POWER ENGINEERING OPERATES AN INDUSTRIAL CHROME PLATING FACILITY THAT REFINISHES CRANKSHAFTS, CONNECTING RODS AND ROD JOURNALS FOR LARGE DIESEL ENGINES. THE FACILITY STRIPS THE OLD CRANKSHAFTS, PREPARES THE SURFACE FOR REFINISHING AND CHROME PLATES THE CRANKSHAFTS TO REMANUFACTURED SPECIFI- CATIONS. AS A RESULT OF THESE OPERATIONS, THE FACILITY GENERATES LARGE QUANTITIES OF F006 CHROME WASTEWATER TREAT- MENT SLUDGE AND D007 CHROME CONTAMINATED MEDIA THAT EXCEEDS THE REGULATORYH STANDARDS FOR TCLP CHROME. THIS CASE INVOLVES OVERFILING ON ENFORCEMENT ACTIONS TAKEN BY THE FEDERALLY AUTHORIZED STATE OF CO. HAZARDOUS WASTE PROGRAM. EPA HAS CONCERNS THAT THE STATE WILL NOT BE ABLE TO FULLY IMPLEMENT ITS FINAL ADMINISTRATIVE COMPLIANCE ORDER AND WILL NOT BE PAID THE FULL $1.1 MILLION PENALTY ASSESSED IN ITS FINAL ORDER. TO DATE, THE ASSESSED PENALTY HAS NOT BEEN PAID. THE PROPOSED CIVIL ACTION WOULD $1,775,868(2,226,368 IF WE PLEAD THE ILLEGAL OPERATOR COUNTS) AND INJUNCTIVE RELIEF.