DEFENDANT WAS 186 DAYS LATE IN START-UP OF RCRA CORRECTIVE ACTION COMPONENT. ACTION IS FOR COLLECTION OF STIPULATED PENALTIES FROM DEFENDANT PURSUANT TO 3008H CORRECTIVE ACTION RFI/CMS ORDER. EPA DEMANDED STIPULATED PENALTIES FROM CECOS. THE LEACHATE PRE-TREATMENT SYSTEM WAS REQUIRED PURSUANT TO EPA'S REQUEST FOR ADDITIONAL WORK AS ALLOWED IN THE RCRA CONSENT ORDER.