THIS COMPLAINT AND NOTICE OF OPPORTUNITY FOR HEARING, WAS ISSUED TO BURLINGTON NORTHERN RAILROAD COMPANY, DOING BUSINESS IN MONTANA. ON JULY 17, 1991, THE RESPONDENT CONDUCTED TEN BURNS OF A TOTAL OF APPROXIMATELY 200 RAILROAD TIES NEAR NAISMITH, MONTANA. THE BURNINGS OCCURRED DIRECTLY IN THE OPEN AIR. THE PROPOSED CIVIL PENALTY FOR THESE SIP VIOLATIONS IS $65,530.