COMPLAINT FILED 3/8/99 PROPOSING A PENALTY OF $154,000. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO RETAIN A COPY OF THE MONITORING RECORDS FOR VISIBLE EMISSIONS FOR AT LEAST 2 YEARS. IN VIOLATION OF CAA 40 C.F.R. SECTION 61.144(B)(7). COUNT II RESPONDENT FAILED TO ADEQUATELY WET ASBESTOS CONTAINING WASTE MATERIAL IN PREPARATION FOR DISPOSAL PRIOR TO BEING SEALED IN LEAK-TIGHT CONTAINERS OR WRAPPING. IN VIOLATION OF CAA 40 C.F.R. SECTION 61.150(A)(1)(I). COUNT III RESPONDENT FAILED TO LABEL ASBESTOS-CONTAINING WASTE MATERIA CONTAINERS OR WRAPPED MATERIALS WITH THE NAME OF THE WASTE GENERATOR AND THE LOCATION AT WHICH THE WASTE WAS GENERATED PRIOR TO TRANSPORTING THE MATERIAL OFF THE FACILITY SITE. IN VIOLATION OF THE CAA 40 C.F.R. SECTION 61.150(A)(1)(V).