THE COMPLAINT IS IN 19 COUNTS, ALLEGING THAT RESPONDENT STORED A COMBUSTIBLE (A WOOD LADDER) WITHIN 5 METERS OF A PCB TRANSFORMER; FAILED TO INSPECT PCB TRANSFORMERS AS RE- QUIRED FOR SEVERAL QUARTERS; FAILED TO NOTIFY USEPA OF PCB WASTE ACTIVITIES; IMPROPERLY DISPOSED OF PCB'S BY ALLOWING THEM TO RUN ONTO FLOOR IN UNCONTROLLED FASHION AT 2 LOCA- TIONS; FAILED TO PROPERLY MARK THE MEANS OF ACCESS TO 4 PCB TRANSFORMERS; FAILED TO DISPOSE OF A PCB CONTAMINATED TRANS- FORMER WITHIN 1 YR FROM THE DATE IT WAS FIRST PLACED INTO STORAGE; FAILED TO DATE A PCB CONTAMINATED TRANSFORMER AS TO WHEN IT WAS PLACED IN STORAGE; FAILED TO DEVELOP AND MAIN- TAIN RECORDS ON THE DISPOSITION OF PCBS AND PCB ITEMS FROM 1984 THROUGH 1989.