COMPLAINT ALLEGES VIOLATION OF SECTION 15 OF TSCA AND 40 CFR SECTION 761.180(A) FOR FAILURE TO DEVELOP AND MAINTAIN ANNUAL DOCUMENT; 40 CFR SECTION 761.30 FOR FAILURE TO REGI- STER WITH FIRE PERSONNEL; FOR STORING COMBUSTIBLE MATERIALS WITHIN 5 METERS OF A PCB TRANSFORMERS, AND FOR FAILURE TO DEVELOP AND MAINTAIN RECORDS OF QUARTERLY INSPECTIONS; 40 CFR SECTION 761.65(A) FOR FAILUTE TO DISPOSE OF PCB TRANS- FORMERS AND PCB FLUID WITHIN 1 YEAR OF THE DATE THEY WERE PLACED IN STORAGE FOR FOR DISPOSAL; AND 40 CFR SECTION 761. 40 FOR FAILURE TO MARK THE ACCESS DOORS TO ITS PCB TRANS- FORMERS WITH THE ML LABEL.