COMPLAINT FILED 7/22/98 PROPOSING A PENALTY OF $32,000 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO MARK THE BLUE DRUM OF SOIL CONTAINING 905 PPM PCBS IN VIOLATION OF TSCA SECTION 15. COUNT II RESPONDENT FAILED TO MARKE THE YELLOW DRUM OF SOIL CONTAINING 1880 PPM PCBS. IN VIOLATION OF TSCA SECTION 15. COUNT III RESPONDENT FAILED TO MARK THE DRUM CONTAINING THE BLOATED LARGE CAPACITOR. IN VIOLATION OF TSCA SECTION 15. COUNT IV RESPONDENT FAILED TO STORE PCB-CONTAMINATED TRANSFORMERS IN AN ADEQUATE STORAGE AREA. IN VIOLATION OF TSCA SECTION 15. COUNT V RESPONDENT FAILED TO STORE THE DRUMS IN AN ADEQUATE STORAGE AREA. IN VIOLATION OF TSCA SECTION 15. COUNT VI RESPONDENT FAILED TO PLACE AN OUT-OF-SERVICE DATE ON THE FOUR PCB-CONTAMINATED TRANSFORMERS. IN VIOLATION OF TSCA SECTION 15. COUNT VII RESPONDENT FAILED TO PLACE A STARTING DATE OF ACCUMULATION ON TWO DRUMS OF PCB-CONTAMINATED CAPACITOR. IN VIOLATION OF TSCA SECTION 15.