WITH RESPECT TO THE CONNECTICUT LIGHT & POWER CO CL&P , THE GIST OF THE SEVEN VIOLATIONS IS CL&P'S FAILURE TO PERFORM TIMELY CLEANUPS OF PCB SPILLS IN ACCORDANCE WITH EPA'S PCB SPILL CLEANUP POLICY. THE EVIDENCE SHOWED THAT, AFTER SEVERAL MONTHS, CL&P HAD NOT INITIATED AND/OR COMPLETED THE CLEANUP OF MANY OF THESE PCB SPILLS. ACCORDINGLY, CL&P VIOLATED THE PCB DISPOSAL REQUIREMENTS OF 40 CFR SECTIONS 761.50 & 761.60. WITH RESPECT TO NORTHEAST NUCLEAR ENERGY COMPANY, EPA HAS ALLEGED THREE VIOLATIONS AT HE MILLSTONE NUCLEAR POWER STATION IN WATERFORD: 1) THE UNAUTHORIZED USE OF PAINT CONTAMINATED WITH PCBS WITH CONCENTRATIONS OF UP TO 4,283 PPM TO COAT THE INTERNAL SURFACE OF A 245,000 GALLON WATER TANK FROM 1969 UNTIL THE WEEK OF SEPTEMBER 20, 1999. 2) THE IMPROPER DISPOSAL OF PCBS DURING THE DRAINAGE OF THE FULL CONTENTS OF THE WATER TANK FROM MARCH TO APRIL 1998; AND 3) THE FAILURE TO PREPARE PROPER MANIFESTS OF FOUR 55 GALLON DRUMS OF WATER AND SLUDGE SHIPPED OFF-SITE FOR DISPOSAL.