RESPONDENT IS THE OWNER AND OPERATOR OF A URANIUM MILL WITH AN ACTIVE SUBGRADE URANIUM MILL TAILINGS PILE, KNOWN AS THE A-9 PIT IN EAST GAS HILLS, NATRONA COUNTY, WYOMING. THIS PIT SERVES AS A DISPOSAL SITE FOR LOW LEVEL RADIOACTIVE WASTE AND IS AN OPERATING EXISTING MILL IMPOUNDMENT. RESPONDENT FAILED TO REPORT RADON EMISSIONS RESULTS; FAILED TO REPORT 1990 TEST RESULTS; AND HAS BEEN IN CONTINUOUS VIOLATION FROM MARCH 31, 1991 TO THE ISSUANCE OF THIS COMPLAINT.