DEFENDANTS HAVE VIOLATED THE PCB REGULATIONS BY STORING PCB TRANSFORMERS AND CAPACITORS IN AN INADEQUATE FACILITY, AND FOR MORE THAN A YEAR AFTER THE EQUIPMENT WAS REMOVED FROM SERVICE AND DESIGNATED FOR DISPOSAL ? 40 CFR SS 761.65(A) AND (B) ?. DEFENDANTS ARE OPERATING A COMMERCIAL PCB STORAGE FACILITY WITHOUT APPROVAL OF THE EPA REGIONAL ADMINISTRATOR, IN VIOLATION OF 40 CFR S 761.65(D). THE COMPLAINT SEEKS AN ORDER UNDER S 17 OF TSCA FOR THE REMOVAL AND PROPER DISPOSAL OF APPROXIMATELY 91 TONS OF PCB'S CONTAINED IN ABANDONED TRANSFORMERS AND CAPACITORS WHICH HAVE BEEN IMPROPERLY STORED AT THE FACILITY FOR OVER THREE YEARS. THE PROLONGED AND IMPROPER STORAGE OF SUCH A LARGE QUANTITY OF PCBS PRESENTS RISKS OF ENVIRONMENTAL HARM THROUGH LEAKS, IMPROPER DISPOSAL AND FIRE.