VIOLATIONS OF STORAGE AND RECORDKEEPING REGULATIONS OF PCB RULE. VIOLATIONS BASED ON LANGUAGE IN INSPECTION REPORT. IM- PROPER DISTRIBUTION IN COMMERCE COUNT REFUTED BY EPA GRANTING PERMISION TO DISTRIBUTE DURING PENDENCY OF RE- QUEST FOR EXEMPTION. IMPROPER RECORDKEEPING -> COURT STALEMATED WITH WEIGHT OF EVIDENCE IN FAVOR OR RESPONDENT. IMPROPER STORAGE FOR DISPOSAL -> WEIGHT AND INFERENCE OF EVIDENCE IN OUR FAVOR HOWEVER DRUM IS PROPERLY DESTROYED AND NO SAMPLES WERE TAKEN TO SHOW CONTAMINATION. PROPOSE DRAFT CAFO WITH ZERO PENALTY WITH SUBSEQUENT SURPRISE INSPECTION.