ILANA DIAMOND ROVNER, Circuit Judge.
After completing the emergency clean-up work they were ordered to perform at a hazardous waste site in Indiana, Akzo Coatings, Incorporated and The O’Brien Corporation (collectively, “Akzo”) brought suit for contribution against Aigner Corporation and a number of other companies (collectively, “Aigner”) that allegedly had generated wastes which had been treated or disposed of at that site. The district court granted summary judgment in favor of Aigner, finding that Akzo’s work was a “matter addressed” by the consent decree that Aigner had entered into with the government. See 42 U.S.C. § 9613(f)(2). Because we conclude that Akzo’s work was for the most part not a “matter addressed” by the consent decree, we reverse the district court’s judgment in part.
I. FACTS
Between 1972 and 1985, more than 200 firms generated hazardous wastes that were sent to various facilities within the Kingsbury Industrial Park in Kingsbury, Indiana comprising what we refer to as the “Fisher-Calo” site. Among these facilities was the “Two-Line Road” facility, where Fisher-Calo Chemicals and Solvents, Incorporated and its predecessor corporations had conducted solvent recycling operations from 1981 until 1985.
In 1988, the federal Environmental Protection Agency (“EPA”) concluded that the wastes stored at the Two-Line Road facility posed an imminent danger of release into the surrounding environment. Exercising the authority granted under section 106 of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (“CERCLA”), 42 U.S.C. § 9606, the EPA issued a unilateral administrative order requiring Akzo and some twenty other companies that qualified as “liable persons” under CERCLA1 to conduct certain “emergency removal activities” at the Two-Line Road facility. Among the tasks required were: (1) fencing off and otherwise securing the facility; (2) securing and removing all drums, tanks, and other containers of hazardous waste from the premises, including buried containers; and (3) determining the extent to which the soil was contaminated and removing any soil that was visibly polluted. Akzo complied with the EPA’s order, incurring [763]*763costs in excess of $1.2 million.2 The work specified by the EPA’s 1988 order has largely been completed.3
In May 1990, approximately thirty-five companies that had generated wastes disposed of at the Fisher-Calo site and were thus “potentially responsible parties” (“PRPs”) under CERCLA (see n. 1, supra) initiated efforts to quantify the nature and extent of the liability of any and all PRPs for clean-up of the site and to evaluate the types of work that the EPA and Indiana might order them to perform. Akzo was among the firms that engaged in' this effort, and it incurred further costs in doing so. However, Akzo withdrew from the group in February 1991 after concluding that it was not liable for any contamination of the Fisher-Calo site beyond the Two-Line Road facility.
In August 1990, the EPA published a Record of Decision (“ROD”) outlining the work it believed necessary to accomplish a complete decontamination of the site. With respect to the work mandated by the 1988 Order, the ROD stated:
A removal action at the north end of the Two-Line facility is being conducted under a Unilateral Removal Order issued by U.S. EPA. The removal action is being carried out in two phases: Phase I involves the staging of drums for removal during Phase II. Phase II includes the excavation of the contaminated soils and buried tanks and drums located on the north end of the Two-Line Road property. The visibly contaminated soils, tanks and drums will be removed from the north end of the Two-Line Road facility and transported to an appropriate disposal facility. A further removal action is being scoped for the south end of the Two-Line facility. For the purposes of this Record of Decision, it is assumed that all drums, tanks, and containers on the Two-Line Road property requiring remedial action are being addressed by these actions.
ROD Summary at 5 (emphasis supplied). The EPA began to negotiate with the PRPs to implement the clean-up outlined in the ROD, and by the end of the following year, it had finalized an agreement with more than 200 PRPs. The EPA filed suit against these PRPs in late December 1991 and asked the court to approve the proposed consent decree it filed contemporaneously with its complaint. United States v. Accurate Partitions Corp., Civ. No. S91-00646 M (N.D.Ind.). Pursuant to the decree, the settling PRPs agreed to undertake the actions specified by the 1990 ROD and to compensate the EPA for some of the costs it had incurred to date. In late February 1992, following the requisite notice period, see 42 U.S.C. § 9622(d)(2), the district court approved the consent decree. Aigner was a party to this decree; Akzo was not.
In 1991, Akzo brought suit against Aigner seeking, inter alia, contribution under CERCLA for the initial clean-up work it had performed at the behest of the EPA as well as the voluntary costs it had incurred in studying the long term clean-up of the site with other PRPs.4 Aigner moved to dismiss the complaint, arguing that the work for which Akzo sought contribution was a “matter addressed” by the Accurate Partitions consent decree and thus Akzo’s claim was barred by the statute. The district court converted the motion into one for summary judgment in accordance with Fed.R.Civ.P. 12(b) and ruled in Aigner’s favor, agreeing that Akzo sought contribution for a “matter addressed” by the consent decree. Akzo Coatings, Inc. v. Aigner Corp., 803 F.Supp. [764]*7641380 (N.D.Ind.1992). Although the court’s ruling did not dispose of all of Akzo’s claims, the court certified its ruling for immediate appeal under Fed.R.Civ.P. 54(b).
II. ANALYSIS
Section 113(f) of CERCLA, added to the statute in 1986, authorizes claims for contribution, subject to the limitation set forth in paragraph (2):
(1) Contribution
Any person may seek contribution from any other person who is liable or potentially liable under section 9607(a) of this title, during or following any civil action under section 9606 of this title or under section 9607(a) of this title_ In resolving contribution claims, the court may allocate response costs among hable parties using such equitable factors as the court determines are appropriate. Nothing in this subsection shall dimmish the right of any person to bring an action for contribution in the absence of a civil action under section 9606 or section 9607 of this title.
(2) Settlement
A person who has resolved its liability to the United States or a State in an administrative or judicially approved settlement shall not be hable for claims for contribution regarding matters addressed in the settlement. Such settlement does not discharge any of the other potentially hable persons unless its terms so provide, but it reduces the potential liability of the others by the amount of the settlement.
42 U.S.C. § 9613(f). The district court concluded that Akzo is seeking contribution under section 113(f)(1) and that Aigner is not liable because the clean-up of the entire Fisher-Calo site is a “matter addressed in the settlement.” Akzo disagrees with both conclusions: it contends that it is not seeking “contribution” at all and that the work the EPA ordered it to perform at the Two-Line Road facility was not a “matter addressed” in the consent decree. The United States, offering its opinion as amicus curiae, suggests that Akzo is wrong on the first argument but right on the second. We agree.
That Akzo’s claim is one for contribution we have no doubt. Akzo argues that its suit is really a direct cost recovery action brought under section 107(a) rather than a suit for contribution under section 113(f)(1); and it is true that section 107(a) permits any “person” — not just the federal or state governments — to seek recovery of appropriate costs incurred in cleaning up a hazardous waste site. 42 U.S.C. § 9607(a), subpart (B). Yet, Akzo has experienced no injury of the kind that would typically give rise to a direct claim under section 107(a) — it is not, for example, a landowner forced to clean up hazardous materials that a third party spilled onto its property or that migrated there from adjacent lands. Instead, Akzo itself is a party liable in some measure for the contamination at the Fisher-Calo site, and the gist of Akzo’s claim is that the costs it has incurred should be apportioned equitably amongst itself and the others responsible. Complaint ¶¶ 10, 11. That is a quintessential claim for contribution. See Restatement (Second) of Torts § 886A (1979); see also Amoco Oil Co. v. Borden, Inc., 889 F.2d 664, 672 (5th Cir.1989); In re Dant & Russell, Inc., 951 F.2d 246, 249 (9th Cir.1991). Section 113(f)(1) confirms as much by permitting a firm to seek contribution from “any other ” party liable under sections 106 or 107. Whatever label Akzo may wish to use, its claim remains one by and between jointly and severally liable parties for an appropriate division of the payment one of them has been compelled to make. Akzo’s suit accordingly is governed by section 113(f). Accord Transtech Indus., Inc. v. A& Z Septic Clean, 798 F.Supp. 1079, 1085-87 (D.N.J.1992), appeal dismissed, 5 F.3d 51 (3d Cir.1993), cert. denied, — U.S. -, 114 S.Ct. 2692, 129 L.Ed.2d 823 (1994). To the extent cases such Burlington N. R.R. Co. v. Time Oil Co., 738 F.Supp. 1339, 1342-43 (W.D.Wash.1990), and Key Tronic Corp. v. United States, No. C-89-694-JLQ, Order at 15 (E.D.Wash. Aug. 9, 1990), judgment rev’d on other grounds, 984 F.2d 1015 (9th Cir.1993), aff'd in part, rev’d in part, and remanded, — U.S. -, 114 S.Ct. 1960, 128 [765]*765L.Ed.2d 797 (1994), have suggested otherwise, we decline to follow them.5
Akzo suggests that whether its claim is one for contribution may depend on whether the harm done to the Fisher-Calo site is divisible. If, for example, all of Akzo’s solvents were deposited at Two-Line Road while Aigner’s were deposited at a different facility, Akzo’s claim for cleaning up the Two-Line Road site looks less like one for contribution and more like a section 107 cost recovery action. But the basis for holding Aigner hable in that scenario escapes us. Only the hypothesis that the whole Fisher-Calo site is the proper unit of analysis, or that both Akzo and Aigner sent solvents to Two-Line Road, would give Akzo a legitimate claim against Aigner. Either way, Akzo is seeking to apportion liability for an injury to which it contributed.6
Our attention thus turns to whether the contribution that Akzo seeks is for “matters addressed” by the consent decree that Aigner signed. The statute itself does not specify how we are to determine what particular “matters” a consent decree addresses. Section 113(f)(1) does direct us, however to “use[] such equitable factors as the court determines are appropriate” in resolving contribution claims. 42 U.S.C. § 9613(f)(1). Thus, rather than adopting any bright lines, Congress quite clearly envisioned a flexible approach to contribution issues. See Kerr-McGee Chem. Corp. v. Lefton Iron & Metal Co., 14 F.3d 321, 326 (7th Cir.1994) (“In determining the relative contribution of the parties, courts must look to the ‘totality of the circumstances.’ ”) (quoting Environmental Transp. Sys., Inc. v. ENSCO, Inc., 969 F.2d 603, 509 (7th Cir.1992)); EMC Corp. v. Aero Indus., Inc., 998 F.2d 842, 846-47 (10th Cir.1993) (collecting cases).
Our starting point, naturally, is the consent decree itself. The decree is expansive, not just in terms of its length (sixty-four pages, exclusive of its appendices) but its scope as well. It addresses the Fisher-Calo site as a whole, defining the relevant “Facility” as “the location where treatment, storage, disposal or other placement of hazardous substances was conducted by Fisher-Calo Chemical Company, and those areas where such substances have come to be located.” Consent Decree at 7, ¶'4. It also incorporates wholesale the far-ranging remedial plan set forth in the EPA’s 1990 ROD (id. at 6, ¶ 1; 11, ¶ 5), a plan which, barring unforeseen problems, would accomplish a complete clean-up of the site at an anticipated cost of more than $30 million. The decree also requires the settling defendants to pay the EPA and the. State of Indiana nearly $3.1 million for their costs to date. Id. at 38-39, ¶ 49. Finally, and most significantly from Aigner’s perspective, the decree includes a covenant not to sue the settling defendants for “covered matters,” which include “any and all claims available to the United States under Sections 106 and 107 of CERCLA ... relating to the Facility, and any and all claims relating to the Facility available to the State under Indiana Code 13-7-8.7 and common law nuisance.” Id. at 46, ¶ 66. Consequently, with certain specific exceptions that are immaterial here (id. at 46 — 49, ¶¶ 67-71), Aigner has been released of any liability to either Indiana or the United States.
[766]*766But the fact that the decree bestows comprehensive immunity from claims by the state and federal governments does not necessarily mean that Aigner enjoys the same immunity from claims brought by a party in Akzo’s position. Whatever light the government’s covenant not to sue may shed on the intended scope of the decree, it should not be treated as dispositive of the contribution protection the settling PRPs are afforded under section 113(f)(2). The government’s agreement to seek nothing more from the parties to the decree does not signal an intent to preclude non-settling parties from seeking contribution. See Transtech, 798 F.Supp. at 1088-89. As the United States observes:
If the covenant not to sue alone were held to be determinative of the scope of contribution protection, the United States would not be free to release settling parties from further litigation with the United States, without unavoidably cutting off all private party claims for response costs.
Amicus Br. at 19. Surely this is not what Congress intended. Rather than give undue weight to a provision of the decree having nothing on its face to do with the claims of non-settling parties, we must look to the decree as a whole to decide whether its provisions encompass the type of activity for which Akzo seeks contribution.7
Other courts have suggested that the “matters addressed” by a consent decree be determined with reference to the particular location, time frame, hazardous substances, and clean-up costs covered by the agreement. United States v. Union Gas Co., 743 F.Supp. 1144, 1154 (E.D.Pa.1990); accord Akzo Coatings of America, Inc. v. American Renovating, 842 F.Supp. 267, 271 (E.D.Mich.1993); United States v. Colorado & E. R.R., 832 F.Supp. 304, 307 (D.Colo.1993); United States v. Pretty Products, Inc., 780 F.Supp. 1488, 1494-95 n. 4 (S.D.Ohio 1991). See also Akzo Coatings, Inc. v. Aigner Corp., 803 F.Supp. at 1384. The United States correctly observes that this should not be treated as an exhaustive list of appropriate considerations, for the relevance of each factor will vary with the facts of the case. Amicus Br. at 17 n. 15. Ultimately, the “matters addressed” by a consent decree must be assessed in a manner consistent with both the reasonable expectations of the signatories and the equitable apportionment of costs that Congress has envisioned. See Transtech, 798 F.Supp. at 1088.8
[767]*767Because Akzo’s work stands apart in kind, context, and time from the work envisioned by the consent decree, we conclude that it is not a “matter addressed” by the decree. Akzo was required to engage in “removal” work (42 U.S.C. § 9601(23)) — that is, a short-term, limited effort to abate any immediate threat posed by the wastes present at the site. See Schalk v. Reilly, 900 F.2d 1091, 1092-93 n. 1 (7th Cir.), cert. denied, 498 U.S. 981, 111 S.Ct. 509, 112 L.Ed.2d 521 (1990). The consent decree, on the other hand, provides for the kind of long-term, “remedial” work (42 U.S.C. § 9601(24)) necessary to accomplish a complete clean-up of the site. See Schalk at 1092-93 n. 1. This distinction is reflected in the two different orders implementing the work. The 1988 order unilaterally directed Akzo to undertake certain “emergency removal activities,” including the extraction and disposal of leaking drums and other hazards from the Two-Line Road facility. In contrast, the 1992 consent decree embodies a negotiated settlement designed to implement a long-range remedial plan for the entire site, as outlined in the EPA’s 1990 Record of Decision (“ROD”). Neither the decree nor the ROD purports to incorporate the 1988 order; on the contrary, the ROD explicitly assumes “that all drums, tanks, and containers on the Two-Line Road property requiring remedial action are being addressed” by that order. ROD Summary at 5. Indeed, by the time Aigner entered into the consent decree, Akzo’s removal work had already been completed.9 Consequently, it comes as no surprise that this work was not addressed in the consent decree:
Settlement negotiations are presumably conducted with affected parties able to participate and work toward a joint cleanup goal. Previous cleanup activities already conducted and paid for by private parties are not likely to be addressed by the government in negotiations of this sort.
Burlington N. R.R. Co., 738 F.Supp. at 1342. Because Akzo’s preliminary clean-up work is thus so clearly distinct from the long-range remedial matters addressed by the decree, Akzo is entitled to seek contribution from the settling PRPs under section 113(f)(1).10
Our conclusion is different with respect to the voluntary costs that Akzo incurred in conjunction with other PRPs in attempting to anticipate the claims that might be asserted against them by the EPA. In contrast to the limited nature of the initial removal work required by the EPA’s 1988 order, the focus of these efforts was on the long-term remedial action necessary to effect a permanent clean-up of the site. In essence, Akzo and its fellow PRPs were attempting to predict, and perhaps shape, the provisions of the consent decree. In that sense, these efforts were necessarily “matters addressed” by the decree, and in the absence of some indication that they accomplished tasks distinct from what the consent decree called for, claims for contribution based on these efforts are barred by section 113(f)(2).
The flexible, fact-based approach we have used to determine what matters are ad[768]*768dressed by the consent decree may not offer settling parties the same degree of repose as one based solely on the facial breadth of the decree. Yet, we perceive no unfairness to Aigner in the result here. Akzo’s work was over and done with by the time Aigner signed the consent decree. Acknowledging a right to contribution in this particular circumstance does not subject a settling PRP like Aigner to open-ended liability for contribution claims based on future, unanticipated remedial work. The extent and cost of Akzo’s work were obviously known to (or at least ascertainable by) the parties to the consent decree, and had they wished to make that work a “matter addressed,” presumably they could have done so.11 The fact is they did not, and permitting Akzo to pursue its contribution claim in this context works no undue hardship on Aigner.12
Our dissenting colleague takes a different tack, implying that because it lies within the EPA’s power to draft the release language more narrowly, we should simply take the language in this settlement on its face and construe it broadly to include the clean-up work for which Akzo seeks contribution. Post at 774. There is some allure in that argument, and had Akzo itself been a party to the agreement, we might find it persuasive. But whatever opportunity Akzo may have enjoyed to comment on the consent decree, it had no control over the language ultimately adopted; indeed, neither the EPA, nor Aigner, certainly, had any incentive to take care with Akzo’s contribution rights.13 Given the sweeping power Congress has given the EPA to extinguish the contribution rights third parties would otherwise enjoy under section 113(f)(2), we believe it prudent to require the settling parties to be more explicit when they intend to bar contribution for work such as Akzo’s which, factually speaking (see post at 771-72), is not clearly a “matter addressed” by the agreement.14
Indeed, we are convinced that a contrary outcome would leave firms like Akzo in an [769]*769untenable position. A party served with a unilateral order under section 106 has little choice but to comply; the statute places strict limits on prior judicial review of such orders and authorizes fines of up to $25,000 per day for a party who refuses to obey. 42 U.S.C. §§ 9606(b)(1), 9613(h); see In re CMC Heartland Partners, 966 F.2d 1143, 1148 (7th Cir.1992). To subsequently preclude a compliant party from seeking contribution for the sums it has expended simply because it had the misfortune to be drafted by the EPA before a remedial plan could be prepared and a settlement negotiated will not expedite cooperative environmental remediation.
If defendants were permitted to settle with the government for part of the clean-up costs of a site, and then become immune from suit for contribution by private entities who paid for other cleanup costs, it would defeat the policy of CERCLA. Settling PRPs should not be made to pay twice for the same clean-ups, but they also should not get a windfall because they settled.
Akzo Coatings of America, 842 F.Supp. at 271 (emphasis in original).15
The dissent suggests that our rationale is at odds with the Supreme Court’s recent opinion in McDermott, Inc. v. AmClyde, — U.S. -, 114 S.Ct. 1461, 128 L.Ed.2d 148 (1994). Post at 773. We disagree. As the dissent points out, McDermott disavows a rule of liability allocation in admiralty cases that would permit nonsettling parties to seek contribution from parties that have settled. Id. at-, 114 S.Ct. at 1467. We do not begin with the blank slate that the Supreme Court confronted in McDermott, however. See id. at-, 114 S.Ct. at 1464-65. Here, Congress has spoken directly to the question of contribution and permitted non-settling parties to seek contribution for any matter not addressed in the settlement. § 9613(f)(2). Consequently, the ease before us is first and foremost one of contractual interpretation, and on that subject, McDer-mott is not controlling.
Of course, policy considerations of the kind discussed in McDermott to some extent have informed our decision on how broadly to construe the “matters addressed” by the consent decree. Thus, the dissent urges that the decree be accorded a generous sweep that shields Aigner from contribution claims and makes settlement more attractive, while we have construed the decree more narrowly based on the underlying circumstances and avoided the potentially inequitable result that might otherwise befall Akzo. As we see it, McDermott's careful balancing of these competing interests lends as much support to our approach as it does to the dissent’s. In McDermott, the Court was called upon to decide how settlement with some defendants affects the liability of other defendants who take their chances and proceed to trial. In deciding which of three rules to adopt, the Court was motivated in part by a desire to protect settling parties from further liability and thus to foster settlement, — U.S. at -, 114 S.Ct. at 1466-67, but in equal measure by a concern that nonsettling parties not be made to pay damages that exceed their equitable portion of the blame for the injury, id. at-, 114 S.Ct. at 1467-68. In adopting what is referred to as the “proportionate share” rule, the Court served both interests: although the nonset-tling party is barred from seeking contribution against a settling party, the nonsettling party’s liability for damages is limited to its equitable share of the judgment as determined at trial. Id. at-, 114 S.Ct. at 1468-70. Here, we do not have the option of capping Akzo’s liability in this way. Akzo is not in the position of a party that opts not to settle and instead to take its chances at trial; it was forced to pay out long before settlement was even on the table. Having concluded that the work the EPA ordered Akzo to perform was not a “matter addressed” by the subsequent consent decree, we do not find it inequitable to permit Akzo to seek contribution from Aigner in this situation.
[770]*770The dissent postulates that the real solution to Akzo’s dilemma lies in a suit against the government for any mistake it may have made in ordering Akzo to conduct the emergency clean-up work, an option which, in the dissent’s view, obviates any need for contribution. Post at 773-74. That avenue of relief may be a dead end for Akzo, however. Section 106(b)(2) of CERCLA does permit a person ordered to perform removal work under section 106(a) to petition the government for reimbursement of its costs and to file suit if the request is refused, but in order to recover, the petitioner must show either that it is not liable for response costs under section 107(a) or that the order compelling the work was arbitrary and capricious or otherwise not in accordance with law. 42 U.S.C. §§ 9606(b)(2)(A)-(D), 9613(j)(3); see Kelley v. EPA 15 F.3d 1100, 1103 (D.C.Cir.1994). Akzo cannot make the first showing, because it sent wastes to the Fisher-Calo site and is therefore liable for response costs under section 107(a). 42 U.S.C. § 9607(a)(3). See Complaint ¶ 10. Moreover, nothing in the record before us suggests that the EPA’s 1988 order was arbitrary and capricious or otherwise unlawful, either in the designation of the work to be performed or in the selection of the parties who were to perform it. Thus, even if the sums Akzo spent in complying with the section 106 order were disproportionate to its measure of culpability for the contamination of the site, the statute does not necessarily permit Akzo to recover the excess from the government.16 Only a suit for contribution against other PRPs offers the concrete prospect of making Akzo whole in this regard.
For that reason, we suspect that if we were to bar Akzo from pursuing contribution, parties who found themselves in a similar position in the future would simply exercise the intervention right granted them by section 113(i) and oppose the approval of any consent decree that might be construed to foreclose their right to contribution. See 42 U.S.C. § 9613(i); United States v. Acton Corp., 131 F.R.D. 431 (D.N.J.1990); but see Arizona v. Motorola, Inc., 139 F.R.D. 141, 144-46 (D.Ariz.1991). Thus, we might accomplish no more than to shift the battle to a different venue.
We have no “disdain” for the contribution protection Congress has bestowed on settling parties in section 113(f)(2). See post at 774. We do, however, think it inconsistent with the legislature’s intent to give “matters addressed” the broad sweep that the dissent proposes. Even the EPA, which stands to gain from any precedent that makes settlements more attractive, does not embrace that approach. The language of the statute, after all, does not create a blanket prohibition against all suits for contribution; the bar extends only so far as the “matters addressed” by the settlement. When the parties to the settlement have not themselves defined those matters explicitly, we believe it in keeping with congressional intent to do so with an eye to the practicalities of the situation underlying the settlement and the reasonable expectations of the settling parties.
III. CONCLUSION
Based on the totality of the circumstances surrounding the work for which Akzo seeks contribution and the subsequent consent decree between the government and Aigner, we conclude that initial removal work that Akzo was compelled to perform was not a “matter addressed” by the consent decree but that Akzo’s voluntary efforts toward long-term clean-up were. Akzo is thus entitled to seek contribution from Aigner for the former, but not the latter. The district court’s judgment against Akzo and in favor of Aigner is therefore AFFIRMED IN PART and REVERSED IN [771]*771Past, and the case is REMANDED for farther proceedings consistent with this opinion.