COMPLAINT FILED 9/29/98 PROPOSING A PENALTY OF $48,600. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO PROPERLY DISPOSE OF 900 GALLONS OF OIL, CONTAMINATED GREATER THAN 50 PPM PCBS. COUNT II RESPONDENT FAILED TO PREPARE A COMPLETE MANIFEST ON PCB WASTES FROM TRANSFORMER 6423261, WHICH WAS SHIPPED TO EAST KENTUCKY POWER FOR DISPOSAL ON NOVEMBER 1, 1997. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.207. COUNT III RESPONDENT FAILED TO MAINTAIN A COMPLETE ANNUAL DOCUMENT LOG FOR CALENDAR 1996. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.180(A). COUNT IV RESPONDENT FAILED TO MAINTAIN A COMPLETE ANNUAL LOG FOR CALENDAR YEAR 1995. IN VIOLATION OF TSCA SECTION 40 C.F.R. SECTION 761.180(A). COUNT V RESPONDENT FAILED TO PRODUCE, AT THE