THE RESPONDENT, JAMES CULLOM, PURCHASED THIS FACTORY SITE FROM DELTA PROPERTIES, INC., WHICH HAD PREVIOUSLY BEEN CITED FOR VIOLATION OF TSCA. CURRENTLY, THE RESPONDENT IS DEMOLIS HING THE BUILDINGS ON THE SITE. SEVERAL PCB ITEMS ARE PRE- SENT AT THE FACILITY INCLUDING 2 PCB TRANSFORMERS, 1 OIL FIL LED NON-PCB TRANSFORMER AND 1 PCB CONTAMINATED TRANSFORMER, WHICH WAS DISCOVERED TO BE LEAKING. ADDITIONALLY 8 PCB CAPA CITORS, 5 OF WHICH WERE LEAKING HAVE BEEN DISCOVERED. THE DRAFT COMPLAINT ALLEGES RECORDKEEPING, STORAGE, DISPOSAL AND MARKING VIOLATIONS, HOWEVER, THERE IS SOME CONCERN REGARDING THE EVIDENCE SUPPORTING THESE VIOLATIONS.