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 DTED 4/22/97, OR TO EPA'S AO NO. 98-151 ISSUED ON 4/29/98, OR THE NOV DATED 8/14/98. IN VIOLATION OF CWA SECTION 308.