Howmet Corporation (“Howmet”) appeals an Initial Decision in which Administrative Law Judge William B. Moran (the “ALJ”) assessed a $309,091 penalty for violations of the Resource Conservation and Recovery Act and the Hazardous and Solid Waste Amendments of 1984 (collectively, “RCRA”), relating to Howmet’s shipment of used potassium hydroxide (“KOH”) to a fertilizer manufacturer.