THE UNILATERAL ADMINISTRATIVE ORDER (UAO) WAS ISSUED TO FOUR DEFENDANTS: HORSEHEAD INDUSTRIES, INC.; HORSEHEAD RESOURCE DEVELOPMENT COMPANY, INC.; VIACOM INTERNATIONAL INC.; AND TCI PACIFIC COMMUNICATIONS, INC. THE UAO REQUIRES THE RESPONDENTS TO IMPLEMENT THE REMAINING PORTION OF THE SELECTED REMEDY SET FORTH IN THE OPERABLE UNIT ONE (OU#1) RECORD OF DECISION (ROD) FOR THE SITE SIGNED ON SEPTEMBER 4, 1987. THE OU#1 ROD REQUIRES REVEGATION OF DEFOLIATED AREAS OF BLUE MOUNTAIN. EPA ENTERED INTO A CONSENT DECREE (CD) WITH ZINC CORPORATION OF AMERICA (ZCA), A DIVISION OF HORSEHEAD INDUSTRIES, INC., FOR IMPLEMENTATION OF THE ROD IN 1988. ZCA REVEGETATED APPROXIMATELY 1,000 ACRES OF BLUE MOUNTAIN, BUT HAS REFUSED TO COMPLETE THE WORK UNDER THE CD. APPROXIMATELY 1,000 ACRES REMAIN TO BE REVEGETATED.