THIS FACILITY IS LOCATED ON APPROXIMATELY 180 ACRES OF TRIBAL TRUST LAND ON THE SHIVWITS BAND OF PAIUTE INDIAN RESERVATION. IN DECEMBER, 1998 RESPONDENT COMPLETED CONSTRUCTION AND BEGAN OPERATING A TUNGSTEN RECLAMATION PROCESS AT THE FACILITY IN ADDITION TO THE COBALT RECYCLING OPERATION. A LARGE QUANTITY GENERATOR, RESPONDENT DOES NOT HAVE, AND NEVER HAS HAD A PERMIT FROM EITHER EPA OR THE STATE OF UTAH FOR THE TREATMENT, STORAGE, OR DISPOSAL OF HAZARDOUS WASTE AT THE FACILITY. THIS ORDER ENCOMPASSES 19 DIFFERENT VIOLATIONS. THE TOTAL PROPOSED PENALTY FOR THESE VIOLATIONS IS $1,481,897.