EPA ISSUED A RCRA 3008(A) COMPLAINT, COMPLIANCE ORDER, AND NOTICE OF OPPORTUNITY TO REQUEST HEARING PROPOSING A $1,200,474 PENALTY AS A PART OF THE COMBUSTION INITIATIVE. THE COMPLAINT PROPOSES A TOTAL PENALTY OF $1,200,474 IN EIGHT COUNTS ALLEGING THAT LAFARGE: 1) FAILED TO CONDUCT HOURLY INSPECTIONS OF TRANSFER AREAS; 2) FAILED TO HAVE AN ADEQUATE WASTE ANALYSIS PLAN; 3) FAILED TO MONITOR METAL FEED RATES; 4) OPERATED IN EXCESS OF PRECOMPLIANCE SPECIFICATIONS; 5) FAILED TO DOCUMENT PERSONNEL TRAINING; 6) SUBMITTED INADEQUATE BIF COMPLIANCE DOCUMENTATION; 7) FAILED TO GET AN ENGINEER'S CERTIFICATION; AND 8) FAILED TO ACCURATELY SET OPERATING LIMITS AND MAINTAIN MINIMUM COMBUSTION ZONE TEMPERATURE.