COMPLAINT FILED 9/30/99 PROPOSING A PENALTY OF $96,680 COMPLAINT ALLEGES: COUNT I RESPONDENT FAILED TO PREPARE A WASTE MANIFEST FOR USED OIL. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.207(A). COUNT II RESPONDENT FAILED TO OBTAIN AN EXEMPTION PRIOR TO DIS- TRIBUTING PCB CONTAMINATED USED OIL FOR ENERGY RECOVERY. IN VIOLTION OF TSCA 40 C.F.R. SECTION 761.20(C). COUNT III RESPONDENT FAILED TO PROPERLY DISPOSE OF THE PCB CONTAMINATE USED OIL. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.60(A)(1 COUNT V RESPONDENT FAILED TO STORE THE PCB STORAGE CONTAINERS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.65(B)(1). COUNT VI RESPONDENT FAILED TO POST THE OUT OF SERVICE DATE ON THE PCB CONTAINERS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.65(A COUNT VII RESPONDENT FAILED TO CONDUCT MONTHLY INSPECTIONS OF THE PCB STORAGE CONTAINERS. IN VIOLATION OF TSCA 40 C.F.R. SECTION 761.65(C)(5). COUNT VIII RESPONDENT FAILED TO POST THE ML LABEL ON THE PCB STORE AREA