COUNT I OF THE COMPLAINT ALLEGES THAT RESPONDENT FAILED TO MAINTAIN RECORDS OF INSPECTION AND MAINTENANCE HISTORY AS REQUIRED BY 40 C.F.R. SECTION 761.30(A)(I). COUNT II ALLEGES THAT RESPONDENT FAILED TO PREPARE APPEAL DOCUMENTS OF ITS PCB TRANSFORMERS FOR CALENDAR YEARS 1978 THROUGH 1984, AS REQUIRED BY 40 C.F.R. SECTION 761.180(A).