THIS CASE WAS FILED AS PART OF THE RCRA ENFORCEMENT BOILER ANDINDUSTRIAL FURNACE (BIF) INITIATIVE, ON SEPTEMBER 27, 1993. S.C.JOHNSON WAS CHARGED WITH VIOLATIONS OF THE BIF REGULATIONS AT 40 CFRSECTIONS 265 AND 266, INVOLVING FAILURE TO ESTABLISH A PROPER WASTEANALYSIS PLAN; EXCEEDENCE OF LEAD WEIGHT LIMITS; EXCEEDENCE OF ACHLORINE LEAD RATE; EXCEEDENCE OF AN ASH FEED RATE, FAILURE TO TAKEEFFECTIVE WASTE ANALYSIS SAMPLES; AND FAILURE TO GIVE PUBLIC NOTICE OFBIF ACTIVITIES. AFTER MEETING WITH THE FACILITY AND EXCHANGINGINFORMATION, U.S. EPA REVISED THE ORIGINAL PENALTY DOWNWARD FROM$1,466,475 TO $1,049,202, AND DROPPED THE SIXTH COUNT (FAILURE TO GIVEPUBLIC NOTICE) OF THE COMPLAINT. SUBSEQUENTLY, NEGOTIATIONS AREOCCURRING, AND BOTH SIDES ARE ATTEMPTING TO RESOLVE THIS CASE BY WAY OFA SEP OFFER AND CASH PENALTY PAYMENT BY S.C. JOHNSON & SON. THIS CASE INVOLVED A BIF - INITIATIVE ACTION, SEEKING PENALTIES ANDCORRECTIVE ACTION FROM AN OPERATOR (S.C. JOHNSON), WHO FAILED TO COMPLYWITH 40 CFR SECTIONS 265.13 AND 266.103, REQUIRING PROPER MONITORING,REGULATING AND DOCUMENTING/SAMPLING OF HAZARDOUS WASTE STREAMS BEING FEDINTO THE FACILITY'S BOILERS. THE PENALTY IS $1.4 MILLION AND WE HAVE ANORDER FOR IMMEDIATE COMPLIANCE ATTACHED TO THE COMPLAINT. WE HAVEPLANNED MEETINGS FOR INFORMAL RESOLUTION OF THE COMPLAINT, AS OF OCTOBER1993. SEP PROPOSED RECEIVED FROM S.C. JOHN