THIS IS A FIVE COUNT COMPLAINT ISSUED AGAINST CONSOLIDATED RAIL CORPORATION FOR: FAILURE TO MARK PCB CONTAINERS; FAILURE TO PROPERLY STORE/CONTAIN PCB'S; FAILURE TO PROPERLY MANIFEST; FAILURE TO PROPERLY NOTIFY EPA OF PCB WASTE ACTIVITY; AND FAILURE TO PROPERLY MARK/LABEL PCB CONTAINERS. THIS COMPLAINT PROPOSES A CIVIL PENALTY OF $325,000.