THIS COMPLAINT, COMPLIANCE ORDER AND NOTICE OF OPPORTUNITY FOR HEARING CONTAINS 11 COUNTS FOR: FAILURE TO PROVIDE APPROPRIATE TREATMENT STANDARDS ON THE LAND DISPOSAL RESTRICTION NOTIFICATION FORMS ACCOMPANYING WASTE BEING SHIPPED OFF-SITE FOR TREATMENT AND/OR DISPOSAL (1-3); FAILURE TO FILE A WSTE ANALYSIS PLAN WITH THE REGIONAL ADMINISTRATOR A MINIMUM OF 30 DAYS PRIOR TO TREATING HAZARDOUS WASTE IN TANKS OR CONTAINERS TO MEET LAND DISPOSAL RESTRICTION TREATMENT STANDARDS (4-9); FAILURE TO CLOSE A CONTAINER OF HAZARDOUS WASTE (10); AND TREATMENT OF HAZARDOUS WASTE WITHOUT A PERMIT (11). THIS ORDER PROPOSES A CIVIL PENALTY OF $98,600.