COMPLAINT FILED 8/31/98 PROPOSING A PENALTY OF $27,224 COMPLAINT ALLEGES: COUNT I RESPONDENT DID NOT THOROUGHLY INSPECT LOWELL ELEMENTARY SCHOOL FOR THE PRESENCE OF ASBESTOS PRIOR TO THE DEMOLITION OF LOWELL ELEMENTARY SCHOOL. IN VIOLATION OF THE CAA 40 C.F.R. SECTION 61.145(A). COUNT II RESPONDENT DID NOT REMOVE ALL RACM FROM THE LOWELL ELEMENTARY SCHOOL BUILDING BEFORE DEMOLITION OF THE BUILDING. IN VIOLATION OF 40 C.F.R. SECTION 61.145(A). COUNT III THE ASBESTOS AT THE DEMOLITION SITE OF LOWELL ELEMENTARY SCHOOL WAS NOT ADEQUATELY WET AT ALL TIMES UNTIL DISPOSED OF. IN VIOLATION OF CAA 40 C.F.R. SECTION 61.150 (C) (III). AMENDED COMPLAINT FILED 9/23/98