COMPLAINT FILED 9/25/98 PROPOSING A PENALTY OF $25,000. COMPLAINT ALLEGES: COUNT I RESPONDENT HAD SIXTEEN (16) LARGE-LOW VOLTAGE PCB CAPACITORS IN THE BUILDING DESIGNATED BY THE INSPECTOR AS BUILDING TWO, WHICH HAD A WOODEN FLOOR THAT DID NOT MEET THE USE REQUIREMENTS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.30 (1) (1) (II). COUNT II RESPONDENT HAD TWENTY-ONE (21) LARGE-LOW VOLTAGE PCB CAPACITORS LOCATED IN THE BUILDING DESIGNEDATED BY THE INSPECTOR AS BUILDING THREE, WHICH HAD A WOODEN FLOOR THAT DID NOT MEET THE USE REQUIREMENTS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.30 (1) (1) (II). COUNT III RESPONDENT HAD EIGHT (8) LARGE-LOW VOLTAGE PCB CAPACITORS LOCATED IN THE BUILDING DESIGNATED BY THE INSPECTOR AS BUILDING FOUR, WHICH HAD A WOODEN FLOOR THAT DID NOT MEET THE USE REQUIREMENTS. IN VIOLATION OF