TSCA COMPLAINT ALLEGES VIOLATIONS OF PCB RULE IN 3 COUNTS COUNT I: FAILURE TO DEVELOP AND MAINTAIN ANNUAL RECORDS ON DISPOSITION OF PCB LIQUID. COUNT II: FAILURE TO REDUCE CONCENTRATION OF PCBS IN ITS HEAT TRANSFER SYSTEM TO BELOW 50 PPM. COUNT III: FAILURE TO LABEL ITS HEAT TRANSFER SYSTEM WITH PCB LABELS AS REQUIRED. PENALTY OF $5500 IS SOUGHT.