COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $5,500. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED ON 12/4/97 TO INSPECT FOUR OF THE SCHOOL BUILDINGS AT ST. FRANCIS DAY SCHOOL. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.85(A). COUNT II RESPONDENT FAILED TO SUBMIT A COPY OF THE APRIL 26, 1995 EXCLUSION LETTER TO THE EPA REGIONAL OFFICE OR INCLUDE A COPY IN ANY MANAGEMENT PLAN FOR THE SCHOOL. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.99(A)(7). COUNT III RESPONDENT FAILED TO DESIGNATE A PERSON TO ENSURE THAT THE LEA COMPLIES WITH ALL REQUIREMENTS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.84.