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 THE REINSPECTIONS THAT WERE DUE IN 1995 AND 1998 AT THE SCHOOLS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.85(B). COUNT II RESPONDENT FAILED AFTER, THE INITIAL NOTIFICATION, TO NOTIFY PARENT, TEACHER, AND EMPLOYEE ORGANIZATIONS, IN WRITING AT LEAST ONCE EACH SCHOOL YEAR, OF THE AVAILABILITY OF MANAGE- MENT PLANS FOR THE SCHOOLS AND TO INCLUDE IN THE MANAGEMENT PLANS, DATED COPIES OF SUCH NOTIFICATIONS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.93(G)(4). COUNT III RESPONDENT FAILED TO PROVIDE THE TWO HOURS OF AWARENESS TRAINING REQUIRED FOR ALL MEMBERS OF ITS MAINTENANCE AND CUSTODIAL STAFF WO MAY WORK IN BUILDINGS THAT CONTAIN ACBM. IN VIOLATION OF TSCA 40 C.F.R. SECTION 763.92(A)(1). COUNT IV RESPONDENT FAILED TO PROVIDE THE 14 HOURS OF ADDITIONAL TRAINING REQUIRED FOR MAINTENANCE AN