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* Union alleges company has adopted "impossible" position

* Strike at Sudbury operation began six months ago

By Cameron French

TORONTO, Jan 13 (Reuters) - The United Steelworkers union filed a labor complaint against Brazilian miner Vale's (VALE5.SA) Inco unit on Wednesday, claiming it has refused to engage in negotiations to end what is now a six-month strike at the company's nickel operations in Sudbury, Ontario.

If the complaint is successful, Vale could be forced to the bargaining table for the first time since more than 3,000 workers at the operation struck on July 13, a lawyer for the union said on a conference call.

The union is also seeking financial compensation for both workers and the union itself, which has been paying strike pay to workers.

Speaking on the call, union officials said the company has refused to negotiate unless the union accepts certain up-front concessions.

"The complaint alleges that the employer... has adopted an intransigent and impossible bargaining position that makes it virtually incapable of entering into a collective agreement with the union under Ontario law," said lawyer Brian Schell.

The move follows Vale's announcement this week that it plans to partially restart the Sudbury smelter using nonstriking workers.

The complaint was filed to the Ontario Labour Relations Board and concerns only the strike at Sudbury and at smaller operations at Port Colborne, Ontario.

It does not affect a parallel strike at the Voisey's Bay nickel and copper mine in the Eastern Canadian province of Newfoundland and Labrador.

Key disagreements between the two sides have centered on pensions and an employee bonus tied to the price of nickel.

Union officials said they are prepared to discuss alterations to the pension plan, but said they would not accept "concessionary" changes.

The strike has come as nickel prices are still recovering from a sharp plunge in 2008-09 that has left the market saturated with capacity.

Vale acquired the former Inco operations when it bought the Canadian company in 2006.

A company spokesman was not immediately available for comment. (Reporting by Cameron French; editing by Peter Galloway