COMPLAINT ALLEGES THAT AMAX COAL COMPANY OPERATING A FACILITY CALLED THE EAGLE-BUTTE MINE, HAS IMPROPERLY DISPOSED OF APPROXIMATELY 6400 GALLONS OF WASTE OIL CONTAMINATED WITH 1,1,1 TRICHLOROETHANE BY SHIPPING MATERIAL IN FIVE SEPARATE SHIPMENTS TO TWO CEMENT KILNS, SYSTECH AND ASH GROVE, LOCATED IN KANSAS AND NEBRASKA RESPECTIVELY. THE KILNS USED THIS FUEL FOR THEIR SUPPLEMENTAL FUELS PROGRAM (I.E. BURNED FOR ENERGY RECOVERY). THE PROPOSED PENALTY FOR THE 14 COUNTS IN THIS COMPLAINT IS $80,650.