THE LITIGATION REPORT DOCUMENTS GOODSON POLYMERS, INC.'S PROTRACTED VIOLATION OF THE TSCA, 15 USC SECTON 2601 ET SEQ. DUE TO IMPROPER DISPOSAL OF PCBS AT A FACILITY OWNED BY GOODSON, AND LOCATED AT 1250 SOUTH UNION STREET, TROY, OHIO. - GOODSON MANUFACTURES POLYSTYRENE CRYSTALS FROM LIQUID STYRENE NOMOMERS, WHICH ARE SOLD CONVERTERS FOR USE IN THE MANUFACTURE OF DISPOSABLE CUTLERY. GOODSON EMPLOYS A HEAT TRANSFER SYSTEM CONTAINED 1600 PPM PCBS. ON OCTOBER 21,1987 THE HEAT TRANSFER SYSTEM EXPLODED, RESULTING IN A PCP SPILL AND CONTAMINATION OF THE PROCESS AREA. ON NOVEMBER 24, 1987 AND ON THREE SUBSEQUENT OCCASIONS, REPRESENTATIVES OF THE OHIO EPA CONDUCTED INSPECTIONS OF THE TROY FACILITY. DURING THE COURSE OF THESE INSPECTIONS, THEY DISCOVERED NUMEROUS VIOLATIONS OF THE PCB MANUFACTURING, PROCESSING, DISTRIBU- TION IN COMMERCE, & USE PROHIBITIONS. THESE PCB REGULATIONS WHICH WERE PROMULGATED BY THE ADMINISTRATOR AT 40 CFR PART 761 ARE ENFORCEABLE, PURSUANT TO TSCA. BASED UPON THESE INSPECTIONS, THE U.S.EPA REGION V, FILED A CIVIL ADMINISTRA- TIVE COMPLAINT AGAINST GOODSON ON DECEMBER 8, 1988. THE PARTIES, TO DATE, HAVE NOT REACHED A SETTLEMENT OF THIS MATTER, ALTHOUGH NEGOTIATIONS ARE STILL BEING CONDUCTED. - UNTIL RECENTLY, GOODSON HAD RETAINED A CONTRACTOR TO UNDER- TAKE CERTAIN SITE CHARACTERIZATION A