THE VIOLATION(S) UPON WHICH THE ACTION IS BASED. THE SHARON STEEL/MIDVALE TAILINGS SITE IS LOCATED TEN MILES SOUTH OF SALT LAKE CITY IN THE SUBURB OF MIDVALE. THE SITE COVERS APPROXIMATELY 260 ACRES AND IS DIRECTLY ADJACENT TO THE JORDAN RIVER. THE HAZARDOUS SUBSTANCES ON THE SITE, ARSENIC, CADMIUM AND LEAD, AMONG OTHERS, RESULTED FROM THE MILLING OPERATIONS OF UV INDUSTRIES, INC. THE ESTIMATED TEN MILLION TONS OF TAILINGS STORED ON THE SITE CONSTITUTE A POTENTIAL THREAT TO THE PUBLIC HEALTH, WELFARE AND THE ENVIRONMENT THROUGH THE RELEASE AND THREATENED RELEASE OF THESE SUBSTANCES INTO THE GROUND WATER, SURFACE WATER AND AIR. EPA HAS INCURRED AND IS INCURRING RESPONSE COSTS CONSISTENT WITH THE NATIONAL CONTINGENCY PLAN TO CONDUCT REMEDIAL INVESTIGATION AND FEASIBILITY STUDY FOR THE SITE. EPA WILL INCUR FUTURE RESPONSE COSTS IN UNDERTAKING OR OVERSEEING THE DESIGN AND IMPLEMENTATION OF A REMEDY FOR THE SITE. THE PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLE- MENT, IF APPLICABLE. A. INJUNCTIVE RELIEF REQUIRING DEFENDANTS, JOINTLY AND SEVERALLY, TO REMEDY THE IMMINENT AND SUBSTANTIAL ENDANGER- MENT TO THE PUBLIC HEALTH, WELFARE OR THE ENVIRONMENT CAUSED BY CONTAMINATION AT THE SITE. B. RECOVERY OF PAST AND FUTURE RESPON