COMPLAINT FILED 9/29/98 PROPOSING A PENALTY OF $35,065. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO LABEL THESE CONTAINERS WITH THE DATE UPON WHICH EACH PERIOD OF ACCUMULATION. IN VIOLATION OF RCRA 40 C.F.R. SECTION 262.34(A)(2). COUNT II RESPONDENT FAILED TO LABEL THESE CONTAINERS WITH THE WORDS HAZARDOUS WASTE . IN VIOLATION OF RCRA 40 C.F.R. SECTON 262.34(A)(3). COUNT III RESPONDENT FAILED TO LABEL 1-GALLON CONTAINERS OF HAZARDOUS WASTE WITH THE WORDS HAZARDOUS WASTE OR WITH WORDS THAT IDENTIFIED THE CONTENTS OF THE CONTAINERS. IN VIOLATION OF RCRA 40 C.F.R. SECTION 262.34(C) (1) (II). COUNT IV RESPONDENT FAILED TO CONDUCT AND RECORD INSPECTIONS OF AREAS WHERE CONTAINERS ARE STORE, AT LEAST WEEKLY. IN VIOLATION OF RCRA 40 C.F.R. SECTION 262.34(A)(1)(I).