CAFO issued 9/30/2004, assessing a penalty of $4,290. Respondent failed to register two PCB Westinghouse Transformers, serial number 7026726, containing 150 gallons of Inerteen fluid, and serial number PCV-7248-01, containing 210 gallons of Inerteen fluid with the EPA on EPA Form 7720-12, as required 40 C.F.R. Section 761.30(a)(1)(vi). Respondent failed to develop and maintain at the facility all annual records and the written annual document log on two Westinghouse PCB Transformers for calendar year 2001, as required in 40 C.F.R. Section 761.180(a). Respondent failed to develop and maintain at the facility all annual records and the written annual document log on two Westinghouse PCB Transformers for calendar year 2002, as required in 40 C.F.R. Section 761.180(a)