ON FEBRUARY 23, 1994, REGION 5 OF THE U.S. ENVIRONMENTAL PROTECTION AGENCY FILED AGAINST CYTEC INDUSTRIES, INC., KALAMAZOO, MICHIGAN, ( CYTEC ), A SIX (6) COUNT COMPLAINT ALLEGING: 1. IT FAILED TO HAVE AN UPDATED WASTE ANALYSIS PLAN, CONTINGENCY PLAN, AND CLOSURE PLAN FOR ITS BIF OPERATIONS FROM AUGUST 21, 1991, TO FEBRUARY 17, 1992 IN VIOLATION OF 40 C.F.R. 266.103(A)(4), 265.13, 254.54, 265.112, AND SECTION 3004(Q) OF RCRA, 42 U.S.C. 6924(Q), (COUNT I) 2. IT FAILED TO DEVELOP A WASTE ANALYSIS PLAN THAT SPECIFIED THE TEST METHOD FOR ASH AND THE FREQUENCY FOR THE REVIEW OR REPETITION OF THE INITIAL WASTE ANALYSIS TO ENSURE ACCURACY, CONSTITUTING A VIOLATION OF 40 C.F.R. 265.13(B), 266.103(A)(4), AND SECTION 3004(Q) OF RCRA, 42 U.S.C. 6924(Q), (COUNT II); 3. FAILED TO MONITOR EQUIPMENT FOR LEAKS IN VIOLATION OF 40 C.F.R. 266.103(A)(4)(VIII), 265.1052, 265.1057, AND SECTION 3004(Q) OF RCRA, 42 U.S.C. 6924(Q) 6924(Q), (COUNT III); 4. FAILED TO INCLUDE A LIMIT FOR THE TOTAL FEED RATE OF ASH IN TOTAL FEED STREAMS IN ITS CERTIFICATION OF COM- PLIANCE IN VIOLATION OF 40 C.F.R. 266.103(C)(1) AND SECTION 3004(Q) OF RCRA, 42 U.S.C. 6924(Q), (COUNT IV); 5. FAILED TO OPERATE WITH AN ADEQUATE AUTOMATIC WASTE FEED CUTOFF SYSTEM IN VIOLATION OF 4