THE VIOLATIONS UPON WHICH THE ACTION IS BASED. THE MIDVALE SLAG SITE IS LOCATED APPROXIMATELY 12 MILES SOUTH OF SALT LAKE CITY IN THE SUBURB OF MIDVALE. THE SITE IS APPROXIMATELY 33O ACRES IN SIZE AND IS DIRECTLY ADJACENT TO THE JORDAN RIVER. THE HAZARDOUS SUBSTANCES ON THE SITE, ARSENIC, LEAD, CADMIUM, CHROMIUM, AND ZINC, AMONG OTHERS, RESULTED FROM THE SMELTING OPERATIONS OF UV INDUSTRIES, INC. THE PILES OF SLAG, SMELTER WASTE, DROSS AND BAGHOUSE DUST PRESENT ON THE SITE CONSTITUTE A POTENTIAL 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 INVESTIGATIONS AT THE SITE. EPA WILL INCUR FUTURE RESPONSE COSTS IN UNDERTAKING OR OVERSEEING A FULL REMEDIAL INVESTIGATION/FEASIBILITY STUDY AND DESIGN AND IMPLEMENTATION OF A REMEDY FOR THE SITE. THE PROPOSED RELEIF 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 INVESTIGATE AND REMEDY THE IMMINENT AND SUBSTANTIAL ENDANGERMENT TO THE PUBLIC HEALTH AND THE ENVIRONMENT CAUSED BY CONTAMINATION AT THE SITE. B. RECOVERY OF PAST AND FUTURE RESPONSE COSTS. THE SIGNIFICANT NATIONAL OR PRECEDEN