COMPLAINT FILED 6/24/99 PROPOSING A PENALTY OF $27,500. COMPLAINT ALLEGES: RESPONDENT FAILED TO SUBMIT A RESPONSE TO EITHER EPA'S 308 LETTER DATED 4/14/97, OR TO EPA'S AO NO. 98-042 ISSUED ON 3/13/98, OR THE NOV DATED 8/14/98. IN VIOLATION OF CWA SECTION 308.