KENT ASSOC. OWNS EDS BUILDING. LEO D. PHILLIPS OPERATES THE BUILDING. RESPONDENTS FAILED TO DEVELOP AND MAINTAIN PCB RECORDS, FAILED TO REGISTER THEIR 3 PCB TRANSFORMERS WITH LOCAL FIRE RESPONSE PERSONNEL; STORED COMBUSTIBLE MA- TERIALS WITHIN THEIR PCB TRANSFORMER ENCLOSURE; FAILED FOR THEIR THREE PCB TRANSFORMERS; FAILED TO CLEAN UP AND PROPER- LY DISPOSE OF MATERIAL LEAKED PCB MATERIAL; AND FAILED TO MAKE THE MEANS OF ACCESS TO THEIR THREE PCB TRANSFORMERS. EPA PROPOSES A CIVIL PENALTY OF $24,300.