An administrative law judge (ALJ) granted the U.S. Environmental Protection Agency's (EPA's) motion for leave to amend its complaint against a manufacturer for Resource Conservation and Recovery Act and state law violations. EPA originally brought four counts against the manufacturer and proposed a penalty assessment of $582,644. In its amended complaint, EPA sought to drop counts 2 through 4 and replace them with a new count 2--operating a treatment, storage, and disposal facility without a permit--based on the same factual allegations in the original counts 2 through 4.