ON OR ABOUT 11/07/91, AN AUTHORIZED EPA INSPECTOR, TOM PAULING, OBSERVED AN UNMARKED CONTAINER, LATER DETERMINED TO CONTAIN PCB WASTE, ON A FLATBED TRUCK FROM OTTO WOLFF U S HOLDING CORPORATION OF HOUSTON, TEXAS, WA NOT MARKED WITH THE PCB LABEL. THE PROPOSED CIVIL PENALTY FOR THIS ONE COUNT VIOLATION IS $45,000.