AN INSPECTION WAS CONDUCTED IN A COMMERCIAL BUILDING CONTAIN ING 6 IN-SERVICE PCB NAMEPLATED TRANSFORMERS AND 6 PCB CAPA- CITORS. AT THE TIME OF THE INSPECTION, THE FACILITY HAD NO PCB ANNUAL DOCUMENTS FOR 1984-1988. THE ONLY RECORD CON- SISTED OF A MPCA CERTIFICATE OF EXEMPTION (COE) FOR 1985 WHICH DID NOT INCLUDE THE CAPACITORS. THE FACILITY ALSO HAD FAILED TO REGISTER ITS 6 PCB TRANSFORMERS WHICH IT DID TWO DAYS AFTER THE INSPECTION. THE PROPOSED PENALTY IS $6,000 FOR COUNT I (IMPROPER RECORDKEEPING), AND $6000 FOR COUNT II (IMPROPER USE).