COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $5,500. COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO CONDUCT A REINSPECTION OF ALL FRIABLE AND NONFRIABLE KNOWN OR ASSUMED ACBM IN EACH SCHOOL BUILDING THAT IT LEASES, OWNS, OR OTHERWISE USES AS A SCHOOL BUILDING AT LEAST ONCE EVERY THREE YEARS AFTER THE MANAGEMENT PLAN IS IN EFFECT. THE LEA FAILED TO CONDUCT REINSPECTIONS THAT WERE DUE IN 1994 AND 1997 AT THE SCHOOLS. IN VIOLATION OF 40 C.F.R. SECTION 763.85(B). COUNT II RESPONDENT FAILED TO NOTIFY PARENT, TEACHER, AND EMPLOYEE ORGANIZATIONS, IN WRITING AT LEAST ONCE EACH SCHOOL YEAR, OF THE AVAILABILITY OF MANAGEMENT PLANS FOR THE SCHOOLS AND FAI LED TO INCLUDE THE MANAGEMENT PLANS, DATED OF SUCH NOTIFI- CATIONS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.93(G)(4 COUNT III RESPONDENT FAILED TO ENSURE THAT SHORT-TERM WORKERS WHO MAY COME IN CONTACT WITH ASBESTOS IN A SHCOOL WERE PROVIDED INFORMATION REGARDING THE LOCTIONS OF ACBM AND SUSPECTED ACBM ASSUMED TO BE ACM. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.84(D). COUNT IV RESPONDENT FAILED TO CONDUCT PERIODIC SURVEILLANCE IN THE SCHOOLS AFTER OCTOBER 17, 1989. IN