THIS IS A TWO COUNT COMPLAINT ISSUED FOR IMPROPER STORAGE FOR DISPOSAL OF PCB CONTAMINATED SOIL IN THE ON-SITE FACILITY URANIUM MILL TAILINGS STOCKPILE FROM THE SUMMER OF 1989 THROUGH AT LEAST AUGUST 1991. THE SECOND COUNT IS FOR VIOLATION OF STORAGE FOR DISPOSAL OF PCB'S IN EXCESS OF ONE YEAR. THIS TWO COUNT COMPLAINT PROPOSES A CIVIL PENALTY OF $30,000.