefit the Great American 
Companies receive for recoveries from PRPs, with respect to each of the Environmental Actions, 
and the Port of Seattle's reservation of the right to contend that the Great American Companies 
and the Port of Seattle did not enter into such a prior agreement;
5.    the agreement between the Port of Seattle and the Great American 
Companies regarding funding of PRP Recovery Costs with respect to the Lower Duwamish 
Waterway, dated April 30, 2013, and the Great American Companies' reservation of the right to 
contend that it and the Port of Seattle entered into a prior, longstanding agreement with respect to 
the Great American Companies' payment of PRP Recovery Costs and the benefit the Great 
American Companies receive for recoveries from PRPs, with respect to each of the 
Environmental Actions, and the Port of Seattle's reservation of the right to contend that the Great 
American Companies and the Port of Seattle did not enter into such a prior agreement;
10

6.    with respect to the Port of Seattle's claims for costs incurred for work 
performed after December 31, 2012 for defense of Environmental Actions, or costs incurred 
before January 1, 2013 which are not Certain Past Incurred Defense Costs for defense of 
Environmental Actions, and with respect to the Port of Seattle's claims for indemnity, the Great 
American Companies' reservations of rights with respect to the Environmental Actions.
VII.  NO CONSTRUCTION AGAINST EITHER PARTY
The wording of this Defense Agreement was reviewed and accepted by legal counsel for 
the Port of Seattle and the Great American Companies prior to its being signed by them, and 
neither the Port of Seattle nor the Great American Companies shall be entitled to have any 
wording of this Defense Agreement construed against the other party in the event of any dispute 
arising between them in connection with it.
VIII.  NO ASSIGNMENT
Neither party hereto shall assign this Defense Agreement without first obtaining the 
written consent of the other party hereto; provided, however, that this Section shall not prohibit 
any assignment by a party hereto by merger, consolidation, operation of law or to a party who 
succeeds to any of such party's assets. Subject to the foregoing, this Defense Agreement shall 
extend to and be binding upon the parties hereto and their successors and assigns.
IX.   INADMISSIBILITY OF AGREEMENT
Any evidence of the existence, terms or negotiation of this Defense Agreement shall be 
inadmissible in any litigation, provided, however, that such evidence may be offered in an action 
seeking solely to enforce the terms of this Defense Agreement, or in an action by the Great 
American Companies to recover contribution or other amounts from the Port of Seattle's other 
insurers. This Defense Agreement has been entered into in reliance upon the provisions of Rule 
408 of the Federal Rules of Evidence and similar state law provisions which preclude the 
introduction of evidence regarding settlement negotiations or agreements. The parties shall, 


11

however, be permitted to disclose the fact that the Great American Companies have agreed to 
defend the Port of Seattle in the Environmental Actions, under reservation of rights.
X.   INTEGRATION/SEVERABILITY
Except as set forth in this Paragraph VI.C. and D., this Defense Agreement constitutes a 
single integrated contract expressing the entire agreement of the parties hereto. Except as set 
forth in this Paragraph VI.C. and D., there have been no other representations or agreements, 
whether oral or written, in regard to this Defense Agreement or its subject matter. If any 
provision of this Defense Agreement is held invalid, it shall be considered severable from the 
remainder, and the remaining provisions shall be given full force and effect.
XI.   EXECUTION OF COUNTERPARTS
This Defense Agreement may be executed in counterparts and each executed counterpart 
shall have the same force and effect as an original instrument, as if all parties to all the 
counterparts had signed the same instrument.
XII.  NO APPLICATION TO THIRD PARTIES
This Defense Agreement is the product of informed negotiations and involves 
compromises of the Parties' previously stated legal positions. Except as expressly set forth 
herein, this Defense Agreement is without prejudice to positions taken by the Port of Seattle or 
the Great American Companies with regard to other persons or entities. All actions taken and 
statements made by the parties to this Defense Agreement, or by their respective representatives, 
relating to this Defense Agreement or participation in this Defense Agreement, including its 
development and implementation, shall be without prejudice or value as precedent, and shall not 
be used as a standard by which other matters may be judged, except as to a breach, alleged 
breach, and/or enforcement of the provisions of this Defense Agreement.



12

XIII.  SIMC CREDIT
The Great American Companies agree not to seek any further credit for the Seattle Iron 
and Metals Corporation's ("SIMC") payment of $1,391,994.73 in resolving the Port of Seattle's 
claims with respect to the Environmental Actions, except that the Great American Companies 
reserves the right to claim a credit of $299,996.03 of the SIMC payment in resolving the 
Environmental Actions with the Port of Seattle. The Port of Seattle reserves all rights with 
respect to the $299,996.03 SIMC credit, including the right to contend that taking such a credit is 
not permissible under the law.


PORT OF SEATTLE               GREAT AMERICAN INSURANCE 
COMPANY

By                       By


GREAT AMERICAN INSURANCE 
COMPANY OF NEW YORK, formerly 
known as AMERICAN NATIONAL FIRE 
INSURANCE COMPANY

By


STATE OF WASHINGTON

13

)   ss.
COUNTY OF KING )

On this _____ day of ______________, 2014, before me personally appeared 
___________________________________________, to me known to be the ______________ 
of PORT OF SEATTLE, the company that executed the within and foregoing instrument, and 
acknowledged said instrument to be the free and voluntary act and deed of said party, for the 
uses and purposes therein mentioned, and on oath stated that he/she was authorized to execute 
said instrument.
Given under my hand and official seal this _____ day of ____________, 2014.


(Signature)

(Name legibly printed or stamped)
Notary  Public  in  and  for  the  State  of 
Washington, residing at _________________.
My appointment expires _____________.

STATE OF _______________ )
)   ss.
COUNTY OF _____________ )

On this _____ day of ______________, 2014, before me personally appeared 
___________________________________________, to me known to be the ______________ 
of GREAT AMERICAN INSURANCE COMPANY and GREAT AMERICAN INSURANCE 
COMPANY OF NEW YORK, formerly known as AMERICAN NATIONAL FIRE 
INSURANCE COMPANY, the company that executed the within and foregoing instrument, and 
acknowledged said instrument to be the free and voluntary act and deed of said corporation, for 
the uses and purposes therein mentioned, and on oath stated that he/she was authorized to 
execute said instrument.
IN WITNESS WHEREOF I have hereunto set my hand and affixed my official seal the 
day and year first above written.

14

(Signature)

(Name legibly printed or stamped)
Notary  Public  in  and  for  the  State  of 
_________, residing at _________________.
My appointment expires _____________.













15

EXHIBIT A

Policy Period             Insurer                 Policy No.
1/1/64 - 1/1/65            Great American            LX84870
1/1/65 - 1/1/66            Great American            LX89900
1/1/66 - 1/1/67            Great American            LX6267450
1/1/67 - 1/1/70            Great American            UAP 3888524
1/1/70 - 1/1/74            Great American            UAP 1153908
1/1/74 - 1/1/77            Great American            UAP 2646000
1/1/78 - 1/1/80            Great American            SLP 9456178
1/1/80 - l/1/81             American National Fire       SLP 9461168
1/1/81 - 1/1/82            American National Fire      SLP 9465924
1/1/82 - 1/1/83            Great American            SLP 9472449
1/1/83 - 1/1/84            American National Fire      SLP 9438815
1/1/84 - 1/1/85            American National Fire      SLP 6255023
1/1/85 - 1/1/86            American National Fire      SLP 6255023








A-1

EXHIBIT B 
CLAIM LIST
1.    East Waterway and West Waterway environmental claims 
Seattle, Washington
2.    Terminal 91 environmental claims
Seattle, Washington
3.    National Resource Damage claims, Elliott Bay/Duwamish River
Seattle, Washington
4.    Lower Duwamish Waterway environmental claims 
Seattle, Washington
5.    Terminal 117 environmental claims
Seattle, Washington











DM1\4902034.2