ELKEM HAS FAILED TO TEST HEAT TRANSFER SYSTEMS FOR PCBS ANNUALLY. ELKEM HAS ALSO FAILED TO MARK MEANS OF ACCESS TO PCB TRANSFORMERS. USEPA HAS A PROGRAM WITH OHIO EPA IN WHICH USEP IS TRYING TO GRADUALLY TEACH OEPA THE PCB PROGRAM AS PART OF THAT PROGRAM, USEPA IS ALLOWING OEPA TO PREPARE THE COMPLAINT, WITH USEPA OVERSIGHT. ONCE COMPLAINT IS COM- PLETED, USEPA WILL PROCEED WITH CASE. THE COMPLAINT IS STILL WITH OEPA.