COMPLAINT FILED 12/14/98 PROPOSING A PENALTY OF $1,159. COMPLAINT ALLEGES: RESPONDENT FAILED TO RETURN THE SIGNED FIELD CITATION AND PENALTY WITHIN THIRTY (30) DAYS, AS REQUESTED BY THE TERMS OF THE CITATION. EPA WITHDREW THE SETTLEMENT OFFERED IN THE CITATION BY LETTER DATED OCTOBER 13, 1998.IN VIOLATION OF RCRA SECTIONS 9002 & 9003.