The Complaint is being issued to JLM Chemicals, Inc. (JLM), of Alsip, Illinois for offering hazardous waste for transport without a manifest on 141 occasions; failing to maintain containers storing hazardous waste in good condition; failing to maintain and operate its facility to minimize the possibility of release of hazardous waste or hazardous waste constituents to air, soil, or surface water; holding hazardous waste in open containers; and failing to properly mark containers holding hazardous waste. The Complaint seeks a civil penalty of $1,086,900 for these failures.