ANSWER SENT IN 1/10/89. TRANSMITTED TO OFFICE OF ALJ 1/18/89. CONFERENCE CALL HELD 1/26/89. - U.S. EPA ISSUED A RCRA SECTION 3008(A) COMPLAINT ON DECEMBER 29, 1988 ALLEGING VIOLATIONS OF FINANCIAL ASSURANCE, INSUR- ANCE, AND CLOSURE AND POST-CLOSURE COST ESTIMATE UPDATING RE QUIREMENTS FOR GENRATORS AND TREATMENT, STORAGE AND DISPOSAL FACILITIES. THE COMPLAINT ASSESSED A PENALTY OF $3,150.