THIS IS A THREE COUNT COMPLAINT ALLEGING THREE DIFFERENT VIOLATIONS OF SECT 16A OF TOXIC SUBSTANCE CONTROL ACT, 15 USC 33 2601 ET SEQ.: 1) RESPONDENT FAILED TO REGISTER ITS PCB TRANSFORMER WITH FIRE RESPONSE PERSONNEL; 2) FAILED TO PROPERLY LABEL THE ACCESS TO THE PCB TRANSFORMER'S LOCATION; 3) AND, FAILED TO DEVELOP AND MAINTAIN ANNUAL REPORTS FROM 1978 THRU 1987 REGARDING THE DISPOSITION OF PCB ITEMS.