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i 6 � I 1 the meastires descri '^ed herein and to resolve completely all 2i claims raised in the Accusation together with any other claims i 3 ( both civ . ' and criminal ) which _he .,e ^a . _.en _ ...ay have agai ,.s _ 4 *?CTC based on any of its or , its agents ' acts , omissions or other conduct which predated this Agree:;Ent , ..ithout a heari:; 6 on the merits of such claims . All such c ;ai_s are hereby released and discharged except as otherwise provided in this 5 ' Agreement . No release or discharge is given by the Department 9 for any claims for civil monetary remedies for any acts , i 10 omissions , or other conduct of MCTC or its agents which 11 postdate this Agreement , except for t`:ose ac -_ s which are 12 performed in accordance with this Abreer;ent . i 13B . The Board and MCTC desire b•: t^e execution of th.z i 14 Ag-eement to resolve all claims under authority of the 15; porter-Cologne Water Quality Control Act which the Board may 16 have against MCTC for any acts , omissions , or other conduct of 17 '. MCTC or its agents which predated this Agreement , without a 18'' hearing on the merits of such claims . All such claims are I 19!i hereby released and discharged except as otherwise provided in 20;1i this Agreement . No release or discharge is given by the Board I� 21 '. for any claims for any acts , omissions , or other conduct of 22 MCTC or its agents which postdate this Agreement , except for 23 ' those acts which are performed in accordance with this 24 Agreement . Furthermore , the Board and MCTC desire by the 25 execution of this Agreement to take remedial action pursuant to 26 Exhibit A of this Agreement and to clean-up or abate the 27 effects of waste discharged or deposited by MCTC where such . 2 couwr PAPER spa �� 113