COMPLAINT FILED 10/14/98 PROPOSING A PENALTY OF $345,293. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO MAKE A HAZARDOUS WASTE DETRMINATION ON AT LEAST 23 WASTE STREAMS FROM AT LEAST APRIL 4, 1995 UNTIL JUNE 23, 1995. IN VIOLATION OF RCRA 40 C.F.R. SECTION 262.11. COUNT II RESPONDENT DOES NOT HAVE AND NEVER HAD A PERMIT TO OPERATE A HAZARDOUS WASTE TREATMENT FACILITY. IN VIOLATION OF RCRA 40 C.F.R. SECTION 270.10.